The five-count complaint names Metro Animal Services Director Dr. Gilles
Meloche and incoming interim director Wayne Zelinsky as co-defendants.
According to the suit, just after then-Sen. Hillary Clinton defeated Sen. Barack
Obama in Kentucky's Democratic primary in May 2008, Meloche told Simpson
"These rednecks would rather have [an obscene word referring to female
genitalia] than a [racial epithet]."

The complaint states that when Simpson expressed her outrage at those
remarks, Meloche repeated the comments and apparently thought himself
amusing.

Simpson's complaint also accuses Meloche of multiple instances of
inappropriate touching, including a claim of Meloche suggestively sticking his
finger in Simpson's stomach.

When Simpson complained to Assistant Director Wayne Zelinsky, the
complaint claims Zelinsky responded, "Our fearless leader doesn't understand
the concept of personal space."

In another instance, the complaint claims Meloche commented on Simpson's
legs and said she should show them off more often, and that Zelinsky's
response was to say, "Look how her face is getting red."

On Tuesday, Louisville Mayor Jerry Abramson announced Meloche's
resignation as director of Metro Animal Services effective Dec. 31. Zelinsky will
become interim director.

"It's astounding," Grafton said. "It's having the fox watch the hen house."
According to the complaint, Meloche repeatedly told Simpson and other animal
services workers about his tight relationship with the mayor in an effort to
prevent any complaints, and on multiple occasions referred to that relationship
being like "gay love."

The complaint also states when Simpson did file a complaint with metro
government, Zelinsky told her when this is all done, he hoped she could sleep at
night.

Then, because of Simpson's complaint, which ended in a written reprimand for
Meloche's personnel file, the lawsuit says Meloche and Zelinsky retaliated
against Simpson.