IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
________________________________________________
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XXXXXXXXXXXXX )
XXXXXXXXXXXXX )
XXXXXXXXXXXXX )
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Plaintiff )
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v. )
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JOHN SNOW, SECRETARY, )
UNITED STATES DEPARTMENT OF TREASURY, )
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and )
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MARK W. EVERSON, COMMISSIONER )
UNITED STATES INTERNAL REVENUE SERVICE )
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Defendant, )
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Serve: )
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UNITED STATES ATTORNEY’S OFFICE )
FOR THE
Attn: Civil Process Clerk )
-Via Certified Mail )
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UNITED STATES ATTORNEY GENERAL )
10th &
-Via Certified Mail )
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JOHN SNOW )
20th and C Streets, NW )
-Via Certified Mail )
MARK W. EVERSON, COMMISSIONER )
-Via Certified Mail )
)
-Via Certified Mail )
________________________________________________)
CIVIL COMPLAINT FOR EQUITABLE AND MONETARY RELIEF
AND DEMAND FOR JURY
1. This action arises out of the Defendant United States Internal Revenue Service’s (IRS) unlawful employment actions against the Plaintiff. Specifically, Mr. XXXXXXXXXX alleges that the IRS discriminated against him on the bases of national origin (Indian) and religion (Hindu), in violation of Title VII of the Civil Rights Act of 1964 (Title VII), as amended, 42 U.S.C. § 2000e et seq., when it failed during over six years of employment to: advance or promote him in any way; to give him any meritorious salary increases; to assign him career-enhancing projects related to modernization; to provide him with the proper support, tools, computer equipment and software to accomplish projects; and to allow him to take necessary training programs to remain updated on technological developments and advance his career.
2. Mr. XXXXXXXXXX also alleges that the IRS repeatedly and persistently harassed him in reprisal for engaging in Equal Employment Opportunities activities in violation of Title VII of the Civil Rights Act of 1964 (Title VII), as amended, 42 U.S.C. § 2000e et seq., when it, inter alia, subjected him to physical and verbal harassment leading to his constructive discharge in 2001.
3. Mr. XXXXXXXXXX also alleges that his former employer, the U.S. Department of the Treasury’s Internal Revenue Service (IRS), through its unlawful discriminatory behavior and retaliation, made his working conditions so unbearable that any reasonable person in his position would feel compelled to resign.
Parties
4. Plaintiff (“Mr. XXXXXXXXXX”) is a
5. Defendant John Snow is the Secretary of the United States Department of the Treasury and is responsible for the lawful administration of the Department of the Treasury and those Agencies and Bureaus under its purview including the Plaintiff’s employer, the United States Internal Revenue Service. As such, Secretary Snow is a proper defendant in this action pursuant to 42 U.S.C. § 2000e-16.
6. Defendant Mark W. Everson is the Commissioner of the United States Internal Revenue Service, the Plaintiff’s former employer and is responsible for the United States Internal Revenue Service’s lawful administration. As such, Commissioner Everson is a proper defendant in this action pursuant to 42 U.S.C. § 2000e-16.
Jurisdiction
7. This Honorable Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1331, as it asserts a claim that arises under the Constitution, laws, or treaties of the United States, specifically Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq.
8. This Honorable Court has jurisdiction over this matter pursuant to 42 U.S.C.
§ 2000e-5(F)(3), as it asserts a claim that arises under Title VII of the Civil Rights Act of 1964.
Venue
9. Venue is proper in the District of Columbia under 29 U.S.C. § 1402 because a substantial part of the acts and omissions that give rise to this Complaint occurred in the Internal Revenue Service’s offices located at 1111 Constitution Avenue,., NW, in Washington, D.C., and venue is proper under § 2000e-5(F)(3) because the Defendant has its principal office in the District of Columbia.
Factual Allegations
10. Mr. XXXXXXXXXX was born in XXXXXX, emigrated to the
11. Mr. XXXXXXXXXX has at all times in his life followed the Hindu religious faith.
12. Mr. XXXXXXXXXX was hired as a Senior Technical Advisor (Computer Science and Electrical Engineering), at the level of GS-15, at the IRS’s
13. The IRS hired Mr. XXXXXXXXXX as one of fifteen hires out of approximately three thousand applicants to take part in the modernization of IRS computer systems.
14. In or around November 1998, the IRS assigned him to its Information Systems Division under the supervision of Steve Benigni.
15. From the outset of his employment under Mr. Benigni, Mr. Benigni displayed a hostile attitude toward Mr. XXXXXXXXXX that he did not display toward Mr. XXXXXXXXXX’s XXXXXXX coworkers.
16. In or around August 1999, Mr. Benigni assigned Mr. XXXXXXXXXX to the ETSS/RGS (Electronic Technical Support System/Report Generation System) project, a project in which almost every week Mr. XXXXXXXXXX had to travel to
17. During his assignment to the ETSS/RGS project, Mr. XXXXXXXXXX would call every week from
18. On or about August 13, 1999, Mr. Benigni admonished in an e-mail Mr. XXXXXXXXXX for Mr. XXXXXXXXXX’s failing to attend meetings at New Carrollton, Maryland, despite the fact that Mr. Benigni was aware that Mr. XXXXXXXXXX was in
19. In or around March, 2000, Mr. XXXXXXXXXX was assigned to prepare an “Alternatives Analysis” for the SCRIPS (Service Center Recognition and Image Processing System project) project, which is one of the systems that processes tax returns.
20. Although Mr. Benigni assigned Mr. XXXXXXXXXX to prepare an “Alternatives Analysis” for the project, he did not identify the particular problem that Mr. XXXXXXXXXX was to analyze.
21. During his undertaking of this “Alternatives Analysis” project, Mr. XXXXXXXXXX repeatedly had to ask Mr. Benigni what the real problem was that he had to analyze.
22. During his undertaking of “Alternatives Analysis” project, Mr. XXXXXXXXXX also repeatedly asked to meet with Mr. Albicker, an important executive at the IRS, who purportedly asked for the analysis to be performed.
23. Mr. Benigni never granted Mr. XXXXXXXXXX’s request for this meeting with Mr. Albicker regarding the “Alternatives Analysis” project.
24. In or around April 2000, Mr. XXXXXXXXXX was assigned an assistant to help with the “Alternatives Analysis” project, but his superiors removed her from this assignment shortly thereafter.
25. The IRS also did not allow Mr. XXXXXXXXXX to meet with the contractor who was already working on this SCRIPS project despite repeated warnings from Mr. XXXXXXXXXX that the project would fall short in its quality without a meeting with the contractor.
26. Through persistent efforts, despite several obstacles put in his way, Mr. XXXXXXXXXX managed to identify the correct problem.
27. After identifying the correct problem involved with the “SCRIPS Alternatives Analysis” project Mr. XXXXXXXXXX completed the study for the project and delivered the study report on time.
28. Despite Mr. XXXXXXXXXX’s success, in or about November of 2000 Mr. Benigni gave Mr. XXXXXXXXXX his annual performance rating, which was less than outstanding despite Mr. XXXXXXXXXX’s outstanding work performance and completion of the project (Mr. XXXXXXXXXX received an “outstanding” rating for the same type of work in the previous year).
29. Whereupon Mr. XXXXXXXXXX informed Mr. Benigni of his dissatisfaction with the rating in the light of all the extraordinary efforts he had to put in for the SCRIPS project, and Mr. Benigni instructed him to speak with Mr. Cecil Hua, Mr. Benigni’s direct superior and the Director of the IRS’s Systems Engineering and Integration Division.
30. Accordingly, Mr. XXXXXXXXXX met with Mr. Hua to discuss his performance rating.
31. During the meeting Mr. Hua lost his temper, physically threw Mr. XXXXXXXXXX’s SCRIPS report and electronic mail exchanges on the floor and said “Get out, that is your rating!”
32. As a result of Mr. XXXXXXXXXX’s dissatisfaction with his performance rating and his inability to resolve the situation due to the IRS’s discriminatory attitude toward him, Mr. XXXXXXXXXX filed an EEO Counseling Report of Discrimination based on his national origin in November 2000.
33. Subsequently, in or around late November or early December of 2000, Mr. XXXXXXXXXX did not elevate his EEO Complaint of Discrimination to the Treasury Department as a gesture to amicably resolve the situation and return his concentration to his work.
34. In or around January of 2001, unknown IRS employees assigned Mr. XXXXXXXXXX a project called the “Impact Assessment,” a multi-million dollar project that pertained to data mining using a data warehouse, and instructed Mr. XXXXXXXXXX, without first consulting Mr. XXXXXXXXXX about his workload, that he was to perform and complete the Impact Assessment within 2 weeks.
35. The Impact Assessment was a prodigious project involving a large amount of time-consuming attention to detail.
36. In response to this unreasonable assignment of work, Mr. XXXXXXXXXX informed in an e-mail that he was not in a position to perform the Impact Assessment project because he already was involved in another project and because the deadline was unreasonable.
37. Shortly thereafter, Mr. XXXXXXXXXX met with Mr. Benigni to discuss the Impact Assessment project and Mr. XXXXXXXXXX’s responsive e-mail.
38. During the meeting between Mr. XXXXXXXXXX and Mr. Benigni to discuss the Impact Assessment project and Mr. XXXXXXXXXX’s responsive e-mail, Mr. Benigni yelled and cursed at Mr. XXXXXXXXXX.
39. When Mr. XXXXXXXXXX attempted to leave the meeting to retrieve his file that contained all correspondence and information related to the Impact Assessment project, Mr. Benigni threatened Mr. XXXXXXXXXX saying, “God damn it, sit down, I will write you up.”
40. On or about March 9, 2001, Mr. Benigni walked into Mr. XXXXXXXXXX’s work area and threw a counseling letter at Mr. XXXXXXXXXX, striking Mr. XXXXXXXXXX in the face with the letter.
41. Mr. XXXXXXXXXX was shocked and astonished at this behavior, and so Mr. XXXXXXXXXX again met with Mr. Hua to discuss the Impact Assessment project and the issues between himself and Mr. Benigni.
42. When Mr. XXXXXXXXXX raised the issue of Mr. Benigni’s abusive conduct with Mr. Hua, Mr. Benigni’s direct supervisor, Mr. Hua curtly responded by telling Mr. XXXXXXXXXX, “Who cares? You Indians are corrupt anyway. What’s the big deal?”
43. Mr. Hua also advised Mr. XXXXXXXXXX that, “You have two problems. You tend to escalate problems, and you associate with the niggers.” Mr. Hua added the names "Charles Murray, Al Holloway, Bridgette Kendrick, Cynthia Forrest, Fred Bumbry.
44. Despite the forgoing, Mr. XXXXXXXXXX pursued the issue of the counseling letter, and Mr. Hua eventually agreed to withdraw Mr. Benigni’s counseling letter.
45. After Mr. Hua failed to withdraw the counseling letter in or about April of 2001, Mr. XXXXXXXXXX filed an EEO discrimination claim on or about April 16, 2001.
46. On or about April 19, 2001, shortly after learning that Mr. XXXXXXXXXX filed his EEO claim, Mr. Benigni came to Mr. XXXXXXXXXX’s cubicle and told Mr. XXXXXXXXXX that he wanted to do Mr. XXXXXXXXXX’s mid-year assessment/performance appraisal.
47. Mr. Benigni then made a gesture with his foot like he was crushing a bug and stated, “We’re going to put you on probation.”
48. Accordingly, Mr. XXXXXXXXXX declined to attend his “mid-year assessment” meeting with Mr. Benigni in the light of Mr. Benigni’s behavior and the stated intent of putting Mr. XXXXXXXXXX on probation.
49. On April 20, 2001, Mr. XXXXXXXXXX then appealed to Mr. Bob Albicker, the IRS’s Deputy Chief Information Officer/Associate Commissioner and Cecil Hua’s supervisor, and Ms. Toni Zimmerman, the IRS’s Deputy Chief Information Officer.
50. Within a few days after Mr. XXXXXXXXXX appealed to Mr. Albicker and Ms. Zimmerman, Mr. Benigni started circling Mr. XXXXXXXXXX’s cubicle repeatedly.
51. Within a few days after Mr. XXXXXXXXXX appealed to Mr. Albicker and Ms. Zimmerman, Mr. XXXXXXXXXX also began receiving multiple silent phone calls a day, however at times he heard heavy breathing on the other end of the line.
52. Mr. XXXXXXXXXX reported these matters to the IRS’s EEO Counselors, but the EEO Counselors did nothing to stop these activities.
53. As a result of Mr. Benigni’s harassment, Mr. XXXXXXXXXX developed a variety of stomach problems, leading to his having to consult with a gastro-intestinal specialist, Dr. Pinnar, when his stomach pain became severe.
54. Around this period, Mr. XXXXXXXXXX also began to experience angina attacks with increasing frequency, and he had to consume liberal doses of nitroglycerin tablets to contain the severe chest pains.
55. After one such severe angina attack, Mr. XXXXXXXXXX was rushed to a cardiologist.
56. Mr. XXXXXXXXXX told Mr. Benigni, Mr. Hua, and the EEO Counselors that all of these incidents of extreme physical distress and psychological pain were being caused by Mr. Benigni’s treatment of Mr. XXXXXXXXXX, but nobody acted to stop Mr. Benigni.
57. Finally, Mr. XXXXXXXXXX informed Mr. Hua that he no longer wanted to work under Mr. Benigni’s purview.
58. Accordingly, in or around July of 2001 Mr. Hua assigned Mr. Behrooz Sabet as a “Management Contact” for XXXXXXXXXX, although he did not define for Mr. XXXXXXXXXX what exactly a “management contact” really meant.
59. Within a week following his assignment as a “Management Contact” for Mr. XXXXXXXXXX, Mr. Sabet told Mr. XXXXXXXXXX, “You better watch out. I’ve been brought into this Division to force you out. If I do that, I have been promised a Senior Executive position.”
60. Mr. Sabet then proceeded to give Mr. XXXXXXXXXX multiple assignments.
61. The first one was to write a White Paper on “How Do We Communicate the New Functionality Resulting from Information System Modernization to Our Stakeholders?” and Mr. Sabet demanded that Mr. XXXXXXXXXX should not affix his name as the author of this White Paper.
62. During Mr. Sabet’s supervision of Mr. XXXXXXXXXX, Mr. Sabet constantly cursed at Mr. XXXXXXXXXX, calling him, among other profanities, a “motherfucker” and repeatedly asked him, “You bastard, who do you think you are?”
63. During Mr. Sabet’s supervision of Mr. XXXXXXXXXX, Mr. Sabet followed Mr. XXXXXXXXXX into the bathroom and spit on the bathroom floor where Mr. XXXXXXXXXX’s feet were.
64. Mr. Sabet also constantly followed Mr. XXXXXXXXXX into the elevators and including the cafeteria, even though Mr. Sabet did not eat his lunch at the cafeteria.
65. At this time Mr. Sabet also referred to Mr. XXXXXXXXXX as a “stupid minority.”
66. At this time Mr. Sabet also told Mr. XXXXXXXXXX, “You are an XXXXXX. You’re a minority. Why don’t you get with it?”
67. Mr. Sabet also frequently interrupted the work Mr. XXXXXXXXXX was doing by entering Mr. XXXXXXXXXX’s cubicle, sitting down very close to him, and then repeatedly cursing at him using profanities even when Mr. XXXXXXXXXX asked him to stop.
68. In addition, at this time Mr. Sabet also told Mr. XXXXXXXXXX, “You Hindus are stupid anyway. You’ve got all those gods running around.”
69. During Mr. Sabet’s supervision of Mr. XXXXXXXXXX, Mr. Sabet also bogged Mr. XXXXXXXXXX down with more and more assignments in an attempt to prevent him from completing his EEO interrogatories timely and in a coherent fashion by aggressively interfering with Mr. XXXXXXXXXX when Mr. Sabet knew that Mr. XXXXXXXXXX was working on his EEO interrogatories.
70. In or about mid August of 2001, Mr. Sabet refused to allow Mr. XXXXXXXXXX to take time off to complete an EEO discovery request, ripping up in front of Mr. XXXXXXXXXX Mr. XXXXXXXXXX’s leave request for leave and then throwing the torn document in the trash can.
71. When Mr. XXXXXXXXXX went to pick up the pieces in the trash can, Mr. Sabet quickly bent over, picked up the pieces and put them in his pocket.
72. After all of this had taken place, Mr. XXXXXXXXXX encountered Mr. Hua in the hall, and Mr. XXXXXXXXXX asked Mr. Hua, “Why are you doing all these things to me?”
73. Mr. Cecil Hua responded by showing Mr. XXXXXXXXXX his middle finger, whereupon Mr. Hua laughed at Mr. XXXXXXXXXX and walked away.
74. During about August of 2001, with increasing frequency Mr. Sabet commenced banging violently on the outside of Mr. XXXXXXXXXX’s cubicle walls, resulting in Mr. XXXXXXXXXX suffering further acute stomach pains, intestinal distress, and angina attacks.
75. On August 16, 2001, Mr. XXXXXXXXXX filed a complaint directly to the Commissioner of the IRS, Mr. Charles Rossotti, in which he notified Mr. Rossotti that IRS employees were retaliating against him for his previous EEO complaint. Mr. XXXXXXXXXX requested that the IRS Commissioner take immediate measures to stop the retaliation and continued harassment. To the best of Mr. XXXXXXXXXX’s knowledge, the IRS took no remedial measures in response to his request.
76. On or about August 22, 2001, Mr. Sabet’s banging on Mr. XXXXXXXXXX’s cubicle walls with a binder markedly increased in frequency, the intimidation becoming more severe in an attempt to intimidate Mr. XXXXXXXXXX into resigning.
77. On or about August 22, 2001, Mr. Sabet threw and hit Mr. XXXXXXXXXX in the shoulder with a 3-ring binder, stating “I’m going to force you out.”
78. On or about August 22, 2001, due to Mr. Sabet’s retaliatory actions and physical assaults, Mr. XXXXXXXXXX was forced to leave the
79. On or about September 4, 2001, Mr. XXXXXXXXXX sent an e-mail to Mr. Hua stating that his civil rights had been violated, and he again requested time off to complete his EEO interrogatories.
80. Hua responded to Mr. XXXXXXXXXX’s e-mail dated in or about September 4, 2001, by telling Mr. XXXXXXXXXX that he was absent without leave and ordered Mr. XXXXXXXXXX not to write to him anymore.
81. On at least three separate occasions prior to September 10, 2001, Mr. Sabet called Mr. XXXXXXXXXX at home and left messages on his voice mail, two of them stating “Get back to work or I will chop your balls off.”
82. On or about September 10, 2001, as the direct and proximate result of the IRS’s illegal discrimination on the basis of his national origin and its illegal retaliation and reprisal for his having made an EEO complaint, Mr. XXXXXXXXXX was compelled to submit his resignation to the IRS.
83. Because of all aggressive, virulent, retaliatory and hostile environment to which Mr. XXXXXXXXXX was subjected, Mr. XXXXXXXXXX was unable to complete his EEO Interrogatories at work.
84. Mr. XXXXXXXXXX was only able to complete them only by in or about September 14, 2001, after he was forced to submit his resignation on or about September 10, 2001.
85. Within two or three weeks after Mr. XXXXXXXXXX submitted his resignation, Mr. XXXXXXXXXX called the IRS’s Commissioner’s office and spoke to a woman named Gail Carol, informing her that he submitted his resignation under duress and wished to withdraw it.
86. Ms. Carol instead laughed at Mr. XXXXXXXXXX and hung up on him.
87. After Mr. XXXXXXXXXX was forced out of the IRS, Mr. Benigni and Mr. Sabet began falsely telling people at the IRS that Mr. XXXXXXXXXX had illegally entered the IRS building, logged into the computers, and sent an electronic mail threatening to kill someone.
Count I
Title VII of the Civil Rights Act of 1964 (Title VII)
42 U.S.C. § 2000e et seq.
Discrimination/Tangible Employment Action
(Including, but not limited to, Constructive Discharge)
88. Plaintiff incorporates the allegations in paragraphs 1 through 87 as though alleged herein.
89. Plaintiff is a “person” and an “employee” as the terms are defined at 42 U.S.C. 2000e and the Defendant is an “executive agency” as the term is defined at 42 U.S.C. 2000e-16.(a).
90. Defendant failed and/or refused to hire Plaintiff for new positions, and otherwise discriminated against the Plaintiff with respect to his compensation, terms, conditions, or privileges of employment, because of Plaintiff’s ethnic origin and religion.
91. Defendant limited, segregated, and/or classified the Plaintiff in a way which would deprive or tend to deprive any individual of employment opportunities or otherwise adversely affect his status as an employee, because of Plaintiff’s ethnic origin and religion.
92. Defendant took a tangible employment action against the Plaintiff when it constructively discharged the Plaintiff when it made the Plaintiff’s working conditions so intolerable that his resignation was compelled and is qualified as a fitting response to Defendant’s behavior and conduct.
93. Defendant did not have a readily accessible and effective policy for reporting and resolving complaints of discrimination and harassment.
94. Plaintiff reasonably availed himself of Defendant’s EEO procedures; however, Defendant’s purported anti-harassment policies and grievance mechanisms were ineffective and were not properly implemented.
95. Plaintiff sustained substantial monetary and non-monetary damages as the result of the Defendant’s illegal conduct.
96. Plaintiff demands such legal or equitable relief as will effectuate the purposes of 42 U.S.C. § 2000e et seq., including, but not limited to, the following:
a. reinstatement and economic damages, including back pay;
b. compensatory damages;
c. punitive damages;
d. reasonable attorney’s fees;
e. court costs; and any other relief that this Court deems just and equitable.
Count II
Title VII of the Civil Rights Act of 1964 (Title VII)
42 U.S.C. § 2000e et seq.
Discrimination/Hostile Work Environment
97. Plaintiff incorporates the allegations in paragraphs 1 through 96 as though alleged herein.
98. Plaintiff is a “person” and an “employee” as the terms are defined at 42 U.S.C. 2000e and the Defendant is an “executive agency” as the term is defined at 42 U.S.C. 2000e-16.(a).
99. Defendant failed and/or refused to hire Plaintiff for new positions, and otherwise discriminated against the Plaintiff with respect to his compensation, terms, conditions, or privileges of employment, because of Plaintiff’s ethnic origin and religion.
100. Defendant limited, segregated, and/or classified the Plaintiff in a way which would deprive or tend to deprive any individual of employment opportunities or otherwise adversely affect his status as an employee, because of Plaintiff’s ethnic origin and religion.
101. Defendant engaged in hostile conduct, including verbal, psychological and physical assaults, against the Plaintiff.
102. Plaintiff sustained substantial monetary and non-monetary damages as the result of the Defendant’s illegal conduct.
103. Plaintiff demands such legal or equitable relief as will effectuate the purposes of 42 U.S.C. § 2000e et seq., including, but not limited to, the following:
a. reinstatement and economic damages, including back pay;
b. compensatory damages;
c. punitive damages;
d. reasonable attorney’s fees;
e. court costs; and any other relief that this Court deems just and equitable.
Count III
Title VII of the Civil Rights Act of 1964 (Title VII)
42 U.S.C. § 2000e et seq.
Retaliation
(Adverse Employment Actions including, but not limited to, Constructive Discharge)
104. Plaintiff incorporates the allegations in paragraphs 1 through 103 as though alleged herein.
105. Defendant, in response to Plaintiff’s engaging in protected activity by filing and prosecuting an EEO complaint against the Defendant, made the Plaintiff’s working conditions so intolerable, through its unlawful discriminatory behavior and retaliation, that his resignation was compelled and is qualified as a fitting response to Defendant’s behavior and conduct.
106. Defendant did not have a readily accessible and effective policy for reporting and resolving complaints of discrimination and harassment.
107. Plaintiff reasonably availed himself of Defendant’s EEO procedures; however, Defendant’s purported anti-harassment policies and grievance mechanisms were ineffective and were not properly implemented.
108. Plaintiff demands such legal or equitable relief as will effectuate the purposes of 29 U.S.C. § 621 et seq., including, but not limited to, the following:
a. reinstatement and economic damages, including back pay;
b. compensatory damages;
c. punitive damages;
d. reasonable attorney’s fees;
e. court costs; and any other relief that this Court deems just and equitable.
Prayer for Relief
WHEREFORE, PREMISES CONSIDERED, Plaintiff XXXXXXXXXX prays this Honorable Court for Judgment against the Defendant, in addition to reinstatement, in the amount of economic damages, compensatory damages, and punitive damages to be determined at trial, plus attorneys’ fees, costs of this action, equitable relief (including Plaintiff’s employment status and awarding back pay) and any other relief this Honorable Court deems just and proper to award.
Respectfully Submitted,
XXXXXX X. XXXXXXXXXX,
By Counsel,
_________________________________
R.
Nicholas Woodfield, D.C. Bar No. 471801
Employment Law Group, P.L.L.C.
(202) 261-2812
(202) 261-2835 (facsimile)
soswald@employmentlawgroup.net
nwoodfield@employmentlawgroup.net
Counsel for Plaintiff
Plaintiff XXXXXXXXXX demands a jury for all issues proper to be so tried.
_________________________________
R. Scott Oswald
Nicholas Woodfield
