Case 2:02-cv-01069-WHA-SRW Document 1 Filed 09/17/2002 Page 1 of 5 , '\ IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA



Similar documents
UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA NATURE OF THE ACTION

Case 3:10-cv JAP -DEA Document 1 Filed 08/11/10 Page 1 of 6 PageID: 1

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA HARRISONBURG DIVISION EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, ) ) )

UNITED STATES DISTRICT COURT DISTRICT OF HAWAII. Case No.: CV-06-00~CK-LEK

Case 1:09-cv Document 1 Filed 12/10/09 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

Case 3:10-cv DRD Document 31 Filed 05/05/11 Page 1 of 9

Case4:13-cv DMR Document1 Filed12/11/13 Page1 of 5

virtue of Title VIII of the Sarbanes-Oxley Act of 2002, Section 806 of the Corporate and

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA EASTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) NATURE OF THE ACTION

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA BROWARD DIVISION. Plaintiff, Case No.: COMPLAINT

Case: 1:12-cv Document #: 1 Filed: 06/04/12 Page 1 of 12 PageID #:1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

Case 1:12-cv RLV-AJB Document 1 Filed 05/14/12 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

Plaintiffs, Defendants. PLEASE TAKE NOTICE that Plaintiff, Rebecca Weston, hereby accepts the Offer of

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) )

Case 3:14-cv HU Document 1 Filed 04/23/14 Page 1 of 12 Page ID#: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON

Case 4:09-cv RCC Document 1 Filed 09/04/09 Page 1 of 7 UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) ) ) Plaintiff,

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO THE UNIVERSITY OF COLORADO HOSPITAL AUTHORITY,

Case 1:05-cv JGK Document 1 Filed 04/04/05 Page 1 of 6. Plaintiff, : Civ. No. 05cv3493

&lagistiiale JUDGE ROSEMONO

Case 1:14-cv Document 1 Filed 12/08/14 Page 1 of 7 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS COMPLAINT

IN THE CIRCUIT COURT OF THE 9 th JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA

unlawful employment practices on the basis of disabilityand to provide appropriate relief to

Case 1:15-cv KMW Document 11 Entered on FLSD Docket 01/28/2016 Page 1 of 8 UNTIED STATE DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

IN THE CIRCUIT COURT OF MOBILE COUNTY, ALABAMA. v. Civil Action No.:CL Plaintiff Demands Trial by Jury COMPLAINT

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA

FIRST AMENDED CLASS ACTION AND COLLECTIVE COMPLAINT AND JURY DEMAND

Plaintiff, : X. Nature of the Action. 1. This is an action for breach of a settlement agreement, retaliation

JEFFERSON CIRCUIT COURT JUDGE DIVISION. MELISSA ROWE, Individually and as Mother and Next Friend of E.R

Case 1:13-cv ESH Document 1 Filed 12/09/13 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMA * *

Case: 1:15-cv Document #: 1 Filed: 11/04/15 Page 1 of 10 PageID #:1

UNITED STATES DISTRICT COURT DISTRICT OF OREGON

Case 1:13-cv SEB-TAB Document 1 Filed 01/02/13 Page 1 of 7 PageID #: 1

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORIGIA-~~T ~:J,-~T,>cURT SAVANNAH DIVISION j Ga. NATURE OF THE ACTION

Case 5:14-cv Document 1 Filed 07/11/14 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

Case 2:15-cv CW Document 2 Filed 05/12/15 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT, DISTRICT OF UTAH CENTRAL DIVISION

Case 4:14-cv A Document 1 Filed 04/10/14 Page 1 of 4 PageID 1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION

COMPLAINT PARTIES. of Transportation & Public Facilities, which is a state agency. propulsion system design, manufacture, sales, and service.

Case: 1:16-cv Document #: 1 Filed: 01/22/16 Page 1 of 18 PageID #:1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Case No: Defendants, Steven Lecy and the City of Minneapolis, through their

Case 4:15-cv RH-CAS Document 1 Filed 03/17/15 Page 1 of 19 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION

Case 1:15-cv RMB-AMD Document 1 Filed 10/15/15 Page 1 of 12 PageID: 1

COMPLAINT WITH JURY DEMAND. of police reports in bad faith. Plaintiff claims that Defendants acted willfully, wantonly and in

Case 2:13-cv RBS Document 1 Filed 03/19/13 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

CASE 0:12-cv RHK-SER Document 1 Filed 11/02/12 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA GAINESVILLE DIVISION

Case 1:12-cv BEL Document 1 Filed 02/15/12 Page 1 of 6. IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND (Northern Division)

Answer to Debt Collection Suit Instructions, Example, Sample Form

Case 2:05-cv JDB-tmp Document 41 Filed 07/12/2006 Page 1 of 15

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO

STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE

IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI DIVISION

Plaintiff Carol Parker ( Plaintiff ), residing at 32 Coleman Way, Jackson, NJ 08527, by her undersigned counsel, alleges the following upon personal

Case: 1:11-cv TSB Doc #: 3 Filed: 08/11/11 Page: 1 of 12 PAGEID #: 22 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOMEWHERE ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

Case 2:14-cv DB Document 2 Filed 09/03/14 Page 1 of 10

IN THE UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF TEXAS DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA

IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO. Plaintiffs, ) CASE NO. 08 CVH vs- ) JUDGE LYNCH

IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA

Case 1:14-cv Document 1 Filed 07/14/14 Page 1 of 17 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

PREVIEW PLEASE DO NOT COPY THIS DOCUMENT THANK YOU. LegalFormsForTexas.Com

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR KING COUNTY. No.

Kenneth L. Smith, in propria persona Genesee Village Rd. COURT USE ONLY Golden, CO Phone: (303)

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, WEST DISTRICT

Case: 5:14-cv Doc #: 1 Filed: 09/08/14 1 of 14. PageID #: 1

Case 1:15-cv MHC Document 1 Filed 09/11/15 Page 1 of 12 ORIGH~~AL

Case 5:14-cv OLG Document 9 Filed 07/31/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

Case 2:14-cv KOB Document 1 Filed 08/20/14 Page 1 of 38

vs. JURY TRIAL DEMANDED COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL Plaintiff JAMES SCHAIRER, by and through undersigned counsel, hereby sues

Case3:15-cv Document1 Filed03/24/15 Page1 of 9

PLAINTIFF S FIRST AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL. MYRIAM DEL SOCORRO LOPEZ, by and through his undersigned counsel, and files this First

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

Commonwealth of Kentucky Court of Appeals

IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA BIRMINGHAM DIVISION

Section 3.2 of HB 2 and Its Impact on Wrongful Discharge Claims

Complaint - Walmart Substance on Floor in Frozen Food Dept.

Case 2:15-cv Document 1 Filed 07/14/15 Page 1of10 Page ID #:1

JOHN MURRAY ( Murray ), for his Complaint in this action against Defendant, Crystex Composites LLC ( Crystex ), alleges as follows:

Case: 1:15-cv DAP Doc #: 1 Filed: 01/29/15 1 of 15. PageID #: 1

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION ) ) ) ) ) ) ) ) ) ) ORIGINAL COMPLAINT

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION INTRODUCTION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF WISCONSIN MILWAUKEE DIVISION. Plaintiffs, ) ) Case No. 14-cv-1358 v.

Case 5:14-cv IPJ Document 1 Filed 10/14/14 Page 1 of 17

Case 1:14-cv ERK-JMA Document 1-1 Filed 02/27/14 Page 1 of 2 PageID #: 6 CIVIL COVER SHEET (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.

Case 1:10-cv JBS -KMW Document 1 Filed 01/12/10 Page 1 of 21 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

SUPERIOR COURT OF THE [INSERT STATE/JURISDICTION] FAMILY DIVISION--DOMESTIC RELATIONS BRANCH

BEFORE THE COMMISSIONER OF INSURANCE OF THE STATE OF KANSAS CONSENT ORDER

Transcription:

Case 2:02-cv-01069-WHA-SRW Document 1 Filed 09/17/2002 Page 1 of 5, '\ IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA D \ \..': t', I ' NORTHERN DIVISION " \ NASH J. COOLEY ) FILED SEp!,1 7 2002 CLERK u. S. DISTRICT COURT MIDDle DIST. OF ALA. crill L..; Plaintiff ) VS. STERLING BANK ) Defendant COMPLAINT 1. This action arises under 42 U. S. C. 1981, the Equal Credit Opportunity Act, 15 U.S.C.A. 1691, and the Federal Fair Housing Act. This court has jurisdiction over this action pursuant to 28 U.S.C. 1331 and 1343 and venue is appropriate in this forum. 2. Plaintiff, Nash Cooley, is an African American male residing in the Middle District of Alabama in Montgomery. 3. Defendant, Sterling Bank, is a corporation doing business in the Middle District of Alabama in Montgomery engaged in the business of making credit transactions. 4. In the summer of2000, Mr. Cooley became interested in obtaining a $100,000.00 unsecured line of credit from Sterling Ban1e 5. Mr. Cooley and Mr. Hill, Vice President of Sterling Bank, had done business together for several years and Mr. Hill had told Mr. Cooley that he was interested in bringing some of Mr. Cooley's business to Sterling Bank. 6. Mr. Hill knew that Mr. Cooley had substantial assets and credit sufficient to obtain a $100,000.00 line of credit from Sterling Bank. I

Case 2:02-cv-01069-WHA-SRW Document 1 Filed 09/17/2002 Page 2 of 5 7. Mr. Hill gave Mr. Cooley assurances that ifhe applied for the $100,000.00 line of credit that Sterling Bank would approve the transaction. 8. Mr. Cooley told Mr. Hill that he wanted an unsecured line of credit of $1 00,000.00. 9. Then, pursuant to an agreement with Mr. Hill, Mr. Cooley deposited $100,000.00 into an account with Sterling Bank and applied for a $100,000.00 unsecured line of credit. 10. Plaintiff sought the $100,000.00 unsecured line of credit, among other things, to purchase real property and to invest in other business opportunities. 11. On September 19,2002, Sterling Bank issued a "Notice of Action Taken" and denied Mr. Cooley's application for an unsecured line of credit of $1 00,000.00. 12. On October 11, 2002, Mr. Cooley wrote to Mr. Hill and told him that he thought that the decision was unfair and he asked Mr. Hill to check with the President of Sterling Bank, W. Allan Worrell, and the Board members of Sterling Bank, and to give him an explanation as to why his application had been denied. 13. On October 27, 2000, Mr. Hill replied and reiterated that Mr. Cooley's request had been denied by Sterling Bank. Sterling Bank refused to extend the credit to Mr. Cooley that he had requested. 14. Mr. Cooley exercised in good faith his rights under 42 U.S.C. 1981, the Equal Credit Opportunity Act, 15 U.S.C.A. 1691, the Federal Fair Housing Act and under the Consumer Credit Protection Act and as a result Sterling Bank discriminated against him with respect to credit transactions. 15. Plaintiff suffered an injury in fact and harm to a legal interest. 16. Plaintiff lost business opportunities and as a result of defendant's intentional and

Case 2:02-cv-01069-WHA-SRW Document 1 Filed 09/17/2002 Page 3 of 5 unlawful conduct, plaintiff suffered and continues to suffer emotional pain and suffering, inconvenience, mental anguish, loss of enjoyment oflife, loss of income. 17. Mr. Cooley had sufficient assets and outstanding credit and should have received the $100,000.00 line of unsecured credit from Sterling Bank but his application was denied and he was discriminated against on the basis of his race. 18. Plaintiff alleges that Sterling Bank has treated African-Americans, including Plaintiff, less favorably than white persons in its banking and other credit transactions. First Claim For Relief 19. Plaintiff incorporates by reference each of the foregoing allegations of fact as 20. Defendant's actions are in violation of 42 U.S.C. 1981. 21. As a result of defendant's intentional and unlawful conduct, plaintiff suffered and 22. Defendant acted with malice or with reckless indifference to plaintiff's federally WHEREFORE, plaintiff demands equitable damages, compensatory and punitive damages, costs and attorneys' fees and all other relief deemed appropriate by this Court and/or the jury. Second Claim For Relief 23. Plaintiff incorporates by reference each of the foregoing allegations of fact as

Case 2:02-cv-01069-WHA-SRW Document 1 Filed 09/17/2002 Page 4 of 5 24. Defendant's actions are in violation of the Equal Credit Opportunity Act, 15 V.S.C.A. 1691. 25. As a result of defendant's intentional and unlawful conduct, plaintiff suffered and 26. Defendant acted with malice or with reckless indifference to plaintiff's federally WHEREFORE, plaintiff demands equitable damages, compensatory and punitive damages, costs and attorneys' fees and all other relief deemed appropriate by this Court and/or the jury. Third Claim For Relief 27. Plaintiff incorporates by reference each of the foregoing allegations of fact as 28. Defendant's actions are in violation of the Federal Fair Housing Act. 29. As a result of defendant's intentional and unlawful conduct, plaintiff suffered and 30. Defendant acted with malice or with reckless indifference to plaintiff's federally WHEREFORE, plaintiff demands equitable damages, compensatory and punitive damages, costs and attorneys' fees and all other relief deemed appropriate by this Court and/or the jury.

Case 2:02-cv-01069-WHA-SRW Document 1 Filed 09/17/2002 Page 5 of 5 OF COUNSEL: FRANKLIN & STEIN, P. C. 63 South Royal Street Suite 1109 Mobile, Alabama 36602 251-433-0051 DEFENDANT MAY BE SERVED BY CERTIFIED MAIL AS FOLLOWS: Sterling Bank c/o W. Alan Worrell,Registered Agent 4121 Carmichael Road Montgomery, Alabama 36106