Yellow Cab lawsuit

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. NASIR ABAGIBE, ABDUL ADAM, ABUKAR ADEN, ALI ALI, NUUR ALI, KETEMA ALIGAZIE, TARIQ AYUUB, MUKTAR BUNI, ABDI DHUUBOW, NASIR FARAH, ABDI HUSSEIN, TOLA ISMAEL, MUUSE JAAMAC, RIZGALLA KHAMIS, ADEN NOOR, ABDUL NUR, AHMED ODAWAAY, SAID OMAR, MOHAMED A. OSMAN, MOHAMED M. OSMAN, AND MOKTAR SAID, Plaintiffs, v. YELLOW CAB CO., D/B/A COLORADO CAB COMPANY, Defendant. ______________________________________________________________________________

COMPLAINT AND JURY DEMAND ______________________________________________________________________________

Plaintiffs, Nasir Abagibe, Abdul Adam, Abukar Aden, Ali Ali, Nuur Ali, Ketema

Aligaze, Tariq Ayuub, Muktar Buni, Abdi Dhuubow, Nasir Farah, Abdi Hussein, Tola Ismael,

Muuse Jaamac, Rizgalla Khamis, Aden Noor, Abdul Nur, Ahmed Odawaay, Said Omar,

Mohamed A. Osman, Mohamed M. Osman, and Mocktar Said, (collectively, “Plaintiffs”), by

and through their attorneys, the law firm of KING & GREISEN, LLP, hereby submit their

Complaint against Yellow Cab Co., d/b/a Colorado Cab Co. (“Defendant” or “Yellow Cab”), and

in support thereof state as follows:

INTRODUCTION

1. Plaintiffs are twenty-one (21) current and former cab drivers for Defendant, and

they are all black and of African descent.

2

2. Defendant has its drivers execute a master contract called a Driver Agreement.

Defendant continually breached the Driver Agreement. Defendant has multiple legal duties and

contractual obligations to Plaintiffs that it has deliberately failed to fulfill.

3. Defendant has discriminated against, harassed, and created a hostile work

environment for Plaintiffs on the basis of their race/color and/or national origin in violation of

federal law. The discrimination, harassment and hostile work environment Plaintiffs have

endured has included, among other things: physical assault, name calling, taunts, jeers, laughing,

gestures, yelling, bribery, and extortion; discriminatory and disparate treatment with regard to

fines, fees, and other charges; discriminatory and disparate treatment with policies, rules, and

discipline; theft and property damage; ostracism and failure to redress grievances; outright

threats and intimidation; and unfair termination.

4. Defendant has refused to give Plaintiffs an explanation for its discriminatory

treatment against them and has retaliated against Plaintiffs with continued harassment and

discrimination when they have complained about the discriminatory conduct.

5. In addition to its discriminatory conduct in violation of federal law, Defendant’s

conduct also sounds in: civil theft and conversion; breach of contract, including breach of

contract for a sum certain and bad faith breach of insurance contract; willful and wanton breach

of the covenant of good faith and fair dealing; promissory estoppel; outrageous conduct and

intentional infliction of emotional distress; interference with prospective contract or business

advantage; and violations of the Motor Vehicle Repair Act.

3

JURISDICTION AND VENUE

6. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §1331 and 1343. This

action is authorized and instituted pursuant to 42 U.S.C. §1981 et seq., as amended. The Court

also has supplemental jurisdiction over Plaintiffs’ state law claims, as they are so related to the

federal law claims that they form part of the same case and controversy pursuant to 28 U.S.C. §

1367(a).

7. Venue is proper with this Court as all employment practices alleged to be

unlawful were committed within the jurisdiction of the United States District Court for the

District of Colorado and pursuant to 28 U.S.C. § 1391.

8. On February 18, 2009, Plaintiffs’ filed “Claimants’ Notice of Intention to

Arbitrate and Demand for Arbitration” with the American Arbitration Association (“AAA”)

pursuant to a forced arbitration provision in a Driver Agreement. Defendant mandated that

Plaintiffs sign a Driver Agreement before they began working for Defendant. The Driver

Agreement was not explained to Plaintiffs and, at the time the Driver Agreements were signed,

many Plaintiffs had minimal proficiency in the English language. Nonetheless, Plaintiffs’

attempted to have the controversy with Yellow Cab adjudicated with the AAA. On November

30, 2009, Plaintiffs received notice that their portion of arbitration costs would be $64,200.

Despite their best efforts, Plaintiffs are unable to afford the costs associated with AAA. As such,

the prohibitive cost of AAA precludes the use of the arbitral forum.

4

PARTIES

A. Plaintiffs

9. Nasir Abagibe began working as a driver for Yellow Cab in April 2006 and

worked there until May 2009. Nasir Abagibe is currently, and at all times relevant to this suit, a

resident of the State of Colorado.

10. Abdul Adam began working as a driver for Yellow Cab in September 2005 and

worked there until October 29, 2006, when Yellow Cab terminated him. Abdul Adam is

currently, and at all times relevant to this suit, a resident of the State of Colorado.

11. Abukar Aden began working as a driver for Yellow Cab on July 15, 2002 and

worked there until October 26, 2007, when Yellow Cab terminated him. Abukar Aden is


12. Ali Ali began working as a driver for Yellow Cab in December 2005 and is still

working there. Ali Ali is currently, and at all times relevant to this suit, a resident of the State of

Colorado.

13. Nuur Ali began working as a driver for Yellow Cab in the spring 2003 and

worked there until August 2005. Nuur Ali is currently, and at all times relevant to this suit, a

resident of the State of Colorado.

14. Ketema Aligaze began working as a driver for Yellow Cab in approximately 1995

and worked there until September 3, 2008, when Yellow Cab terminated him. Ketema Alagaze

is currently, and at all times relevant to this suit, a resident of the State of Colorado.

5

15. Tariq Ayuub worked as a driver for Yellow Cab from 2002 until 2005 and again

from 2006 until January 31, 2007, when Yellow Cab terminated him. Tariq Ayuub is currently,

and at all times relevant to this suit, a resident of the State of Colorado.

16. Muktar Buni began working as a driver for Yellow Cab in November 2001 and

worked there until October 25, 2006, when Yellow Cab terminated him. Muktar Buni is


17. Abdi Dhuubow began working as a driver for Yellow Cab on September 24, 2003

and worked there until 2005, when Yellow Cab terminated him. Abdi Dhuubow is currently, and

at all times relevant to this suit, a resident of the State of Colorado.

18. Nasir Farah began working as a driver for Yellow Cab in April 2006 and worked

there until August 2009, when Yellow Cab terminated him. Nasir Farah is currently, and at all

times relevant to this suit, a resident of the State of Colorado.

19. Abdi Hussein began working as a driver for Yellow Cab in September 2001 and

worked there until approximately August 2002, when Yellow Cab terminated him. When Abdi

Hussein first arrived to the United States in 2001, shortly before he started working for Yellow

Cab, he spoke no English. Prior to arriving to the United States, Mr. Hussein was taken prisoner

and tortured for two (2) years in Somalia. As a result, he suffered from severe trauma and sought

daily medical treatment for his injuries throughout the time worked for Yellow Cab. Abdi

Hussein is currently, and at all times relevant to this suit, a resident of the State of Colorado.

20. Tola Ismael began working as a driver for Yellow Cab in November 2007 and

worked there until July 9, 2008, when Yellow Cab terminated him. Tola Ismael is currently, and

at all times relevant to this suit, a resident of the State of Colorado.

6

21. Muuse Jaamac began working as a driver for Yellow Cab in 2002 and worked

there until 2003, when Yellow Cab terminated him. He returned to working for Yellow Cab in

2005 and worked there until January 2008. He returned to working for Yellow Cab in June 2008

and worked there until July 22, 2008, when Yellow Cab terminated him again. He returned to

working for Yellow Cab from August 2008 until September 2008. Muuse Jaamac was, at all

times relevant to this suit, a resident of the State of Colorado.

22. Rizgalla Khamis began working as a driver for Yellow Cab on August 21, 2006

and worked there until June 19, 2007, when Yellow Cab terminated him. Rizgalla Khamis is


23. Aden Noor began working as a driver for Yellow Cab in April 2004 and worked

there until August 2006. He returned to working for Yellow Cab on August 9, 2007 and worked

there again until Yellow Cab terminated him on August 29, 2007. Aden Noor is currently, and at

all times relevant to this suit, a resident of the State of Colorado.

24. Abdul Nur began working as a driver for Yellow Cab in 2000 and worked there

until 2001, when Yellow Cab terminated him. He returned to working for Yellow Cab in 2006

and is still working there. Abdul Nur is currently, and at all times relevant to this suit, a resident

of the State of Colorado.

25. Ahmed Odawaay began working as a driver for Yellow Cab in October 2002 and

worked there until 2004, when Yellow Cab terminated him. He returned to working for Yellow

Cab in 2004 and worked there until January 2009, when Yellow Cab terminated him. Ahmed

Odawaay is currently, and at all times relevant to this suit, a resident of the State of Colorado.

7

26. Said Omar began working as a driver for Yellow Cab in 2004 and worked there

until May 2006, when Yellow Cab terminated him. Said Omar is currently, and at all times

relevant to this suit, a resident of the State of Colorado.

27. Mohamed A. Osman began working as a driver for Yellow Cab on June 10, 2004

and worked there until May 2009. Mohamed A. Osman is currently, and at all times relevant to

this suit, a resident of the State of Colorado.

28. Mohamed M. Osman began working as a driver for Yellow Cab on September 24,

2004 and worked there until November 28, 2005, when Yellow Cab terminated him. Mohamed

M. Osman is currently, and at all times relevant to this suit, a resident of the State of Colorado.

29. Mocktar Said began working as a driver for Yellow Cab in 2001 and worked there

until 2002, when Yellow Cab terminated him. He then returned to working for Yellow Cab in

2002 and worked there until 2006, when Yellow Cab terminated him again. He returned to

working for Yellow Cab a third time in 2006 and is still working there. Mocktar Said is


B. Defendants

30. Colorado Cab Co., LLC, d/b/a Denver Yellow Cab, is a Colorado corporation

with a principal place of business in Colorado. Colorado Cab Co. is owned by Veolia

Transportation Co., an Illinois corporation, which is owned by Veolia Transport, a French

corporation. Colorado Cab Co. was formerly owned by Shamrock Transportation Co., a

Colorado corporation, until September 2008.

8

FACTUAL ALLEGATIONS A. Race/Color and/or National Origin Discrimination

31. Defendant has engaged in a pattern and practice of discriminating against,

harassing, and creating a hostile work environment for Plaintiffs on the basis of their race/color

and/or national origin.

32. The primary offenders of this race/color and/or national origin discrimination

have included: Regional General Manager and Vice-President Ross Alexander; Driver

Supervisor Michael Rivera; Manager of Driver Operations Wayne Roberson; Claims Manager

Christine Doer; and Lead Cashier Kay Jordan.

33. Roberson frequently verbally abused, harassed, and yelled at Plaintiffs by saying

things like:

• “African monkey”;

• Liar;

• Dumb;

• Idiot;

• “Dumb African”;

• “Nigger”;

• “Nigger, go back to your country.”;

• “Go back to your country.”;

• “Stupid immigrant”;

• “Sit down and shut up”;

• “Get out of my office”;

• “You Somalis are hard people to deal with.”;

9

• “Crazy Somalis”;

• “Why don’t you just stay in Africa? You guys are making so much money

and you are just taking the money to Africa.”;

• “Somalis are some of the dumbest people because they don’t listen.”;

• “Go back to Africa”;

• “I have worked here for thirty-eight years. No one will fire me.”;

• “You’re an advocate for the Somali drivers. What is your problem?”

• “Don’t go there. I am powerful and I can hurt you and ruin your future.”;

• “Get out! Don’t you understand English? Get out!”

• “Go back to where you came from!”

• “You need to hear what I say. Go back to where you come from.”;

• “We don’t want African immigrants here.”; and

• “I can do whatever I want.”

34. Rivera frequently verbally abused, harassed, and yelled at Plaintiffs by saying

things like:

• “Nigger, go back to your country”;

• “We don’t need you, nigger”;

• “You are a black monkey. Go back to where you came from. Get lost.”;

• “Sit your ass down, monkey!”

• “This is America. This is how it works. It is not Africa, or wherever you

came from.”;

• “Other taxi companies will not hire you. You have to take it if you want to

work.”;

10

• “Go back to Africa”;


• “You are a black monkey. Go back to where you came from. Get lost.”;

• “Go back to Africa, you nigger!”

• “Sit down and eat your banana. You’re a second class citizen. That is why

the white guy goes ahead.”

• “You’re just like all the other immigrants.”

• Liar;

• Dumb;

• Idiot;

• “Get the fuck out of my office! This is not Africa! If you don’t want to make

a living in this country, go back to Africa! Fucking idiot!”

• “You’re an animal”;

• “We can do whatever we want, you dumb African!”;

• “You don’t have a right”;

• “You’ll never work in Colorado again.”;

• “Who are you affiliated with? Since you went home, we don’t know who you

are anymore. There’s a lot of animals over there.”;

• “Well, there’s a lot of monkeys around here, and I hope you’re not one of

them!”;

• “Monkey,”

• “Nigger,”

• “Animal,”

11

• “Mother fucker,”

• “Immigrant”

• Get the fuck out of my face! You’re a chicken!”

• “Go back to your country”; and

• “We don’t want African immigrants here.”

35. Alexander frequently verbally abused, harassed, and yelled at Plaintiffs by saying

things like:


• Liar;

• Dumb;

• Idiot;

• Nigger;

• “You are not going to work at any cab company in this City.”;

• “We don’t need somebody like you; go back to your country.”;

• “You are a monkey, and we don’t need you here.”;

• “You don’t deserve anything”;

• “You’ll never drive in this city again if you don’t get out of my office. Go

back to fucking Africa.”;

• “Nigger, go back to your country.”;

• “Go back to your country”; and

• “We don’t want African immigrants here.”

36. Roberson frequently verbally abused, harassed, and yelled at other African drivers

and Plaintiffs saw and/or knew about it while working for Defendant.

12

37. Rivera frequently verbally abused, harassed, and yelled at other African drivers

and Plaintiffs saw and/or knew about it while working for Defendant.

38. Alexander frequently verbally abused, harassed, and yelled at other African

drivers and Plaintiffs saw and/or knew about it while working for Defendant.

39. Roberson physically assaulted Plaintiffs, including incidents where:

• Roberson yanked Nasir Abagibe out of his chair and pushed him out of the

office;

• Roberson pushed Abukar Aden;

• Roberson pushed Mohamed M. Osman; and

• Roberson punched Mohamed M. Osman in the face and then tried to pretend

like it was a joke.

40. Rivera physically assaulted Plaintiffs; including incidents where:

• Rivera cornered Abukar Aden and tried to fight him; and

• Rivera shoved Aden Noor by taking his open palm and shoving it into his

chest then threatened to call the police and have Mr. Noor arrested if tried to

complain.

41. Alexander physically assaulted Plaintiffs, including incidents where:

• Alexander attempted to forcibly take Abdi Hussein’s car, took a screwdriver

to the car and attempted to remove his tags, then grabbed Mr. Hussein from

behind the head and waist and threw him into the open door of his car. Mr.

Hussein attempted to call 9-1-1 twice but was unsuccessful in communicating

with the operators. He fled, fearing more abuse;

• Alexander pushed Abdi Dhuubow twice and told him to get out of his office;

13

• Alexander cornered Abukar Aden and tried to fight him; and

• Alexander swatted Abukar Aden as if he were a fly.

42. Alexander physically assaulted other African drivers and Plaintiffs saw and/or

knew about it while working for Defendant, including incidents where:

• Alexander pushed an African driver over a trash can;

• Alexander kicked out the taillight on a car belonging to an African driver;

• Alexander punched an African driver until he was unconscious, which he later

admitted, saying, “I did it, I was mad,” and apologized to a group of African

drivers.

43. Roberson, Rivera, and Alexander never directed these assaults and outbursts

toward non-African drivers.

44. Customers verbally abused, harassed, and yelled at Plaintiffs and Defendant failed

to take action to put a stop to it. One customer told an African driver, “Go back to your country

if you don’t want to do things our way.” Without conducting any investigation, Defendant fined

and suspended the driver and shut off the computer in his cab. When one customer refused to

pay the fare to the driver, Defendant fined the driver instead of the customer.

45. Management frequently shut off or blocked the computers in the cabs of Plaintiffs

and other African drivers from the central office so that they would not be able to make any

money or do their jobs. Management did this as a form of punishment, retaliation, and/or simply

as a way to arbitrarily harass and upset them.

46. Defendant routinely discriminates against Plaintiffs and other African drivers by

assigning them lower paying jobs through the dispatcher and making them wait longer than other

14

drivers to receive calls for jobs. This happens even when Plaintiffs and other African drivers are

first in line for a job in their designated zones.

47. Plaintiffs and other African drivers were afraid to complain about this problem

because they knew the dispatchers would give them no calls at all if they did complain. When

one driver did complain, Dispatcher Pat (last name unknown) said, “If you don’t like it, just go

back home.”

48. Dispatchers made fun of the accents of Plaintiffs and other African drivers over

the radio and laughed at them, and Defendant did nothing to stop it.

49. Defendant requires only African drivers to drive newer model cars, which is more

expensive. Defendant claims this is a Public Utility Commission (“PUC”) requirement, but it

does not enforce this requirement against non-African drivers. When Plaintiffs tried to complain

about this unfair treatment, management said, “We can do whatever we want, this is America.”

50. Defendant regularly refuses to repair cars for Plaintiffs and other African drivers

for several days after they break down, unless Plaintiffs and other African drivers pay bribes.

Defendant does not treat non-African drivers in the same manner.

51. Jordan and Rivera also demanded that Plaintiffs and other African drivers pay

them bribes in order to give them cabs or process their requests, but they have never demanded

such bribes from non-African drivers. When one driver complained about unfair charges on his

account, Rivera said, “If you don’t want all these charges, you will have to take care of us.”

52. Rivera regularly demands money and gifts from Plaintiffs and other African

drivers, which he does not demand from non-African drivers. Rivera once terminated a Plaintiff

when the Plaintiff was unable to bring him back the exact gifts he had demanded from Africa.

Yellow Cab managers did not expect Non-African drivers to bring them similar gifts.

15

53. Defendant refuses to provide Plaintiffs and other African drivers with interpreters

when they tell them to sign important documents that it knows they cannot understand—even

after Plaintiffs and other African drivers specifically request an interpreter.

B. Retaliation

54. Defendant has engaged in a pattern and practice of retaliating against Plaintiffs

and other African drivers for the numerous acts of opposition to the race/color and/or national

origin discrimination at Yellow Cab, including their numerous complaints of discrimination to

various members of management.

55. Defendant regularly threatened to terminate Plaintiffs and other African drivers

whenever they tried to complain about discrimination.

56. Whenever Plaintiffs and other African drivers went to the Yellow Cab office to

complain about discrimination, Defendant deliberately made them wait in the waiting room for

several hours to speak with someone, until they finally gave up and left.

57. Whenever Plaintiffs and other African drivers complained directly to managers,

they would often ignore them and walk away or refuse to return their calls.

58. Other times when managers actually did talk to Plaintiffs and other African

drivers about their complaints, the managers would shout at them and continue harassing them in

retaliation for the complaints.

59. Alexander responded to the complaints of Plaintiffs and other African drivers by

saying things like:

• “You want to take my money back to Africa?”;

• “You sue me and now you ask me for a favor?? Do you think that I’m

stupid??”;

16

• “You Africans don’t know the rules”;

• “You are not going to work at any cab company in this City.”;

• “You’ll never drive in this city again if you don’t get out of my office. Go

back to fucking Africa.”

• “We hate you”; and

• “If you can’t do this job, go back home to Africa.”

60. Roberson responded to the complaints of Plaintiffs and other African drivers by

saying things like:

• “I can do whatever I want.”;

• “We hate you.”;

• “Immigrant from Africa”;

• “We don’t care, you idiot! Get out of here!”

• “Get out of my office! I don’t have to talk to you!”

• “Go back to Africa if you don’t like what you’re hearing.”;

• “If you can’t do this job, go back home to Africa.”; and

• “If you don’t like it, you can go somewhere else.”

61. Rivera responded to the complaints of Plaintiffs and other African drivers by

saying things like:

• “If you can’t do this job, go back home to Africa.”;

• “Monkey”;

• “We hate you.”;

• “Get out of my office!”

• “We don’t care, you idiot! Get out of here!”

17

• “Get out of my office! I don’t have to talk to you!”

• “You don’t like this company. You always complain. If you don’t like it,

why do you stay?”;

• “Leave my office now, you dog!”;

• “I will report you for being a criminal and you will never work in Colorado

again.”;

• “I was going to charge you $500, now I’m charging you $1,000”; and

• “This is the American way!”

62. When one Plaintiff complained to Doer about abuse, Doer threatened, “You don’t

know what abuse is.” Doer also told another driver who complained about excessive charges, “If

you don’t leave right now, we will fire you.”

63. When another Plaintiff complained to Shop Manager Ken Tanner, Tanner called

him a “pain in the butt” and told him he would put more charges on his account if he did not stop

complaining.

64. Defendant often terminated Plaintiffs and other African drivers shortly after they

complained, for pretextual reasons, in retaliation for their complaints of discrimination.

65. Defendant intimidated Plaintiffs and other drivers into not complaining by

keeping pictures of them at ProTaxi meetings (a new cab company that Plaintiffs and other

African drivers are starting on their own) and showing them the pictures when they tried to

complain—implying that Defendant would terminate them if they continued to complain.

66. Defendant charged Plaintiffs and other African drivers excessive and unsupported

fees and fines in retaliation for their complaints.

18

67. Managers also shut off or blocked the computers in the cabs of Plaintiffs and

other African drivers from the central office in retaliation for their complaints.

68. Defendant forced Plaintiffs and other African drivers to take English writing tests

in retaliation for their complaints.

69. Defendant kept the cabs of Plaintiffs and other African drivers, refused to return

them, and repaired them incorrectly in retaliation for their complaints.

70. Defendant revoked Plaintiffs’ medical benefits and gave them less desirable work

schedules in retaliation for their participation in this case.

C. Unlawful Terminations

71. Defendant terminated Plaintiffs and other African drivers in violation of the driver

agreements and of its own written policies.

72. Defendant’s “Accident Prevention Program” states that it will fine drivers after

their first “preventable” accident, but it will not terminate a driver until after his third

“preventable” accident.

73. In violation of this policy, Defendant has terminated Plaintiffs and other African

drivers after their first and second accidents.

74. Defendant terminated Plaintiffs and other African drivers after they refused to

sign documents stating that they were at fault for accidents for which they were clearly not at

fault.

75. In some cases, Defendant has refused to give Plaintiffs and other African drivers

written notice of their terminations or any reason or explanation for their terminations.

19

76. In other cases, Defendant told Plaintiffs and other African drivers that it was

terminating them because they were “too risky” or because the accident in which they were

involved cost the company money.

77. In contrast, Yellow Cab simply told Caucasian drivers to take a class after they

were involved in their first and second accidents.

78. Defendant routinely “de-hagged” or “de-hacked” the cabs of Plaintiffs and other

African drivers when it terminated them. This meant that Defendant removed all of the branding

from the cabs so that Plaintiffs and other African drivers would not be able to take any

passengers, and it often caused substantial damage to the cabs. Often times, Defendant spray-

painted, “Not for Hire” on the sides of the cabs.

79. Defendant also took airport badges from Plaintiffs and other African drivers when

it terminated them and told them they would never work at the airport again. These badges did

not belong to Defendant but rather belonged to the Airport Authority.

D. Improper Withholding from Plaintiffs

80. Defendant withholds security deposits and other funds from Plaintiffs and other

African drivers in violation of their Driver Agreements.

81. The Driver Agreements state that the drivers’ security deposits, which they pay

when they begin driving for Defendant, are fully refundable and will be returned to them after

their separation from Yellow Cab.

82. In some cases, Plaintiffs and other drivers pay the security deposit all at once. In

other cases, Defendant collected the deposit in weekly installments, which it deducted from the

drivers’ accounts.

20

83. Defendant frequently continued to collect these weekly installments from

Plaintiffs and other African drivers, even after it had already collected the entire security deposit.

84. Defendant often refused to return all or a portion of the security deposit at the

time of separation without explanation. Even when it does return a portion of a deposit, it

usually only does so after many months and repeated demands from Plaintiffs and other African

drivers.

85. When Plaintiffs and other African drivers tried to ask for their deposits back,

Defendant would tell them come back in a week or a month. When they came back, Defendant

would tell them the same thing again.

86. Defendant told one driver—who did not owe any money—that he would have to

contact his attorney if he ever wanted to see the deposit again. When one Plaintiff asked

Alexander for his deposit or an explanation of where it went, Alexander said, “Don’t call me

again. We don’t give papers.” Alexander then said, “Go talk to a lawyer and see what they do to

us.” When another Plaintiff told Defendant he was hiring an attorney, Defendant returned a

portion of the deposit, but still refused to return the remainder.

87. Defendant charges Plaintiffs and other African drivers for a second security

deposit without any reason or explanation, even though it still had security deposits collected for

those drivers.

88. Defendant collected prepaid lease fees from Plaintiffs and other African drivers,

which it later refused to give them credit for and refused to return to them when it terminated

them prior to the expiration of the lease payment period.

21

89. Defendant promised Plaintiffs and other African drivers certain discounts if they

returned to Yellow Cab, which it later refused to provide. In reliance on those promises,

Plaintiffs spent money getting their cabs ready and returning to Yellow Cab.

E. Excessive Fines and Fees

90. Defendant has repeatedly charged Plaintiffs and other African drivers excessive

and unsupported fines, fees and penalties.

91. In violation of its own written policies, Defendant charges Plaintiffs and other

African drivers excessive and unsupported fines for “preventable” accidents, even when

Plaintiffs and other African drivers were clearly not at fault for the accidents and the accidents

were clearly not preventable.

92. Defendant charges Plaintiffs and other African drivers excessive fines, allegedly

for the “costs of the accident,” even where they have insurance coverage and even where there

has been very little property damage, and sometimes none, resulting from the accident. When

Plaintiffs and other African drivers ask for verification that Defendant actually paid the alleged

costs, Defendants often refuse and threatens them with termination. When one Plaintiff

complained to Alexander, Alexander told the Plaintiff that if he hired an attorney, he would

correct the fees.

93. Defendant charges Plaintiffs and other African drivers fines for allegedly

receiving complaints from other drivers, which it refuses to explain or adjust.

94. Defendant charges Plaintiffs and other African drivers excessive lease fees for

periods when their cabs are in the shop or they do not otherwise have access to or are not driving

theirs cabs. Defendant does not assess lease fess to non-African drivers under the same or

similar circumstances.

22

95. Defendant charges fines directly to Plaintiffs and other African drivers for alleged

violations from the Colorado Public Utilities Commission (PUC). These have included fines for

safety inspections, alleged toll violations, parking tickets, and other minor traffic infractions.

Defendant has refused to provide any information, documentation, or evidence to Plaintiffs and

other African drivers about the basis for these fines. Likewise, it has refused to provide any

notice or information regarding the rights of Plaintiffs and other African drivers to appeal the

fines. Moreover, the amounts Defendant has assessed for PUC violations are often more than

double the fine that the PUC would normally impose. Accordingly, there is no way to know

whether the fines actually originated from the PUC, whether the PUC assessed the fines against

Plaintiffs and other African drivers or against Defendant, or whether Defendant simply assessed

bogus fines under the guise of the PUC.

96. Defendant charges Plaintiffs and other African drivers excessive charges for

“shop revenue,” “failure to report for maintenance,” shop inspection fees, and other

miscellaneous fines and charges from the Yellow Cab Shop, which it refuses to explain or adjust.

97. Defendant charges Plaintiffs and other African drivers fines for alleged “late

fees,” which it refuses to explain or adjust.

98. Defendant charges Plaintiffs and other African drivers fines for alleged

“incomplete trip sheet” fees, which it refuses to explain or adjust.

99. Defendant charges Plaintiffs and other African drivers fines for alleged “blew off

bell” fees, which it refuses to explain or adjust.

100. Defendant charges Plaintiffs and other African drivers fines for alleged “loaner

cab” fees, including late fees on their late fees, which it refuses to explain or adjust.

23

101. Defendant charges Plaintiffs and other African drivers fines for alleged “payoff

penalties,” which it refuses to explain or adjust.

102. Defendant charges Plaintiffs and other African drivers excessive fines for

allegedly failing to report an accident to the Yellow Cab accident investigator, even though it

never explained to Plaintiffs and other African drivers that doing so was mandatory and it

refused to give Plaintiffs and other African drivers anything in writing that required them to do

so.


allegedly failing to report an accident to the Yellow Cab accident investigator even when they

have reported the accident to the Yellow Cab accident investigator.


customer misconduct, which it refuses to explain or adjust.

105. Defendant charges Plaintiffs and other African drivers excessive fines for alleged

littering, when in fact such an event never occurred and Defendant provided no proof,

corroboration, or other information to support the allegation.

106. On July 7, 2006, Alexander promised Abukar Aden in writing that if he went until

January 1, 2007 without an at-fault accident, he would reduce the excessive and unfair accident

fine. However, when Mr. Aden satisfied these conditions, Alexander refused to reduce the fine.

When Mr. Aden complained to Alexander, Alexander responded, “Go for it. Get a lawyer.”

107. On August 18, 2006, Defendant incorrectly charged Abukar Aden for fees that

clearly applied to another driver. Cashier Manager Christy (last name unknown) even admitted

in writing that it was an error, but Defendant refused to adjust or correct the error.

24

108. Defendant charged Abdi Dhuubow excessive fees and fines upon his return after

the time he was in a coma from an accident, even after Doer specifically assured Mr. Dhuubow

that he would not owe anything.

109. Defendant charges Plaintiffs and other African drivers who return after leaving

Yellow Cab an explained and excessive fine for the privilege of returning to Yellow Cab. The

fine is a condition of getting their jobs back. Defendant does not charge this fine to non-African

drivers in order to get their jobs back.


allegedly being late to pick up customers, which it refuses to explain or adjust.


allegedly talking on the phone while driving, even when the allegation is untrue and Defendant

provides no proof, corroboration, or other information to support the allegation.

112. Defendant charges Plaintiffs and other African drivers fines for allegedly

assaulting other employees, even though the allegation is untrue and Defendant provides no

proof, corroboration, or other information to support the allegation.

113. Defendant charges Plaintiffs and other African drivers excessive credit card

processing fees, which it refuses to explain or adjust.

114. Defendant sends Plaintiffs and other African drivers to collections agencies, even

when they do not actually owe Defendant any money. Typically, this happens when Defendant

owes the Plaintiff money, and not the other way around. Moreover, Defendant does not inform

the Plaintiff in advance that it intends to take such action.

25

F. Unlawful Insurance Practices

115. Defendant is self-insured entity that charges drivers a weekly fee in advance for

property damage liability insurance premiums. Defendant has refused to provide Plaintiffs and

other African drivers with the benefits they paid for under these policies.

116. In addition to the various premiums for property damage, drivers also pay weekly

premiums for medical insurance. Defendant has refused to provide Plaintiffs and other African

drivers with the benefits they paid for under these policies.

117. Defendant has represented to Plaintiffs and other African drivers that certain

insurance premiums were mandatory when in fact they were optional.

118. Defendant has charged Plaintiffs and other African drivers excessive insurance

premiums in violation of their policies.

119. Defendant has failed to give Plaintiffs and other African drivers credit for the

premiums they have paid.

120. Defendant has charged Plaintiffs and other African drivers excessive deductibles,

fines, and fees for accidents in violation of their policies.

121. Defendant has refused to repair the cabs of Plaintiffs and other African drivers in

violation of their policies.

122. Defendant has charged Plaintiffs and other African drivers for repairs to the cars

of other parties involved in accidents in violation of their policies.

123. Defendant has undervalued the cabs of Plaintiffs and other African drivers for

purposes of insurance payouts in violation of their policies. Defendant has refused to provide

Plaintiffs and other African drivers with an explanation for the changes in value.

26

124. Defendant has terminated Plaintiffs and other African drivers in retaliation for

attempting to obtain the benefits to which they were entitled under their insurance policies.

125. Defendant has issued installment loans to Plaintiffs and other African drivers in

bad faith by failing to disclose the terms and conditions of those loans, which Plaintiffs and other

African drivers need in order to pay the excessive and unfair premium and deductible charges

Defendant has assessed.

126. Defendant has terminated the insurance policies of Plaintiffs and other African

drivers without any notice or explanation when they have sought to obtain benefits for an

accident, even though they had been paying their insurance premiums regularly.

G. Other Instances of Theft

127. Defendant has charged Plaintiffs and other African drivers for unauthorized,

unnecessary, and excessive motor vehicle repairs.

128. Defendant has required Plaintiffs and other African drivers to have all of their cab

repairs done at the Yellow Cab Shop at higher rates than they would pay at other shops.

129. When Plaintiffs and other African drivers have tried to get their cabs repaired

elsewhere, Defendant has refused to accept the repairs and required them to have the same

repairs done again at the Yellow Cab Shop.

130. Defendant has failed to provide information or estimates in advance of repairing

the cabs of Plaintiffs and other African drivers.

131. Defendant has charged Plaintiffs and other African drivers more than once for the

same repairs and then refused to correct the errors or provide any explanation.

27

132. Defendant has performed faulty repairs on the cabs of Plaintiffs and other African

drivers by replacing good working parts with old and and/or broken parts without their

knowledge or consent.

133. Defendant has kept the cabs of Plaintiffs and other African drivers in its shop for

excessive periods of time without their consent.

134. Defendant has damaged the cabs of Plaintiffs and other African drivers in the

process of its retaliatory “de-hagging” or “de-hacking.”

135. Defendant has damaged and/or confiscated the cabs of Plaintiffs and other

African drivers, removed parts from the cabs, sent the cabs to the junk yard, claimed that the

cabs were “missing,” and re-sold or reinstalled the stolen parts to make additional profits.

136. Defendant has required Plaintiffs and other African drivers to undergo

unnecessary and excessive PUC inspections.

137. Defendant has confiscated the airport badges of Plaintiffs and other African

drivers, which did not belong to Defendant but rather belonged to Airport Authority. Defendant

has threatened to assess fines against Plaintiffs and other African drivers if they do not hand over

their airport badges. When they do turn the badges in to Defendant, Airport Authority assess a

fine against them for not returning them to Airport Authority.

138. Defendant has stolen money from the drop boxes that Plaintiffs and other African

drivers deposited. Defendant then accuses Plaintiffs and other African drivers of not depositing

the money and then requires them to pay again for the “missing” money, along with an

additional fine on top of that.

28

139. Defendant has received computerized credit card approvals though Yellow Cab’s

system on behalf of Plaintiffs and other African drivers and then later claimed that the approvals

were invalid and required them to pay for the transaction again.

H. Interference with Plaintiffs’ Ability to Work Elsewhere

140. Defendant has tried to prevent Plaintiffs and other African drivers from obtaining

employment elsewhere.

141. On June 19, 2007, Alexander told Rizgalla Khamis when he terminated him, “If

you don’t work here, you won’t work elsewhere.” When Mr. Khamis later tried to get a job at

Metro Taxi, they said to him, “Insurance doesn’t approve you.”

142. In September 2007, Max Sir, manager at Freedom Taxi Co., informed Plaintiff

Aden Noor that Yellow Cab had sent Freedom Taxi an email telling them not to hire him.

143. Rivera told Plaintiff Abdul Adam, “Other taxi companies will not hire you. You

have to take it if you want to work.” Shortly thereafter, Mr. Adam began contacting Metro Taxi

and Freedom Cab seeking work. Both companies told Mr. Adam that they were not hiring, even

though he knew that they were because they hired other people he knew around the same time

period.

144. After Defendant terminated Plaintiff Tola Ismael in July 2008, he tried to get a

job at Metro Taxi, but Metro called him back and said they would not hire him after talking to

Yellow Cab.

29

FIRST CLAIM FOR RELIEF RACE/COLOR AND/OR NATIONAL ORIGIN DISCRIMINATION

HOSTILE WORK ENVIRONMENT AND DISPARATE TREATMENT IN VIOLATION OF 42 U.S.C. § 1981 (All Plaintiffs)

145. Plaintiff realleges and incorporates by reference paragraphs 1-144 set forth above

in this Complaint as if fully set forth herein.

146. Defendant subjected Plaintiffs and other African drivers to a hostile work

environment with conduct including but not limited to: name calling, taunts, jeers, laughing,

gestures, yelling, bribery, extortion, and physical assault; discriminatory and disparate treatment

with regard to fines, fees, and other charges; discriminatory and disparate treatment with

policies, rules, and discipline; theft and property damage; ostracism and failure to redress

grievances; outright threats and intimidation; and unfair termination.

147. Plaintiffs and other African drivers did not welcome the conduct creating the

hostile work environment.

148. Race/color and/or national origin was a determinative or motivating factor behind

the conduct creating the hostile work environment.

149. The conduct creating the hostile work environment was so severe or pervasive

that a reasonable person in the position of Plaintiffs and other African drivers would find the

work environment to be hostile or abusive.

150. Plaintiffs and other African drivers believed their work environment to be hostile

or abusive as a result of the conduct that created the hostile work environment.

151. Defendant terminated Plaintiffs and other African drivers.

152. Race/color and/or national origin was a determinative or motivating factor in

Defendant’s termination decisions.

30

153. Defendant knew race/color and/or national origin discrimination was occurring

against Plaintiffs and other African drivers and failed to take adequate measures to stop the

discrimination.

154. As a proximate result of the Defendant's above-stated discriminatory actions, the

Plaintiff has suffered damages and has suffered extreme emotional distress. 42 USC§ 1981 entitles

Plaintiffs to the full panoply of damages, including punitive damages, attorney fees and costs.

SECOND CLAIM FOR RELIEF – RETALIATION HOSTILE WORK ENVIRONMENT, DISPARATE TREATMENT, DISPARATE IMPACT AND

TERMINATION IN VIOLATION OF 42 U.S.C. § 1981

(Nasir Abagibe, Abukar Aden, Ali Ali, Nuur Ali, Muktar Buni, Abdi Dhuubow, Nasir Farah, Abdi Hussein,Tola Ismael, Muuse Jaamac, Rizgalla Khamis, Aden Noor, Abdul

Nur, Ahmed Odawaay, Said Omar, Mocktar Said)

155. Plaintiffs reallege and incorporate by reference paragraphs 1-154 set forth above


156. Plaintiffs and other African drivers engaged in activities that are protected by 42

U.S.C. § 1981, including but not limited to: opposing, reporting, and complaining about

Defendant’s race/color and/or national origin discrimination against them; and assisting or

participating in an investigation or legal proceeding, with a good faith belief that such race/color

and/or national origin discrimination had taken or was taking place against them or others.

157. Defendant subjected Plaintiffs and other African drivers to materially adverse

actions at the time, or after, the protected conduct took place.

158. A causal connection exists between the protected activities of Plaintiffs and other

African drivers and the materially adverse actions of Defendant.

159. As a proximate result of the Defendant’s above-stated discriminatory actions, the

Plaintiffs have suffered damages and have suffered extreme emotional distress. 42 USC

31

§1981entitles Plaintiffs to the full panoply of damages, including punitive damages, attorney fees

and costs.

THIRD CLAIM FOR RELIEF BREACH OF CONTRACT

(Nasir Abagibe, Abdul Adam, Abukar Aden, Ali Ali, Ketema Aligaze, Tariq Ayuub, Muktar Buni, Abdi Dhuubow, Nasir Farah, Abdi Hussein, Tola Ismael, Muuse Jaamac,

Rizgalla Khamis, Rizgalla Khamis, Aden Noor, Ahmed Odawaay, Said Omar, Mohamed A. Osman, Mocktar Said)



161. Defendant entered into contracts with Plaintiffs.

162. Defendant failed to honor its obligations under those contracts causing Plaintiffs

damages and entitling them to the full panoply of remedies provided by law.

FOURTH CLAIM FOR RELIEF THEFT

(Nasir Abagibe, Abukar Aden, Ali Ali, Ketema Aligaze, Tariq Ayuub, Nasir Farah, Abdi Hussein, Tola Ismael, Muuse Jaamac, Rizgalla Khamis, Aden Noor, Abdul Nur, Ahmed

Odawaay, Mohamed A. Osman, Mocktar Said)



164. Defendant knowingly obtained or exercised control over something of value of

Plaintiffs.

165. Defendant did so without proper authorization.

166. Defendant did so by threat or deception.

167. Defendant did so with the intent to deprive Plaintiffs permanently of the use or

benefit of the things(s) of value, or it knowingly used, concealed, or abandoned the thing(s) of

value so as to deprive Plaintiffs permanently of its use or benefit, or it used, concealed, or

abandoned the thing(s) of value so as to deprive Plaintiffs permanently of its use or benefit, or it

32

demanded consideration to which it was not legally entitled as a condition of restoring the

thing(s) of value to Plaintiffs, causing Plaintiffs damage, or loss to Plaintiffs.

FIFTH CLAIM FOR RELIEF BREACH OF THE COVENANT OF GOOD FAITH AND FAIR DEALING

(Abukar Aden, Ali Ali, Ketema Aligaze, Tariq Ayuub, Nasir Farah, Abdi Hussein, Tola Ismael, Muuse Jaamac, Rizgalla Khamis, Aden Noor, Mocktar Said)



169. Defendant had discretionary authority over Plaintiffs to determine the terms of the

agreements into which Plaintiffs entered with Defendant.

170. Plaintiffs expected Defendant to honor their reasonable expectations as provided

by the agreements.

171. Defendant failed to honor those expectations.

172. Defendant’s failure to honor the Plaintiffs’ reasonable expectations caused injury,

damage, or loss to Plaintiffs.

SIXTH CLAIM FOR RELIEF BAD FAITH BREACH OF INSURANCE CONTRACT

(Ali Ali, Tola Ismael, Mocktar Said)



174. Plaintiffs suffered injuries, damages, or losses.

175. Defendant misrepresented pertinent facts or insurance policy provisions related to

coverage under the policies; failing to acknowledge, investigate, and pay out on claims with

reasonable promptness; failing to attempt in good faith to fairly settle claims; forcing Plaintiffs to

institute litigation in order to receive the benefits due under the policy; and/or unilaterally

decreasing the coverage benefits of its policies to Plaintiffs.

33

176. Defendant misrepresented the benefits, advantages, conditions, and/or terms of its

insurance policies to Plaintiffs.

177. Defendant engaged in the above actions willfully or with such frequency as to

indicate a tendency to engage in a general business practice.

178. Defendant engaged in unfair claim settlement practices by engaging in the above

actions.

179. Defendant’s actions were unreasonable.

180. Defendant’s conduct was a cause of Plaintiffs’ injuries, damages, or losses.

SEVENTH CLAIM FOR RELIEF PROMISSORY ESTOPPEL

(Nasir Abagibe, Abdul Adam, Abukar Aden, Tariq Ayuub, Aden Noor)



182. Defendant made representations to Plaintiffs.

183. Defendant should reasonably have expected Plaintiffs to rely on its

representations.

184. Plaintiffs did rely on Defendant’s representations.

185. Defendant’s failure to fulfill Plaintiffs’ expectations resulted in harm to Plaintiffs.

EIGHTH CLAIM FOR RELIEF OUTRAGEOUS CONDUCT/INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

(Nasir Farah, Abdi Hussein and Aden Noor)

186. Plaintiff realleges and incorporates by reference paragraphs 1-185 set forth above


187. Defendant engaged in extreme and outrageous conduct.

34

188. Defendant’s managers were in positions of authority over which they had power

to affect Plaintiffs’ interests.

189. Defendant’s managers used their positions to force Plaintiffs to endure racially

demeaning, harassing, offensive and retaliatory conduct.

190. Defendant’s conduct was so outrageous as to be intolerable within this

community.

191. Defendant’s conduct was willful and wanton, and was attended by circumstances

of malice and reckless disregard for Plaintiffs’ rights.

192. Defendant’s conduct was intentional, extreme and outrageous, and was the

proximate cause of Plaintiffs’ severe emotional distress, as well as their injuries, damages and

losses, as described above.

193. Defendant engaged in extreme and outrageous conduct recklessly or with the

intent of causing Plaintiffs severe emotional distress.

NINTH CLAIM FOR RELIEF – INTENTIONAL INTERFERENCE WITH PROSPECTIVE BUSINESS RELATIONS

(Abdul Adam, Abukar Aden, Tola Ismael, Rizgalla Khamis, Aden Noor)



195. Defendant intentionally and improperly interfered with Plaintiffs’ prospective

contractual or business relationships with other cab companies by inducing or otherwise causing

other cab companies not to enter into relationships with Plaintiffs or continue their prospective

relationships with Plaintiffs, or by preventing Plaintiffs from acquiring or continuing the

prospective relationship(s).

196. Defendant’s interference caused injuries, damages, or losses to Plaintiffs.

35

TENTH CLAIM FOR RELIEF ASSAULT

(Nasir Farah and Abdi Hussein)



198. Defendant intended to make physical contact with Plaintiff Farah or intended to

place them in apprehension of physical contact.

199. Defendant placed Plaintiff Farah in apprehension of immediate physical contact.

200. The contact was harmful or offensive or appeared to be harmful or offensive.

ELEVENTH CLAIM FOR RELIEF – UNLAWFUL MOTOR VEHICLE REPAIRS (Nasir Abagibe, Ali Ali, Nasir Farah, Tola Ismael)



202. The Yellow Cab Shop is a motor vehicle repair facility as defined in the Motor

Vehicle Repair Act, C.R.S. § 42-9-101 et seq.

203. Plaintiffs are customers as defined in the Motor Vehicle Repair Act, C.R.S. § 42-

9-101 et seq.

204. The Yellow Cab Shop charged Plaintiffs for motor vehicle repairs to which they

have not consented.

205. The Yellow Cab Shop charged Plaintiffs for motor vehicle repairs in excess of the

amounts allowed in the Motor Vehicle Repair Act, C.R.S. § 42-9-101 et seq.

206. The Yellow Cab Shop represented to Plaintiffs that repairs were necessary when

they were not.

207. The Yellow Cab Shop represented to Plaintiffs that repairs had been performed

when they had not.

36

208. The Yellow Cab Shop represented to Plaintiffs that motor vehicles or motor

vehicle parts were in a dangerous condition when they were not.

209. The Yellow Cab Shop failed to issue invoices to Plaintiffs as required by the

Motor Vehicle Repair Act, C.R.S. § 42-9-101 et seq.

210. The Yellow Cab Shop failed to provide advance estimates to Plaintiffs as required

by the Motor Vehicle Repair Act, C.R.S. § 42-9-101 et seq.

211. Defendant’s conduct caused injuries, damages, or losses to Plaintiffs.

WHEREFORE, Plaintiffs respectfully request that this Court enter judgment in their favor and

against Defendant, and award them all relief as allowed by law, including, but not limited to, the

following:

a. Back pay, in an amount to be determined at trial;

b. Front pay and lost future earnings, in lieu of reinstatement;

c. Compensatory and consequential damages as allowed;

d. Emotional distress damages as allowed;

e. Punitive damages as allowed;

f. Injunctive and/or declaratory relief requiring Defendant to, among other

things, cease all illegal racial/color and/or national origin harassment of its

African employees, and to institute and enforce policies preventing such

illegal conduct in the future;

g. Liquidated damages as allowed;

h. Attorneys’ fees and costs as provided for by law;

i. Pre- and post-judgment interest, costs, expert witness fees, and such

similar relief as the Court deems just and proper; and

37

j. All such further relief as justice requires.

PLAINTIFFS DEMAND A JURY TRIAL ON ALL ISSUES SO TRIABLE.

Dated this 18th day of June, 2010. Respectfully submitted, KING & GREISEN, LLP By: s/Diane S. King Diane S. King, #16925 Monica C. Guardiola, #32077

King & Greisen, LLP 1670 York Street Denver, Colorado 80206 (303) 298-9878 (303) 298-9879 (fax) [email protected] [email protected]

Attorney for Plaintiffs

Plaintiffs’ Addresses: Nasir Abagibe 364 S. Ironton Street #322 Aurora, CO 80012

Muktar Buni 2350 Cleveland Pl. #406 Denver, CO 80205

Abdul Nur 1799 S. Dayton Street #552 Denver, CO 80247

Abdul Adam 12692 E. Ohio Ave. Aurora, CO 80012

Abdi Dhuubow 1799 S. Dayton Street #328 Denver, CO 80247

Ahmed Odawaay 1243 S. Chester Street Denver, CO 80247

38

Abukar Aden 8555 E. Evans Ave. #3-202 Denver, CO 80231

Nasir Farah 7100 E. Mississippi Ave. #18-108 Denver, CO 80224

Said Omar 9999 E. Yale Ave. #B-205 Denver, CO 80231

Ali Ali 9057 E. Mansfield Ave Denver, CO 80237 Nuur Ali 8831 E. Florida Ave #C-213 Denver, CO 80247

Abdi Hussein 1010 S. Oneida Street #D-208 Denver, COP 80224 Tola Ismael 13254 E. Ohio Ave. Aurora, CO 80012

Mohamed A. Osman 10086 E. Evans Ave. Denver, CO 80247 Mohamed M. Osman 8841 E. Florida Ave. #A-103 Denver, CO 80247

Ketema Aligazie 22882 E. Belleview Lane Aurora, CO 80015

Muuse Jaamac 5318 S. 15th Street Phoenix, AZ 85040

Moktar Said 8871 E. Florida Ave. #D-103 Denver, CO 80247

Tariq Ayuub 2685 S. Dayton Way #108 Denver, CO 80231

Rizgalla Khamis 8000 E. Girard Ave. #320 Denver, CO 80231

Aden Noor 1799 S. Dayton Street #112 Denver, CO 80247

Documents

Yellow Cab lawsuit