Complaint Review: Allstate Imaging Bernard Wyatt Michael Orcutt Michael Bolebruch Michael Salcito - Tucson Arizona

Attorney General's Office, Civil Rights, Pima Superior Court Lawsuit Approved Below you will find my first lawsuit against Allstate Imaging for violation of national and local Civil Rights and employment law. It is presented as a typical Civil Rights lawsuit so that any in a hostile work environment can make the very best use of it in any way possible. We cannot make gains against racism, sexism, and prejudice against the elderly and handicapped, we cannot make a safe world for your children and yourselves, we cannot abolish all war and earth's heinous, wicked and untenable and unmaintainable conditions without your help. How could anyone do this in increasingly democratic societies of informed and intelligent adults? My personal position is that I will put any company that involves fascism and racism in workplace harassment out of business, clearly and unequivocably, and those that unrepentantly continue directly in hell. In my conversations with the local office of the FBI, and discussions with Federal Prosecutors regarding additional abuses of Allstate Imaging - cartridges being used to nationally and internationally ship cocaine, defrauding the government - qui tam - any particularly complete records of sales directly to the government would be appreciated. Please email me directly if you would like to be included in class action lawsuit against these fraudulent, unrepentant and utterly irresponsible wickeds. May also attempt to inform any and every company that Allstate Imaging does business with of the untold and despicable, life-ruining evils of this company. To me all this is only a token gesture. I will relay some more details of this company's clear and flagrant abuses of blacks, Jews, women, Hispanics in another place, plus the absolute measures that will be taken against this company and it's owners in another posting. This case has already been assigned and accepted not only as representative of flagrant abuses of Civil Rights and workplace law by the Arizona Attorney General's Office, but has been filed and accepted by the Superior Court of Pima County, Arizona. Take very great care. The actions of this company have already resulted not only in terrorism and in fact death and various felony behaviors, but apparently some wicked little racist, nationalist denouements are actually controlling others to violate even the children of former employees. When we fail to correct flagrant economic abuses, we not only fail our better selves, goodness and love, we fail to make a better world and dysfunctionally initiate cycles of continued abuses, even if this is not immediately obvious to you. Lawrence Morris Leight, pro per [[email protected]] Tucson, Arizona 85716-5506 Plaintiff IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR PIMA COUNTY LAWRENCE MORRIS LEIGHT, ) ) No. Applicant ) COMPLAINT ) Application for Order to Show ) Cause and order Enforcing Vs. ) Subpoena ) Allstate Imaging Inc., a California ) Assigned to: Corporation, it's owners, management, ) and employees, both individually and ) as company officers. ) Defendants. ) _______________________________) Applicant Pima County, Arizona, resident Lawrence Morris Leight, pro per, and the Civil Rights Division of the Arizona Department of Law allege as follows: 1. This Court has jurisdiction of the instant application pursuant to A.R.S. section 41-1403(B)(3). This action is also filed under Federal Statute Title VII and ADA. 2. The Civil rights division of the Arizona Department of Law (hereinafter the Division) is an administrative agency created by A.R.S. section 41-1401-1984 for the purpose of investigating and conciliating charges of discrimination in employment and public accommodations. 3. A.R.S. section 41-1481(B) requires the Division to investigate charges of employment discrimination within A.R.S. section 41- 1463, which have been filed with it by members of the public. 4. To aid in investigating such charges, the Division is authorized by A.R.S. section 41-1403(B)(1) to issue subpoenas compelling the attendance and testimony of witnesses and the production of documents. Under A.R.S. section 41-1403(B)(4) such subpoenas may be served personally or by registered mail. 5. On October 5, 2007, Lawrence Leight filed a charge of employment discrimination with the Division against Allstate Imaging Incorporated. A copy of that charge is attached hereto as Exhibit A and is incorporated by reference herein. That charge was assigned to Keith Shaw for investigation. 6. In October, 2007, the Division caused to be served on Allstate Imaging a set of interrogatories and an administrative subpoena duces tecum requiring answers to question and documents and records which are relevant to Leight's charge. 7. Those interrogatories and subpoena were served on Respondent. 8. Respondent has not been granted additional time to respond to the interrogatories or the subpoena duces tecum nor has objection been made to the subpoena on the grounds set out at A.R.S. Section 41-1403(B)(3), e.g. that the evidence does not relate to unlawful practices covered by this chapter, that it is not relevant to the charge which is the subject matter of the investigation, that it does not describe with sufficient particularity the evidence whose production is required, or that it is unduly burdensome or oppressive. 9. A.R.S. section 41-1403(B)(1) provides in relevant part: The Superior Court, upon application by the division or the person subpoenaed, shall have jurisdiction to issue an order (a) requiring such person to appear before the division, the Board or the duly authorized agent of either, there to produce evidence relating to the matter under investigation if so ordered.Any failure to obey such order may be punished by such court as a contempt. 9. The Plaintiff was at all times herein a resident of Pima County, Arizona. 10. The Defendant, ALLSTATE IMAGING, INC. is a California Corporation based in Chatsworth. 11. The Defendants, each and all of them, were acting in their capacities as agents, employees and representatives of Said Defendant; the Defendants JOHN DOES I-V and JANE DOES I-V were at all times relevant herein employees, officers or agents of the Defendant, each and all of them; the Defendants JOHN DOES I-V and Jane DOES I-V are as yet undetermined, but the Plaintiff will move this Court to amend the Complaint as soon as their identities are determined; the Defendants, each and all of them were acting in their capacities agents servants and employees of each and all of the other Defendants and acted for all pertinent purposes within the course and scope of their employment. 12. The acts complained of herein took place primarily within Pima County, Arizona. 13. Plaintiff is a male of Hebraic descent who was employed as a phone salesperson by the Defendant. 14. Defendant is in the business of selling both remanufactured and other ink and toner cartridges. Defendant had at least one employee for twenty consecutive weeks in calendar years 2007-2008. 15. Plaintiff filed a charge of employment harassment and discrimination with the Civil Rights Division on October 5, 2007, alleging among other things, that during his employment manager(s), closer(s) and employees of Allstate Imaging made unwelcome and unsolicited racist, sexist and anti-semetic comments and innuendos. 16. Defendant's comments also amounted to illegal conversation regarding both drugs and sex, including the sexual violation of a minor and the use of company property to transport felony drugs, that Plaintiff reported these to the Tucson Police as well as other government agencies. 17. Continuous and daily sexism and racism was displayed by employees of this company, not only violating the rights of other employees of these protected classes (women, a black man, older men, pregnant women, those with medical condition, Jews) but making Allstate Imaging a hostile and illegal work environment. 18. Claims made by employees regarding product origins and longevity when compared to Original Equipment Manufacturer (OEM) contradicted those at the company website, and thus this company has been accused of fraud and defrauding the government. 19. The Defendant was fired from his job by manager Steve Geraci in the presence of two managers flown in from California to specifically address Plaintiffs complaints and objections to the illegal ways in which Allstate Imaging was run and managed. 20. That the de facto requirement that the Plaintiff stay overtime to address these concerns was given no notice. COUNT I Violation of Arizona Discrimination Laws 21. The facts previously set out give rise to a cause of action for discrimination pursuant to Arizona law. It is unlawful for an employer to discriminate against an employee on the basis of gender, religion, race or ethnicity, or to otherwise create a hostile work environment. The Defendants, each and all of them, discriminated against the Plaintiff by creating and allowing a hostile work environment because of the Plaintiff's gender and race, and regardless of both. The Defendants, each and all of them, knew or reasonably should have known of the individual Defendant's conduct. The Plaintiff was constructively discharged and seriously harmed by this conduct. As such, the Plaintiff seeks recovery for his damages. COUNT II Constructive Discharge 22. The facts set out previously give rise to a cause of action for constructive discharge when the Plaintiff criticized the bad management and judgment of Steve Geraci and objected to being asked to stay overtime without warning. Despite repeated requests that the Defendants stop the harassment and verbal abuse, the Defendants failed to correct the situation. The constructive discharge of the Plaintiff by the Defendants was wrongful, in bad faith, and in violation of the public policy of the State of Arizona as embodied in the State's discrimination laws, Title VII, civil rights Act of 1964. Being constructively discharged from his employment has damaged the Plaintiff. The constructive discharge of the Plaintiff was done in bad faith, with malice and with evil minds. COUNT III Violation of Title VII, Civil Rights Act of 1964 23. The facts set out previously give rise to a cause of action for violations under Title VII of the Civil rights Act of 1964; the Plaintiff was a member of a protected class and the Defendant is a covered employer; The Plaintiff has set forth facts demonstrating employment discrimination, retaliation and other violation of his civil rights. Said actions were willful and warrant the implementation of damages for the harms the Plaintiff suffered. 24. The Plaintiff has suffered damages because of the actions and inaction of the Defendants. The Defendants' conduct proximately caused the Plaintiff to suffer severe emotional distress, mental anguish, indignation, wounded love, shame and despair. In addition to these injuries, the Defendants' conduct has proximately caused the Plaintiff to suffer pecuniary losses and lost employment opportunities. 25. The conduct of the Defendants described in this Complaint was willful and malicious so as to entitle the Plaintiff to recover exemplary damages to punish the Defendants and to deter such conduct in the future. The Plaintiff will show that, as a result of the Defendant's conduct, the Plaintiff has suffered loss of time and expenses, including reasonable attorneys fees incurred in this investigation and prosecution of this action. Accordingly, the Plaintiff asks that exemplary damages be awarded against the Defendants in an amount greatly exceeding the minimum jurisdictional limits of this court. COUNT IV Arizona Wage Law Violations 26. The Defendants actions caused severe harm to the Plaintiff, including monetary losses, severe emotional distress, harm to the Plaintiff's reputation and humiliation among others; said harms are permanent in nature. 27. The Defendants' conduct was intentional or was based upon a reckless disregard for the harm that would be caused and subjects the Defendants to punitive damages. 28. The conduct of the Defendant described in this Complaint was willful and malicious so as to entitle the Plaintiff to recover exemplary damages to punish the Defendants and to deter such conduct in the future. The Plaintiff will show that, as a result of the Defendant's conduct, the Plaintiff has suffered loss of time and expenses, including fees incurred in this investigation and prosecution of this action. Accordingly, the Plaintiff asks that exemplary damages be awarded against the Defendants in an amount greatly exceeding the minimum jurisdictional limits of this court. WHEREFORE, the Plaintiff requests judgment as follows: 1. That the Plaintiff be awarded compensatory damages including but not limited to emotional distress, back pay, front pay, lost benefits, interest on any sums certain, treble damages pursuant to statute; 2. That the Plaintiff be awarded punitive damages; 3. That the Plaintiff recovers his costs; 4. That the Plaintiff have such other and further relief as the Court deems proper; and, 5. That the Plaintiff be awarded any attorneys' fees incurred herein. Dated August 8, 2008. Lawrence Morris Leight, pro per _______________________________ WHEREFORE, THE APPLICANT respectfully requests the Court to order Respondent Allstate Imaging Incorporated, it's owners, managers and/or representative to appear before the Court to produce responses to interrogatories and subpoena relating to the charges of employment discrimination filed by Lawrence Leight, at reasonable time and date set by the Court. DATED this 29th day of October 2008. LAWRENCE LEIGHT STATE OF ARIZONA ) ) County of Pima ) Lawrence Morris Leight, being acquainted with the facts, aver that I have read the above and foregoing application and know the contents thereof and that the same is true of my own personal knowledge except as to those statements made on information and belief and as to them, I believe them to be true. _______________________________ Lawrence Morris Leight, Applicant SUBSCRIBED AND SWORN TO before me this th day of August 2008. Notary Public in and for the State of Arizona. My commission expires:

[This regarded a company that has clearly, remorselessly and repeatedly demonstrated harassment of employees based on age, religion, ethnic origins, sex and medical condition, Allstate Imaging, which has offices in Tucson, AZ and Chatsworth and Culver City, CA.] 12/14/2007 Mr. Glaser and the Arizona Civil Rights Mediation Process: I have also found this company unworthy of negotiating with and look forward to both legal action and damning action regarding this company to press it's potential clients. Really note this: I showed up to the negotiation and was strong-armed by police, Ed Neidkowski, Corporal, State of Arizona Department of Administration Arizona State Capitol Police (ask what he was doing in Tucson...) in the lobby and they continued to hold me even after showing them a copy of the Civil Rights Complaint; therefore the dysfunction of your office will also be reported both to government agencies and the press. Evil, wicked and false are the chances for honest negotiation. Write back if you have the intelligence and honor/interest to actually receive copies of what amounts to the damnation of your office publicly. If after this the state fails to return a letter allowing me to continue litigation, I will be damning this state, the Attorney General's Office by name and profession in fact dans autre langues, ce vous comprenez? Lawrence Morris Leight I beg any and all to assist in prosecuting Allstate Imaging. Adam Glaser wrote: From Adam Glaser Thu Dec 13 10:41:25 2007 X-Apparently-To: [email protected] via 216.252.100.188; Thu, 13 Dec 2007 10:46:36 -0800 X-Originating-IP: [159.87.87.17] I did hear from Respondent's representative. They are no longer interested in mediation. Respondent has asked me to return the case back to Civil Rights, so Civil Rights can continue with the investigation. Sorry we couldn't help you more on this end. Good Luck with it! >>> "Law L-ight" 12/10/2007 3:55 PM >>> Monday, December 10, 2007 Mr. Glaser: Thank you for your quick response. Please reschedule another phone mediation as soon as possible, as I am concerned regarding practically exceeding the time limit to file a lawsuit if Allstate's proposal simply amounts to compliance to already mandated employment practices. I have suffered clear and various harms both financial and otherwise because of this company's continued hazing and harassment. Mr. Glaser, I live about two short blocks from Tucson's Allstate Imaging office...I originally decided to apply for employment because of the convenient location, which I used to walk by almost every day. A few days ago on my way home, while walking by the office, a female employee actually ran outside and followed me to shout harassments as to what I can and cannot do. This company's remorselessness for utterly blatant racism, sexism, hazing, and in fact absolutely every form of discrimination - harassment based on age, attire, physical handicap is utterly despicable. Mr. L---- PS: Please call down to security so I am not again arrested upon going to your office, and take great care...what violates homes and families so that racist and other control tactics continue can, perhaps beyond your experience, exert some highly sadistic and high-handed and heavy-handed tactics to make sure not only that any complaints are ignored, but that sadistic exploitation that is in fact illegal continues. Adam Glaser wrote: I'll check with Allstate regarding rescheduling another phone mediation. Would that be of interest to you? In the alternative, if you want to make a proposal that you want me to pass on to Allstate, I can do that as well. Let me know. Thanks >>> "Law L-ight" 12/08/07 10:09 AM >>> ... 15 minutes before our meeting standing in front of the elevator to the floor you office is on...[I was stopped by police at the elevator and held long enough to miss my meeting, cited for "disorderly conduct" and released having been told, despite apparently contacting you by phone in your office, that if I return I would be trespassing.] Fwd: TUC-#8788-v1-NOFAULTSETTLEMENTAGREEMENT.DOC Adam Glaser wrote: From: " To: ---- Date: Fri, 30 Nov 2007 14:57:55 -0700 Subject: TUC-#8788-v1-NOFAULTSETTLEMENTAGREEMENT.DOC Confirming Mediation via phone Conference on Dec. 7th @ 11AM. Please allow 2 hours for the Mediation. Our office is located at the State Bldg. 400 W. Congress North Bldg. Suite 223. I've attached the No Fault Settlement Agreement form. Any agreements reached in mediation will be incorporated into this agreement form. Any questions, please let me know. Thanks [This regarded a company that has clearly, remorselessly and repeatedly demonstrated harassment of employees based on age, religion, ethnic origins, sex, medical condition, Allstate Imaging]

[This regarded a company that has clearly, remorselessly and repeatedly demonstrated harassment of employees based on age, religion, ethnic origins, sex and medical condition, Allstate Imaging, which has offices in Tucson, AZ and Chatsworth and Culver City, CA.] 12/14/2007 Mr. Glaser and the Arizona Civil Rights Mediation Process: I have also found this company unworthy of negotiating with and look forward to both legal action and damning action regarding this company to press it's potential clients. Really note this: I showed up to the negotiation and was strong-armed by police, Ed Neidkowski, Corporal, State of Arizona Department of Administration Arizona State Capitol Police (ask what he was doing in Tucson...) in the lobby and they continued to hold me even after showing them a copy of the Civil Rights Complaint; therefore the dysfunction of your office will also be reported both to government agencies and the press. Evil, wicked and false are the chances for honest negotiation. Write back if you have the intelligence and honor/interest to actually receive copies of what amounts to the damnation of your office publicly. If after this the state fails to return a letter allowing me to continue litigation, I will be damning this state, the Attorney General's Office by name and profession in fact dans autre langues, ce vous comprenez? Lawrence Morris Leight I beg any and all to assist in prosecuting Allstate Imaging. Adam Glaser wrote: From Adam Glaser Thu Dec 13 10:41:25 2007 X-Apparently-To: [email protected] via 216.252.100.188; Thu, 13 Dec 2007 10:46:36 -0800 X-Originating-IP: [159.87.87.17] I did hear from Respondent's representative. They are no longer interested in mediation. Respondent has asked me to return the case back to Civil Rights, so Civil Rights can continue with the investigation. Sorry we couldn't help you more on this end. Good Luck with it! >>> "Law L-ight" 12/10/2007 3:55 PM >>> Monday, December 10, 2007 Mr. Glaser: Thank you for your quick response. Please reschedule another phone mediation as soon as possible, as I am concerned regarding practically exceeding the time limit to file a lawsuit if Allstate's proposal simply amounts to compliance to already mandated employment practices. I have suffered clear and various harms both financial and otherwise because of this company's continued hazing and harassment. Mr. Glaser, I live about two short blocks from Tucson's Allstate Imaging office...I originally decided to apply for employment because of the convenient location, which I used to walk by almost every day. A few days ago on my way home, while walking by the office, a female employee actually ran outside and followed me to shout harassments as to what I can and cannot do. This company's remorselessness for utterly blatant racism, sexism, hazing, and in fact absolutely every form of discrimination - harassment based on age, attire, physical handicap is utterly despicable. Mr. L---- PS: Please call down to security so I am not again arrested upon going to your office, and take great care...what violates homes and families so that racist and other control tactics continue can, perhaps beyond your experience, exert some highly sadistic and high-handed and heavy-handed tactics to make sure not only that any complaints are ignored, but that sadistic exploitation that is in fact illegal continues. Adam Glaser wrote: I'll check with Allstate regarding rescheduling another phone mediation. Would that be of interest to you? In the alternative, if you want to make a proposal that you want me to pass on to Allstate, I can do that as well. Let me know. Thanks >>> "Law L-ight" 12/08/07 10:09 AM >>> ... 15 minutes before our meeting standing in front of the elevator to the floor you office is on...[I was stopped by police at the elevator and held long enough to miss my meeting, cited for "disorderly conduct" and released having been told, despite apparently contacting you by phone in your office, that if I return I would be trespassing.] Fwd: TUC-#8788-v1-NOFAULTSETTLEMENTAGREEMENT.DOC Adam Glaser wrote: From: " To: ---- Date: Fri, 30 Nov 2007 14:57:55 -0700 Subject: TUC-#8788-v1-NOFAULTSETTLEMENTAGREEMENT.DOC Confirming Mediation via phone Conference on Dec. 7th @ 11AM. Please allow 2 hours for the Mediation. Our office is located at the State Bldg. 400 W. Congress North Bldg. Suite 223. I've attached the No Fault Settlement Agreement form. Any agreements reached in mediation will be incorporated into this agreement form. Any questions, please let me know. Thanks [This regarded a company that has clearly, remorselessly and repeatedly demonstrated harassment of employees based on age, religion, ethnic origins, sex, medical condition, Allstate Imaging]

This company is exceeding the bounds of wickedness and evil. After filing two ripoff reports and a visit from police to the company's Tucson office, and after scheduling meeting with the Civil Rights Division of the Arizona Attorney General's office, the secretary/receptionist of the company, Melissa, actually ran out of the office and followed me to tell me what I can and cannot do...(I live a block away and simply silently walked by, which is how I found out about the company and started working at Allstate Imaging about 9 months ago). Former Allstate Imaging salesperson and closer Micheal Orcutt, who saluted the n**i Party in front of the entire sales office of 25 employees and sadistically performed racist experiment regarding a black employee by hazing him like an animal behind his back, has since been arrested and sentenced to felony cocaine charges and prison by the Pima County Superior Courts - but he almost got out on a pathetic $ 1500 bail. It appears that the apparently underage female he was arrested with was not quite young enough...ce vous comprenez... The truth about ink and toner cartridges is that you can find them at about half the price Allstate offers them at any local store. You might also consider refills - they are far less expensive. I managed to down the website of this despicably unrepentant and sadistic company because the claims that salespersons made and those on the website are utterly contradictory...the website said the cartridges last 1.25 times OEM and salespersons clearly and surely stated that they last 1.5 times as long for ink and up to twice as long for toner cartridges. The truth is that many of the cartridges the company sells are simply over-priced OEM, particularly the DELL cartridges. The manager of the Tucson office, Steve Geraci, in fact told salesperson more than once that they can actually tell the customers the cartridges are more expensive and overcharge them even on the prices that the company offers to earn higher commissions. Just so you know the utterly heinous and sadistic McCarthyist tactics the Italian and other b*****d white trash racists of this company employ, I was actually arrested and held just long enough to miss my first Civil Rights hearing against this company at the elevator to the second floor of the Tucson building where I was to have my hearing, 400 West Congress, Suite 223, on December 7, 2007 just before my meeting at 11 AM with Adam Glaser, and just held long enough to miss the meeting. And just so you know how very difficult proceeding with meaningful complaint really is, this writer has three full college and university degrees from Claremont Men's College and Stanford University and I still cannot even get a cursory response from the company. Please really purchase ink and toner cartridges anywhere else. I will be personally putting the management and owners and employees of this company in hell and doing everything I can to but Allstate Imaging out of business utterly. If you can help in ANY way please write back.