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Cusic Complaint

Cusic Complaint

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Published by josephlord
Lawsuit filed Tuesday.
Lawsuit filed Tuesday.

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Published by: josephlord on Oct 01, 2013
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02/17/2014

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COMMONWEALTH OF KENTUCKYFRANKLIN CIRCUIT COURTCASE NO. ____________  NICOLE CUSICPLAINTIFFvs.
VERIFIED COMPLAINT
LEGISLATIVE RESEARCH COMMISSION,Serve:Hon. Jack ConwayOffice of the Attorney General700 Capital Avenue, Suite 118Frankfort, Kentucky 40601BOBBY SHERMAN,Serve:Bobby Sherman214 Delaplain RoadWinchester, KY 40391-9264andWILL COURSEY DEFENDANTSServe:Will Coursey702 Capitol AveAnnex Room 351AFrankfort KY 40601
 
* * * * * * *Come the Plaintiff 
, Nicole Cusic (“Nicole”), by counsel, and for her VerifiedComplaint against the Defendants,
Legislative Research Commission ("LRC"), BobbySherman (“Sherman”), and Will Coursey
(“Coursey”) (collectively the “Defendants”),
stateas follows:
THE PARTIES
1.The Plaintiff, Nicole, is and was at all relevant times hereto, a resident of theCommonwealth of Kentucky and employed by the LRC.2.The Defendant, the LRC, is an agency of the legislative branch of state
 
government and was created by KRS Chapter 7. LRC has its principal office is located inFrankfort, Kentucky.3.The Defendant, Sherman, is and was at all relevant times hereto, a resident of theCommonwealth of Kentucky and the director of the LRC.4.The Defendant, Will Coursey, is and was at all relevant times hereto, aDemocratic Kentucky state Representative.
JURISDICTION & VENUE
5.This Court has original jurisdiction over this action pursuant to KRS 23A.010.6.Venue is proper in this Court pursuant to KRS 452.460(1).
FACTS
7.Plaintiff, Nicole, is employed by the LRC and currently serves as a secretary inthe Senate.8.Upon information and belief, on or around November of 2012, Coursey wasengaging in sexually harassing behavior toward interns and LRC employees.9.Upon information and belief, Coursey's conduct was a topic of discussion amonginterns, LRC employees, and other representatives.10.Out of concern for Coursey, Nicole notified Coursey of his inappropriate conductand how it was drawing comments from other interns, representatives, and LRC employees.11.After Nicole made a good faith complaint to Coursey, Coursey quitcommunicating with Nicole and started complaining about Nicole's work performance.2
 
12.Upon information and belief, Coursey went to Representative Greg Stumbo'soffice requesting that Nicole be transferred to another representative.13.Prior to Nicole being transferred, Nicole was removed from Coursey's office and placed in a separate office, where she sat for about one month with no work.14.Cusic was later advised by former LRC Director, Bobby Sherman, that Nicolewas being transferred to the Senate.15.Thereafter, Nicole was transferred from her position as a secretary for ademocratic House of Representative to a secretary for a republican Senator.16.Defendants' actions have resulted in Nicole being shunned at work, feelinghumiliated as well as degraded, alienated, and constantly uncomfortable at work.
COUNT IViolation of KRS 344.280(Retaliation)
17.The Plaintiffs incorporate by reference, as if set forth fully herein, each and everyaverment, allegation, or statement contained in the previous paragraphs of this VerifiedComplaint.18.During Nicole’s employment with LRC, Sherman and Coursey conspired andretaliated against Nicole for making a complaint against Coursey regarding his sexuallyharassing behavior.19.Sherman and Coursey were both aware of Nicole’s complaint against Coursey.20.As a result of Nicoles complaint, Sherman and Coursey subjected her to theabove-described adverse treatment.21.As a direct and proximate result of the aforementioned conduct, Nicole suffered3

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