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Denton County Lawsuit

Denton County Lawsuit

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Published by Eric Nicholson

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Published by: Eric Nicholson on Jun 26, 2012
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01/06/2014

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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASSHERMAN DIVISIONNADIYA WILLIAMS-BOLDWARE§Plaintiff§§v.§§DENTON COUNTY, TEXAS,§No._______________DENTON COUNTY CRIMINAL§DISTRICT ATTORNEY, CARY§PIEL, SUSAN PIEL and§RYAN CALVERT§Defendants§PLAINTIFF'S ORIGINAL COMPLAINT
Plaintiff, NADIYA WILLIAMS-BOLDWARE, files her Original Complaint againstDefendants, Denton County, Texas, Denton County Criminal District Attorney,Cary Piel, Susan Piel and Ryan Calvert (collectively “Defendants”).
PARTIES
1. Plaintiff, Nadiya Williams-Boldware (“Boldware”), is a Texas resident, living inMcKinney, Texas.2. Defendant, Denton County, Texas (the “County”), is a governmental entity thatcan be served under Rule 4(j)(2) of the Federal Rules of Civil Procedure by servingCounty Judge Mary Horn at 110 West Hickory Street, 2nd Floor, Denton, Texas76201-4168.3. Defendant, Denton County Criminal District Attorney (“DA”), is a governmentalentity that can be served under Rule 4(j)(2) of the Federal Rules of Civil Procedureby serving Denton County Criminal District Attorney Paul Johnson at 1450 EastMcKinney, 3rd Floor, Denton, Texas 76201.4. Defendant, Assistant District Attorney Cary Piel (“Cary Piel”), is a Texasresident who may be served with process at 1450 East McKinney, 3rd Floor,
PLAINTIFF'S ORIGINAL COMPLAINTPAGE 1
Case 4:09-cv-00591-RC-ALM Document 1 Filed 12/01/09 Page 1 of 17 PageID #: 1
 
Denton, Texas 76201 or his residence of 2408 Cavendish Lane, Argyle, Texas76226-1586.5. Defendant, Assistant District Attorney Susan Piel (“Susan Piel”), is a Texasresident who may be served with process at 1450 East McKinney, 3rd Floor,Denton, Texas 76201 or her residence of 2408 Cavendish Lane, Argyle, Texas76226-1586.6. Defendant, Assistant District Attorney Ryan Calvert (“Calvert”), is a Texasresident who may be served with process at 1450 East McKinney, 3rd Floor,Denton, Texas 76201 or his residence of 4808 Sabine Street, Fort Worth, Texas76137-5688.
 JURISDICTION
7. This Court has subject matter jurisdiction over this action under 28 U.S.C. §1331 because this action arises under Title VII of the Civil Rights Act of 1964, 42U.S.C. § 2000(e), 42 U.S.C. § 1981, and 42 U.S.C. § 1983.8. Denton County, Texas and the Denton County Criminal District Attorney areemployers within the meaning of the above statutes because they employeefifteen or more employees for each working day in each of twenty or morecalendar weeks.9. Ms. Boldware has performed all conditions precedent to bringing this lawsuitand all claims asserted herein as the law requires.
VENUE
10. Venue is proper in the Eastern District of Texas, Sherman Division, under 28U.S.C. § 1391 because Defendants reside or are located within the judicial districtof this Court.
PLAINTIFF'S ORIGINAL COMPLAINTPAGE 2
Case 4:09-cv-00591-RC-ALM Document 1 Filed 12/01/09 Page 2 of 17 PageID #: 2
 
FACTS
11. Ms. Boldware is an African-American female presently employed by theDenton County Criminal District Attorney. Ms. Boldware began such employmenton February 28, 2007.12. At all times during her employment with the Denton County Criminal DistrictAttorney, Ms. Boldware has been an Assistant District Attorney assigned to theMisdemeanor Trial Division with her job duties defined as representing the Stateof Texas in pending criminal misdemeanor matters.13. At all times during her employment with the Denton County Criminal DistrictAttorney, Ms. Boldware has been supervised by Paul Johnson, Elected CriminalDistrict Attorney (supervisor to all staff), Jamie Beck, First Assistant DistrictAttorney (supervisor to all staff other than Paul Johnson) and Defendant SusanPiel, Misdemeanor Trial Division Chief (supervisor to all prosecutors assigned tothe Misdemeanor Trial Division). Defendant Susan Piel is also the wife of Defendant Cary Piel and the sister of Defendant Ryan Calvert believed to be theperson best suited to understand the racist-belief motivated behavior of herhusband and her brother upon Plaintiff. Defendant Susan Piel is Plaintiff's directsupervisor.14. On or about April 2, 2009, Defendant Cary Piel came into Plaintiff's office atthe Denton County Criminal District Attorney's Office to discuss a case that hewas preparing for trial. The pending case involved a criminal defendant by thename of Bagley, an African-American female.15. The Bagley case was to be heard before a local State district judge.Defendant Cary Piel explained that after viewing the tapes from the arrest of Bagley he had never been so enraged. He further state that it made him“understand why people hung people from trees” (referencing lynchingsperformed in the past by members of the Ku Klux Klan). Defendant Cary Pielcontinued to elaborate by stating that the conduct of Bagley made him “want to
PLAINTIFF'S ORIGINAL COMPLAINTPAGE 3
Case 4:09-cv-00591-RC-ALM Document 1 Filed 12/01/09 Page 3 of 17 PageID #: 3

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