Stephen R. Bruce
Attorney for Plaintiffs

202.289.1117 phone
stephen.bruce@prodigy.net

1667 K Street NW, Suite 410
Washington, DC 20006

This is a class action under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), 29 U.S.C. § 1001 et seq., and a representative action under the Age Discrimination in Employment Act of 1964, as amended (the “ADEA”), 29 U.S.C. § 621 et seq. Defendants have violated the ERISA and the ADEA by amending a defined benefit pension plan, effective January 1, 2005, in a manner that freezes the retirement benefits of older, longer-service employees and offers lower rates of benefit accrual at older ages. Defendants have also violated ERISA by failing to provide adquate notice of the changes.

(The following sections are included in the full Complaint:

• THE PARTIES
• JURISDICTION AND VENUE
• CLASS ACTION ALLEGATIONS
• FACTUAL ALLEGATIONS
• Each of six Claims for Relief
• PRAYER FOR RELIEF)

The full Complaint is 24 pages in length. Click to download the full Complaint in pdf format. You may wish to download Adobe Reader, which is needed to read pdf files.