Case 1:17-cv-00649-DNH-CFH Document 1 Filed 06/15/17 Page 1 of 9

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT COURT OF NEW YORK

CATHERINE WEBB,

Plaintiff,
-against- CIVIL COMPLAINT

Civil Case No.: 1:17-CV-0649 (DNH/CFH)

NEW YORK STATE JOINT COMMISSION

ON PUBLIC ETHICS.
Defendants.

JURY TRIAL DEMANDED

PRELIMINARY STATEMENT

1. Plaintiff, Catherine Webb, by and through her attorney the Law Office of Patrick Sorsby

PLLC, brings this action under Title VII of the Civil Rights Act of 1964, as amended, codified at

42 U.S.C. 2000e et seq., the Civil Rights Act of 1991, and the New York Human Rights Law

(NYHRL), N.Y. Exec. Law 290 et seq. for employment sexual discrimination and specifically

misogynistic comments made directly to the Plaintiff. The Plaintiff alleges that the Defendant by

and through its management and agents, treated the Plaintiff in a demeaning and abusive manner

by verbal conduct in a sexual nature which was severe, pervasive and frequent; and directed at the

Plaintiff. The Plaintiff also alleges that the Defendant by and through its management or agents

created a hostile work environment for the Plaintiff. The Plaintiff additionally alleges that the

Defendant retaliated against the Plaintiff, terminating her for an unknown and unreported reason

stating, we have some bad news, we are going to have to let you go. Really nothing else to say,

decision has been made. Lastly the Plaintiff alleges that she was wrongfully terminated by the

Page 1 of 9
 Case 1:17-cv-00649-DNH-CFH Document 1 Filed 06/15/17 Page 2 of 9

Defendant on the basis of sex. The Plaintiff is now seeking compensatory damages, back pay with

interest, punitive damages, costs and attorneys fees for the Defendants wrongful conduct.

JURISDICTION

2. This Court has jurisdiction pursuant to 28 U.S.C. 1331 and 1343. Plaintiff's claims are

brought under Title VII of the Federal Civil Rights Act of 1964, 42 U.S.C. 2000(e), et seq., as

amended and 28 U.S.C. 1331.

VENUE

3. This action properly lies in the Northern District of New York, pursuant to 29 U.S.C.

1391(b), because the claim arose in this judicial district, and pursuant to 42 U.S.C. 2000e-5(f)(3),

because the unlawful employment practice was committed in this judicial district.

4. On May 17, 2017, the EEOC issued "right to sue" letters, authorizing plaintiff to commence

an action against Defendants within 90 days from receipt of the same. A copy of the right to sue

letter is annexed hereto as Exhibit A.

5. This action is commenced within 90 days of plaintiff's receipt of the right to sue letter as

the Plaintiff received the February 18th right to sue letter on February 20th.

PARTIES

6. The Plaintiff, Catherine Webb, is a citizen and resident of the United States, State of New

York, Dutchess County.

7. Defendant NEW YORK STATE JOINT COMMISSION ON PUBLIC ETHICS (herein

after JCOPE or Defendant used interchangeably) is a Division of New York State doing business

in Albany County.

Page 2 of 9
 Case 1:17-cv-00649-DNH-CFH Document 1 Filed 06/15/17 Page 3 of 9

FACTS

8. The plaintiff, a female, was employed by JCOPE as a Forensic Financial Auditor/Examiner

by from June of 2014 to January 21, 2016. On information and belief, during her employment with

the Defendant, the Plaintiff maintained a satisfactory work record, receiving the highest possible

annual performance evaluations.

SEXUAL ANIMUS AND DISPARATE TREATMENT

9. From June 2014 to February 2015 a coworker by the name of Gareth Perrin (herein after

Perrin) began to harass the Plaintiff by making misogynistic comments to the Plaintiff on a

fairly-regular basis.

10. Perrin disliked women which is apparent by his statements:

a) that the worst day of my life was the day my daughter was born and he would not have

another child because of the chance that it might be a girl

b) woman should stay home and cook and cleanthat it worked well for thousands of

yearswhy change it

c) that it was disrespectful of me not to take my husbands name

d) that under no (emphasis on no) circumstances should a man stay at home with children,

that is a womans job

HARASSMENT AND HOSTILE ANIMUS

11. Perrin harassed the Plaintiff in a bullying manner by his statements to the affect:

a) you take no initiative

b) you are a technical dinosaur

c) you are a slow worker

Page 3 of 9
 Case 1:17-cv-00649-DNH-CFH Document 1 Filed 06/15/17 Page 4 of 9

d) just because you are old does not make you better

12. In March of 2015 Perrin was promoted by supervisor Martin Levine whereby Perrin

became the Plaintiffs supervisor. Mr. Levine was informed that it would not be appropriate to

promote Perrin as Plaintiffs supervisor because Plaintiff had just endured a period of gender based

harassment by Perrin. Nonetheless, in spite of being put on notice of this gender discrimination

Mr. Levine still promoted Perrin providing him with greater control over the Plaintiff.

13. Starting in May of 2015 supervisor Perrin began using misogynistic comments again.

However, this conduct exacerbated beyond comments to demeaning insults directed at the

Plaintiff.

14. In August of 2015 Plaintiff requested a meeting with Chief of Staff Monica Stamm wherein

the Plaintiff requested if she could physically move her office away from Supervisor Perrin.

Monica stated that she could not do anything until they hired a new executive director. She further

added by saying to the Plaintiff that I have a job until then (meaning until a new director is

hired).

15. In December of 2015 Plaintiff watched a sexual harassment video and a violence in the

workplace video and realized that many of the situations portrayed in the video were very similar

to what the Plaintiff had been experiencing with Perrin at JCOPE. The video explained that every

government agency in NY State has a person who is designated to be the special person in charge

of handling issues that were similar to that experienced by the Plaintiff. Plaintiff went to the HR

specialist, Steve Boland, and asked who the person is for JCOPE. Mr. Boland looked it up and

told the Plaintiff that it was Kevin Gagan, the new Executive Director of JCOPE.

16. The very next day, Plaintiff was summoned to HR specialist Steve Bolands office to meet

with director Gagan who wanted to know why the Plaintiff had inquired about him with Steve

Page 4 of 9
 Case 1:17-cv-00649-DNH-CFH Document 1 Filed 06/15/17 Page 5 of 9

Boland the previous afternoon. The Plaintiff explained that she recognized the similarities

between some of the situations portrayed in the video presented by JCOPE and her own

experiences with Supervisor Perrin. Kevin Gagan then said well, we have to have an investigation

then.

17. Approximately two weeks following this meeting, Plaintiff was called into a conference

room to meet with JCOPE investigators Patrick Coulson and Stacey Hamilton for the purpose of

an investigation. Ms. Hamilton asked the Plaintiff to tell the story from the beginning,

whereby the Plaintiff did. According to the Plaintiff, both Patrick Coulson and Stacey Hamilton

kept copious notes as she spoke. The meeting concluded almost two hours later. Plaintiff became

aware that in the following days that both Supervisor Perrin and another coworker Taryn were

taken into the same conference room for questioning, presumably for the investigation.

18. On January 21, 2016 Plaintiff was asked by Director Gagen to come down to HR specialist

Steve Bolands office. Plaintiff complied and took a seat in the office. Director Gagen said we

have some bad news, we are going to have to let you go. Really nothing else to say, decision has

been made. Gagen continued to say, Pat (from Investigations) will walk you out to your car.

19. Plaintiff states that she never received, nor was in any way informed, about the result of

the investigation of Sexual harassment by Supervisor Perrin.

20. Plaintiff adds that she believes that Supervisor Perrins conduct created a hostile work

environment for her based on her gender. Supervisor Perrin engaged in verbal conduct of a sexual

nature which was severe and pervasive and culminated in the termination of the Plaintiff. The

employer, New York State and JCOPE, is liable for the conduct of supervisor Perrin because the

Plaintiff appropriately reported the same to the correct authorities of the employing agency as

indicated in the video presented by the employer and because Perrin was the supervisor of the

Page 5 of 9
 Case 1:17-cv-00649-DNH-CFH Document 1 Filed 06/15/17 Page 6 of 9

Plaintiff. The actions of the State agency and subsequent termination of the Plaintiff constitute

discrimination and violations of Title VII and New York State Human Rights Law.

21. The Defendant retaliated against the Plaintiff by and when they terminated her. The

Defendants actions to terminate the Plaintiff, despite the well documented work proficiency of the

Plaintiff, took place within only a few weeks of the Plaintiff reporting exactly what she was trained

by the agency to do in the presence of sexual harassment. The termination was conducted by the

agency absent any stated reason or justification. Any conceivable reason the agency could put

forth will be a tainted pretext for retaliation.

22. That the harasser Gareth Perrin used his position of authority to have access to the Plaintiff

in order to harass, intimidate bully and discriminate against the Plaintiff thus creating the hostile

work environment.

AS FOR THE FIRST CAUSE OF ACTION

SEXUAL ANIMUS AND DISPARATE TREATMENT

23. The allegation in paragraphs 1 through 22 are incorporated herein as if set forth in full.

24. That as alleged throughout this complaint the Defendant through and by its supervisor

Gareth Perrin, did engage in unwanted verbal and sexual misconduct that was evidenced by his

disrespect for women, that the Plaintiff did, and a reasonable person in Plaintiffs position would

find this conduct offensive, unacceptable and in violation of agency policies.

25. Supervisor Gareth Perrin openly displays a negative sexual animus toward the female sex

through his comments toward the Plaintiff and has stereotyped women in a negative manner.

26. On information and belief, the Defendant had documented Discrimination and Sexual

Harassment policies in place. However, said policies are clearly ineffective in preventing

discrimination and sexual harassing behaviors by management to the extent that employees

Page 6 of 9
 Case 1:17-cv-00649-DNH-CFH Document 1 Filed 06/15/17 Page 7 of 9

exercising their rights when subjected to harassment or sexual discrimination would be terminated

without cause of action.

AS AND FOR A SECOND CAUSE OF ACTION

HARASSMENT AND A HOSTILE ANIMUS

27. The allegation in paragraphs 1 through 26 are incorporated herein as if set forth in full.

28. That as alleged throughout this complaint the Defendant through and by its supervisor

Gareth Perrin, did engage in unwanted harassment and hostility whereby the Plaintiff did, and a

reasonable person in Plaintiffs position would find that this conduct sufficiently severe enough to

alter the terms and conditions of her employment.

29. Section 704 Title VII, 42 USC 2000e-3 makes it an unlawful employment practice for

an employer to discriminate against any of his employeesbecause he has opposed any practice

made an unlawful employment practice by this subchapter, or because he has made a charge

under this subchapter.

30. The plaintiff opposed the unlawful employment practice by the Defendant for sexual

harassment, misogynistic comments which were degrading in nature.

31. On information and belief, despite the video pertaining to Sexual Harassment and presented

to all employees by the Defendant agency, was ineffectively enforced or disregarded by

management as it related to recognizing and handling issues with discrimination and sexual

harassment in the workplace.

Page 7 of 9
 Case 1:17-cv-00649-DNH-CFH Document 1 Filed 06/15/17 Page 8 of 9

AS AND FOR A THIRD CAUSE OF ACTION

(WRONGFUL TERMINATION)

32. The allegation in paragraphs 1 through 31 are incorporated herein as if set forth in full.

33. Title VII of the Civil Rights Act of 1964 ("Title VII"), 42 U.S.C. 2000e et seq., forbids

employment discrimination on the basis of "race, color, religion, sex, or national origin." See 42

U.S.C. 2000e-2(a).

34. On information and belief, the harassing supervisor Gareth Perrin terminated (or had

influence in the termination of) the Plaintiffs employment because of sexual animus and because

the Plaintiff opposed the harassment as alleged in her complaint.

35. The Plaintiff was terminated under circumstances that give rise to an inference of

discrimination. She was terminated by her supervisor who made prejudicial statements and

engaged in conduct that evidenced an animus towards women. Moreover, the Defendants lack of

reasons for termination give rise to the inference of pretext. The lack of reasons for termination is

in itself harassing in nature, cruel and unconscionable.

36. The ethical posture by the Defendants as displayed by the manner for which the Plaintiff

was supervised and managed is a violation of the spirit of one of its own mission statements. The

Commission failed an ethical duty to a public servant, the Plaintiff, and promoted Gareth Perrin

who lacks an understanding of his own employment and supervisory ethical obligations. The

agency through the supervisor Gareth Perrin show a lack of accountability and ethical conduct.

Page 8 of 9
 Case 1:17-cv-00649-DNH-CFH Document 1 Filed 06/15/17 Page 9 of 9

WHEREFORE, plaintiff respectfully requests that this court enter a judgment:

1. Declaring that the acts and practices of the agency as complained of herein are in violation

of Title VII of the Civil Rights Act of 1964 and constitute the basis for awarding back pay

with interest, compensatory damages, other lost benefits, and such other further relief as to

this Court seems just and proper.

2. Award to the Plaintiff Catherine Webb compensatory damages in each cause of action in an

amount to be proven at trial.

3. Award to the Plaintiff Catherine Webb exemplary damages in each cause of action in an

amount to be proven at trial.

4. Award plaintiff Catherine Webb the costs, disbursements and attorneys fees for the

prosecution of this matter along with such other and further relief as the Court may deem

just and proper.

DATED:
June 15, 2017 LAW OFFICE OF PATRICK SORSBY PLLC
By S/
Patrick Sorsby
Bar Roll No.: 517840
Attorney for Plaintiff
1568 Central Avenue
Albany, NY 12205
Phone: (518) 545-4529
E-mail: [email protected]

Page 9 of 9
 Case 1:17-cv-00649-DNH-CFH Document 1-1 Filed 06/15/17 Page 1 of 1

E1s= Fenn181(11116), U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

DISMISSAL AND NOTICE OF RIGHTS

To: Catherine Webb From: New York District Office
578 Tyrrel Road 33 Whitehall Street
Milibrook, NY 12545 5th Floor
New York, NY 10004

On behalf of person(s) aggrieved whose Identity Is

CONFIDENTIAL (29 CFR 1601.7(e))
EEOC Charge No. EEOC Representative Telephone No.
Holly M. Woodyard,
525-2016-00544 State & Local Program Manager (212) 336-3643
THE EEOC IS CLOSING ITS FILE ON THIS CHARGE FOR THE FOLLOWING REASON:
EDThe facts alleged In the charge fall to state claim under any of the statutes enforced by the EEOC.
a

ED Your allegations did not involve disability defined by the Americans With Disabilities Act.
a as

EDThe Respondent employs less than the required number of employees Is not otherwise covered by the statutes.
or

p Your charge to not timely filed with EEOC; in other words, you waited too long after the date(s) of the allege.d
was
discrimination file your charge
0 The EEOC issues the following determination: Based upon Its investigation, the EEOC is unable to conclude that the
information obtained establishes violations of the statutes, Thls does not certify that the respondent Is in compliance with
the statutes. No finding Is made as to any other Issues that might be construed as having been raised by this charge.

ElThe EEOC has adopted the findings of the state cr local falr employment practices agency that investigated thls charge.

13 Other (briefly state) Charging Party wishes to pursue matter In Federal District Court.

NOTICE OF SUIT RIGHTS

(See the additional Information attached to this form.)
Title VII, the Americans with Disabilities Act, the Genetic Information Nondiscrimination Act, or the Age
Discrimination in Employment Act: This will be the only notice of dismissal and of your right to sue that we will send you.
You may file a lawsuit against the respondent(s) under federal law based on this charge in federal or state court. Your
lawsuit must be filed WITHIN 90 DAYS of your receipt of this notice; or your right to sue based on thls charge will be
lost. (The time limit for filing suit based on a claim under state law may be different.)

Equal Pay Act (EPA): EPA suits must be filed In federal or state court within 2 years (3 years for willful violations) of the
alleged EPA underpayment. This means that backpay due for any violations that occurred more than 2 years (3 years)
before you file suit may not be collectible.

On bp,half of the Commission

Mar 17, 2017
Enclosures(s) Keviiii Berry,. (Date Mailed)
District Director
CC:

Attn: Director of Human Resources

Attn: Director of Human Resources
NEW YORK STATE JOINT COMMISSION Law Office of Patrick Soraby PLLC
ON PUBLIC ETHICS 1568 Central Avenue
540 Broadway Albany, NY 12205
Albany, NY 12202
 Case 1:17-cv-00649-DNH-CFH Document 1-2 Filed 06/15/17 Page 1 of 3

United States Equal Employment Opportunity Commission

CATHERINE WEBB,
Plaintiff

v. EEOC COMPLAINT

NEW YORK STATE JOINT COMMISSION ON PUBLIC

ETHICS,
Defendants

Based onthe assertions below I request that the EEOC take whatever action is necessary
against the above named individual Defendants to vindicate my rights under Federal and New
York State Law for discrimination based on a disability.
By submitting this statement I am intending to activate the EEOC's administrative
process to investigate the charges made, to provide the employer notice of this charge, to provide
an opportunity for conciliation before suit if
possible and to take whatever action is necessary to
vindicate my rights under Federal and New York State Law.

CATHERINE WEBB asserts the following:

1. My name is CATHERINE WEBB.

2. My current address is 578 TYRREL ROAD, MILLBROOK, NY 12545. All mail should
be sent to this address and I would ask that all mail on my case also be sent to my New
York Attorney identified hereinafter and that my case be venued before the EEOC in
New York State where I have my permanent address, where the events occurred, where
the Defendant NEW YORK STATE JOINT COMMISSION ON PUBLIC ETHICS is located.

3. My attorney Patrick Sorsby's address is: Law Office of Patrick Sorsby PLLC, 1568
Central Avenue, Albany, New York 12205

4. The name of my former employer is NEW YORK STATE JOINT COMMISSION ON PUBLIC
ETHICS ("JCOPE").

5. The STATE OF NEW YORK together with the NEW YORK STATE JOINT COMMISSION ON
PUBLIC ETHICS employs in excess of 500 employees.
 Case 1:17-cv-00649-DNH-CFH Document 1-2 Filed 06/15/17 Page 2 of 3

6. NEW YORK STATE JOINT COMMISSION ON PUBLIC ETHICS, is an agency of the STATE
OF NEW YORK and has a principle place of business located at 540 Broadway, in the
City and County of Albany, New York.

7. I began my employment at NEW YORK STATE JOINT COMMISSION ON PUBLIC ETHICS in

2014 in the capacity of a Forensic Financial Auditor/Examiner.

8. From the commencement of my employment until January 26, 2016 I had a satisfactory
work record with great annual evaluations, receiving the highest evaluation possible.

9. From June 2014 to February 2015 a coworker by the name of Gareth Perrin (herein after
"Perrin") began to harass me by making misogynistic comments to me on a fairly regular
basis.

10. In March of 2015 Gareth Perrin was promoted by my current supervisor Martin Levine
whereby he became my supervisor. Mr. Levine was informed that it would not be
appropriate to promote Perrin as my supervisor because I had just endured a period of
gender based harassment by him. Nonetheless in spite of being put on notice of this
gender discrimination Mr. Levine still promoted Perrin providing him with greater
control over me.

11. Starting in May of 2015 supervisor Perrin began using misogynistic comments again but
this time they weren't just comments but insults.

12. In August of 2015 I requested a meeting with Chief of Staff Monica Stamm wherein I
requested if I could physically move my office from Supervisor Perrin. Monica stated
that she could not do anything until they hired a new executive director. She further
added that "I have a job until then" (meaning until a new director is hired).

13. In December of 2015 I watched a "sexual harassment" video and a "violence in the
workplace" video and realized that many of the situations portrayed in the video were
very similar to what I had been experiencing with Perrin at JCOPE. In the video, we
learned that every government agency in NY State has a person who is designated to be
the "special person" in charge of handling these kinds of issues. So, I went to our HR
specialist, Steve Boland, and asked who that person is for JCOPE. He looked it up and
told me that it was Kevin Gagan the new Executive Director of JCOPE.

14. The very next day, I was summoned to HR specialist Steve Boland's office to meet with
director Gagan who wanted to know why I had inquired about him with Steve the
previous afternoon. So, I explained that I recognized the similarities between some of the
situations portrayed in the videos and my own experiences with Perrin. Kevin then said
"well, we have to have an investigation then".
 Case 1:17-cv-00649-DNH-CFH Document 1-2 Filed 06/15/17 Page 3 of 3

15. Approximately two weeks following this meeting, I was called into a conference room to
meet with JCOPE investigators' Patrick Coulson and Stacey Hamilton for the
"investigation". Stacey essentially asked me to "tell the story" from the beginning and I
did. Both Pat and she kept copious notes as I spoke. The meeting concluded almost two
hours later. I was aware that in the following days, both supervisor Perrin and another
coworker Taryn were taken into the same conference room for questioning, presumably
for the "investigation".

16. On January 21 2016 I was asked by Director Gagen to come down to HR specialist Steve
Boland's office. I took a seat and Director Gagen said "we have some bad news, we are
going to have to let you go. Really nothing else to say, decision has been made....Pat
(from Investigations) will walk you out to your car".

17. I neverreceived or was in any way informed about the result of the investigation of
Sexual harassment by Supervisor Perrin.

18. I believe that Supervisor Perrin's conduct created a hostile work environment based on
gender because he engaged in verbal conduct of a sexual nature which was severe and
pervasive and culminated in my termination. My employer New York State is liable for
his conduct because I reported it and because he was my supervisor. I believe this is
discrimination in violation of Title VII and New York State Human Rights Law.

19. I believe that the Defendant Retaliated against me when they terminated me within
weeks of reporting what believed to be sexual harassment without any stated reason. My
work record is more than satisfactory and I have received great annual reviews. So
although they gave me no reason for termination any reason they come up with will be
pretext for retaliation.

Date:
`11/3, 2016

.41Wlf%^
CA I RINE WEBB

TO:
Equal Opportunity Commission
6 Fountain Plaza
Suite 350
Buffalo, NY 14202

3
JS 44 (Rev. 12/12)
Case 1:17-cv-00649-DNH-CFH Document 1-3 Filed 06/15/17 Page 1 of 2
CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

NY State Joint Commission on
CATHERINE WEBB Public Ethics "JCOPE"

(b) County of Residence of First Listed Plaintiff Dutchess County County of Residence of First Listed Defendant Albany
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Law Office of Patrick Sorsby PLLC, 1568 Central Avenue, Albany NY,
518-545-4529

II. BASIS OF JURISDICTION (Place an X in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
IV. NATURE OF SUIT (Place an X in One Box Only)
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 400 State Reapportionment
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 410 Antitrust
140 Negotiable Instrument Liability 367 Health Care/ 430 Banks and Banking
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 450 Commerce
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 460 Deportation
151 Medicare Act 330 Federal Employers Product Liability 830 Patent 470 Racketeer Influenced and
152 Recovery of Defaulted Liability 368 Asbestos Personal 840 Trademark Corrupt Organizations
Student Loans 340 Marine Injury Product 480 Consumer Credit
(Excludes Veterans) 345 Marine Product Liability LABOR SOCIAL SECURITY 490 Cable/Sat TV
153 Recovery of Overpayment Liability PERSONAL PROPERTY 710 Fair Labor Standards 861 HIA (1395ff) 850 Securities/Commodities/
of Veterans Benefits 350 Motor Vehicle 370 Other Fraud Act 862 Black Lung (923) Exchange
160 Stockholders Suits 355 Motor Vehicle 371 Truth in Lending 720 Labor/Management 863 DIWC/DIWW (405(g)) 890 Other Statutory Actions
190 Other Contract Product Liability 380 Other Personal Relations 864 SSID Title XVI 891 Agricultural Acts
195 Contract Product Liability 360 Other Personal Property Damage 740 Railway Labor Act 865 RSI (405(g)) 893 Environmental Matters
196 Franchise Injury 385 Property Damage 751 Family and Medical 895 Freedom of Information
362 Personal Injury - Product Liability Leave Act Act
Medical Malpractice 790 Other Labor Litigation 896 Arbitration
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 791 Employee Retirement FEDERAL TAX SUITS 899 Administrative Procedure
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: Income Security Act 870 Taxes (U.S. Plaintiff Act/Review or Appeal of
220 Foreclosure 441 Voting 463 Alien Detainee or Defendant) Agency Decision
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 871 IRSThird Party 950 Constitutionality of
240 Torts to Land 443 Housing/ Sentence 26 USC 7609 State Statutes
245 Tort Product Liability Accommodations 530 General
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION
Employment Other: 462 Naturalization Application
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration
Other 550 Civil Rights Actions
448 Education 555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an X in One Box Only)
1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation
(specify)
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
Title VII of the Civil Rights Act of 1964, as amended, codified at 42 U.S.C. 2000e et seq.,
VI. CAUSE OF ACTION Brief description of cause:
Discrimination based on gender including hostile work environment and termination, retaliation.
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
06/15/2017 S/
FOR OFFICE USE ONLY
0206-4043108 $400.00 DNH CFH
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Print Save As... Case No.: 1:17-CV-0649 Reset

JS 44 Reverse (Rev. 12/12) Case 1:17-cv-00649-DNH-CFH Document 1-3 Filed 06/15/17 Page 2 of 2
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.

IV. Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is
sufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more than
one nature of suit, select the most definitive.

V. Origin. Place an "X" in one of the six boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407.
When this box is checked, do not check (5) above.

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service

VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.

Date and Attorney Signature. Date and sign the civil cover sheet.