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UNITED STATES DISTRICT COURT - Title VII Race Discrimination in Employment
UNITED STATES DISTRICT COURT - Title VII Race Discrimination in Employment
DISTRICT OF COLUMBIA
PATRICIA A. MCNEIL
7893 Patriot Drive
Annandale, Virginia 22003
Plaintiff,
v.
Defendant
1. This is a suit brought pursuant to Title VII of the Civil Rights Act of
1984, 29 U.S.C. Sec. 2000e at. seq., as amended. Plaintiff brings this
action for redress of injuries sustained as a result of the defendant's
unlawful conduct terminating her employment after 4 and 1/2 years
because of her race.
2. Jurisdiction of this Court is invoked pursuant to 29 U.S.C. Sec. 626(c).
PARTIES
________
5. The defendant, Akin, Gump, Strauss, Hauer & Feld, is a law firm with
its principal offices at 1333 New Hampshire Ave. N.W., Washington,
D.C. 20036 At all times relevant to this complaint, defendant was an
employer within the meaning of federal law, engaged in an industry
affecting commerce and employing more than 20 employees.
7. During the 4 1/2 years that she worked for defendant, plaintiff was
regularly rated on her performance reviews as meeting or exceeding job
expectations.
12. In July, 1991, Ms. Robertson called a meeting of three of the black
employees under her supervision, including plaintiff, and asked them if
they thought she was prejudiced against blacks. She explained that her
black male receptionist had accused her of being prejudiced against blacks
and she wanted to know whether they shared that view. All three
employees responded in the affirmative and provided her the reasons they
felt that way, giving her examples of the way she treated blacks differently
than whites.
13. In March 1991, two black employees in the Litigation Support group
in which plaintiff worked were laid off allegedly because of budget cuts.
Within a very short period of time thereafter, their positions were filled
by white employees. Plaintiff does not believe the black employees laid off
were offered reinstatement to their former positions.
14. In August 1991, plaintiff informed Ms. Robertson that she had
recently learned that she (plaintiff) was pregnant with her second child.
Ms. Robertson responded that she did not understand why blacks have so
many babies.
15. Plaintiff had a very difficult pregnancy and eventually lost her baby
through a miscarriage. Although she had medical documentation
supporting her request for eight weeks of maternity leave after the
delivery, she was told by defendant's personnel administrator, Laurel
Digweed, that she did not qualify for maternity leave because her baby
died. Meanwhile, plaintiff had a terrible time coping with the emotional
pain of losing her baby, in addition to the physical recovery from the
miscarriage.
17. When Plaintiff returned to her work area, Ms. Schotz approached her
and asked why she had a meeting with Ms. Robertson. Plaintiff told her it
was confidential in nature and she did not want to talk about it.
18. On April 9, 1992, plaintiff was asked to meet with Laurel Digweed
from Personnel. Ms. Digweed told plaintiff that she had been advised by
Ms. Robertson that plaintiff had called Isabelle Schotz a "Jewish bitch"
and that the two of them then got into a shoving and fighting match.
Plaintiff denied calling Ms. Schotz any such name, or that she got into any
kind of fight and suggested that Ms. Schotz be called to the office to clear
the matter up, since plaintiff did not believe that she would fabricate such
assertions in her presence. Ms. Digweed responded that Ms. Schotz had
no reason to lie about the incident and that she would have to write
plaintiff up for the incident and place the memo in her personnel file.
Plaintiff continued to argue that this was not fair, and Ms. Digweed told
her to "shut [her] god damn mouth up bitch." Plaintiff then left the office
since she felt that she did not have to put up with that type of abuse.
19. A short time later, Ms. Digweed called plaintiff at her work area and
instructed her to return to her office immediately. Plaintiff responded
that she would agree to return to her office only if a third person were
present because she would not put up with her abuse alone.
Approximately at noon that same day, Ms. Digweed came to plaintiff's
work area and informed her that she was being terminated for refusing to
talk to management.
20. Plaintiff believes that the entire handling of this incident was
discriminatory by Ms. Robertson and Ms. Digweed, in that their
investigation of the incident did not comply with the firm's own
procedures for investigating such matters between coworkers. Were it not
for the discriminatory attitudes harbored by these two individuals toward
blacks, plaintiff does not believe they would have taken the assertion of
one employee against another without having conducted a thorough
investigation to determine who was telling the truth.
21. Since her termination, plaintiff has been unable to find comparable
work elsewhere. She has become depressed and anxious for her family
and has had to seek medical attention for these symptoms.
CAUSE OF ACTION
___________
2. Order the defendant to make the plaintiff whole for all wages and
benefits which the plaintiff lost as a result of the defendant's
discriminatory conduct;
4. Grant to plaintiff pain and suffering damages which she sustained due
to the job loss and the traumatic effect that has had on her personally and
on her family;
JURY DEMAND
___________
THE PLAINTIFF
[signed]