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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION RICHARD BOONE II, COURIE BRYANT GARY DOLLAR, JASON GORDON, JAMES GROOM, RYAN PAYNE, RODERICK ROBINSON and JAMES WHITE, Plaintiffs, Civil Action No. CITY OF RED OAK, TEXAS and CRAIG RUDOLPH, Individually, Defendants. PLAINTIFFS' ORIGINAL COMPLAINT Plaintiffs RICHARD BOONE II, COURIE BRYANT, GARY DOLLAR, JASON GORDON, JAMES GROOM, RYAN PAYNE, RODERICK ROBINSON and JAMES WHITE (collectively "Plaintiffs") le this Original Complaint against Defendant CITY OF RED OAK, TEXAS and Defendant CRAIG RUDOLPH in his Individual Capacity ("Rudolph")(collectively "Defendants"), and would show as follows: A. Parties 1. Plaintiff RICHARD BOONE II ("Boone") brings this action individually. Plaintiff Boone resides in Ellis County, Texas and is employed by Defendant City as a police ofcer. 2. Plaintiff COURIE BRYANT ("Bryant") brings this action individually. Plaintiff Bryant resides in Ellis County, Texas and is employed by Defendant City as a police ofcer. 3. Plaintiff GARY DOLLAR ("Dollar") brings this action individually. Plaintiff Dollar resides in Ellis County, Texas and is employed by Defendant City as a police ofcer.
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4. Plaintiff JASON GORDON ("Gordon") brings this action individually. Plaintiff Gordon resides in Ellis County, Texas and is employed by Defendant City as a police ofcer. 5. Plaintiff JAMES GROOM ("Groom") brings this action individual. Plaintiff Groom resides in Dallas County, Texas and was previously employed by Defendant City as a police ofcer. 6. Plaintiff RYAN PAYNE ("Payne") brings this action individually. Plaintiff Payne resides in Ellis County, Texas and is employed by Defendant City as a police ofcer. 7. Plaintiff RODERICK ROBINSON ("Robinson") brings this action individually. Plaintiff Robinson resides in Dallas County, Texas and is employed by Defendant City as a police ofcer. 8. Plaintiff JAMES WHITE ("White") brings this action individually. Plaintiff White resides in Ellis County, Texas and is employed by Defendant City as a police ofcer. 9. Defendant CITY OF RED OAK ("City") is a municipality in the State of Texas. Defendant City can be served via the City Manager, Todd Fuller at 200 Lakeview Parkway, Red Oak, T exas 75154. 10. Defendant CRAIG RUDOLPH ("Rudolph") is an individual that may be served at his residence. Given his prior status as Chief of Police, Plaintiffs have not included Defendant Rudolph's address on this public ling. B. Jurisdiction and Venue 11. This case is brought under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C 2000e et. seq.\ the Family Medical Leave Act, 29 U.S.C. 2601 et. seq.; 42 U.S.C. 1983; and 42 U.S.C. 1985(3).

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12. This Court has jurisdiction over this matter according to 28 U.S.C. 1331; 28 U.S.C. 1343; 29 U.S.C. 2601 et seq.; 42 U.S.C. 2000e; 42 U.S.C. 1983; and 42 U.S.C. 1985(3). 13. The court has jurisdiction over the state law claims regarding violations of the Texas Commission on Human Rights Act, Section 21.051 et seq. of the Texas Labor Code ("TCHRA) by virtue of 28 U.S.C. 1367. 14. Venue is proper in this district under 28 U.S.C. 1391(b)(2) and 42 U.S.C. 2000e-5(f)(3) because a substantial part of the events or omissions giving rise to the claim occurred in this District. C. Exhaustion of Administrative Remedies 15. Plaintiffs Boone, Bryant, Gordon and Robinson timely led a charge of discrimination against Defendant City with the Equal Employment Opportunity Commission ("EEOC"). 16. Plaintiffs Boone, Bryant, Gordon and Robinson le this Original Complaint within 90 days after receiving the notice of their right to sue from the EEOC. D. Facts 17. From the start of each Plaintiffs' employment with Defendant City, Defendant Rudolph created a hostile working environment based on racial, ethnic and gender discrimination and retaliatory actions. 18. On several occasions, Defendant Rudolph told Plaintiff Boone and Plaintiff Dollar that he did not want to hire female ofcers because he did not want to take the chance on them having sexual relations on duty with male ofcers.

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19. Moreover, Defendant Rudolph required Plaintiff Bryant to undergo tests and requirements that white police ofcers were not required to undergo. 20. On one occasion, Plaintiff Bryant, an African American, logged onto his computer and discovered a desktop picture of a dark-colored animated monkey in a police uniform. 21. In January 2012, Plaintiff Boone complained to Defendant Rudolph regarding the unsanitary conditions at the city jail, which posed a risk to ofcers and inmates. Defendant Rudolph responded "they are in jail, f em." It was apparent to Plaintiff Boone that Defendant Rudolph did not appreciate Plaintiff Boone's complaints. 22. In March 2013, Defendant Rudolph used the term "nigger" while talking to Plaintiff Boone, Plaintiff Dollar and Plaintiff Gordon to describe what he termed "misdemeanor murder", which, according to Defendant Rudolph, means that when an African-American is killed, a thorough investigation is not conducted by the City of Red Oak's police department. 23. Defendant Rudolph likewise disciplined Plaintiffs Robinson and Bryant for actions for which he did not discipline white police ofcers. 24. On a number of occasions, Defendant Rudolph interrogated Plaintiff Payne regarding his deployment to Afghanistan often referring to the "towel heads" in that country. Defendant Rudolph also asked Plaintiff Payne if one of the detainees in custody at the police station was the same '"nigger' that was breaking into houses." Plaintiff Payne expressly opposed the use of said terms by Defendant Rudolph. 25. In March 2013, during a meeting with Plaintiff Boone and Plaintiff Gordon, Defendant Rudolph stated "I don't know which is worse, your kid showing up with a nigger or being a faggot?" Plaintiff Boone and Plaintiff Gordon both expressly objected to Defendant
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Rudolph's use of these words by telling Defendant Rudolph that they objected to the use of those terms because they had African-American and/or homosexual family members and/or friends. Defendant Rudolph responded that he "stuck [his] foot in his mouth." 26. A few days after this meeting, Defendant Rudolph stopped Plaintiff Gordon in the hallway and commented that he heard Plaintiff Gordon was the founding member of the Black Peace Ofcer's Association in Lancaster, Texas. Defendant Rudolph told Plaintiff Gordon that he would "let it slide this time." 27. Thereafter, Defendant Rudolph, with the assistance of others on the police department management team, began a campaign of harassment, intimidation and retaliation against Plaintiff Boone and Plaintiff Gordon. 28. In March 2013, Plaintiffs began voicing their concerns regarding the police department's use of a particular gun, the SR911. While on-duty and off-duty, Plaintiffs expressed that the guns had not been adequately tested; that the guns were unsafe for the citizens and ofcers; that the police ofcers had not received adequate training to use the guns; and using the guns would put ofcers in danger. 29. Thereafter, Lieutenant Nicki Flores ("Flores"), at the direction of and in conspiracy with Defendant Rudolph, began interrogating Plaintiffs regarding their concerns. Flores told Plaintiff Payne that only one person could have an opinion in the police department Defendant Rudolph. Flores reminded Plaintiff Payne that "back in the day, ofcers were terminated for voicing their concerns." 30. Importantly, Defendant Rudolph and several Lieutenants did not complete the required training to carry the SR911. Plaintiff Boone expressed his concerns about this to Defendant Rudolph and to Flores. Specically, Plaintiff Boone expressed his concerns that not
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only were these ofcers in danger, but also other ofcers in the eld who relied upon these untrained ofcers would also be endangered. 31. On or about April 8,2013, Plaintiff Groom started working for Defendant City. 32. On or about May 8, 2013, Flores verbally reprimanded many ofcers, including Plaintiffs, for voicing their concerns regarding the SR911. 33. On or about May 10, 2013, Defendant Rudolph verbally chastised Plaintiff Payne for expressing his concerns over the SR911 and demanded that Plaintiff Payne turn in his badge. Defendant Rudolph sent Plaintiff Payne home with instructions to think about whether Plaintiff Payne wanted to work for Defendant City. Defendant Rudolph warned Plaintiff Payne that he too would be thinking about whether he wanted Plaintiff Payne to work for Defendant City. 34. On or about May 17, 2013, as a new ofcer, Plaintiff Groom voiced his concerns regarding his ability to safely use his SR911 due to his lack of training. 35. On or about May 21, 2013, Plaintiff Groom voiced his concerns regarding the SR911 and difculties he was having while practicing with the gun. 36. On or about May 22, 2013, Defendant Rudolph terminated Plaintiff Groom. Notably, Defendant Rudolph failed to provide Plaintiff Groom with a reason for the termination and classied Plaintiff Groom's termination as a "General Discharge", a classication only used when police ofcers are terminated for cause. This classication has affected Plaintiff Groom's ability to obtain another job. Notably, Defendant City failed to even be present at the hearing regarding Plaintiff Groom's classication, instead choosing to force Plaintiff Groom to retain counsel and appeal this classication. 37. On or about May 23,2013, in the presence of Plaintiff Boone, Defendant Rudolph falsely accused Plaintiff Groom of damaging his SR911.
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38. On or about May 24, 2013, Defendant Rudolph asked Plaintiff Boone to rum in his resignation, but Plaintiff Boone refused. Defendant Rudolph could not provide Plaintiff Boone with a reason for his request for Plaintiff Boone to resign. 39. In late May 2013, many of the Plaintiffs experienced shift changes. 40. Moreover, all of Plaintiffs have been, harassed, intimidated, ostracized and ridiculed. The harassment has been so severe, some of the Plaintiffs have sought medical treatment. In fact, Plaintiffs Boone and Dollar had to take leave under the Family Medical Leave Act due to health concerns. 41. All of the Plaintiffs led grievances regarding the above-referenced concerns with the City. 42. Plaintiff Bryant and Plaintiff Robinson led Charges of Discrimination with the EEOC. 43. After the ling of these EEOC charges, Defendant City began investigating the allegations made by Plaintiff Bryant and Plaintiff Robinson. However, neither Defendant City nor Defendant Rudolph launched an investigation beyond the ofcial investigation concerning Plaintiffs Bryant and Robinson's EEOC charges. 44. In the course of this investigation, many of the Plaintiffs were harassed about their knowledge and opinions concerning the above-noted allegations. For example, many of the Plaintiffs were approached by other members of the police department and asked to sign a letter supporting Defendant Rudolph. When they refused to do so, they were further ostracized by their superiors and fellow ofcers, who likewise continued to intimidate Plaintiffs for not cooperating. One Plaintiff was told that "heads were going to roll" over the complaints led against Defendant Rudolph.
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45. At the onset of the City's investigation into the allegations made by Plaintiffs, the ofcers ling the grievances were subjected to intensive and intrusive interrogation by the City Attorney. Said interrogations, operating under the guise of "interviews," were demanded pursuant to city policy. Said interviews invaded the personal lives of the complaining ofcers and were inexcusably intrusive, arbitrary, and many of the questions asked of Plaintiffs during their interrogations had no relevance whatsoever to Bryant and Robinson's allegations of racial discrimination. 46. The City further ordered some of the complaining ofcers to submit themselves for polygraph examinations and interrogated them during the examinations as if they were the harassers or offenders rather than the victims. The polygraphs were performed in a room so small that their attorney could not be present during the examination, in violation of an agreement between counsel for Plaintiffs and Defendants before the polygraphs took place. One attorney for the Plaintiffs objected on numerous occasions to the content of the questions being asked and the conduct of the polygraph operators towards the ofcers. Plaintiffs' counsel had an agreement as to the nature, scope and questions to be asked during the polygraph. The polygraph operators and Defendants ignored the agreement. In spite of the conduct of the operators, based upon information and belief, all Plaintiffs passed their polygraph examinations and Defendant Rudolph failed his. 47. As of the ling of this Complaint, all of the Plaintiffs who are still employed with Defendant City continue to be harassed, intimidated, ridiculed and retaliated against by City ofcials. Some have attempted to reach out to superiors, command staff and other ofcers and their attempts have been rebutted.

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E. Count 1Racial Discrimination under Title VII and TCHRA 48. Plaintiffs Bryant and Robinson incorporate by reference all of the allegations made in the preceding paragraphs. 49. Plaintiffs Bryant and Robinson are employees within the meaning of Title VII and TCHRA and belongs to a class protected under the statute, namely they are African-American men. 50. Defendant City is an employer within the meaning of Title VII and TCHRA. 51. Defendant City intentionally discriminated against Plaintiffs Bryant and Robinson because of their race by creating a racially hostile work environment. Specically, Plaintiffs Bryant and Robinson belong to a protected group, were subjected to unwelcome verbal and physical conduct constituting harassment, which harassment was based on race, the harassment complained of affected a term, condition, or privilege of employment. 52. Plaintiff Bryant's and Plaintiff Robinson's immediate supervisor, Defendant Rudolph caused this racially-hostile work environment. 53. Defendant City failed to exercise reasonable care to prevent, cure and correct any racially harassing behavior, even after the original complaint was led. 54. In addition, Defendant City's negligence led to the creation and/or continuation of the racially-hostile working environment. Specically, Defendant City failed to prevent racial harassment from occurring at the workplace by, but not limited to the following: failing to monitor the workplace; failing to provide an adequate system for registering racial harassment complaints; failing to respond to racial harassment complaints; and discouraging complaints from being led.

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F. Count 2Retaliation under Title VII and TCHRA 55. Plaintiffs Boone, Bryant, Gordon and Robinson incorporate all of the allegations made above. Under 42 U.S.C. 2000e-3(a), it is an unlawful employment practice for an employer to discriminate against any of its employees because that employee led a Charge of Discrimination with the EEOC or because the employee opposed a practice that violates Title VII. 56. Defendant City retaliated and/or discriminated against Plaintiffs Bryant and Robinson for their Charges of Discrimination. 57. After Plaintiffs Bryant and Robinson led their Charges of Discrimination, Plaintiffs Bryant and Robinson suffered materially adverse employment actions. Said material adverse employment actions would not have occurred "but for" the ling of their Charges of Discrimination. 58. Defendant City retaliated and/or discriminated against Plaintiffs Boone, Bryant, Gordon and Robinson for opposing practices and actions that violate Title VII. 59. After said Plaintiffs opposed Defendant Rudolph's use of racially and sexually hostile and harassing language, said Plaintiffs suffered materially adverse employment actions. Said material adverse employment actions would not have occurred "but for" their opposition to actions that violate Title VII. 60. Defendant City's wrongful conduct also violates TCHRA. G. Count3-FMLA 61. Plaintiffs Boone and Dollar incorporate by reference all of the allegations made above.

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62. Plaintiffs Boone and Dollar are eligible employees within the meaning of the FMLA. Plaintiffs Boone and Dollar were employed by Defendant City for at least 12 months and for at least 1,250 hours of service during the previous 12-month period. See 29 U.S.C. 2611(2). 63. Plaintiffs Boone and Dollar were entitled to 12 work weeks of leave during the period of January 1, 2013 through December 31, 2013 because they or a close family member suffered a serious health condition. 64. Plaintiffs Boone and Dollar gave their employer at least 30 days' notice before the date the leave was to begin and/or practicable notice when the leave was needed. 65. Plaintiffs Boone and Dollar provided Defendant City with information that they were unable to perform the functions of their job, the medical necessity for leave and the expected duration of the leave. 66. It is unlawful for an employer to discriminate or retaliate against an employee for engaging in FMLA-protected activity. 29 U.S.C. 2615(a)(l and 2). 67. Plaintiffs Boone and Dollar engaged in FMLA-protected activity by requesting and taking leave and Defendant City discriminated and/or retaliated against Plaintiffs Boone and Dollar for engaging in FMLA-protected activity. 68. As a result of Defendant City's unlawful actions, Plaintiffs Boone and Dollar have suffered economic losses and mental anguish, and will continue to suffer such losses in the future. H. Count 4-First Amendment Retaliation (Free Speech) pursuant to 42 U.S.C. 1983 69. All Plaintiffs incorporate by reference all of the allegations made above. 70. Defendants violated Plaintiffs' right to free speech guaranteed by the First Amendment to the United States Constitution.
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71. Specically, Plaintiffs made statements that involved a matter of public concern and that are constitutionally protected under the First Amendment. 72. Plaintiffs' interest in making these statements outweighs any interest of Defendant City in promoting the efcient operation and administration of government services. 73. Plaintiffs' speech was a substantial and motivating factor in Defendants' actions against Plaintiffs, including the termination of Plaintiff Groom. 74. The aforementioned adverse employment actions and harassment occurred because Plaintiffs exercised their right to free speech on a matter of public concern under the United States Constitution. 75. The aforementioned deprivations were done under color or state law, ordinance, regulation and custom or usage. Defendants are liable because their actions were committed while acting under color of state law. Defendants knew or should have known and/or were deliberately indifferent to, the violation of Plaintiffs' rights. 76. Defendant City is liable because Plaintiffs' injuries were caused by the unconstitutional actions of municipal policymakers and/or a municipal policy. Specically, the actions taken against Plaintiffs, including, but not limited to termination, were taken by ofcials with nal policymaking authority. 77. Defendant Rudolph is liable because the law regarding First Amendment retaliation, as alleged supra, is clearly established and Defendant Rudolph knew or should have known that taking the subject actions were a violation of Plaintiffs' clearly-established constitutional rights. I. Count 5-First Amendment Retaliation (Redress of Grievances) Pursuant to 42 U.S.C. $1983 78. All Plaintiffs incorporate by reference all of the allegations made above.
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79. Defendants violated Plaintiffs' right to free speech guaranteed by the First Amendment to the United States Constitution. 80. Specically, Plaintiffs led grievances with Defendant City and said grievances are constitutionally protected under the First Amendment. 81. Plaintiffs' grievances were a substantial and motivating factor in Defendants' actions against Plaintiffs, including in the termination of Plaintiff Groom. 82. The aforementioned adverse employment actions and harassment occurred because Plaintiffs exercised their right to free speech and led grievances with Defendant City. 83. The aforementioned deprivations were done under color or state law, ordinance, regulation and custom or usage. Defendants are liable because their actions were committed while acting under color of state law. Defendants knew or should have known and/or were deliberately indifferent to, the violation of Plaintiffs' rights. 84. Defendant City is liable because Plaintiffs' injuries were caused by the unconstitutional actions of municipal policymakers and/or a municipal policy. Specically, the actions taken against Plaintiffs, including, but not limited to termination, were taken by ofcials with nal policymaking authority. 85. Defendant Rudolph is liable because the law regarding First Amendment retaliation, as alleged supra, is clearly established and Defendant Rudolph knew or should have known that taking the subject actions was a violation of Plaintiffs' clearly-established constitutional rights. J. Count 6-Fourteenth Amendment (Equal Protection) Pursuant to 42 U.S.C. 1983 86. Plaintiffs Bryant and Robinson incorporate by reference all of the allegations made above.
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87. Defendants violated Plaintiff Bryant's and Plaintiff Robinson's right to equal protection under the Fourteenth Amendment to the United States Constitution. 88. Specically, Defendants intentionally discriminated against Plaintiffs Bryant and Robinson because of their race by creating a racially-hostile work environment. Specically, Plaintiffs Bryant and Robinson are African-American, were subjected to unwelcome verbal and physical conduct constituting harassment, which harassment was based on race, and the harassment complained of affected a term, condition, or privilege of employment. 89. The aforementioned deprivations were done under color or state law, ordinance, regulation and custom or usage. Defendants are liable because their actions were committed while acting under color of state law. Defendants knew or should have known and/or were deliberately indifferent to, the violation of Plaintiff Bryant's and Plaintiff Robinson's rights. 90. Defendant City is liable because Plaintiff Bryant's and Plaintiff Robinson's injuries were caused by the unconstitutional actions of municipal policymakers and/or a municipal policy. Specically, the actions taken against Plaintiffs Bryant and Robinson were taken by ofcials with nal policymaking authority. 91. Defendant Rudolph is liable because the law regarding equal protection based on race, as alleged supra, is clearly established and Defendant Rudolph knew or should have known that taking the subject actions was a violation of Plaintiffs' clearly established constitutional rights. K. Count - 42 U.S.C. 1985(3) 92. Plaintiffs incorporate by reference all of the allegations made above. 93. Defendant Rudolph and at least two (2) other City ofcials conspired against Plaintiffs for the purpose of depriving, directly and/or indirectly, Plaintiffs of the equal
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protection of the laws, or of equal privileges under the laws; and acted in furtherance of the conspiracy whereby Plaintiffs were denied their First Amendment rights (Free Speech and Redress of Grievances). L. Damages 94. As a direct and proximate result of Defendants' actions, Plaintiffs suffered the following injuries and damages: a. Plaintiff Groom - back pay (wages for off-duty jobs); and b. All Plaintiffs - compensatory damages (including past and future mental anguish). M. Attorney Fees and Costs 95. Plaintiffs are entitled to an award of attorney fees and costs under Title VII, 42 U.S.C. 2000e-5(k); the Family Medical Leave Act; and 42 U.S.C. 1983. N. Jury Demand 96. Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiffs request a trial by jury on all issues. O. Prayer 97. For these reasons, Plaintiffs ask for judgment against Defendants for the following: a. actual damages; b. compensatory damages; c. prejudgment and post-judgment interest at the highest rate allowed by law; d. reasonable attorney's fees; e. costs of suit;
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f. equitable relief; g. injunctive relief; h. liquidated-damages within the meaning of the FMLA; and i. any and all other damages to which they are entitled.

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Respectfully submitted, Ramsey Hill

C. Ramse Bar No. Justin A. Hill State Bar No. 24057902 8584 Katy Freeway, Suite 105 Houston, TX 77024 Phone:(713)489-7577 Fax: (888) 858-1452 Email: john@rhlawgroup.com Email: Justin@rhlawgroup.com Melissa Morales Fletcher State Bar No. 24007702 Lawrence Morales II State Bar No. 24051077 The Morales Firm 115 E.Travis, Suite 1530 San Antonio, Texas 78205 Phone:(210)225-0811 Facsimile: (210) 225-0821 Email: melissa@themoralesrm.com Email: lawrence@themoralesrm.com Rodney Ramsey State Bar No. 24040103 Law Ofce of Rodney Pat Ramsey 201 E. Main Street, Suite 203 Waxahachie, Texas 75165 Phone:(972)935-9111 Fax: (972) 935-0224 Email: occides@hotmail.com Attorneys for Plaintiffs

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