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AndWhat the suit is asking for
23. Among the other relief sought, Mr. Flores seeks the following injunctive relief:
i. Increase the influence of Black individuals in hiring and termination decisions for General Manager, Head Coach and Offensive and Defensive Coordinator positions;
a. Ensure diversity of ownership by creating and funding a committee dedicated to sourcing Black investors to take majority ownership stakes in NFL Teams;
b. Ensure diversity of decision-making by permitting select Black players and coaches to participate in the interviewing process for General Manager, Head Coach and Offensive and Defensive Coordinator positions;
ii. Increase the objectivity of hiring and termination decisions for General Manager, Head Coach and Offensive and Defensive Coordinator positions;
a. Require NFL Teams to reduce to writing the rationale for hiring and termination decisions, including a full explanation of the basis for any subjective influences (e.g., trust, personality, interview performance, etc.);
b. Require NFL Teams to consider side-by-side comparisons of objective criteria, such as past performance, experience and objective qualifications;
iii. Increase the number of Black Offensive and Defensive Coordinators;
a. Create and fund a training program for lower-level Black coaches who demonstrate an aptitude for coaching and an interest in advancing to a Coordinator position;
iv. Incentivize the hiring and retention of Black General Managers, Head Coaches and Offensive and Defensive Coordinators through monetary, draft and/or other compensation such as additional salary cap space; and
v. Complete transparency with respect to pay for all General Managers, Head Coaches and Offensive and Defensive Coordinators.
WHEREFORE, Plaintiff prays that the Court enters judgment in his favor and against the Defendants for the following relief:
A. A declaratory judgment that the actions, conduct and practices of the Defendants complained of herein violate the laws of the United States and the State and City of New York, and the State of New Jersey;
B. An award of injunctive relief necessary to cure Defendants’ discriminatory policies and practices;
C. Certification of this action as a class action pursuant to Rule 23 of the Federal Rules of Civil Procedure;
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Case 1:22-cv-00871 Document 1 Filed 02/01/22 Page 57 of 58
D. An award of damages to Plaintiff and the Proposed Class and against the Defendants, in an amount to be determined at trial, to compensate them for all monetary and/or economic damages;
E. An award of damages to Plaintiff and the Proposed Class and against the Defendants, in an amount to be determined at trial, to compensate them for all non-monetary and/or compensatory damages, including, but not limited to, loss of reputation, loss of opportunity and mental anguish;
F. An award of punitive damages to Plaintiff and the Proposed Class and against the Defendants in an amount to be determined at trial;
G. Pre- and post-judgment interest on all amounts due;
H. An award of Plaintiff and the Proposed Class’s reasonable attorneys’ fees and
costs; and
I. Such other and further relief as the Court may deem just and proper.











