Objection to motion to dismiss — Brown v. Azar (N.D. Ga.)

Summary

A pro se objection to a motion to dismiss with prejudice filed by Kimberly Brown against HHS Secretary Alex Azar in the U.S. District Court for the Northern District of Georgia, Case 1:19-cv-02152-LMM, filed 08/23/19 as Document 6. It lists her allegations of a hostile workplace at the agency from March 20, 2014 through her departure on September 6, 2014, including an AWOL charge that she says was reversed on December 18, 2014. It says that on the same day she received a letter of caution about unscheduled leave, which she calls retaliation, and was placed on a detail in the file room while her complaint was processed. It names supervisors Dawne Hines and Vincent Williams.

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FILED IN CLERK’S OFFICE
U.S.D.C. - Atlanta
S
~
AUG 232019
~:
UNITEDSTATESDISTRICTCOURT
~‘
For the
JAMES
. HATTEN, Clerk
NORTHERN District of GEORGIA
By:
Deputy Clerk
KIMBERLY BROWN
I
333 Nelson Street
I
Unit 221
I
CIVIL ACTION FILE NO.
Atlanta, GA 30313
I
1:19-cv-@a%et-LMM
V.
I
HONORABLE ALEX AZAR
I
SECRETARY, UNITED STATES
I
DEPARTMENT OF HEALTH AND
I
HUMAN SERVICES
I
OBJECTION TO MOTION TO DISMISS WITH PREJUDICE
1.
The ongoing hostile workplace lasted from March 20, 2014, through Plaintiff’s departure from
the Agency, September 6, 2014.
2.
Plaintiff was charged AWOL on March 20, 2014, in spite of a medical note from Plaintiffs doctor,
and statement from 3 of the Plaintiffs associates(disclosing personal medical information).
3.
Plaintiff disputed AWOL charge immediately.
4.
Plaintiff discussed an EEOC complaint with her supervisor, Dawne Hines, who said “she’d rather
we worked things out”.
5.
Plaintiff was dissuaded from filing an actual complaint with EEO.
6.
Plaintiff felt intimidated by Vincent Williams, and Dawne Hines.
7.
Plaintiff discussed the tension with Dawne Hines, who dismissed the issue.
8.
A complaint was filed.
9.
AWOL charge was reversed on December 18, 2014, after 9 months of being in a hostile
environment.
10. On December 18, 2014, Plaintiff was ambushed by supervisory staff, and issued a “Letter of
Caution: Excessive Unscheduled Leave, for 3 incidents that happened over a year prior to the
issuance of said letter.(retaliation).
11. Plaintiff was placed on a 3 month detail, in the File Room, that lasted 9 months, “while plaintiffs
complaint was processed”.
12. Plaintiff was asked to “recertify” disabilities with the Agency, even though Plaintiffs disabilities
were certified with her application for employment.
13. Plaintiff was belittled and harassed forthe remainderof employment.
14. Dawne Hines did nothing to diffuse the situation.
15. Vincent Williams and the plaintiff did not speak for approximately 18 months.
Case 1:19-cv-02152-LMM   Document 6   Filed 08/23/19   Page 1 of 2

been sent to Defendant and the District Court on August 23, 2019
Plaintiff
Case 1:19-cv-02152-LMM   Document 6   Filed 08/23/19   Page 2 of 2

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