(INDIVIDUAL AND COLLECTIVE ACTION CLAIMS)   (INDIVIDUAL AND CLASS CLAIMS)   (INDIVIDUAL AND CLASS CLAIMS)  (DISPARATE TREATMENT AND DISPARATE IMPACT DISCRIMINATION)    Dr. Ahad is female and a citizen of Pakistan. She is a member of protected  classes, as recognized by Title VII of the Civil Rights Act of 1964, as amended (42 U.S.C. §  2000e et seq.).    Dr. Ahad was well-qualified for her work duties described herein.    Based on her accomplishments, in June 2008, Dr. Ahad started work as an  Assistant Professor for Surgery/Bariatric Surgeon for Defendants via an O-1 visa, which is  approved only for individuals with extraordinary ability or achievement. She executed  employment contracts (Exhibit A) in 2008 and 2011 that referenced obligations of SIU  Physicians & Surgeons, Inc. and SIU School of Medicine, which are both affiliated entities of   Dr. Ahad incorporates all prior paragraphs of this Complaint as if fully set forth  herein.    Defendants have discriminated against Dr. Ahad and similarly-situated female  workers in violation of the Fair Labor Standards Act of 1938, 29 U.S.C. § 206(d), as amended by  the Equal Pay Act of 1963, by subjecting them to unequal pay on the basis of sex.    Defendants have discriminated against Dr. Ahad and similarly-situated female  workers by treating them differently from and less preferably than similarly-situated male  employees who performed jobs which required equal skill, effort, and responsibility, and which  were performed under similar working conditions. Defendants so discriminated by subjecting  them to lesser (discriminatory) pay and benefits in violation of the Equal Pay Act.    Defendants caused, attempted to cause, contributed to, or caused the continuation  of, the wage rate discrimination based on sex in violation of the Equal Pay Act. Further,  Defendants knew of or showed reckless disregard for the fact their conduct was in violation of  the Equal Pay Act.    Dr. Ahad and similarly-situated female workers should be awarded all legal and  equitable remedies, including underpaid wages, doubled compensatory awards for all willful  violations and reasonable attorneys’ fees under 29 U.S.C. §§ 216, et seq.   Dr. Ahad incorporates all prior paragraphs of this Complaint as if fully set forth  herein.    This Count is brought on behalf of Dr. Ahad and all members of the class.    Defendants’ conduct above has discriminated between employees on the basis of  sex by paying wages to female employees, including Dr. Ahad and similarly-situated female  workers, at rates less than the rates at which Defendants paid wages to male employees for the  same or substantially similar work on jobs the performance of which required equal skill, effort,  and responsibility, and which were performed under similar working conditions. Defendants  thereby violated the IL Equal Pay Act at 820 ILCS 112/ et seq.      Dr. Ahad and similarly-situated female workers should be awarded the entire  amount of underpayment, interest, costs, reasonable attorneys’ fees and other statutory penalties  or relief as may be allowed by the court.   Dr. Ahad incorporates all prior paragraphs of this Complaint as if fully set forth  herein.    This Count is brought on behalf of Dr. Ahad and all members of the class.    Defendants have discriminated against Dr. Ahad and similarly-situated female  workers by treating them differently from and less preferably than similarly-situated male  employees and by subjecting them to discriminatory (lesser) pay and benefits, discriminatory  terms and conditions of employment, and other forms of discrimination, in violation of Title VII.    Defendants’ conduct has been intentional, deliberate, willful, malicious, reckless  and conducted in callous disregard of the rights of Dr. Ahad and similarly-situated female  workers, entitling them to punitive damages.    By reason of the continuous nature of Defendants’ discriminatory conduct, which  persisted throughout the employment of Dr. Ahad and similarly-situated female workers, they  are entitled to application of the continuing violations doctrine to all violations alleged herein.  Additionally, Plaintiff, on behalf of herself and all others similarly situated, specifically invokes  the Lilly Ledbetter Fair Pay Act provisions of Title VII.    As a result of Defendants’ conduct alleged in this complaint, Dr. Ahad and  similarly-situated female workers have suffered and continue to suffer harm, including but not  limited to lost wages and benefits, diminished employment opportunities, and humiliation,  embarrassment, emotional and physical distress, and mental anguish.    By reason of Defendants’ discrimination, Dr. Ahad and similarly-situated female  workers are entitled to all remedies available for violations of Title VII, including an award of  punitive damages. Reasonable attorneys’ fees should be awarded under 42 U.S.C. § 2000e-5(k).  Dr. Ahad’s Employment Background  