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SHAHIN INDOREWALA,
Case No.
Plaintiff,
Hon.
v. Magistrate
Defendant.
_____________________________________________________________________________/
Plaintiff SHAHIN INDOREWALA, by and through her attorneys, CAIR Legal Defense
Fund, brings this action against FAST TRAK MANAGEMENT, INC. (“Defendant” or “Fast
Trak”), for compensatory and punitive damages, declaratory and injunctive relief, prejudgment and
post-judgment interest, costs and attorneys’ fees for violations of Title VII of the Civil Rights Act of
1964, as amended, 42 U.S.C. § 2000(e), et seq. (“Title VII”) committed when Defendant denied Ms.
Indorewala a reasonable religious accommodation and refused to hire her on the basis of her faith.
1. Plaintiff’s claim for discrimination on the basis of religion in violation of Title VII is
2. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1343.
3. This Court has personal jurisdiction over Defendant because Defendant conducts
conducts business in this judicial district and this district is where a substantial part of the events or
5. Costs and attorneys’ fees may be awarded pursuant to Title VII, 42 U.S.C. § 2000e-
Parties
Defendant Fast Trak Management, Inc. Ms. Indorewala resides in this judicial district.
7. Defendant Fast Trak Management, Inc. (“Fast Trak”) is a for profit corporation
incorporated under the laws of Maryland (Business Entity No. D15013741). Defendant Fast Trak’s
headquarters and principal place of business is located at 2735 Hartland Rd, Suite 100 in Falls Church,
Virginia. Fast Trak regularly and systematically conducts business in the Commonwealth of Virginia
and within this judicial district. Fast Trak was at all relevant times an “employer” as the term is defined
in Title VII.
Administrative History
10. This Complaint is being timely filed within 90 days from the date Plaintiff received the
Factual Background
12. Ms. Shahin Indorewala is a graduate of George Mason University with a Bachelor’s
Degree in English Language and Literature. She currently works at the Center for Autism & Related
Disorders where she provides autistic children with individualized care to help them achieve the
necessary life skills to lead a healthy and happy life. She also has extensive marketing experience,
including creating and managing social media campaigns, creating and running advertisements, liaising
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with board members, and conducting community outreach. Further, Ms. Indorewala has several years
of teaching experience, including conducting evaluations and creating personalized learning plans,
providing English teaching instruction for grades 6-12, teaching AP English, and advising students
13. In order to gain more experience in the marketing sector, Ms. Indorewala applied for
14. On September 3, 2018, Human Resources (“HR”) Director Nicky Gordon informed
Ms. Indorewala that she was selected for an interview because the “hiring director saw qualities in
15. Ms. Gordon went on to explain that after the interview, Ms. Indorewala would be
“transition[ed] in the Account Management position. Here, you will teach, train, and manage all of
the new reps as they are hired. In 5/6 months you’ll transition into opening a new location and
16. The following day, Ms. Indorewala appeared for the interview, which was scheduled
with Corporate Executive Officer Ramses Gavilondo (“CEO Gavilondo”). CEO Gavilondo asked
Ms. Indorewala to tell him about herself and asked why she believed she would be a good fit for Fast
Trak. The interview lasted approximately ten minutes and CEO Gavilondo ended by asking whether
17. Later that day, a Fast Trak employee called Ms. Indorewala to congratulate her and
asked her to come in the next day wearing professional attire. HR Director Gordon also contacted
Ms. Indorewala and sent her a congratulatory email advising her to come in for a meeting the next day
18. The next day, Ms. Indorewala met with Fast Trak Assistant Manager Josie (“Assistant
Manager Josie”), who provided Ms. Indorewala with her job duties, informing her that she would be
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working on a large contract with Verizon. Assistant Manager Josie also explained to her the
promotions process.
19. Finally, Assistant Manager Josie provided Ms. Indorewala with her schedule. In
response, Ms. Indorewala requested a religious accommodation to allow her to take two short five-
minute breaks in order to perform her obligatory prayers, in accordance with her sincerely held
religious beliefs. She suggested shortening her hour and a half lunch break to accommodate her
request.
20. Assistant Manager Josie abruptly ended the meeting after denying her request for two
five-minute breaks to allow her to pray, before walking her to a common area, and – in front of other
staff– announcing to CEO Gavilondo that Ms. Indorewala’s “hours don’t work for her.”
21. He immediately threw his arms up in the air and chastised her exclaiming “this is a
business.”
22. He then pointed at her hijab1 and mocked her, saying “Religion? I don’t wanna deal
23. He took Ms. Indorewala’s file, crossed out her information, and refused to hire her.
24. Ms. Indorewala was humiliated, especially when she noticed Fast Trak employees
staring at her in silence and disbelief. She quietly walked out at approximately 11 am and Defendant
right to be free from religious discrimination in the workplace, knowing full well that Title VII
required, unless excused by undue hardship, reasonable accommodations of its employees’ sincerely-
held religious beliefs, by denying her a reasonable religious accommodation and refusing to hire her
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26. Defendant Fast Trak acted with malice due to pique at Ms. Indorewala’s request for a
27. As a direct and proximate result of Defendant’s actions, Ms. Indorewala has suffered
emotional distress, anxiety, humiliation, inconvenience, lost wages and benefits and other
consequential damages.
Count I
Religious Discrimination in Violation of Title VII
28. Plaintiff hereby realleges and incorporates by reference herein the foregoing
29. Defendant violated Title VII by (1) subjecting Plaintiff to harassment, intimidation
and a hostile work environment for exercising her sincerely-held religious beliefs; (2) denying her a
reasonable religious accommodation of two five-minute prayer breaks in exchange for a shortened
lunch break; and, (3) refusing to hire Plaintiff by terminating her meeting and crossing out her job
application in response to her having a requested a reasonable religious accommodation and on the
30. Plaintiff’s request for a religious accommodation of two five-minute prayer breaks in
exchange for a shortened lunch break does not constitute undue hardship upon Defendant or
WHEREFORE, Plaintiff requests this Honorable Court grant relief in the form described in
the Prayer for Relief below, plus all such other relief this Honorable Court deems just and proper,
Count II
Retaliation in Violation of Title VII
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31. Plaintiff hereby realleges and incorporates by reference herein the foregoing
32. Defendant retaliated against Plaintiff in violation of Title VII by terminating her
employment in response to her having a requested a reasonable religious accommodation and on the
WHEREFORE, Plaintiff requests this Honorable Court grant relief in the form described in
the Prayer for Relief below, plus all such other relief this Honorable Court deems just and proper,
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WHEREFORE, Plaintiff requests that this Honorable Court enter judgment in her favor and
against Defendant, on each and every count in this Complaint, and enter an Order awarding the
following relief:
Muslim workers to take short prayer breaks to perform their obligatory prayers during
C. Payment for all economic damages, including but not limited to, back pay, front pay,
E. Punitive damages;
F. Statutory damages;
F. Any further relief to which Plaintiff is entitled or that this Honorable Court deems just
and proper.
JURY DEMAND
NOW COMES Plaintiff, by and through her undersigned counsel, and hereby demands a trial
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Title VII of the Civil Rights Act of 1964
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Denial of religious accommodation and refusal to hire on basis of religion
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