NO.

JEFFERSON CIRCUIT COURT

CIVIL DIVISION
JUDGE

MATTIE MILLS
6621 ARBOR CREEK DRIVE
LOUISVILLE, KENTUCKY 40228

VS.

PLAINTIFF

COMPLAINT

Dr. DONNA HARGENS, SUPERINTENDENT

JEFFERSON COUNTY PUBLIC SCHOOLS
3332 NEWBURG ROAD
LOUISVILLE, KY 40219
DR. MICHAEL RAISOR
JEFFERSON COUNTY PUBLIC SCHOOLS
3332 NEWBURG ROAD
LOUISVILLE, KY 40219
STEPHANIE JOHNSON
JEFFERSON COUNTY PUBLIC SCHOOL
DAWSON ORMOND CENTER
900 SOUTH FLOYD STREET
LOUISVILLE, KY 40203

JEFFERSON COUNTY PUBLIC SCHOOLS

SERVE: Any Board Member
3332 NEWBURG ROAD
LOUISVILLE, KY 40219

DEFENDANTS

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Comes the Plaintiff, Mattie Mills, and for her cause of action states as follows:
1. That the Plaintiff has been an employee of the Jefferson County Public Schools on a
regular basis since 2011. Since 2013, Plaintiff was an itinerary substitute position
with Early Childhood.
2. That on or about April 14, the Plaintiff was appointed lead teacher replacing J.
Koeppel at the George Unseld Early Childhood Learning Center.
3. That a letter praising her ability and notifying the parents of the children ion her
classroom were issued. See: Exhibits 1 and 2.
4. That subsequent to a brief conversation with Stephanie Johnson, the Director of the
George Unseld Early Childhood Center, Plaintiff was removed as lead teacher of the
class.
5. That Mattie Mills is African American.
6. That Mattie Mills was replaced by a Caucasian who was less qualified.
7. That the Defendant, Stephanie Johnson, demoted and/or replaced Mattie Mills because
of her race, same being African American.
8. That the Defendant, Dr. Donna Hargens, is the Superintendent of the Jefferson County
Public Schools and has the ultimate task of approving employees for the promotions
and/or demotions.
9. That the Defendant, Dr. Donna Hargens, knew or should have known of the racial
animus of Defendant, Stephanie Johnson, who as Stephanie Allen, was demoted as
principal of Dixie Elementary and was placed on administrative leave because of
weird racially sensitive e-mails. See: Exhibit 3

10. That the Defendant, Dr. Michael Raisor, is the Chief Operating Officer of the
Jefferson County Public Schools and has the ultimate task of approving employees
for promotions and/or demotions.
11. That the Defendant, Dr. Michael Raisor, knew or should have known of the racial
animus of Stephanie Johnson, who as Stephanie Allen was demoted as principal of
Dixie Elementary and was placed on administrative leave because of weird racially
sensitive e-mails. See: Exhibit 3.
12. That the Jefferson County Public Schools is named as a party defendant because of
the violation of the Plaintiffs civil rights.
13. That the actions of the Defendants, individually and jointly, were in violation of KRS
344.et seq, and the Constitution of the Commonwealth of Kentucky.
14. That as a result of the violation of the Civil Rights of the Plaintiff, the Plaintiff
suffered lost wages, embarrassment and humiliation.
15. That the damages complained of herein exceed the jurisdictional limit of the
Jefferson Circuit Court
Wherefore the Plaintiff, Mattie Mills, demand judgment against the Defendants,
Jefferson County Public Schools, Dr. Donna Hargens, Dr. Michael Raisor, and Stephanie
Johnson jointly and severally liable, as follows:
1. Actual damages that exceed the jurisdictional limit of the Jefferson Circuit Court,
2. Pre-judgment and post-judgment interest,
3. Attorneys fees where allowed by law,
4. Her court costs herein expended,
5. A trail by jury herein,

6. Any and all other relief to which the Plaintiff, Mattie Mills, may appear entitled.

______________________________
TEDDY B. GORDON
Attorney for Plaintiff
807 W. Market Street
Louisville, KY 40202
(502) 585-3534

Plaintiff, Mattie Mills, states that she has read the allegations of the foregoing
Complaint, and the statements contained herein are true and correct as she verily
believes.

_______________________________
MATTIE MILLS
SUBSCRIBED AND SWORN to before me by MATTIE MILLS on this _____ day of
May, 2016.
My commission expires: __________________________.

_________________________________
NOTARY PUBLIC, State at Large, KY