of Har-rah’s management by its own admissions in the EEBOP is a common course of conduct against all plaintiffs in the putative class. Each and every claim applicable to the class is premised upon defendants’ discriminatory conduct commonly directed to the Caucasian class members as a group.. .At the heart of the class claims is the fact that the class was deprived of and continues to be deprived of employment opportunities as a result of Harrah’s implementation of the EEBOP. . Pl.’s Br. at 16. To support this claim, Plaintiff cites several cases in which courts have found that the existence of documentation of an entity’s general policy of discrimination suffices to establish typicality. See, e.g., Welch v. Bd. of Directors of Wildwood Golf Club, 146 F.R.D. 131, 135 (W.D.Pa.1993) (<HOLDING>). Plaintiffs argument is supported by the Third
holding that the plaintiffs benefits were found in the new york state constitution and vested in the plaintiffs by the terms of a statutory scheme recognizing that plaintiffs genderbased burk tort parallels a federal gender discrimination claim holding that ejxcept in matters governed by the federal constitution or by acts of congress the law to be applied in any case is the law of the state holding that statute which became effective after claimants death but prior to the trial of wrongful death case was remedial constitutional and governed pending litigation proceedings that were pending when statute was enacted holding that the wildwood golf clubs constitution and bylaws which governed transferability of membership in the case of death and divorce adequately established typicality of plaintiffs claim of genderbased discrimination