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Exhibit A
Case: 1:21-cv-06627 Document #: 2-1 Filed: 12/10/21 Page 1 of 4 PageID #:4
EEOC Form 5 ('11109)
CHRncr or D rscRrMrNATtoN
This form is affected by the Privacy Actol 1974. See enclosed Privacy Act
Statement and other information before completing this form.
Charge Presented To: Agency(ies)Charge No(s)
X
FEPA
EEOC
and EEOC
State or local Agency, if any
lllinois Depa rtment of Human Riqhts
Home Phone (lncl. Area Code) of Birth
947
i,
sid u M.D.
Name (rndlcafe Mr., Ms.,
Dr. T
City, State and ZIP Code
Chicago, lL 60610
Street Address
1335 N. Astor St. #138
Named is the Employer, Labor Organization, Employment Agency, Apprenticeship Committee, or State or t-oc4{l6ovbrnment'Agency That I Believe
Discriminated Against Me or Others. (lf more than two, list under PARTICULARS below.)
Name
Northwestern Medical Group f/Ua Northwestern Medical Faculty Foundation,
Northwestern University Feinberg School Of Medicine, Northwestern University,
Northwestern Memorial Healthcare
No. Employees, Members
$51,:ir
, ,l: [t,i'T"w"
Area Code)
,l
3 695-6609
( 2',)
Street Address
21 E. Ontario St.. Suite 1800
City, State and ZIP Code
Chicaqo. lL 60611
DATE(S) DISCRIMINATION TOOK PLACE
Earliest Latest
November 1,2013 July 1, 2019
(approximate)
CONTINUING ACTION
DISCRIMINATION BASED ON (Check appropriate box(es).)
X
RELIGION
RETALIATION
RACE COLOR SEX
AGE DISABILITY
n OTHER (Specify)
FMLA see below
NATIONAL
ORIGIN
GENETIC
INFORMATION
THE PARTICULARS ARE (lf additional paper is needed, attadh extra sheet(s)):
I am a physician-scientist, internationally recognized as an expert in neuromuscular disease and a pioneering world-
renowned neurogeneticist who has discovered multiple causative genes for the inherited form of amyotrophic lateral
sclerosis (ALS), commonly known as Lou Gehrig's disease. My research has been continuously funded by the National
Institutes of Health G,{IH) since 1985, and I have 160 peer-reviewed publications, hundreds of abstracts, given dozens of
invited seminars, and published several book chapters to my credit. I have received all the major national and
international awards for ALS research, and I have been recognized as Top Doctor (Chicago Magazine and Castle
Connolly) consecutively for the last 18 years.
On or about August 9, 1990, I received a formal offer of employment from Northwestern University Feinberg School of
Medicine ('NU Feinberg"). NU Feinberg is a medical school owned, operated, and controlled by Northwestern
University ('IU"). In or about November 1990, I accepted and signed a contract of employment with Northwestern
Medical Faculty Foundation ('IMFF"), the clinical arm of NU Feinberg to become effective on January 1,199I.
Northwestern Medical Group ('NMG") is the successor to NMFF. Northwestern Memorial HealthCare ('NMHC") is
the healthcare ann of NU, is the umbrella or parent co{poration of NMG, and is closely affrliated with NU Feinberg.
Accordingly, NU Feinberg, lrIIJ, NMFFAIMG, and NMHC (collectively, the'Northwestem Employers") were my joint-
employer during the relevant time period for the pulposes of Title VII and the ADEA. I have been continuously
employed in good standing with the Northwestern Employers from January 1, l99l to the present, and I am currently a
tenured professor. The contact information for the Northwestern Employers is attached hereto as Exhibit A.
I am now 72 years old. Since 2013, the Northwestern Employers have discriminated against me based on age with
respect to the terms, conditions, and privileges of my employment. [See additional page]
NOTARY - When necessary for State and Local Agency Requirements
I want this charge filed with both the EEOC and the State or local Agency, if any. I
will advise the agencies if I change my address or phone number and I will
cooperate fully with them in the processing of my charge in accordance with their
procedures.
I swear or affirm that I have read the above charge and that it is true to
IS DATE
SWORN TO
st
XX
,
the best of my lnformation and belief
I declare under penalty of perjury that the above is true and corect.
23 dfi
Yil rr1 ffiDDiiElllilluilm/zl
1
Case: 1:21-cv-06627 Document #: 2-1 Filed: 12/10/21 Page 2 of 4 PageID #:5
fContinued from previous page]
Specifically, by funding cuts and interference with and redirection of my funding for research,
experiments, staffing, andlor laboratory and clinical work, the Northwestern Employers have tried to set
me up for failure by making my job responsibilities virtually impossible to perform at the highest level.
From 2013 to the present, my long-standing established responsibilities have been systematically reduced
or eliminated, among other things.
In or about 2016, the Chair of the NU Feinberg Department of Neurology announced at a department
meeting that I had been "put out to pasture." Shortly thereafter, the Chair sent an email to the entire NU
Feinberg neurology faculty informing that he was actively looking to fill my position. I was blindsided
by this email, as the job search had not been discussed with me and I was unaware that the Northwestern
Employers were seeking my replacement.
Although my employment conkact provides that I shall "(d)irect the Neuromuscular Disorders program
having direct supervision of the Les Turner Foundation Lois Insolia ALS Clinic, the Les Turner
Foundation ALS Research Program, and the Department's muscle histochemical laboratory", in2016,the
Northwestem Bmployers - again, without my advance knowledge - advertised for an academic
neurologist to becomc Director of a ncw Lcs Turncr ALS Rcscarch and Paticnt Ccntcr. This job scarch
effectively sought to eliminate my position, responsibility, and authority. In 2017, the Northwestern
Employers hired a new Director of the Division of Neuromuscular Medicine, previously the
Neuromuscular Program/Division, and Director of the new Les Turner ALS Center, making him
responsible, instead of me, for the Les Tumer ALS Foundation relationships and the neuromuscular
clinics. The new Director is younger than me, and he has had far fewer contributions to ALS,
neuromuscular research, and patient care than me. On July 1, 20l9,the Northwestern Employers further
discriminated against me by reducing my pay.
The Northwestern Employers' actions are in direct conflict with both my employment contract and the
applicable rules governing the treatment of tenured professors. I am now 7I years old, and I believe the
Northwestern Employers targeted me for a salary reduction and engaged in the other aforementioned acts
of discrimination against me because of my age.
I declare under penalty of perjury that the above is true and correct.
J tb
Charging Party
Case: 1:21-cv-06627 Document #: 2-1 Filed: 12/10/21 Page 3 of 4 PageID #:6
Exhibit A
After conducting a reasonable investigation, including reviewing publically available information, upon
information and belief, the contact information for the Northwestern Employers is as follows:
Employer
No.
Employees,
Members
Phone No.
Street Address
City, State and ZIP Code
Northwestern Un ivers ity 50+
(847) 491-374r
(847) 491-s60s
633 Clark St.
Evanston,IL 60208
Northwestern Memorial
Healthcare
50+ (3r2) 69s-6609
21 E. Ontario St., Suite 1800
Chicaeo. IL 60611
Northwestern Medical Group
f/k/a Northwestem Medical
FaculW Foundation
50+ (3r2) 69s-6609
21 E. Ontario St., Suite 1800
Chicago, IL 60611
Northwestern University
Feinbers School Of Medicine
50+ (3t2) s03-8194
420 E. Superior St.
Chicaeo. IL 60611
Case: 1:21-cv-06627 Document #: 2-1 Filed: 12/10/21 Page 4 of 4 PageID #:7
Exhibit B
Case: 1:21-cv-06627 Document #: 2-2 Filed: 12/10/21 Page 1 of 5 PageID #:8
~ve& ~ VJ7M
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION cyY
~ I
Chicago District Office
JCK Federal Building
230 S. Dearbol1l
Suite 1866 (Enforcement, Slate and Local & Hearings)
Suite 2920 (Legal & ADR)
Chicago, IL 60604
Intake Infonnafion Group: (800) 669~4000
Intake Infonnatioll Group TTY: (800) 669-6820
Chicago Direct Dial: (312) 872-9777
Administration Fax: (312) 588-1255
Enforcement/File Disclosure Fa"':: (312) 588-1260
Federal Sector Fax: (312) 588-1265
Intake FIL~: (312) 588-1286
Legal Fa" (312) 588-1494
Mediation Fax: (312) 588-1498
Website: v'....w.eeoc.gov
DISMISSAL AND NOTICE OF RIGHTS ENCLOSED
RE: EEOC Charge No.:
Charging Party:
Respondent:
Dear Mr. Siddique:
440-2019-07444
Teepu Siddique
NORTHWESTERN UNIVERSITY
The United States Equal Employment Opportunity Commission (EEOC) issued the enclosed
Dismissal and Notice of Rights (Notice) in the above-referenced charge on the date reflected
thereon. Specifically, on that date, EEOC sent you an email notification that EEOC had made a
decision regarding the above-referenced charge and advised you to download a copy of the
decision document from the Portal. Our records indicate you have not downloaded the Notice from
the Portal. For your convenience, a copy of the Notice is enclosed with this letter.
Please note that if the Charging Party wants to pursue tius matter further in court, Charging Party
must file a lawsuit within 90 days ofthe date they receive the Notice. The 90-day period for filing
a private lawsuit cannot be waived, extended, or restored by tile EEOC.
I hope this information is helpful. If you have questions, please contact Robert Shelton
by telephone at (312) 872-9725 or email at robert.shelton@eeoc.gov.
Sincerely,
T~13ow~cW
District Director
Enclosure
9/812021
Date Mailed
Case: 1:21-cv-06627 Document #: 2-2 Filed: 12/10/21 Page 2 of 5 PageID #:9
EEOC Form 161 {11f2020} U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
DISMISSAL AND NOTICE OF RIGHTS
To: Teepu Siddique
clo Sleven J. Rosenberg, Esq.
GOLAN CHRISTIE TAGLIA LLP
70 West Madison St, Suite 1500
Chicago,Il60G02
From: Chicago District Office
230 S. Dearbom
D
EEOC Charge No.
440-2019-07444
On behalf ofperson(s) aggrieved whose identity is
CONFIDENTIAL (29 CFR §1601. 7(a))
EEOC Representative
Robert Shelton,
Investigator
Suite 1866
Chicago, IL 60604
THE EEOC IS CLOSING ITS FILE ON THIS CHARGE FOR THE FOLLOWING REASON:
Telephone No.
(312) 872-9725
o The facts alleged in the charge fail to state a claim under any of !he statutes enforced by the EEOC.
o
o
D
o
o
Your allegations did not involve a disability as defined by the Americans With Disabilities Act.
The Respondent employs less than the reqUired number of employees or is not otherwise covered by the statutes.
Your charge was not timely filed with EEOC; in other words, you waited too long after the date(s) of 1I1e alleged
discrimination to file your charge
The EEOC issues the following determination: The EEOC will not proceed further with its investigation, and makes no
determination about whether further investigation would establish violations of the statute. This does not mean the claims
have no merit. This determination does not certify that the respondent is in compliance with the statutes. The EEOC
makes no finding as to the merits of any other issues that might be construed as having been raised by this charge.
The EEOC has adopted the findings of the state or local fair employment practices agency that investigated this charge.
Other (briefly state)
- NOTICE OF SUIT RIGHTS -
(See the additional information attached to this form.)
Title VII, the Americans with Disabilities Act, the Genetic Infonnation Nondiscrimination Act, or the Age
Discrimination in Employment Act: This will be the only notice of dismissal and of your right to sue that we will send you.
You may file a lawsuit against the respondent(s) under federal law based on this charge in federal or state court. Your
lawsuit must be filed WITHIN 90 DAYS of your receipt of this notice; or your right to sue based on this charge will be
lost. (The time limit for filing suit based on a claim under state law may be different.)
Equal Pay Act(EPA): EPA suits must be filed in federal or state court within 2 years (3 years for willful violations) of the
alleged EPA underpayment. This means that backpay due for any violations that occurred more than 2 vears (3 years)
before you file suit may not be colleclible. '
On behalf of the Commission
Julianne 13owman/msa
Enclosures(s)
cc: NORTHWESTERN UNIVERSITY
clo Scott Wamer, Esq.
Husch Blackwell LLP
120 South Riverside Plaza, Ste. 2200
Chicago, IL 60606
Julianne Bowman,
District Director
8/25/2021
(Date Issued)
Case: 1:21-cv-06627 Document #: 2-2 Filed: 12/10/21 Page 3 of 5 PageID #:10
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Chicago District Office
JCK Federal Building
230 S. Dearbom
Suite 1866 (Enforcement, Slate and Local & Hearings)
Suite 2920 (Legal & ADR)
Chicago, IL 60604
Intake Infomlation Group: (800) 669~4000
Inlake I11fonnalio11 Group TIY: (800) 669-6820
Chicago Direct Dial: (312) 872-9777
Administration Fax; (312) 588-1255
Enforcement/File Disclosure Fax: (312) 588-1260
Federal Sector Fax; (312) 588-1265
Intake F",:: (312) 588-1286
Legal Fax: (312) 588-1494
Mediation Fax: (312) 588-1498
Website: ww'.....eeoc.go'
DISMISSAL AND NOTICE OF RIGHTS ENCLOSED
RE: EEOC Charge No.:
Charging Party:
Respondent:
Dear Mr. Siddique:
440-2019-07276
Teepu Siddique
NORTHWESTERN MEDICAL GROUP
F/KIA NORTHWESTERN MEDICAL FACULTY
The United States Equal Employment Opportunity Commission (EEOC) issued the enclosed
Dismissal and Notice of Rights (Notice) in the above-referenced charge on the date reflected
thereon. Specifically, on that date, EEOC sent you an email notification that EEOC had made a
decision regarding the above-referenced charge and advised you to download a copy of the
decision document from the POlial. Our records indicate you have not downloaded the Notice from
the Portal. For your convenience, a copy ofthe Notice is enclosed with this letter.
Please note that if the Charging Party wants to pursue tlus matter further in court, Charging Paliy
must file a lawsuit within 90 days ofthe date they receive the Notice. The 90-day period for filing
a private lawsuit cannot be waived, extended, or restored by the EEOC.
I hope this information is helpful. If you have questions, please contact Robert Shelton
by telephone at (312) 872-9725 or email at robert.shelton@eeoc.gov.
Sincerely,
T~13owl'!'UM'l/cW
District Director
Enclosure
9/8/2021
Date Mailed
Case: 1:21-cv-06627 Document #: 2-2 Filed: 12/10/21 Page 4 of 5 PageID #:11
EEOC Form 161 (11/2020) U.S. EQUAL EMPLOYMENT OPPORTUNITY COM MISSION
DISMISSAL AND NOTICE OF RIGHTS
To: Teepu Siddique
clo Steven J. Rosenberg, Esq.
GOLAN CHRISTIE TAGLIA LLP
70 West Madison St, Suite 1500
Ch icago, IL 60602
From: Chicago District Office
230 S. Dearbom
D
EEOC Charge No.
On behalf ofperson(s) aggrieved whose identity is
CONFIDENTIAL (29 CFR §1601.7(a))
EEOC Representative
Robert Shelton,
440-2019-07276 Investigator
Suite 1866
Chicago,IL60604
THE EEOC IS CLOSING ITS FILE ON THIS CHARGE FOR THE FOLLOWING REASON:
Telephone No.
(312) 872-9725
D The facts alleged in the charge fail to state a claim under any of the statutes enforced by the EEOC.
D
D
D
D
D
Your allegations did not involve a disability as defined by the Americans With Disabilities Act.
The Respondent employs less than the required number of employees or is not otherwise covered by the statutes.
Your charge was not timely filed with EEOC; in other words, you waited too long after the date(s) of the alleged
discrimination to file your charge
The EEOC issues the following determination: The EEOC will not proceed further with its investigation, and makes no
determination about whether further investigation would establish violations of the statute. This does not mean the claims
have no merit. This determination does not certify that the respondent is in compliance with the statutes. The EEOC
makes no finding as to the merits of any other issues that might be construed as having been raised by this charge.
The EEOC has adopted the findings of the state or local fair employment practices agency that investigated this charge.
Other (briefly state)
- NOTICE OF SUIT RIGHTS -
(See the additional information attached to this form.)
Title VII, the Americans with Disabilities Act, the Genetic Infonmation Nondiscrimination Act, or the Age
Discrimination in Employment Act: This will be the only notice of dismissal and of your right to sue that we Will send you.
You may file a lawsuit against the respondent(s) under federal law based on this charge in federal or state court. Your
lawsuit must be filed WITHIN 90 DAVS of you r receipt of this notice; or your right to sue based on this charge will be
lost. (The time limit for filing suit based on a claim under state law may be different.)
Equal Pay Act (EPA): EPA suits must be filed in federal or state court within 2 years (3 years for willful violations) of the
alleged EPA underpayment. This means that backpay due for any violations that occurred more than 2 years (3 years)
before you file su it may not be collectible.
On behalf of the Commission
JuCianne 'Bowman/msa
Enclosures(s) Julianne Bowman,
District Director
cc: NORTHWESTERN MEMORIAL HEALTHCARE
clo William Miossi, Esq.
Winston & Strawn, LLP
1700 KSt. NW
Washington, D.C. 20006
8/25/2021
(Date ISsued)
Case: 1:21-cv-06627 Document #: 2-2 Filed: 12/10/21 Page 5 of 5 PageID #:12

Siddique_vs_NMFF_2021_1_21-cv-06627 - Northwestern Medicine Employment Discrimination

  • 1.
    Case: 1:21-cv-06627 Document#: 2 Filed: 12/10/21 Page 1 of 3 PageID #:1
  • 2.
    Case: 1:21-cv-06627 Document#: 2 Filed: 12/10/21 Page 2 of 3 PageID #:2
  • 3.
    Case: 1:21-cv-06627 Document#: 2 Filed: 12/10/21 Page 3 of 3 PageID #:3
  • 4.
    Exhibit A Case: 1:21-cv-06627Document #: 2-1 Filed: 12/10/21 Page 1 of 4 PageID #:4
  • 5.
    EEOC Form 5('11109) CHRncr or D rscRrMrNATtoN This form is affected by the Privacy Actol 1974. See enclosed Privacy Act Statement and other information before completing this form. Charge Presented To: Agency(ies)Charge No(s) X FEPA EEOC and EEOC State or local Agency, if any lllinois Depa rtment of Human Riqhts Home Phone (lncl. Area Code) of Birth 947 i, sid u M.D. Name (rndlcafe Mr., Ms., Dr. T City, State and ZIP Code Chicago, lL 60610 Street Address 1335 N. Astor St. #138 Named is the Employer, Labor Organization, Employment Agency, Apprenticeship Committee, or State or t-oc4{l6ovbrnment'Agency That I Believe Discriminated Against Me or Others. (lf more than two, list under PARTICULARS below.) Name Northwestern Medical Group f/Ua Northwestern Medical Faculty Foundation, Northwestern University Feinberg School Of Medicine, Northwestern University, Northwestern Memorial Healthcare No. Employees, Members $51,:ir , ,l: [t,i'T"w" Area Code) ,l 3 695-6609 ( 2',) Street Address 21 E. Ontario St.. Suite 1800 City, State and ZIP Code Chicaqo. lL 60611 DATE(S) DISCRIMINATION TOOK PLACE Earliest Latest November 1,2013 July 1, 2019 (approximate) CONTINUING ACTION DISCRIMINATION BASED ON (Check appropriate box(es).) X RELIGION RETALIATION RACE COLOR SEX AGE DISABILITY n OTHER (Specify) FMLA see below NATIONAL ORIGIN GENETIC INFORMATION THE PARTICULARS ARE (lf additional paper is needed, attadh extra sheet(s)): I am a physician-scientist, internationally recognized as an expert in neuromuscular disease and a pioneering world- renowned neurogeneticist who has discovered multiple causative genes for the inherited form of amyotrophic lateral sclerosis (ALS), commonly known as Lou Gehrig's disease. My research has been continuously funded by the National Institutes of Health G,{IH) since 1985, and I have 160 peer-reviewed publications, hundreds of abstracts, given dozens of invited seminars, and published several book chapters to my credit. I have received all the major national and international awards for ALS research, and I have been recognized as Top Doctor (Chicago Magazine and Castle Connolly) consecutively for the last 18 years. On or about August 9, 1990, I received a formal offer of employment from Northwestern University Feinberg School of Medicine ('NU Feinberg"). NU Feinberg is a medical school owned, operated, and controlled by Northwestern University ('IU"). In or about November 1990, I accepted and signed a contract of employment with Northwestern Medical Faculty Foundation ('IMFF"), the clinical arm of NU Feinberg to become effective on January 1,199I. Northwestern Medical Group ('NMG") is the successor to NMFF. Northwestern Memorial HealthCare ('NMHC") is the healthcare ann of NU, is the umbrella or parent co{poration of NMG, and is closely affrliated with NU Feinberg. Accordingly, NU Feinberg, lrIIJ, NMFFAIMG, and NMHC (collectively, the'Northwestem Employers") were my joint- employer during the relevant time period for the pulposes of Title VII and the ADEA. I have been continuously employed in good standing with the Northwestern Employers from January 1, l99l to the present, and I am currently a tenured professor. The contact information for the Northwestern Employers is attached hereto as Exhibit A. I am now 72 years old. Since 2013, the Northwestern Employers have discriminated against me based on age with respect to the terms, conditions, and privileges of my employment. [See additional page] NOTARY - When necessary for State and Local Agency Requirements I want this charge filed with both the EEOC and the State or local Agency, if any. I will advise the agencies if I change my address or phone number and I will cooperate fully with them in the processing of my charge in accordance with their procedures. I swear or affirm that I have read the above charge and that it is true to IS DATE SWORN TO st XX , the best of my lnformation and belief I declare under penalty of perjury that the above is true and corect. 23 dfi Yil rr1 ffiDDiiElllilluilm/zl 1 Case: 1:21-cv-06627 Document #: 2-1 Filed: 12/10/21 Page 2 of 4 PageID #:5
  • 6.
    fContinued from previouspage] Specifically, by funding cuts and interference with and redirection of my funding for research, experiments, staffing, andlor laboratory and clinical work, the Northwestern Employers have tried to set me up for failure by making my job responsibilities virtually impossible to perform at the highest level. From 2013 to the present, my long-standing established responsibilities have been systematically reduced or eliminated, among other things. In or about 2016, the Chair of the NU Feinberg Department of Neurology announced at a department meeting that I had been "put out to pasture." Shortly thereafter, the Chair sent an email to the entire NU Feinberg neurology faculty informing that he was actively looking to fill my position. I was blindsided by this email, as the job search had not been discussed with me and I was unaware that the Northwestern Employers were seeking my replacement. Although my employment conkact provides that I shall "(d)irect the Neuromuscular Disorders program having direct supervision of the Les Turner Foundation Lois Insolia ALS Clinic, the Les Turner Foundation ALS Research Program, and the Department's muscle histochemical laboratory", in2016,the Northwestem Bmployers - again, without my advance knowledge - advertised for an academic neurologist to becomc Director of a ncw Lcs Turncr ALS Rcscarch and Paticnt Ccntcr. This job scarch effectively sought to eliminate my position, responsibility, and authority. In 2017, the Northwestern Employers hired a new Director of the Division of Neuromuscular Medicine, previously the Neuromuscular Program/Division, and Director of the new Les Turner ALS Center, making him responsible, instead of me, for the Les Tumer ALS Foundation relationships and the neuromuscular clinics. The new Director is younger than me, and he has had far fewer contributions to ALS, neuromuscular research, and patient care than me. On July 1, 20l9,the Northwestern Employers further discriminated against me by reducing my pay. The Northwestern Employers' actions are in direct conflict with both my employment contract and the applicable rules governing the treatment of tenured professors. I am now 7I years old, and I believe the Northwestern Employers targeted me for a salary reduction and engaged in the other aforementioned acts of discrimination against me because of my age. I declare under penalty of perjury that the above is true and correct. J tb Charging Party Case: 1:21-cv-06627 Document #: 2-1 Filed: 12/10/21 Page 3 of 4 PageID #:6
  • 7.
    Exhibit A After conductinga reasonable investigation, including reviewing publically available information, upon information and belief, the contact information for the Northwestern Employers is as follows: Employer No. Employees, Members Phone No. Street Address City, State and ZIP Code Northwestern Un ivers ity 50+ (847) 491-374r (847) 491-s60s 633 Clark St. Evanston,IL 60208 Northwestern Memorial Healthcare 50+ (3r2) 69s-6609 21 E. Ontario St., Suite 1800 Chicaeo. IL 60611 Northwestern Medical Group f/k/a Northwestem Medical FaculW Foundation 50+ (3r2) 69s-6609 21 E. Ontario St., Suite 1800 Chicago, IL 60611 Northwestern University Feinbers School Of Medicine 50+ (3t2) s03-8194 420 E. Superior St. Chicaeo. IL 60611 Case: 1:21-cv-06627 Document #: 2-1 Filed: 12/10/21 Page 4 of 4 PageID #:7
  • 8.
    Exhibit B Case: 1:21-cv-06627Document #: 2-2 Filed: 12/10/21 Page 1 of 5 PageID #:8
  • 9.
    ~ve& ~ VJ7M U.S.EQUAL EMPLOYMENT OPPORTUNITY COMMISSION cyY ~ I Chicago District Office JCK Federal Building 230 S. Dearbol1l Suite 1866 (Enforcement, Slate and Local & Hearings) Suite 2920 (Legal & ADR) Chicago, IL 60604 Intake Infonnafion Group: (800) 669~4000 Intake Infonnatioll Group TTY: (800) 669-6820 Chicago Direct Dial: (312) 872-9777 Administration Fax: (312) 588-1255 Enforcement/File Disclosure Fa"':: (312) 588-1260 Federal Sector Fax: (312) 588-1265 Intake FIL~: (312) 588-1286 Legal Fa" (312) 588-1494 Mediation Fax: (312) 588-1498 Website: v'....w.eeoc.gov DISMISSAL AND NOTICE OF RIGHTS ENCLOSED RE: EEOC Charge No.: Charging Party: Respondent: Dear Mr. Siddique: 440-2019-07444 Teepu Siddique NORTHWESTERN UNIVERSITY The United States Equal Employment Opportunity Commission (EEOC) issued the enclosed Dismissal and Notice of Rights (Notice) in the above-referenced charge on the date reflected thereon. Specifically, on that date, EEOC sent you an email notification that EEOC had made a decision regarding the above-referenced charge and advised you to download a copy of the decision document from the Portal. Our records indicate you have not downloaded the Notice from the Portal. For your convenience, a copy of the Notice is enclosed with this letter. Please note that if the Charging Party wants to pursue tius matter further in court, Charging Party must file a lawsuit within 90 days ofthe date they receive the Notice. The 90-day period for filing a private lawsuit cannot be waived, extended, or restored by tile EEOC. I hope this information is helpful. If you have questions, please contact Robert Shelton by telephone at (312) 872-9725 or email at robert.shelton@eeoc.gov. Sincerely, T~13ow~cW District Director Enclosure 9/812021 Date Mailed Case: 1:21-cv-06627 Document #: 2-2 Filed: 12/10/21 Page 2 of 5 PageID #:9
  • 10.
    EEOC Form 161{11f2020} U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION DISMISSAL AND NOTICE OF RIGHTS To: Teepu Siddique clo Sleven J. Rosenberg, Esq. GOLAN CHRISTIE TAGLIA LLP 70 West Madison St, Suite 1500 Chicago,Il60G02 From: Chicago District Office 230 S. Dearbom D EEOC Charge No. 440-2019-07444 On behalf ofperson(s) aggrieved whose identity is CONFIDENTIAL (29 CFR §1601. 7(a)) EEOC Representative Robert Shelton, Investigator Suite 1866 Chicago, IL 60604 THE EEOC IS CLOSING ITS FILE ON THIS CHARGE FOR THE FOLLOWING REASON: Telephone No. (312) 872-9725 o The facts alleged in the charge fail to state a claim under any of !he statutes enforced by the EEOC. o o D o o Your allegations did not involve a disability as defined by the Americans With Disabilities Act. The Respondent employs less than the reqUired number of employees or is not otherwise covered by the statutes. Your charge was not timely filed with EEOC; in other words, you waited too long after the date(s) of 1I1e alleged discrimination to file your charge The EEOC issues the following determination: The EEOC will not proceed further with its investigation, and makes no determination about whether further investigation would establish violations of the statute. This does not mean the claims have no merit. This determination does not certify that the respondent is in compliance with the statutes. The EEOC makes no finding as to the merits of any other issues that might be construed as having been raised by this charge. The EEOC has adopted the findings of the state or local fair employment practices agency that investigated this charge. Other (briefly state) - NOTICE OF SUIT RIGHTS - (See the additional information attached to this form.) Title VII, the Americans with Disabilities Act, the Genetic Infonnation Nondiscrimination Act, or the Age Discrimination in Employment Act: This will be the only notice of dismissal and of your right to sue that we will send you. You may file a lawsuit against the respondent(s) under federal law based on this charge in federal or state court. Your lawsuit must be filed WITHIN 90 DAYS of your receipt of this notice; or your right to sue based on this charge will be lost. (The time limit for filing suit based on a claim under state law may be different.) Equal Pay Act(EPA): EPA suits must be filed in federal or state court within 2 years (3 years for willful violations) of the alleged EPA underpayment. This means that backpay due for any violations that occurred more than 2 vears (3 years) before you file suit may not be colleclible. ' On behalf of the Commission Julianne 13owman/msa Enclosures(s) cc: NORTHWESTERN UNIVERSITY clo Scott Wamer, Esq. Husch Blackwell LLP 120 South Riverside Plaza, Ste. 2200 Chicago, IL 60606 Julianne Bowman, District Director 8/25/2021 (Date Issued) Case: 1:21-cv-06627 Document #: 2-2 Filed: 12/10/21 Page 3 of 5 PageID #:10
  • 11.
    U.S. EQUAL EMPLOYMENTOPPORTUNITY COMMISSION Chicago District Office JCK Federal Building 230 S. Dearbom Suite 1866 (Enforcement, Slate and Local & Hearings) Suite 2920 (Legal & ADR) Chicago, IL 60604 Intake Infomlation Group: (800) 669~4000 Inlake I11fonnalio11 Group TIY: (800) 669-6820 Chicago Direct Dial: (312) 872-9777 Administration Fax; (312) 588-1255 Enforcement/File Disclosure Fax: (312) 588-1260 Federal Sector Fax; (312) 588-1265 Intake F",:: (312) 588-1286 Legal Fax: (312) 588-1494 Mediation Fax: (312) 588-1498 Website: ww'.....eeoc.go' DISMISSAL AND NOTICE OF RIGHTS ENCLOSED RE: EEOC Charge No.: Charging Party: Respondent: Dear Mr. Siddique: 440-2019-07276 Teepu Siddique NORTHWESTERN MEDICAL GROUP F/KIA NORTHWESTERN MEDICAL FACULTY The United States Equal Employment Opportunity Commission (EEOC) issued the enclosed Dismissal and Notice of Rights (Notice) in the above-referenced charge on the date reflected thereon. Specifically, on that date, EEOC sent you an email notification that EEOC had made a decision regarding the above-referenced charge and advised you to download a copy of the decision document from the POlial. Our records indicate you have not downloaded the Notice from the Portal. For your convenience, a copy ofthe Notice is enclosed with this letter. Please note that if the Charging Party wants to pursue tlus matter further in court, Charging Paliy must file a lawsuit within 90 days ofthe date they receive the Notice. The 90-day period for filing a private lawsuit cannot be waived, extended, or restored by the EEOC. I hope this information is helpful. If you have questions, please contact Robert Shelton by telephone at (312) 872-9725 or email at robert.shelton@eeoc.gov. Sincerely, T~13owl'!'UM'l/cW District Director Enclosure 9/8/2021 Date Mailed Case: 1:21-cv-06627 Document #: 2-2 Filed: 12/10/21 Page 4 of 5 PageID #:11
  • 12.
    EEOC Form 161(11/2020) U.S. EQUAL EMPLOYMENT OPPORTUNITY COM MISSION DISMISSAL AND NOTICE OF RIGHTS To: Teepu Siddique clo Steven J. Rosenberg, Esq. GOLAN CHRISTIE TAGLIA LLP 70 West Madison St, Suite 1500 Ch icago, IL 60602 From: Chicago District Office 230 S. Dearbom D EEOC Charge No. On behalf ofperson(s) aggrieved whose identity is CONFIDENTIAL (29 CFR §1601.7(a)) EEOC Representative Robert Shelton, 440-2019-07276 Investigator Suite 1866 Chicago,IL60604 THE EEOC IS CLOSING ITS FILE ON THIS CHARGE FOR THE FOLLOWING REASON: Telephone No. (312) 872-9725 D The facts alleged in the charge fail to state a claim under any of the statutes enforced by the EEOC. D D D D D Your allegations did not involve a disability as defined by the Americans With Disabilities Act. The Respondent employs less than the required number of employees or is not otherwise covered by the statutes. Your charge was not timely filed with EEOC; in other words, you waited too long after the date(s) of the alleged discrimination to file your charge The EEOC issues the following determination: The EEOC will not proceed further with its investigation, and makes no determination about whether further investigation would establish violations of the statute. This does not mean the claims have no merit. This determination does not certify that the respondent is in compliance with the statutes. The EEOC makes no finding as to the merits of any other issues that might be construed as having been raised by this charge. The EEOC has adopted the findings of the state or local fair employment practices agency that investigated this charge. Other (briefly state) - NOTICE OF SUIT RIGHTS - (See the additional information attached to this form.) Title VII, the Americans with Disabilities Act, the Genetic Infonmation Nondiscrimination Act, or the Age Discrimination in Employment Act: This will be the only notice of dismissal and of your right to sue that we Will send you. You may file a lawsuit against the respondent(s) under federal law based on this charge in federal or state court. Your lawsuit must be filed WITHIN 90 DAVS of you r receipt of this notice; or your right to sue based on this charge will be lost. (The time limit for filing suit based on a claim under state law may be different.) Equal Pay Act (EPA): EPA suits must be filed in federal or state court within 2 years (3 years for willful violations) of the alleged EPA underpayment. This means that backpay due for any violations that occurred more than 2 years (3 years) before you file su it may not be collectible. On behalf of the Commission JuCianne 'Bowman/msa Enclosures(s) Julianne Bowman, District Director cc: NORTHWESTERN MEMORIAL HEALTHCARE clo William Miossi, Esq. Winston & Strawn, LLP 1700 KSt. NW Washington, D.C. 20006 8/25/2021 (Date ISsued) Case: 1:21-cv-06627 Document #: 2-2 Filed: 12/10/21 Page 5 of 5 PageID #:12