Filed D.C. Superior Court 12/08/2016 13: 462m Clerk of the Court SUPERIOR COURT FOR THE DISTRICT OF COLUMBIA CIVIL DIVISION YINKA T, ALAO c/o The Chambers Firm 8403 Colesville Road, Si Silver Spring, MD 20910 1100 Plaintiff, Civil Action No, Judge v. Next Event: THE DISTRICT OF COLUMBIA Serve On: Mayor Muriel Bowser 1350 Pennsylvania Avenue, NW Washington, DC 20004 Serve On: Attorney General Karl Racine 441 4 Street, NW, Suite 600 South Washington, DC 20001 RASHAD M. YOUNG, Individually and in his Official Capacity as District of Columbia City Administrator John A Wilson Building 1350 Pennsylvania Avenue, NW Suite $13 Washington, DC 20004 Defendants, COMPLAINT Plaintiff Yinka T. Alao files this complaint against the District of Columbia government and Rashad Young, City Administrator for the District of Columbia, alleging as follows: NATURE OF THE CASE This action arises out of the Plaintiff’ termination of employment after he was responsible for saving District taxpayers almost $10 million dollars in the performance of his,duties as Associate Director of the Department of General Services (DGS) for Contracting and Procurement, Plaintiff, as the Chief Procurement Officer for DGS, recommended that contracts to develop Buzzard Point (Buzzard) and St. Elizabeths East (St. E’s) not be awarded to Fort Myer Construction Co. (Ft. Myer), one of the largest campaign contributors to Mayor Muriel Bowser and her now-defunct Fresh Political Action Committee (also known as Fresh-PAC). Plaintiff made these recommendations despite the fact that he received unprecedented pressure from the City Administrator and the Executive Office of the Mayor to award both contracts to Ft Myer. Shortly after making the recommendation to award the St. E's contract to Gilbane Building Company (Gilbane), Plaintiff was terminated in retaliation for failing to cooperate with EOM efforts to award the contract to Ft. Myer. After terminating Plaintiff, in order to deflect attention from the obvious breach of the public trust and violations of the Whistleblower Protection Act, City Administrator Rashad Young and Bowser Spokesman Rob Hawkins embarked on a crusade to defame Plaintiff and another fired DGS employee in the media Because of the District’s and Defendant Young’s illegal acts of terminating the Plaintiff and publicly defaming and embarrassing him, Plaintiff is entitled to monetary damages. JURISDICTION 1, This Court has subject matter jurisdiction over this civil action under D.C. Code § 11-921(a). PARTIES 2. Plaintiff is a resident of the State of Virginia and the former Associate Director of DGS for Contracting and Procurement. 3. Defendant, the District of Columbia, is the municipal government 4, Defendant Young is the City Administrator for the District of Columbia, Defendant Young exercised and attempted to exercise direct supervisory control over the Plaintiff's work,directing the Plaintiff to take a number of specific actions. Defendant Young arranged for Plaintiff s termination after the Director of DGS refused to terminate Plaintiff at Defendant Young’ request. FACTUAL ALLEGATIONS In January of 2016 Plaintiff, as the DGS Associate Director for Contracting and Procurement, was notified that the Buzzard Point Infrastructure contract, site of the new DC United Stadium, and the St. Elizabeths East contract, site of the new Wizards and Mystics practice facility (the latter previously assigned to the District Department of Transportation (DDOT) and the former including streetscape and utilities work typically procured by DDOT) were either being transferred or assigned to DGS for the issuance of Requests for Proposal s involved horizontal construction, which DDOT This was unusual because both proj generally handles. DGS generally handles vertical construction, mostly school buildings. Upon information and belief, EOM transferred the contracts to DGS because of an ongoing Inspector General investigation into the finances of a DDOT employee, Ali Shakeri, who failed to disclose $170,000 in income on his 2012 and 2013 financial disclosure forms. Upon information and belief, Mr. Shakeri received thousands of dollars from various companies within and outside the District in 2012 and 2013 and failed to disclose the income on his financial disclosure. Upon information and belief, some of the unreported money may have come from entities related to Ft. Myer. Ft, Myer is one of DDOT’s main contractors, winning a number of DDOT contracts each year.10. In an apparent effort to assist Ft. Myer to win the Buzzard Point and St. E's awards without the stain of scandal caused by the investigation, EOM moved the contracts to DGS. 11. It quickly became clear that EOM and Ft. Myer did not have the leverage at DGS that each enjoyed at DDOT. 12, Plaintiff issued the RFP for Buzzard Point in January of 2016 and two companies responded, Schlosser and Fi, Myer. Schlosser responded appropriately. Ft, Myer did not. 13, First, Ft. Myer replaced the DGS disclosure form with a DDOT disclosure form, which required less information than the DGS form. fier being notified that the District was aware that they had switched the forms and filled out the incorrect one, Ft, Myer filled out the correct DGS form but failed to disclose at least one lawsuit against the company. Ft. Myer also failed to disclose related entities. 14, As the Contracting Officer responsible for recommending the award of the contract, Plaintiff researched Ft. Myer and quickly leamed of apparent related entities that Ft. Myer failed to mination lawsuit against Ft. Myer where the company disclose and a dis required to pay almost $1 million in damages to the aggrieved employees. 15. These omissions were intentional and necessarily impacted the Plaintiff"s decision in recommending an award, The winner of the contract would be responsible for managing the contract, including awarding contracts to sub-contractors. This is a function usually performed by a District government employee but that was not the case for this type of DGS contract, Disclosing related entities ensures transparency for the District and ensures the contractor can’t, without the District’s knowledge, award sub-contracts to itself, subverting the integrity of the bidding process and potentially costing the District additional money.16, Plaintiff, in consultation with the DGS General Counsel, Deputy General Counsel, and Assistant General Counsel, determined that Ft, Myer should be held “Non Responsible” and ineligible to bid on the Buzzard Point contract. 17. During this time, but before an award recommendation was made, Plaintiff received several emails from EOM requesting updates on the Buzzard Point RFP. Some of the emails referred to the ‘Ft, Myer award’ of the Buzzard Point contract, the obvious implication being, that Ft, Myer was expected to win the contract. EOM would not have known that Ft. Myer was “expected” to win the award without knowledge that Ft. Myer had more points than Schlosser. 18, Upon information and belief, one or more DGS employees colluded with EOM and Ft, Myer by feeding them information relating to the scoring of each contract bidder for the Buzzard Point project to influence the Contracting Officer's decision. 19, Plaintiff recommended awarding the contract to Schlosser. Former DGS Director, Rear Admiral Christopher Weaver (Ret. USN) (“Admiral Weaver”) approved the award. Both bidders were notified. An hour later Plaintiff received an angry call from Ketan Gada of EOM inquiring about why Fl. Myer failed to win the contract. In response to a request from Mr. Gada for an official communication describing the process and rationale for the award determination, the Plaintiff drafted a memorandum to Mr. Gada and consulted with his chain of command. Upon approval, Plaintiff transmitted the memorandum to EOM. The Plaintiff did not rescind the award to Schlosser 20, Plaintiff endured several communications from Mr. Gada, one of which was a conference call with other individuals also on the call.21. At some point after the contract was awarded to Schlosser, Defendant Young convened a ‘meeting attended by Admiral Weaver, the Plaintiff, DGS's General Counsel and Deputy General Counsel, Barry Krieswirth, Ketan Gada, Mark Tuohey, Nancy Hapeman, Ronald Ross, Brian Kenner, and Maia Estes. EOM employees criticized DGS’s decision to find Ft. Myer Non-Responsible. 22. At the meeting with EOM, EOM officials requested that Plaintiff fragment the contract which had already been awarded to Schlosser, and re-bid portions of the work in order to give Ft. Myer the opportunity to compete again. Plaintiff knew this action could subject the District to litigation. 23. Upon adjourning the meeting, Mr. Young stated “the Mayor deserves the opportu weigh in on this procurement.” 24, Plaintiff had never been faced with such pressure from an outside agency to take illegal action on a procurement, Plaintiff knew that the implications of terminating the contract with Schlosser would be disadvantageous to the District and would open the District up to liability. Plaintiff believed the options put forth by the EOM to overcome the Non- Responsible determination, to include re-bidding the contract to assist Ft. Myer in winning the award, were illegal. Plaintiff did not reverse his decision on Ft. Myer’s Non- Responsibility nor did he terminate the contract with Schlosser 25. Ft. Myer did not formally protest the award to Schlosser or the finding that they were Non- Responsible to the Contracts Appeals Board (CAB), 26, In February of 2016, Plaintiffissued a RFP for the St. E's project. Two contractors responded, Ft. Myer and Gilbane.27. Defendant Young directed DGS to “counsel [Ft. Myer] through” the DGS disclosure form that Ft, Myer first attempted to avoid then failed to properly complete during the Buzzard Point bid process. This responsibility would necessarily fall upon Plaintiff-as the Chief Procurement Officer for DGS. Presumably, Plaintiff was ordered to do so to ensure Ft. Myer ‘was not found Non-Responsible again. 28, Plaintiff was not directed to provide Gilbane with any such assistance in completing its bid package. 29. As directed, Plaintiff worked closely with Ft, Myer to ensure that they clarified their responses on the DGS disclosure form, 30. Once the bids were in, Plaintiff determined that Ft, Myer’s bid was nearly $10 million higher than the bid submitted by Gilbane, Gilbane also accumulated more points than Ft, Myer. 31, Plaintiff was prepared to recommend awarding the contract to Gilbane, however, he was instructed through his chain of command, based on directions from Mr. Young, not to issue an award to Gilbane. This was an unprecedented interference by an outside government agency in the independent DGS procurement process. 32. Plaintiff issued a memorandum detailing the reasons why an award to Ft. Myer could not possibly be justified. This did not appease EOM and he was still not permitted to issue the award to Gilbane. Plaintiff then suggested to his chain of command that he request a “Best and Final Offer” (BAFO) from both contractors. While even this step was extraordinary because of the wildly divergent cost estimates, the pressure Plaintiff was getting from EOM for this procurement and the pressure he had gotten for the Buzzard Point procurement, caused Plaintiff to suggest this possible solution, Plaintiff was of the belief that making this suggestion was the only way to appease EOM and for him to move forward with an award33, 34, 35. 36. 37. 38. recommendation. Plaintiff would not have otherwise suggested a BAFO in this, circumstance. Defendant Young consented to the BAFO process. Plaintiff then requested a BAFO from each of the bidders. Gilbane did not change its bid. Ft. Myer made several changes which, when taken together, pushed Ft, Myer over the top on points while allowing the company to maintain pricing that still exceeded Gilbane’s price by almost $10 million Ft. Myer likely had information on Gilbane’s bid and pricing for individual contract, deliverables, allowing it an advantage over Gilbane in the BAFO process. Upon information and belief, one or more DGS employees colluded with EOM and Ft. Myer by feeding them information relating to Gilbane’s pricing of each contract deliverable, giving Fi, Myer an advantage in the BAFO process, in an effort to influence the Contracting Officer's decision fier the BAFO process, Plaintiff recommended an award to Gilbane, Former DGS Director, Admiral Weaver, approved the recommendation. Both Gilbane and Ft, Myer were informed of the award. After the contract was awarded to Gilbane, Plaintiff was contacted by a Ft, Myer employee for a post award debriefing. During this debriefing, Lewis F. Shrensky, a Ft. Myer principal, pointedly stated that the Plaintiff was new (at DGS), did not appreciate the history of this procurement action (coming from DDOT), and didn’t know what he (Plaintiff) was walking into.39. Thereafter, Plaintiff was called into a meeting at Defendant Young’s office along with others from DGS and EOM officials including Barry Kreiswirth, Ronald Ross, Sarosh Olpadwala, Brian Kenner and Nancy Hapeman. 40. During this session, EOM officials challenged the BAFO, arguing that the process was flawed and requesting that the award to Gilbane be rescinded and that a second BAFO be issued to allow Ft. Myer to rework their numbers and come down on price. Plaintiff disagreed with EOM officials that the BAFO process was flawed and communicated his position during the meeting, and afterwards, in writing, to Barry Kreiswirth and Ronald Ross. 41, Plaintiff had only once prior to this procurement been faced with such pressure from outside agencies to control the direction of a procurement; the Buzzard Point procurement, w! also involved EOM officials attempting to secure a contract award to Fi, Myer. Plaintiff knew that the implications of terminating the contract with Gilbane would be disadvantageous to the District and would open the District up to liability. Plaintiff believed that EOM’s suggestions to terminate the Gilbane contract award and to issue a second BAFO were illegal 42. EOM officials were clearly attempting to influence Plaintiff's decision to recommend that the St. E’s contract be awarded to Gilbane. Plaintiff refused to terminate the Gilbane contract of issue a second BAFO during the meeting and in later emails. 43, Plaintiff informed Admiral Weaver what transpired during the meeting, 44, Ft, Myer protested the award to Gilbane. This had the effect of automatically staying Gilbane’s ability to continue any work on the contract. Plaintiff, in conjunction with DGS General Counsel office, prepared a Determination and Finding (D&F) which would have had the effect of lifting the stay and allowing Gilbane to continue contract work. Plaintiff wasdirected by EOM officials to refrain from filing the D&F. This order continued in effect for 53 days, until August 12, 2016, the date that Admiral Weaver officially stepped down as DGS Director. 48. Upon information and belief EOM officials were angry that Ft, Myer did not win the Buzzard Point or the St. E’s awards and, despite the fact that the award recommendations to Schlosser and Gilbane were proper, isked Admiral Weaver to terminate the Plaintiff’ s employment because of Plaintiff's recommendations that Ft. Myer not receive either award. 46. While Gilbane was stayed from doing any contract work, EOM officials instructed Plaintiff to increase the Certified Business Enterprise (CBE) participation requirement from the statutorily mandated 35% up to 74% so that Ft. Myer could receive up to 74% of the subcontracted work on the St. E’s project. 47. On or around the week beginning August 8, 2016, Defendant Young and/or officials from the Executive Office of the Mayor were told by Admiral Weaver that the award to Gilbane would proceed and that the D&F should be filed. Defendant Young agreed with that course of action on the express condition that Admiral Weaver terminate Plaintiffs employment. 48. On Friday August 12, 2016, Plaintiff was informed that EOM had permitted the D&F to be filed. Also on Friday August 12, 2016, rather than terminate the Plaintiff in retaliation for Ft. Myer not receiving one of the two contract awards, Admiral Weaver resigned his position as DGS Director. 49. The Defendant Young, aided by other officials at EOM including Mr. Gada and Ms. Hapeman, and officials at DCHR, initiated a personnel action to terminate Plaintif"s employment, 1050. On Monday, August 15, 2016, Justin Zimmerman, Associate Director for Policy for the D.C. Department of Human Resources (DCHR) and Margaret Radabaugh, General Counsel for DCHR came to DGS and called Plaintiff into a meeting. 51. At this meeting, they presented Plaintiff with a Notice of Separation signed by Margaret Radabaugh on behalf of Ventris Gibson, Director of DCHR. The letter provided that Plaintiff would be placed on Administrative Leave on that date and would be separated from District employment effective August 30, 2016, Further, the letter stated that despite the circumstances, the appointing authority thanked the Plaintiff for his service to the District of Columbia. According to the letter, Plaintiff was not terminated for cause. fier the District terminated the Plaintiff, in order to deflect attention from the obvious breach of the public trust and various violations of law, Defendant Young and Bowser Spokesman Rob Hawkins embarked on a crusade to publicly defame Plaintiff using the media, 53. Government officials stated publicly on the radio and in print that Plaintiff was terminated because he changed a long-standing government policy related to the number of points, awarded to contract bidders, which disadvantaged CBEs. In fact, because of the actions taken by EOM, coupled with statements made to the media by the Government officials, Plaintiff was made to look like an insubordinate, rogue employee who took unauthorized actions without the knowledge or consent of his superiors. This placed Plaintiff in a false light not only to the public at large, but also to prospective employers. 54, Specifically, to provide protection to District officials and support for PlaintifY’'s wrongful discharge, and to conceal his own wrongdoing, Defendant Young stated on The Kojo ‘Nnamdi Show on August 29, 2016 that Plaintiff was terminated because: 11a, He made “changes to a longstanding practice that favored CB preference points...” disadvantaging CBI He made those changes without the knowledge or approval of his superiors, the City Administrator's office, or EOM; He engaged in “indefensible procurement practices”; He “exposed [the District] to millions of dollars of financial losses...” He failed to “fairly and appropriately within guidelines policy and practice administer procurement solicitations in the District of Columbia...” s in getting - ee 55, It was clear from the context and topic of the conversation, and the subject of the interview, that Mr. Young's false statements were about the Plaintiff and his comments were directed towards Plaintifl’s work performance. 56. Defendant Young also stated to the Washington City Paper on September 1, 2016 that the contracting system put in place by Plaintiff was “indefensible.” 57. Mayor Bowser Spokesperson Rob Hawkit tated to the Washington City Paper on September 1, 2016 that Plaintiff sought to “undermine local and minority businesses...” and that his actions would not be tolerated by the Administration, 58. These statements are particularly damaging to Plaintiff, a government contracting and procurement and risk management professional whose reputation in the community has been damaged by the public characterizations that Plaintiff was terminated because he was a rogue employee who changed government policies without authorization, discriminated against minority businesses by undermining their ability to win government contracts, and exposed the District to millions of dollars in financial losses. 59, None of these statements made against the Plaintiff are true. Plaintiff never changed or approved changes to government policy without the approval of his superiors. Plaintiff never approved changes to procurement practices that were intended to discriminate against CBEs and never approved changes to procurement practices that were intended to disadvantage CBEs, not fF always used best practices in his procurements. Plaintiff's actions 2expose the District to millions of dollars in losses, in fact, Plaintiff’s actions saved the District almost 10 million taxpayer dollars when he refused to break the law as directed by officials in EOM. UNT 1 IOLATION OF THE DISTRICT OF COLUMBIA WHISTLEBLOWER PROTECTION ACT ALL DEFENDANTS 60, Plaintiff hereby incorporates by reference the allegations contained in paragraphs 1-59 as if fully set forth herein, 61. Under the DC Whistleblower Protection Act, D.C. Code § 1-615.53, a supervisor shall not take, or threaten to take, a prohibited personnel action or otherwise retaliate against an employee because of an employee's refusal to comply with an illegal order. 62. Under the DC Whistleblower Protection Act, “supervisor” means an individual employed by the Dist government who meets the definition of a “supervisor” in § 1-617.01(d) or who has the authority to effectively recommend or take remedial or corrective action for the violation of a law, rule, regulation or contract term, or the misuse of government resources. jout tion. that an employee may allege or report pursuant to this section, including an agency head, department director, or manager. Defendant Young and other EOM officials named and unnamed in this Complaint have the authority to effectively recommend or take remedial or corrective action for the violation of a law, rule or regulation Plaintiff refused to violate, 63. Under D.C, Code § 1-617.01(d), a “supervisor is a District employee having authority, in the interest of an agency, to hire, transfer, suspend, lay off, recall, promote, discharge, assign, reward, of discipline other employees, or responsibility to direct them, or to evaluate their performance, or to adjust their grievances, or effectively to recommend such action, if in 2B64. 66. 67. connection with the foregoing the exercise of authority is not of a merely routine or clerical nature, but requires the use of independent judgment. Defendant Young and other EOM officials named and unnamed in this Complaint have the authority to hire, transfer, suspend, lay off, recall, promote, discharge, assign, reward, or discipline other employees, or effectively to recommend such action, In fact, Defendant Young and other EOM officials named and unnamed in this Complaint requested that Admiral Weaver terminate Plaintiff" employment, When Admiral Weaver refused, Defendant Young initiated a personnel action to terminate the Plaintiff using DCHR officials instead Pursuant to Title IV § 401(b)(1) of the Procurement Practices Reform Act of 2010, “a District employee or official shall not attempt to influence a procurement professional with respect to source selection.” Title IV § 401(b)(2) outlines the penalties for violating 401(b)(1), stating “[a]ny employee or official who violates this section shall be subject to suspension, dismissal, or other disciplinary action under the procedures pursuant to Title XVLA of the District of Columbia Government Comprehensive Merit Personnel Act of 1978, approved June 10, 1998 (D.C. Law 12-124; D.C. Official Code § 1-616.51 et seq.).” Pursuant to 27 D.C.M.R. 4725.2, the Contracting Officer is the only DGS representative with the authority to terminate or modify a contract. Afier making the Buzzard Point award to Schlosser, Plaintiff received an angry call from Ketan Gada of OM inquiring about why Ft. Myer failed to win the contract. Mr. Gada also demanded an official communication describing the process and rationale for the award determination. Defendant Young convened a meeting attended by Admiral Weaver, the Plaintiff, DGS"s General Counsel and Deputy General Counsel, Barry Krieswirth, Ketan Gada, Mark Tuohey, 14Nancy Hapeman, Ronald Ross, Brian Kenner, and Maia Estes where the EOM employees criticized Plaintiff's decision to find Ft. Myer Non-Responsible. 68. At the meeting with EOM, EOM officials requested that Plaintiff fragment the contract which had already been awarded to Schlosser, and re-bid portions of the work to give Ft Myer the opportunity to compete again. This was an attempt by EOM to modify the Schlosser contract award, a power granted exclusively to the Contracting Officer. This was also an attempt by EOM to influence the contract award to Schlosser, action which is expressly prohibited by the Procurement Practices Reform Act. 69. Upon adjourning the meeting, Mr. Young stated “the Mayor deserves the opportu 'y to on this procurement.” 70 Plaintiff knew that if he were to modify the contract as requested by EOM, it would be an unlawful modification since there was no rationale for modifying the contract. This would subject the District to litigation for breach of contract. 71. After soliciting bids to redevelop the St. Elizabeths site, Plaintiff determined that Ft. Myer’s bid was nearly $10 million higher than the bid submitted by Gilbane, Gilbane also accumulated more points than Ft. Myer. 72, Plaintiff was prepared to recommend awarding the contract to Gilbane, however, he was instructed through his chain of command, based on directions from Defendant Young, not to issue an award to Gilbane, This was an unprecedented interference by an outside government agency to influence Plaintiff to secure a contract award for Ft. Myer. 73, Plaintiff requested a BAFO from the bidders at the behest of Defendant Young. Gilbane did not change its bid. Ft. Myer made several changes which, when taken together, pushed Ft. 1574, 15, 16. 71. 8. 79. Myer over the top on points while allowing the company to maintain pricing that still exceeded Gilbane’s price by almost $10 million, Fi, Myer likely had information on Gilbane’s bid and pricing for individual contract deliverables, allowing it an advantage over Gilbane in the BAFO process. The information was likely provided to Ft, Myer by an EOM official and/or a DGS official. The goal of this information sharing was to influence Plaintiff's award of the St. Elizabeths contract. After the BAFO process, Plaintiff recommended an award to Gilbane, Former DGS Director, Admiral Weaver, approved the recommendation. Both Gilbane and Ft, Myer were informed of the award, ler the contract was awarded to Gilbane, Plaintiff was contacted by a Ft. Myer employee for a post award debriefing. During this debriefing, Lewis F. Shrensky, a Ft, Myer principal, pointedly stated that the Plaintiff w: new (at DGS), did not appreciate the history of this procurement action (coming from DDOT), and didn’t know what he (Plaintiff) was walking into. Thereafter, Plaintiff was called into a meeting at the Defendant Young’s office with others from DGS and EOM officials including Barry Kreiswirth, Ronald Ross, Sarosh Olpadwala, Brian Kenner and Naney Hapeman. During this session, EOM officials requested that Plaintiff rescind the award to Gilbane and issue a second BAFO to allow Ft, Myer to rework their numbers and come down on price, Plaintiff refused. Plaintiff knew that if he were to terminate the award to Gilbane as requested by EOM, it would be an unlawful modification since there was no rationale for terminating the contract, This would subject the District to litigation for breach of contract. 1680. Plaintiff refused to follow the illegal directives to modify the Buzzard Point contract awarded to Schlosser or to terminate the St. Elizabeths contract awarded to Gilbane, Because of and in retaliation for these refusals, Defendant Young and other officials at EOM including Mr. Gada and Ms, Hapeman, aided by DCHR, initiated a personnel action to terminate Plaintiff” s employment, 81. These directives were intended to interfere with and influence Plaintiff's independent authority to procure contracts for these projects, a violation of the Procurement Practices Reform Act (PPRA). By directing Plaintiff to modify and terminate contracts, Defendant ‘Young and EOM officials were effectively usurping Plaintiff's exclusive authority under the PPRA to modify and terminate contracts. The following actions taken by Defendant Young, and EOM are illegal and against publie policy: a. Attempting to influence Plaintiff is the source selection for the Buzzard Point and St. Elizabeths contracts; b. Attempting to influence Plaintiff to modify the award to Schlosser; ¢. Attempting to influence Plaintiff to terminate the award to Gilbane; 4d. Directing Plaintiff to modify the award to Schlosser; e. Directing Plaintiff to terminate the award to Gilbane; f, Directing Plaintiff to refrain from issuing and filing the D&F; g. Directing Plaintiff to increase the CBE requirement from 35% to 74% to shift a large percentage of the contract work to Ft. Myer; 82. Defendant Young and other EOM officials who directed Plaintiff to take these unlawful actions were exercising authority over Plaintiff as supervisors. 83. Plaintiff suffered, and continues to suffer, severe emotional stress and mental anguish as a result of Defendants’ actions and omissions. 84, Plaintiffs professional reputation has been irreparably damaged because of the Defendants’ actions. As a result of the actions of the District and its officials, Plaintiff suffered financial 7losses, lost wages, lost benefits, pension losses, pain and suffering, embarrassment and humiliation, and permanent damage to his professional reputation. WHEREFORE, Plaintiff requests that this Court issue a judgment against the Defendants in the amount of $5,000,000 in compensatory damages and $5,000,000 in punitive damages against the individual defendant. COUNT WRONGFUL DISCHARGE ALL DEFENDANTS 85. Plaintiff hereby incorporates by reference the allegations contained in paragraphs 1-84 as if fully set forth herein, 86. The common-law tort of wrongful discharge is “an exception to the traditional at-will doctrine governing termination of employment, where the discharge violates ‘a clear mandate of public policy.”” Carter v, District of Columbia, 980 A.2d 1217 (DC, 2009) citing District of Columbia v. Beretta, U.S.A., Corp., 812 A.2d 633, 645 (D.C.2005) (en banc) (quoting Carl v. Children's Hosp., 702 A.2d 159, 164 (D.C.1997) (Terry, J., concurring)); see also Fingerhut v. Children's Nat'l Med. Ctr, 738 A.2d 799, 803-04 (D.C.1999); Adams v. George W. Cochran & Co., 597 A.2d 28, 34 (D.C.1991). 87. Plaintiff's discharge violates clear public policy mandates against government corruption. Specifically, the following acts by District government officials violate clear mandates of public policy: a, Attempting to influence Plaintiff in the source selection for the Buzzard Point and St. Elizabeths contracts; Attempting to influence Plaintiff to modify the award to Schlosser; Attempting to influence Plaintiff to terminate the award to Gilbane; Directing Plaintiff'to modify the award to Schlosser; Directing Plaintiff to terminate the award to Gilbane; Directing Plaintiff to refrain from issuing and filing the D&F; aos 18g. Directing Plaintiff to increase the CBE requirement from 35% to 74% to shift a large percentage of the contract work to Ft. Myer; 88. The District has clear public policy interest in ensuring transparency and fairness in procurements, and engendering the confidence of District residents, businesses, and procurement professionals in the integrity of the procurement process, as evidenced by the PPRA 89, The District has a clear public policy interest in preventing high-ranking officials from directing procurements towards government contractors who donate large sums of money to the administration the officials serve and retaliating against employees who refuse to assist. Fi. Myer, one of the largest campaign contributors to Mayor Muriel Bowser and her now- defunct Fresh Political Action Committee, was the losing bidder for the Buzzard Point and St. Elizabeths awards, When it was clear that Ft, Myer would not be awarded the contract, Admiral Weaver was instructed to terminate Plaintiff's employment, When Admiral Weaver refused, Administration officials arranged Plaintiff's termination, 90. The District has a clear public policy interest in preventing high-ranking officials from interfering with the procurement process in a way that would waste millions in taxpayer dollars, Plaintiff awarded the St. Elizabeth contract to Gilbane, instead of the Administration's preferred contractor, Ft. Myer, because Gilbane’s bid was almost $10 million less than Ft, Myers’ bid, By refusing to buckle to the pressure applied by Defendant ‘Young and EOM Officials, Plaintiff saved nearly $10 million taxpayer dollars. 91. Ignoring these policies would be contrary to the District’s public policy interest in preventing, the chilling effect the termination of an employee who refuses to assist in contract steering would have on other employees. 92. Plaintiff's termination was against clear public policy mandates. 1993, 94, Plaintiff suffered, and continues to suffer, severe emotional stress and mental anguish as a result of Defendants’ actions and omissions. Plaintiff's professional reputation has been irreparably damaged because of the Defendants’ actions. As a result of the actions of the District and its officials, Plaintiff suffered financial losses, lost wages, lost benefits, pension losses, pain and suffering, embarrassment and humiliation, and permanent damage to his professional reputation WHEREFORE, Plaintiff requests that this Court issue a judgment against the Defendants in the amount of $5,000,000 in compensatory damages and $5,000,000 in punitive damages against the individual defendant 95: 96. 97. 98. COUNTIN DEFAMATION OF CHARACTER LIBEL AND SLANDER ALL DEFENDANTS Plaintiff hereby incorporates by reference the allegations contained in paragraphs 1-94 as if fully set forth herein, Defendants made and publicized false and defamatory statements about the Plaintiff's job performance and the purported reasons Plaintiff was terminated from his employment with the District, Defendants’ statements were made by Defendant Young and are attributable to Defendant District since Defendant Young is a District employee and, as City Administrator, a high- ranking government official Defendants’ statements were publicized to the Kojo Nnamdi radio show and the Washington City Paper. Subsequently the Defendants’ statements appeared in every major newspaper in the Greater Washington Metropolitan Area, 2099. Spe lly, Defendant Young stated on The Kojo Nnamdi Show on August 29, 2016 that Plaintiff was terminated because he: a, Disadvantaged CBEs when he made “changes to a longstanding practice that favored CBEs in getting preference points. .”; Changed longstanding practices and policies without the approval of his superiors, the City Administrator's office, or EOM; Engaged in “indefensible procurement practices”; “exposed [the District] to millions of dollars of financial losses...”; failed to “fairly and appropriately within guidelines policy and practice administer procurement solicitations in the District of Columbia...” s es 100. Defendant Young also stated to the Washington City Paper on September 1, 2016 that the contracting system put in place by Plaintiff was “indefensible.” 101, When asked why Plaintiff was terminated Rob Hawkins, Spokesman for DC Mayor Muriel Bowser, stated to the Washington City Paper on September 1, 2016 that the yees who seek to “undermine local and minority administration would not tolerate empl: businesses 102, These statements are particularly damaging to Plaintiff, a government contracting and procurements professional whose reputation in the community has been damaged by the public characterization that he was terminated because he was a rogue employee who changed government policies without authorization, discriminated against minority businesses by undermining their ability to win government contracts, and exposed the ‘government to millions of dollars in financial losses. 103. None of the statements published about Plaintiff were true, In fact, Plaintiff's termination appears to be related to the fact that Ft, Myer, which happens to be one of the largest campaign contributors to Mayor Muriel Bowser and her now-defunct Fresh Political Action Committee, lost out on two government contracts, 21104, Defendants had no right, consent, permission, or privilege to publish the above statements about the Plaintiff to the public. No reasonable person in Defendants’ position would have published such false and defamatory statements regarding a government employee knowing that the consequences would be damaging to the employee's reputation and that it would limit and inhibit the employee's future job prospects 105. Knowing the possible consequences to Plaintiff, Defendants made and published the above statements nonetheless, 106. Defendants’ publicized statements were false. Plaintiff did not disadvantage CBEs during his tenure at DGS. Plaintiff did not implement s ‘stems or make changes to practices or policies without the express consent and encouragement of his superiors. Plaintiff did not implement any procurement system changes that were not approved by his superiors. Plaintiff used best practi in his procurements, Plaintiff did not expose the District to millions of dollars of financial losses; in fact, Plaintiff saved District taxpayers almost $10 million on the St, Elizabeths procurement, Plaintiff fairly and appropriately, within guidelines policy and practice, administered procurement solicitations on behalf of DGS. 107. Asa result of the oral and written statements published by Defendants, Plaintiff suffered special harm to his reputation as colleagues questioned Plaintiff about his job performance and whether he implemented policies without Admiral Weaver's approval. After the Defendants’ statements, Plaintiff was regarded as a rogue employee by his colleagues and associates, having to explain and defend himself against Defendants’ allegations. Plaintiff suffered, and continues to suffer, severe emotional stress and mental anguish as a result of Defendants’ actions and omissions. Plaintiff was embarrassed and humiliated by Defendants’ false statements about his job performance as any reasonable person would be. 2108. _ Plaintiff's professional reputation has been irreparably damaged because of the Defendants’ actions WHEREFORE, Plaintiff requests that this Court issue a judgment against the Defendants in the amount of $5,000,000 in compensatory damages and $5,000,000 in punitive damages against the individual defendant. COUNT IV INVASION OF PRIVACY — FALSE LIGHT ALL DEFENDANTS 109. _ Plaintiff hereby incorporates by reference the allegations contained in paragraphs 1-108 as if fully set forth herein 110, Defendants published statements about the Plaintiff's job performance and the purported reasons Plaintiff was terminated from his employment with the District. 111, Defendants’ statements were made by Defendant Young and are attributable to Defendant District since Defendant Young is a District employee and, as City Administrator, a high-ranking government official. 112, Defendants’ statements were publicized to the Kojo Nnamdi radio show and the Washington City Paper. Subsequently the Defendants” statements appeared in every major newspaper in the Greater Washington Metropolitan Area. 113, Specifically, Defendant Young stated on The Kojo Nnamdi Show on August 29, 2016 that Plaintiff was terminated because he: a, Disadvantaged CBEs when he made “changes to a longstanding practice that favored CBEs in getting preference points..." Changed longstanding practices and policies without the approval of his, superiors, the City Administrator's office, or EOM; Engaged in “indefensible procurement practices”; “exposed [the District] to millions of dollars of financial losses...”; failed to “fairly and appropriately within guidelines policy and practice administer procurement solicitations in the District of Columbia...” - pee 23114, Defendant Young also s ated to the Washington City Paper on September 1, 2016 that the contracting system put in place by Plaintiff was “indefensible.” 115, When asked why Plaintiff was terminated Rob Hawkins, Spokesman for DC Mayor Muriel Bowser, stated to the Washington City Paper on September 1, 2016 that the administration would not tolerate employees who seek to “undermine local and minority businesses 116, These statements are particularly damaging to Plaintiff, a government contracting and procurements professional whose reputation in the community has been damaged by the public characterization that he was terminated because he was a rogue employee who changed government policies without authorization, discriminated against minority businesses by undermining their ability to win government contracts, and exposed the government to millions of dollars in financial losses. 117. Defendants’ statements were obviously about Plaintiff since Defendant Young agreed to appear on the Kojo Nnamdi Show specifically to discuss the “shake-up” at DGS. This “shake-up” involved Plaintiff and Carlos Sandoval, the Deputy General Counsel for DGS. Of the two, Plaintiff had primary responsibility for procurements and he relied on the advice and counsel of Mr. Sandoval. The statements made were about poor procurement practices, policies, and procedures which risked costing the District millions of taxpayer dollars. 118, Defendants’ statements, oral and written, placed Plaintiff in a false light to the general public in the Metropolitan DC Area, his colleagues and associates, former and potential employers, and his family and friends, Defendants’ statements were offensive to PlaintitY and would have been offensive to a reasonable person. 24119, None of the statements published about Plaintiff were true. In fact, Plaintif?’s termination appears to be related to the fact that Ft. Myer, which happens to be one of the largest campaign contributors to Mayor Muriel Bowser and her now-defunct Fresh Political Action Committee, lost out on two government contracts, 120, Defendants had no right, consent, permission, or privilege to publish the above statements about the Plaintiff to the public. No reasonable person in Defendants’ position would have published such false and defamatory statements regarding a government employee knowing that the consequences would be damaging to the employee's reputation and that it would limit and inhibit the employee's future job prospects 121. Knowing the possible consequences to Plaintiff, Defendants made and published the above statements nonetheless, 122, Defendants’ publicized statements were false. Plaintiff did not disadvantage CBEs during his tenure at DGS. Plaintiff did not implement systems or make changes to practices or policies without the express consent and encouragement of his superiors. Plaintiff did not implement any procurement system changes that were not approved by his superiors. Plaintiff used best practices in his procurements. Plaintiff did not expose the District to millions of dollars of financial losses; in fact, Plaintiff saved District taxpayers almost $10 million on the St. Elizabeths procurement. Plaintiff fairly and appropriately, within ‘guidelines policy and practice, administered procurement solicitations on behalf of DGS. 123, Asa result of the oral and written statements published by Defendants placing Plaintiff in a false light to the public, Plaintiff suffered special harm to his reputation as colleagues questioned Plaintiff about his job performance and whether he implemented policies without Admiral Weaver's approval. After the Defendants’ statements, Plaintiff was regarded as a 25rogue employee by his colleagues and associates, having to explain and defend himself against Defendants’ allegations 124, Plaintiff suffered, and continues to suffer, severe emotional stress and mental anguish as, a result of Defendants’ actions and omissions, Plaintiff was embarrassed and humiliated by Defendants’ false statements about his job performance as any reasonable person would be. 125, Plaintiff's professional reputation has been irreparably damaged because of the Defendants’ actions. WHEREFORE, Plaintiff requests that this Court issue a judgment against the Defendants in the amount of $5,000,000 in compensatory damages and $5,000,000 in punitive damages against the individual defendant. JURY DEMAND Plaintiff demands a trial by jury in this matter. Dated: Respecttully submitted, ambers [980872] ‘The Chambers Firm, L 8403 Colesville Road Suite 1100 Silver Spring, MD 20910 (240) 638-2831 darrell@chambersfirmDCMD.com 26Superior Court of the District of Columbia CIVIL DIVISION- CIVIL ACTIONS BRANCH Yale T Ane meres " pac ramber 52016 Dutrct of Clumbi'a Ftal. ‘One ofthe defendants is being sued in thee official capacity. ‘Name: (Please Prin ipo Law Peeve POTN ral \ Chambers ace Firm Name:- + forney for — he. Chownlaes ic fi a) C2 saitro sey elephone No: ix digit Unified Baz Nor ‘ane. 634%~ 343) 30 673 © otter: ‘TyPE OF case: C) NonJury 6 Person Jury © 12 Person Jury Demand: $10, 000 9g0 Other: PENDING CASE(S) RELATED TQ THE ACTION BEING FILED CaseNo.: 2016 CA 73 PS sudge: Me Dameo Calendar é: Case Nox: Judge: Calendart NATURE OF SUIT: __ (Check One Box Only) A, CONTRACTS COLLECTION CASES Do. Breach of Contract 2 ta tinder $25,000 Pte Grants Consent [I 16 Under $25,000 Consent Denied (G02 Breach of Warranty 2117 ovER 525,000 Pe Grants Consent] 18 OVER $25,000 Consent Denied (L0G Negotiable Instrument 1] 27 Insurance/Subrogation (226 Insuranee/Subrogation [07 Personal Property ‘Over $25,000 Pit. Grants Consent Over $25,000 Consent Denied B13 Employment Discrimination [7] 07 InsurancelSubrogation| 734 Insurance/Subrogaton [515 Special Education Fees ‘Under $25,000 Pitt Grants Consent Under $25,000 Consent Denied 28 Motion to Confirm Arbitration Avvard (Colletion Cases Onty) B. PROPERTY TORTS Dot Automobite 03 Destruction of Pavate Property I 05 Trespass Der Conversion 04 Property Damage 07 Shopliting, D.C. Code § 27-102 (0) C. PERSONAL TORTS D1 Abuse of Process [10 ineasion of Privacy (C17 Persona Injury: (Not Automobile, (©102 Alienation of affection [£11 Libel and Slander ‘Not Malpractice) 03 Assault and Battery: 12 Malicious interference 1 iswrongfat Death (Not Malpractice) Ht Atcmote Peso iniry 1 13 Males Prone Ci) Wenge Eton 15105 Deceit Misrpresentstion) ] 14 Malpractice Legal B2oriendly Suit 1506 False Accusation EES walpsice Metical att Wig sy E]21 Asbestos [07 False Arest Ele Negligence (Not Automobile, 1 22 Toxic/Mass Tors os Fraud "Not Malpractice) 123 Tobacco [724 Lea Paine SEE REVERSE SIDE AND CHECK HERE IF USED (€V-496i4une 2015,Information Sheet, Continued C. OTHERS Dor Accounting (717 Merit Personnel Act (OBA) T1102 An. Before Judgment (DC. Code Tike 1, Chapter 6) B05 ejectment 1D 1s Product Liability 0» Special Wri Warrants (DC Code § 11-941) [24 Application to Conse, Modify, [110 Trafic Adjudication ‘Vacate Arbitration Award (DC Code § 16-4401) 111 Writ of Replevin [5 20 Merit Personnel Act (OHR) iE nForce Mechanics Lien 2) 31 Housing Code Regulations Cio Declaratory dgment Tam “3 Whistleblower 1 02 Change of Name 15 Libel of information 06 Foreign SudgmenDomestic [} 19 Enter Administrative Order as Glos Foreign Judgmenvimemational Judgment { D.C. Code § 113 Comection of Birth Certificate 2-1802.03 (h) oF 32-151 9 (0) 2 14 Contection of Marriage © 20 Master Meter (D.C. Code § Cerificate 42.3301, et seq), (L 26 Petition for Civil Asser Forfeiture (Vehicle) TD 27 Petition for Civil Asset Forfeiture (Curency) 7 28 Petition for Civ Asset Forfeiture (Other) 121 Petition for Subpoena, [Rute 2641 @)) 22 Release Mechanice Lien 2 Rute270x1) (Perpetuate Testimony) 7 24 Petition for Strctured Settlement (5 25 Petition for Liquidation D. REAL PROPERTY 09 Real Property-Real Estate hos Quiet Tite BP? Specific Perfomance (25 Liens: Tex / Water Consent Granted 5) 04 Condemnation (Eminent Domain) }30 Liens: Tax / Water Consent Denied Elo Mongage ForeclosureJudicial Sate [131 Tax Lien Bid Of Certificate Consent Granted 5 1s Petition for Civil Asset Forfeiture (RPY A Attorney's Signature (€V-496/ Jone 2015 PLES Bole~ Superior Court of the District of Columbia an ae ow ‘Washington, D.C. 20001 Telephone: (202) 879-1133 Mine asds elle — “ ‘Case Number Distivet of Columbia, Sires OA Suan SUMMONS ‘To the above named Defendant: ‘You are hereby summoned and required to serve an Answer to the attached Complaint, either Personally or through an attorney, within twenty (20) days after service of this summons upon you, exclusive of the day of service. If you are being sued as an officer or agency of the United States Government or the District of Columbia Goverment, you have sixty (60) days after service of this summons to serve your Answer. A copy of the Answer must be mailed to the attomey for the party plaintiff who is suing you. ‘The attomey’s name and address appear below. if plaintiff has no attomey, a copy of the Answer must be mailed to the plaintiff at the address stated on this Summons. ‘You are also required to file the original Answer with the Court in Suite 5000 at 500 Indiana Avenue, N.W., between 8:30 a.m, and 5:00 p.m., Mondays through Fridays or between 9:00 a.m, and 12:00 noon on Saturdays. You may file the original Answer with the Court either before you serve a copy of the Answer on the plaintiff or within five (5) days after you have served the plaintiff. If you fil to file an Answer, judgment by default may be entered against you for the relief demanded in the complaint, ee Bore I Cramlecs Wa2 Coksw(k Road — Si MS 20% Deputy Clerk (290) € 38- j 7 "Telephone SORBR WIT Om) s7O4I ——_Vaslor epee ou (202) 70-428 pour une aucon Edm ich iy oi (02) 870-4828 I tee, (202) 70-4828. NEA — eaeNCH Hove” AOrTHD (20) 8704828 eat Clerk of the Court IMPORTANT: IF YOU FAIL TO FILE AN ANSWER WITHIN THE TIME STATED ABOVE, OR IF, AFTER YOU ANSWER, YOU PAIL TO APPEAR AT ANY TIME THE COURT NOTIFIES YOU TO DO SO, A JUDGMENT BY DEFAULT MAY BE ENTERED AGAINST YOU FOR THE MONEY DAMAGES OR OTHER RELIEF DEMANDED IN THE COMPLAINT. IF THIS OCCURS, YOUR WAGES MAY BE ATTACHED OR WITHHELD OR PERSONAL PROPERTY OR REAL ESTATE YOU OWN MAY BE TAKEN AND SOLD TO PAY THE JUDGMENT. IF YOU INTEND TO OPPOSE THIS ACTION, 1F you with otto a lawyer and fel hat you camo afford to pay a fet a awyer, promptly contact oe ofthe offices ofthe Legal 'Ai Solty (202-6216) or te Neiitorhod Legal Suess (202-2795 100) or beh oF cone Sane 300 8 HD Indiana Avenue, NW, for more information concerning places whee you may ask for soch help. See reverse side for Spanish transation ‘Vea al dorso la traducci6n al espaol [FORM SUMMONS Jen 2012 CASUM doeSuperior Court of the District of Columbia CIVIL DIVISION 500 Indiana Avenue, N.W., Suite 5000 ‘Washington, D.C. 20001 Telephone: (202) 879-1133 A\oo mr * Case Number Dist of Glunbia, Sever May Boasee ad SUMMONS To the above named Defendant: You are hereby summoned and required to serve an Answer to the attached Complaint, either personally or through an attomey, within twenty (20) days after service of this summons upon you, exclusive of the day of service. If you are being sued as an officer or agency of the United States Government or the District of Columbia Government, you have sixty (60) days after service of this summons to serve your Answer. A copy of the Answer must be mailed to the attomey for the party plaintiff who is suing you, ‘The attomey’s name and address appear below. If plaintiff has no attorney, a copy of the Answer must be mailed to the plaintiff atthe address stated on this Summons, ‘You are also required to file the original Answer with the Court in Suite 5000 at 500 Indiana Avenue, N.W., between 8:30 am. and 5:00 p.m., Mondays through Fridays or between 9:00 a.m, and 12:00 noon on Saturdays. You may file the original Answer with the Court either before you serve a copy of the Answer on the plaintiff or within five (5) days after you have served the plaintiff. Ifyou fil to file an Answer, judgment by default may be entered against you for the relief demanded in the complaint, Rove C S ‘Name of PainifPs Atiomey 2 eX GUO® Coles By camel vel Spring, MS 20% Peoaty Ck (a4) €38- QRdi Dee "Feiephone SOE AFT ER (202) 670.4828 Vouiles appeer au (202) 879-4828 pour une aduction DL bit ii dich, hy go (202) 879-4828 eis BAD, 202) 670-4008. RIRAIAD —eneVCY HCA AMTFD (200) 870-4828 perm Clerk of the Court IMPORTANT: IF YOU FAIL TO FILE AN ANSWER WITHIN THE TIME STATED ABOVE, OR IF, AFTER YOU ANSWER, YOU FAIL TO APPEAR AT ANY TIME THE COURT NOTIFIES YOU TO DO SO, A JUDGMENT BY DEFAULT. MAY BE ENTERED AGAINST YOU FOR THE MONEY DAMAGES OR OTHER RELIEF DEMANDED IN THE COMPLAINT. IF THIS OCCURS, YOUR WAGES MAY BE ATTACHED OR WITHHELD OR PERSONAL PROPERTY OR REAL ESTATE YOU OWN MAY BE TAKEN AND SOLD TO PAY THE JUDGMENT. IF YOU INTEND TO OPPOSE THIS ACTION, i ym i tk oct ey rm eo fi coat ae Na cet eae Sr i et irom nae Sey uss taerne na sce See reverse side for Spanish translation ‘Vee al dotso la traduccién al espaol FORM SUMMONS Jan. 2011 ASU doeSuperior Court of the District of Columbia CIVIL DIVISION 500 Indiana Avenue, N.W., Suite 5000 ‘Washington, D.C. 20001 Telephone: (202) 879-1133 y nko Tt Ales : hay Case Number Qe shad Young in his Drdividual Gpocity SUMMONS To the above named Defendant: ‘You are hereby summoned and required to serve an Answer to the attached Complaint, either Personally or through an attorney, within twenty (20) days after service of this summons upon you, exclusive Of the day of service. If you are being sued as an officer or agency of the United States Government or the District of Columbia Government, you have sixty (60) days after service of this summons to serve your Answer. A copy of the Answer must be maifed to the attomey for the party plaintiff who is suing you. ‘The attomey’s name and address appear below. If plaintiff has no attorney, a copy of the Answer must be mailed to the plaintiff at the address stated on this Summons. ‘You are also required to file the original Answer with the Court in Suite 5000 at 500 Indiana Avenue, N.W.., between 8:30 a.m. and 5:00 p.m., Mondays through Fridays or between 9:00 a.m. and 12:00 noon on Saturdays. You may fie the original Answer with the Court either befare you serve a copy of the Answer on the plaintiff or within five (5) days after you have served the plaintiff. Ifyou fail to file an Answer, judgment by default may be entered against you for the relief demanded in the complaint, Nave Cha mrs Clerk of the Court ‘Name of Plaintiff's Attomey i} UNQ Coles’[k Road by eS S Lee Sein, MD 20% Peoaty Ce (aC 38- 284] Date Smme Tea coneTo«1 ——_vshzap ae parison Blouse ream (ete HEAL, 202) 079.4678 @ IMEAAG —eDeMEN HCH AMPED (200) 970-4008 San IMPORTANT: IF YOU FAIL TO FILE AN ANSWER WITHIN THE TIME STATED ABOVE, OR IF, AFTER YOU ‘ANSWER, YOU FAIL TO APPEAR AT ANY TIME THE COURT NOTIFIES YOU TO DO SO, A JUDGMENT BY DEFAULT MAY BE ENTERED AGAINST YOU FOR THE MONEY DAMAGES OR OTHER RELIEF DEMANDED IN THE COMPLAINT. IF THIS OCCURS, YOUR WAGES MAY BE ATTACHED OR WITHHELD OR PERSONAL PROPERTY OR REAL ESTATE YOU OWN MAY BE TAKEN AND SOLD TO PAY THE JUDGMENT. IF YOU INTEND TO OPPOSE THIS ACTION, | you wish to talk toa lawyer and feel that you cannot afford to pay a fee to a lawyer, promptly contact one ofthe offices of the Legal Aid Society (202-628-1161) or the Neighborhood Legal Services (202-279-5100) for help or come to. Suite 5000 at 500 Indiana Avenue, N.W., for more information concerning places where you may ask for such help. See reverse side for Spanish transtation ‘Vee al dorso la traducci6n al espafiol FORM SUMMONS Jen 2011 ‘CASUM doeSuperior Court of the District of Columbia CIVIL DIVISION 500 Indiana Avenue, N.W., Suite S000 ‘Washington, D.C. 20001 Telephone: (202) 879-1133 Wika E Alng Pashod bun Ct Ndmiattra for O€6eia) Capacity a SUMMONS ‘Case Number To the above named Defendant; ‘You are hereby summoned and required to serve an Answer to the attached Complaint, either Personally or through an attomey, within twenty (20) days after service of this summons upon you, exclusive of the day of service. If you are being sued as an officer or agency of the United States Government or the District of Columbia Goverment, you have sixty (60) days after service of this summons to serve your Answer. A copy of the Answer must be mailed to the attomey for the party plaintiff who is suing you. ‘The attorney's name and address appear below. If plaintiff has no attorney, a copy of the Answer must be mailed to the plaintiff at the address stated on this Summons. ‘You are also required to file the original Answer with the Court in Suite S000 at 500 Indiana Avenue, N.W., between 8:30 a.m. and 5:00 p.m., Mondays through Fridays or between 9:00 a.m, and 12: 00 noon on ‘Saturdays. You may file the original Answer with the Court either before you serve a copy of the Answer on the plaintiff or within five (5) days after you have served the plaintif. Ifyou fil to fle an Answer, judgment by default may be entered against you forthe relief demanded in the complaint. don Ln Cha mics Clerk of the Court Name of Pint Auosey $402 eswi'l{e Road By MNS itvec Sorina, MDS 20% Pepa Ce ACI ART Date SRORMITEH consecrate aioiebaisporum ican phous uiaa nrenean enue let BA, 202) 870.4008. IMRIMG PNAC HCE ATTA (200) 879-4908 Beane IMPORTANT: IF YOU FAIL TO FILE AN ANSWER WITHIN THE TIME STATED ABOVE, OR IF, AFTER YOU ANSWER, YOU PAIL TO APPEAR AT ANY TIME THE COURT NOTIFIES YOU TO DO SO, A JUDGMENT BY DEFAULT MAY BE ENTERED AGAINST YOU FOR THE MONEY DAMAGES OR OTHER RELIEF DEMANDED IN THE COMPLAINT. IF THIS OCCURS, YOUR WAGES MAY BE ATTACHED OR WITHHELD OR PERSONAL PROPERTY OR REAL ESTATE YOU OWN MAY BE TAKEN AND SOLD TO PAY THE JUDGMENT. IF YOU INTEND TO OPPOSE THIS ACTION, DONOT PAL 70 ANSWER WITHIN THE REQUIRED TIME, of te offices of the 1F you wis tak oa lawyer ad el hat you cant afford to pay ae ting, promptly contact on ofthe Legal A Society (212-628-1161) orth Neigbornod Legal Serves (202-2785100) or help arson © Sue S00) 30D India Avenue, N.W, for more information conceming places wre you may ask for such ep ‘See reverse side for Spanish translation ‘Vea al dorso la tradueci6n al espaol FORM SUMMONS Jan 2013 CASUM doe