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BRUBAKER v. BARRETT ET AL Complaint

BRUBAKER v. BARRETT ET AL Complaint

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Published by: ACELitigationWatch on Nov 17, 2010
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Case 3:10-cv-00477   Document 1    Filed 11/12/10   Page 1 of 10   PageID #: 1
IN
THE UNITED STATES DISTRICT
COURT FOR
THE EASTERN
S E C ~ t 
<h
E 0
TENNESSEE
AT
KNOXVILLE
NOV
121010
JAMIE BRUBAKER,
Cler:k,
U. S.
District CourtEastern District
of
Tennessee
Plaintiff,
At
Knoxville '
v.
Docket No.:
:f
:)Q=:C1f--
4'7'7
MICHAEL DAVID BARRETT,
Jury
Trial Demanded.
COMBINED INSURANCE COMPANY OF AMERICA,
pIli
~
nO
;
{)
~
l
S
V t J . - ( t ~ 
AON
INSURANCE MANAGEMENT SERVICES, INC.
Y
~
J
l
Defendants.COMPLAINT FOR DAMAGESComes the Plaintiff,
by
and through
undersigned counsel,
and
for her Complaintfor civil damages against the Defendants, jointly
and
severally,
would
state to thisHonorable
Court
as follows:PARTIES
1.
Plaintiff, Jamie Brubaker, is a citizen
and
resident of Tennessee, residing
in
Knox County, Tennessee;
2.
Defendant, Michael David Barrett, is believed
to
be a citizen
and
residentof Westmont, Illinois, 60606;
3.
Defendant, Combined Insurance
Company
of America, has itsheadquarters located
at
1000
North
Milwaukee Avenue, Glenview, Illinois, 60025;
1
 
Case 3:10-cv-00477   Document 1    Filed 11/12/10   Page 2 of 10   PageID #: 2
4.
Defendant, AON Insurance Management Services Inc.,
has
itsheadquarters located
at
200
East Randolph Street, Chicago, Illinois 60601;JURISDICTION
&
VENUE
5.
Jurisdiction is
proper
before this Honorable
Court
as the parties herein arecompletely diverse providing
proper
jurisdiction
in
this court
pursuant
to
28
U.S.C.
§
1332. Further jurisdiction
and
venue
is
proper
before this Honorable
Court
as the
amount in
controversy exceeds $75,000;FACTS GIVING
RISE
TO CAUSE OF ACTION
6.
Plaintiff
was
employed
by
Combined Insurance
Company
of America(hereinafter, "Combined")
in
February of
2002;
7.
Plaintiff resigned
her
position from Combined
to
accept a job
with New
York Life until June 2005
whereupon
Plaintiff took a job
with
Waddle
&
Reed until July2006;
8.
Plaintiff
was
re-employed by Combined
on
July 2006
in
the Life
Health
Division. The
purpose
was
to build a successful branch of this division over the Statesof Wyoming
and
Montana -Plaintiff
was promoted
to Branch Manager
on
December of2006;
9.
Co-Defendant, Michael David Barrett (hereinafter, "Barrett"),
was
alsoemployed
at
Combined
at
all relevant times herein
and
was
the ExecutiveAdministrator over the Life Health Division of Combined;
2
 
Case 3:10-cv-00477   Document 1    Filed 11/12/10   Page 3 of 10   PageID #: 3
10. As
part
of Barrett's position as Executive Adnlinistrator over the LifeHealth Division Barrett
was
to oversee all other administrative assistants of the Life
Health
Division,
which
included the Plaintiff;11. In January of 2007, Plaintiff attended a Branch Managers Congress
in
Chicago, Illinois where she
met
Barrett for the first time;12.
In
April of 2007, Plaintiff
was
required
by
Combined to
attend
Jet
VI
Training
in
Chicago, Illinois. Plaintiff
was
provided
a
room
a the Hilton
by
Combined
where
the training conferences were conducted
by
Barrett;13.
In August
of 2007, Combined conducted a contest
with
all the branchmanagers
in the
Life
Health
Divisions. Barrett
bet
the other divisional managers
and
picked the Plaintiff
and
her
team
to represent his division;14. Also
in August
of 2007, Plaintiff
was
required by Combined to
attend
a
third
phase of the Jet
VI
training
in
Chicago, Illinois. Plaintiff
saw
Barrett
at
the
hotel
on
several occasions
during
this training event;15. That
during
this same time Plaintiff
began
achieving records
in
sales.
Due
to Plaintiff's success Barrett insisted
that
she be written
up
in
the Combined
Company
paper. Thereafter, Plaintiff continued achieving excellent sales for Combined Barrettinsisted Plaintiff be written
up
in
the Combined
Company
paper
only this time
with
her
picture included;16. As
part
of
standard
operating procedures
with
Combined Plaintiff
would
have a roommate
when
she attended seminars
and
business trips which required travel
3

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