Declaration of Kiara Moore in Support of Plaintiff’s Motion for Attorneys’ Fees and Reimbursement of Expenses — Kiara Moore v. Mount Zion Baptist Church (Dkt. 63, M.D. Tenn.)

Summary

A declaration of plaintiff Kiara Moore in support of the plaintiff's motion for attorneys' fees and reimbursement of expenses, in Kiara Moore v. Mount Zion Baptist Church, Joseph W. Walker, III, and Stephaine Walker, Case No. 3:22-cv-00965, in the U.S. District Court for the Middle District of Tennessee, filed November 17, 2023 as Document 63. Moore states that she began attending Mount Zion as a parishioner in 2009, was offered a position in its Health and Wellness ministry, began working for the church in January 2016, reporting to Dr. Stephaine Walker. Moore submits the declaration in support of her attorneys' request for fees and costs and praises the result counsel achieved. The four-page declaration is dated November 16, 2023 and made under penalty of perjury.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Record facts

Full text

Text recognized from a scanned document; may contain errors.

UNITED STATES DISTRICT COURT

                   FOR THE MIDDLE DISTRICT OF TENNESSEE

                                NASHVILLE DIVISION

 KIARA MOORE,                               )   Case No. 3:22-cv-00965
                                            )
        Plaintiff,                          )
                                            )   Judge Trauger
                     Vv.                    )
                                            ) DECLARATION OF KIARA MOORE IN
 MOUNT ZION BAPTIST CHURCH,                 )   SUPPORT OF PLAINTIFF’S MOTION FOR
 JOSEPH W. WALKER, III, and                 )   ATTORNEYS’ FEES AND REIMBURSEMENT
 STEPHAINE WALKER,                          )   OF EXPENSES
                                            )
        Defendant.                          )

       I, Kiara Moore, the Plaintiff in the above-referenced matter, declare as follows:

       1.    I am over the age of 18, and the following facts are within my personal

knowledge and, if called as a witness, I can and will testify competently.

       2.    I submit this Declaration in support of my attorneys’ request for attorney’s fees

and reimbursement of costs.

       3.    I began attending Mount Zion as a parishioner in 2009. In 2015, Dr. Walker

contacted me to discuss the potential for Mount Zion to hire me into the Health and Wellness

ministry led by Dr. Walker. Upon receiving an offer, I became even more excited at the chance

to merge two worlds that I was, and remain, passionate about: public health and ministry.

       4.    I began working for Mount Zion Baptist Church in January 2016. Throughout my

employment with Mount Zion, I have reported to Dr. Stephaine Walker.

       5.    In March 2020, I gave birth to my daughter, K.M. She was diagnosed with Sickle

Cell Disease a short time thereafter.

       6.    In December 2020, my daughter was hospitalized for the very first time due to

complications from her disease.

DECLARATION OF KIARA MOORE IN SUPPORT OF PLAINTIFF’S                         Page | of 4

MOTION FOR ATTORNEYS’ FEES AND REIMBURSEMENT OF EXPENSES
 Case 3:22-cv-00965 Document63_ Filed 11/17/23. Page 1of 4 PagelD #: 1059

7. In early January 2021, Mount Zion informed me that my full-time salaried role
was being reduced to part-time, that I would become an hourly employee making $22.57 per
hour and I would no longer be eligible for healthcare benefits that were provided by the church.
This part-time role capped my hours at 20 per week.

8. Prior to this, my base salary was approximately | per year. After I went
part-time, I made approximately half of what I made before the Adverse Employment Action.

9. On November 1, 2021, I filed a charge (No. 494-2021-02248) with EEOC
alleging that Mount Zion Baptist Church discriminated against me because of my relationship
with my daughter.

10. _—_ Before filing the charge, I contacted four Nashville-based law firms about
representing me against Mount Zion. They all declined, and so I filed the charge without
representation.

11. In November 2021, I contacted Will Harris about representing me. I had not
worked with Mr. Harris before then, but I heard that he represented employees against big
companies in the past on contingency.

12. When he did agree to represent me on a contingency, frankly, I was relieved for a
couple of reasons. First, I am not sure I would have continued to pursue my claims against such
powerful people without representation. Second, I certainly could not afford to pay Mr. Harris, or
anyone else, an hourly rate or any money up front.

13. = After I filed my first EEOC charge, my work environment deteriorated. After
first allowing me to keep my health insurance benefits after I went part-time, Mount Zion
terminated those benefits and backdated the termination to the month I filed my first charge. I
only discovered this when I took my daughter to the doctor. I was devastated. I leaned on my
attorneys, who clearly explained my options, and assisted me with filing a retaliation charge with
the EEOC on March 7, 2022 (No. 494-2022-01323).

14. This experience has taken a tremendous toll on me. It has forever changed my

outlook on life, how I trust and confide in people, and how I navigate my professional, personal,

DECLARATION OF KIARA MOORE IN SUPPORT OF PLAINTIFF’S Page 2 of 4

MOTION FOR ATTORNEYS’ FEES AND REIMBURSEMENT OF EXPENSES
Case 3:22-cv-00965 Document63 _ Filed 11/17/23 Page 2 of 4 PagelD #: 1060

and spiritual life in light of my daughter’s disability. Despite this, I remained in my role until
October 24, 2023, in part because I wanted to keep the defendants honest in discovery and force
them to produce relevant documents that I knew existed. For instance, during my case, I was able
to discover that someone from Mount Zion tried to delete relevant emails from my work email
account. I alerted my attorneys and they immediately addressed and resolved the issue.

15. | Mycontinued employment came at a cost to my personal, and spiritual well-
being. Because of this, I wanted my attorneys to resolve my case as quickly and beneficially for
me and my family as possible. So in July, when the possibility of mediation and settlement came
up, I was excited about potentially putting this nightmare behind me then.

16. Throughout my lawsuit, and even when my charges were being investigated by
the EEOC, my primary attorney, Mr. Harris, has always made himself available to me, day or
night, even while he was traveling. For example, when he was traveling with his family in
Australia, he agreed to speak with me at 3:30am local time. On several occasions, Mr. Harris and
Mr. Wagenleitner accommodated my requests to meet after 9pm local time so that I could feed
my children and put them to bed before working with them on my case.

17. Mr. Harris never turned me away when I had questions, no matter how busy he
was. I had a lot of questions, especially during the EEOC phase of my case when I was scared
and did not fully understand the process. He always took the time to communicate to me exactly
what was going on in my case, which made me feel empowered and in charge of the direction of
my lawsuit. On average, Mr. Harris and I spoke twice per week. We had calls or conferences
ranging in length from 5 minutes to over 2 hours. By my very unofficial count, over the last two
years, I have spent about 107 hours working with my attorneys on my case.

18. Mr. Harris and his colleagues thoroughly explained to me exactly what to expect
in the discovery process, including how depositions work, and walked me through what
information I had to give to the other side. Because of my knowledge of Mount Zion’s systems
and internal procedures, I also worked closely with them to make sure we requested and received

information from defendants that would help my case.

DECLARATION OF KIARA MOORE IN SUPPORT OF PLAINTIFF’S Page 3 of 4

MOTION FOR ATTORNEYS’ FEES AND REIMBURSEMENT OF EXPENSES
Case 3:22-cv-00965 Document63_ Filed 11/17/23. Page 3 of 4 PagelD #: 1061

19. In September, when Defendants expressed serious interest in settling my case, Mr.
Harris and his team moved quickly. Mr. Harris even changed his international travel plans to
come to Nashville to try and resolve my case.

20. On October 18, 2023, I participated in a mediation with Defendants. Throughout
that process my attorneys made sure I understood my rights and the process, which again, made
me feel empowered. Even when I became overwhelmed with emotion, my attorneys supported
me in a way I was not expecting, but certainly appreciated.

21. | What was clear to me during the mediation, and throughout the entirety of my
case, was that my attorneys genuinely cared about me as a person and what I went through
during my employment with defendants. I felt like that motivated them to fight for me.

22. After over ten hours of mediation, and in consultation with my attorneys, I settled
my case. I signed the settlement agreement on October 24, 2023.

23. I really struggle to find the words that accurately capture, just how much I
appreciate Mr. Harris, Mr. Ryan Wagenleitner and Mr. Chris Sabis.

24. It is my sincere hope that you will reward my attorneys for their hard and
excellent work on my behalf. What they achieved for me is truly something I did not think was
possible.

I declare under penalty of perjury that the foregoing is true and accurate. Executed this

16th day of November, 2023, in Rutherford County, Murfreesboro, Tennessee.

Dated: November 16, 2023 Respectfully Submitted,

Kiara Moore

Plaintiff

DECLARATION OF KIARA MOORE IN SUPPORT OF PLAINTIFF’S Page 4 of 4

MOTION FOR ATTORNEYS’ FEES AND REIMBURSEMENT OF EXPENSES
Case 3:22-cv-00965 Document63_ Filed 11/17/23. Page 4 of 4 PagelD #: 1062

File and source

File

gov.uscourts.tnmd.92679.63.0.pdf

Size

115,465 bytes

SHA-256

c99af01bc76e928d7f605b78e37ebe41dfed6469f970316692f4d1e475f3b7e3

Our copy

gov.uscourts.tnmd.92679.63.0.pdf

Original

archive.org