Cahill et al v. Nike, Inc.

Filing 1

Complaint. Filing fee in the amount of $400 collected. Agency Tracking ID: 0979-5514167 Jury Trial Requested: Yes. Filed by Sara Johnston, Kelly Cahill against Nike, Inc. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Civil Cover Sheet, #4 Proposed Summons). (Salerno Owens, Laura)

DocuSign Envelope ID: 32D07204-6DB5-473A-BFF8-D20BF35D0EF0

CONSENT TO BECOME PARTY PLAINTIFF IN
COLLECTIVE ACTION UNDER 29 U.S.C. § 216(b)
Cahill et al. v. Nike, Inc.
United States District Court for the District of Oregon
Case No. ____________
1.

I, Sara Johnston, consent to be a party plaintiff in the above-listed action under

29 U.S.C. § 216(b), and agree to be bound by any settlement or judgment of the Court in the
action.
2.

I worked for Defendant Nike, Inc. in and around Beaverton, Oregon from June

2008 through November 2017 first as a Swim Instructor, then as an Account Service
, and finally as an Intermediate

Representative, then
BSA.
3.

During my time at Nike, I was paid less than male Nike employees for

substantially equal work.

When I was initially hired at Nike as an Account Service

Representative, my annual salary was $33,000. I tried to negotiate a higher salary at hire, but
Nike told me that it does not negotiate starting salary. However, about two months after I was
hired, Nike hired a man into the same role on my Team, and his starting annual salary was
$35,000. On information and belief, he was able to negotiate a higher starting salary even though
I had more relevant experience and higher-level credentials. He had no idea how to do the job
and I had to train him, but he was paid more than I was.
4.
I performed duties as a Tableau Developer and a Product Owner in addition to my BSA
responsibilities. For my work as a Tableau Developer, I should have been promoted to
Application Engineer, which position I am informed and believe earned between $85,000 and
$135,000. As a Product Owner, I should have been promoted Lead or Senior BSA, which
positions were in the higher U-Band pay level. I never received these promotions despite doing
the work required of these positions and was only making $75,000 per year when I left Nike in
2017.
5.

715522.2

Shortly after I left the company, Nike split my position into two roles, hired men

Exhibit A
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DocuSign Envelope ID: 32D07204-6DB5-473A-BFF8-D20BF35D0EF0

into both of those roles, and placed both of those men into the higher U-Band pay level, whereas
I had remained in the lower L-Band level throughout my time there. On information and belief,
the male employees were paid at a higher rate for the same work in the U-Band level than I had
been paid in the L-Band level.
6.
7.

Upon consideration of my rights with respect to my legal representation, I hereby

authorize the named Plaintiffs

Ackermann &

Tilajef PC; India Lin Bodien Law; and Markowitz Herbold PC) to make decisions with respect
to the conduct and handling of this action, including the settlement thereof, as they deem
appropriate or necessary.
Please type or print in ink the following:
Name:

Sara Renee Johnston

Address:
Beaverton
(City)
Email:

OR
(State)

97006
(Zip)

_________

Tel:
(Day)

(Evening)

Date: 8/9/2018 9:18:05 AM PDT
Signature

715522.2

Exhibit A
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