birdwatcher (birdwatcher) wrote,

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8. At all relevant times herein, plaintiff was an exemplary employee, and met or exceeded all of his employer's reasonable expectations.
9. At all times relevant herein, plaintiff worked in Knight's main office in Jersey City, New Jersey.
10. At all times relevant herein, defendant McCarthy worked in Knight's main office in Jersey City, New Jersey.
11. Plaintiff is an observant Orthodox Jew of Syrian descent.
12. Plaintiff was initially hired at EdgeTrade by Joseph Wald and Brandon Krieg, both of whom are Jewish.
13. Brandon Krieg was intially plaintiff's immediate supervisor at EdgeTrade, and after a period of transition continued as plaintiff's immediate supervisor at Knight.
14. On or about January 29, 2011, plaintiff attended an engagement celebration for Brandon Krieg and his fiancé, Denise Schuler, in New York City.
15. The party was attended by a number of Brandon Krieg's friends and work colleagues, including other employees from Knight.
16. Defendant Brendan McCarthy was in attendance.
17. During the party, plaintiff and defendant McCarthy engaged in conversation.
18. Defendant McCarthy brought up in the discussion another Knight employee named Ray Ross, who is also Jewish, and whose mother is a Syrian Jew.
19. Defendant McCarthy claimed that Ray Ross was once interested in marrying a woman who is not Jewish, and that supposedly Ross' family prevented him from doing so because the woman was not Jewish (изучающие английский язык, обратите внимание на времена женщины).
20. Defendant McCarthy told plaintiff words to the effect that he (McCarthy) believed the Syrian Jewish community is a closed-knit community, where people will only live in a certain section of Brooklyn, New York, and/or in Deal, New Jersey.
21. Defendant McCarthy went on to tell plaintiff that he (McCarthy) believed the Syrian Jews were "strange" and "backward", and McCarthy generally expressed disdain for their religious beliefs and practices.

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