COMPLAINT AND ANSWER
The legal document that is the formal statement of legal claims is called a Complaint.
The original Complaint on behalf of the plaintiffs and the proposed Class was dated and filed December 28, 2007 in the United States District Court for the District of Kansas, in Kansas City, Kansas.
On March 31, 2008, Class Counsel filed a First Amended Complaint on behalf of the retirees. The Amended Complaint adds claims under the federal statute against age discrimination, the Age Discrimination in Employment Act, and under state anti-discrimination statutes in Ohio, Oregon and Tennessee. Additional plaintiffs were added to the lawsuit for this purpose. Claims under other state anti-discrimination laws will be added as the case moves forward. The Amended Complaint also refines the previous claims under the federal pension law, ERISA. A Second Amended Complaint was filed on September 29, 2008 for the limited purpose of adding one additional plaintiff.
On April 7, 2009, Class Counsel filed a motion to allow a Third Amended Complaint adding new plaintiffs and additional proposed class representatives. Although the defendants opposed this motion, the Court, acting through Magistrate Judge James P. O’Hara, granted the motion in a Memorandum and Order dated September 24, 2009.
If you would like to review, download or print a copy of the Memorandum and Order dated September 24, 2009, click on the tab for “Court Rulings” on the left side of this page.
If you would like to review, download or print a copy of either the Complaint, the First Amended Complaint, or the current Third Amended Complaint, click on the appropriate line below.
