You are on page 1of 15

Case 3:18-cv-02081-M Document 1 Filed 08/09/18 Page 1 of 13 PageID 1

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION

DANETTE GALVIS, §
§
Plaintiff, §
§
v. §
§ CIVIL ACTION NO. _______________
HOLY YOGA FOUNDATION and §
HOLY YOGA GLOBAL, LLC, §
§
Defendants. §

PLAINTIFF’S ORIGINAL COMPLAINT

TO THE HONORABLE JUDGE OF SAID COURT:

Plaintiff Danette Galvis (“Plaintiff” or “Galvis”) files this her Original Complaint against

Defendants Holy Yoga Foundation and Holy Yoga Global, LLC (collectively “Defendants,” the

“Company,” or “Holy Yoga”) and would respectfully show the Court as follows:

I. PARTIES

1. Ms. Galvis is an individual who currently resides in Dallas County, Texas, and resided in

Dallas County, Texas throughout her former employment with Defendants.

2. Defendant Holy Yoga Foundation (“Holy Yoga”) is an Arizona based non-profit

organization that is authorized to do business in Texas. Holy Yoga may be served with process

through the Texas Secretary of State’s office. 1 See FED. R. CIV. P. 4(h)(1)(A); FED. R. CIV. P.

(e)(1); TEX. BUS. ORG. C. § 5.251(1)(A).

1
Prior to her resignation, Ms. Galvis was the Registered Agent for Holy Yoga. Ms. Galvis resigned as Holy Yoga’s
Registered Agent effective August 6, 2018. See Exhibit A, Certificate of Filing of Resignation of Registered Agent
for Holy Yoga Foundation. As of the date of filing, Holy Yoga has not appointed a replacement Registered Agent,
and, thus, may be served through the Texas Secretary of State’s office per Tex. Bus. Org. C. § 5.251(1)(A).

PLAINTIFF’S ORIGINAL COMPLAINT PAGE 1
Case 3:18-cv-02081-M Document 1 Filed 08/09/18 Page 2 of 13 PageID 2

3. Defendant Holy Yoga Global, LLC is a Delaware limited liability company, which is an

affiliate or subsidiary of Holy Yoga Foundation and is authorized to do business in Texas. Holy

Yoga Global, LLC may be served with process through Texas Secretary of State’s office. See FED.

R. CIV. P. 4(h)(1)(A); FED. R. CIV. P. (e)(1); TEX. BUS. ORG. C. § 5.251(1)(A).

II. JURISDICTION AND VENUE

4. The Court has subject matter jurisdiction under 28 U.S.C. § 1331 because this civil action

arises under Title VII of the Civil Rights Act of 1964, 42 U.S.C. §2000e et. seq., as amended. The

Court has supplemental jurisdiction over the Plaintiff’s defamation claim, which is based on Texas

law, as conferred on this Court by 28 U.S.C. § 1367, since it is related to her Title VII claims.

5. The Court has personal jurisdiction over Defendants because the entities conduct business

in Texas and have entered into a contractual relationship with Ms. Galvis in Texas, and committed

actions in Texas that give rise to this cause of action.

5. Venue is proper in the Northern District of Texas, Dallas Texas, pursuant to 28 U.S.C.

§ 1391(b)(2), because a substantial part of the events or omissions giving rise to the claims herein

occurred in this District.

6. On or about June 1, 2018, Ms. Galvis filed a Charge of Discrimination with the Equal

Employment Opportunity Commission (“EEOC”), alleging sexual harassment, discrimination,

and retaliation for engaging in protected activity. This action is being commenced within the

required time limits of Title VII, in that (a) the charge was filed with the EEOC within 300 days

of the actions being complained of in this lawsuit, and (b) this action is being filed within ninety

(90) days of receiving the Notice of Right to Sue from the EEOC.

PLAINTIFF’S ORIGINAL COMPLAINT PAGE 2
Case 3:18-cv-02081-M Document 1 Filed 08/09/18 Page 3 of 13 PageID 3

III. FACTUAL BACKGROUND

7. Holy Yoga is a religious organization that touts itself as using yoga to serve as a Christian-

focused organization. While Holy Yoga holds itself out as a “ministry,” none of the instructors or

leaders are required to become ordained ministers, whether they serve as volunteers or full-time

employees.

8. Ms. Galvis became a volunteer instructor for Holy Yoga in the spring of 2010, shortly after

receiving her certificate as a yoga instructor. In that capacity, Ms. Galvis was instrumental in

facilitating Holy Yoga’s brand and growth strategy in the Dallas area. In fact, Ms. Galvis began

Holy Yoga’s first set of classes in several Dallas area locations.

9. Because Ms. Galvis’ contribution to growing Holy Yoga’s footprint in the Dallas area for

several years was so significant, Holy Yoga hired Ms. Galvis as a part-time employee in April

2016 to become the Southwest Regional Director, responsible for Texas, Arizona, New Mexico,

and Oklahoma. As Southwest Regional Director, Ms. Galvis was responsible for welcoming new

instructors, managing Holy Yoga’s FaceBook page, equipping instructors to grow in their own

cities, attend leadership conference calls, planning and preparing Regional Leaders’ conference

calls, attending two Holy Yoga Immersion retreats each year, and hosting various events for the

Southwest Region. Ms. Galvis reported directly to Brooke Toftoy, the Community Development

Director.

10. One talent Ms. Galvis developed while serving as Holy Yoga’s Southwest Regional

Manager was to provide paid instructional classes for students who attended in person and classes

provided through Holy Yoga’s website. Ms. Galvis’s talents for teaching such classes resulted in

Holy Yoga promoting Ms. Galvis to Retreat & Event Director in May 2017, Ms. Galvis’s second

promotion with the Company.

PLAINTIFF’S ORIGINAL COMPLAINT PAGE 3
Case 3:18-cv-02081-M Document 1 Filed 08/09/18 Page 4 of 13 PageID 4

11. As Holy Yoga’s Retreat & Event Director, Ms. Galvis was charged with the planning and

execution of Holy Yoga’s Immersion Retreats (the in-person, national yoga workshops) and the

Holy Yoga Experience (its subscription, on-line based training). As the Retreat & Event Director,

Ms. Galvis was also responsible for the training and management of the Events Coordinator, and

any additional Retreat Coordinator Assistants needed to coordinate Immersion Training Retreats.

As Retreat & Event Director, Ms. Pearson remained one of Ms. Galvis’s supervisors once she

become Retreat & Event Director. Ms. Galvis also began reporting to Jonnie Goodmanson, Holy

Yoga’s Chief Operating Officer with her new role.

12. Ms. Galvis accepted the promotion as Holy Yoga’s Retreat & Event Director and was

successfully fulfilling her responsibilities as detailed in her job description. In October 2017, she

organized a retreat in Arizona for approximately 300 students who flew across the world to attend

the 6-day training, required in-person hours for certification.

13. Every Holy Yoga employee who works a retreat is encouraged to take at least one class

during any one retreat, to enjoy the experience for themselves and to help ensure that the paying

patrons are feeling satisfied with the classes Holy Yoga is providing on-site.

14. On or about October 23, 2017, Ms. Galvis decided to take one of the classes for the

retreat—led by Beverly Steiger, Holy Yoga’s Northeast Regional Director. Dianne Suozzo,

another leader from Holy Yoga’s Northeast Region, was assigned as one of Ms. Steiger’s

instruction assistants for that class. Ms. Suozzo’s responsibilities as an instruction assistant was to

observe every student, and make certain adjustments to enable the students to mimic each of the

poses Ms. Steiger led them into following during her sequencing. If a particular student struggled

with reaching a particular pose, Ms. Suozzo would help each student physically achieve each pose

as best as possible, without hurting them.

PLAINTIFF’S ORIGINAL COMPLAINT PAGE 4
Case 3:18-cv-02081-M Document 1 Filed 08/09/18 Page 5 of 13 PageID 5

15. Ms. Suozzo came up behind Ms. Galvis during the class and hugged Ms. Galvis from

behind, in a yoga pose that had Ms. Suozzo pressing the front of her body, with her chest, against

Ms. Galvis’s back and buttocks.

16. Ms. Galvis initially considered Ms. Suozzo adjustment “hug” as “normal” since she

believed Ms. Suozzo was giving her an adjustment as she was required to do as an instruction

assistant. However, Ms. Suozzo’s adjustment “hug” continued through a series of 3 poses and

took a completely abnormal turn, as soon as Ms. Suozzo simultaneously being whispering in an

intimate manner to Ms. Galvis, very close to Ms. Galvis’s ear: “You are so beautiful,” and

“shhhhhh” as Ms. Galvis asked her to stop. Ms. Galvis continued to a third pose as instructed and

Ms. Suozzo went to the other side of Ms. Galvis’s body and continued to whisper: “I mean, if I

wasn’t married…”

17. Ms. Suozzo’s behavior shocked Ms. Galvis. Ms. Suozzo’s conduct made Ms. Galvis

believe that Ms. Suozzo was making sexual advances towards her in class, in front of several

hundred people, at a Christian-based retreat. While this was the first time Ms. Suozzo made sexual

advances to Ms. Galvis, Ms. Galvis was aware of Ms. Suozzo’s own admissions of being sexually

attracted to women, despite the fact that Ms. Suozzo is married to a man who is a minister and a

board member of Holy Yoga.

18. Ms. Galvis was terribly shocked and physically unsettled by Ms. Suozzo’s conduct, so

much so that she discussed what occurred with Randi Wells, another Holy Yoga employee whom

Ms. Galvis considered to be a personal friend. Ms. Wells encouraged Ms. Galvis to immediately

report the incident to Ms. Pearson, one of her supervisors who was also attending the Arizona

Retreat. Within two hours of Ms. Suozzo’s unwelcome sexual harassment, Ms. Galvis reported

the incident to Ms. Pearson, who responded by saying she too was shocked by Ms. Suozzo’s

PLAINTIFF’S ORIGINAL COMPLAINT PAGE 5
Case 3:18-cv-02081-M Document 1 Filed 08/09/18 Page 6 of 13 PageID 6

conduct and would immediately report what occurred to Brooke Boon, Holy Yoga’s Founder and

CEO.

19. Later that same day, Ms. Galvis related Ms. Suozzo’s unwelcome sexual harassment to a

larger group of Holy Yoga’s leadership, many of whom were also aware of Ms. Suozzo’s history

of engaging in same-sex sexual relationships. The next day, Ms. Galvis began requesting the

chance to confront Ms. Suozzo directly in a meeting with Holy Yoga’s leadership team, a request

she made throughout the remainder of the Arizona Retreat. Holy Yoga refused Ms. Galvis’s

request.

20. After reporting Ms. Suozzo’s unwelcome sexual harassment towards her to Holy Yoga’s

leadership at least twice while on-site in Arizona, and discussing the incident at least a third time

via conference call after she returned to her Dallas home, Holy Yoga cut Ms. Galvis’s pay from

$30,000 per year to $18,000 per year on or about November 15, 2018. That pay cut was Holy

Yoga’s first wrongful and retaliatory action against Ms. Galvis for reporting Ms. Suozzo’s

unwelcome sexual harassment during the Arizona Retreat.

21. On or about November 22, 2017, Ms. Boon, the Founder/CEO, led a leadership conference

that was attended by approximately 30 other members of Holy Yoga’s leadership team, including

Ms. Galvis. During that call, Ms. Boon publicly informed Ms. Galvis that the Company was

demoting her from her current position of Retreat & Event Director. Additionally, Ms. Boon

informed Ms. Galvis that one of her subordinates, Beata Rafacz, would now be her boss. No one

at Holy Yoga gave Ms. Galvis any prior notice of her demotion prior to Ms. Boon’s public

announcement. That demotion constituted Holy Yoga’s second wrongful and retaliatory conduct

against Ms. Galvis for reporting Ms. Suozzo’s unwelcome sexual harassment during the Arizona

Retreat.

PLAINTIFF’S ORIGINAL COMPLAINT PAGE 6
Case 3:18-cv-02081-M Document 1 Filed 08/09/18 Page 7 of 13 PageID 7

22. Ms. Rafacz, who was present at the Arizona Retreat, had been hired by Holy Yoga as a

Retreat Coordinator while she worked full-time for another company. When Ms. Rafacz was hired,

she reported directly to Ms. Galvis. As a result of the wrongful and retaliatory demotion,

Ms. Rafacz became Ms. Galvis’s new supervisor.

23. After the November 22, 2017 leadership conference call that announced Ms. Rafacz’s

promotion as Retreat & Event Director and Ms. Galvis’s demotion to Retreat Coordinator,

Ms. Rafacz informed Ms. Galvis that she had not yet accepted the promotion as Retreat & Event

Director. In fact, Ms. Rafacz informed Ms. Galvis that she could only accept the Retreat & Event

Director position if Holy Yoga matched her then current salary of $65,000 per year—which was

more than double Ms. Galvis’s yearly salary of $30,000 as Retreat & Event Director. Ms. Rafacz

stated told Ms. Galvis Holy Yoga promised her that the Company would try to match her much

higher salary if she agreed to accept the position. Ms. Rafacz ultimately did accept that position,

and upon information and belief, remains in that position.

24. During one of her discussions with Holy Yoga’s leadership concerning Ms. Suozzo’s

unwelcome sexual harassment, which included both Ms. Boon and Ms. Pearson, Holy Yoga

informed Ms. Galvis that Ms. Suozzo’s unwelcome sexual harassment towards her was not Holy

Yoga’s responsibility, despite the fact that the conduct occurred during a Holy Yoga organized

event and while both employees were working on Holy Yoga’s benefit (at the Arizona Retreat).

25. Remarkably, Ms. Suozzo admitted to Ms. Galvis of making the “if you were married”

comment; however, she attempted to excuse away her statement as a “joke” which she realized

Ms. Galvis did not take well by Ms. Galvis’s facial expressions immediately thereafter. While

Ms. Suozzo explained she only meant the exchange as a compliment to Ms. Galvis for the success

PLAINTIFF’S ORIGINAL COMPLAINT PAGE 7
Case 3:18-cv-02081-M Document 1 Filed 08/09/18 Page 8 of 13 PageID 8

of the Arizona Retreat—rather than as an expression of sexual desire, she never addressed her

physical contact with Ms. Galvis during that same exchange.

26. After Holy Yoga retaliated against Ms. Galvis, first by significantly cutting her salary and

then demoting her, the Company made it clear to Ms. Galvis that it would accept her resignation

if she believed she could not continue on. Based on Holy Yoga’s refusal to take any remedial

measures in response to her complaint, and then retaliating against her for doing so, Ms. Galvis

felt she had no other option but resign her employment, resulting in her constructive dismissal.

27. Following Ms. Galvis’s constructive discharge, Holy Yoga engaged in social media with

the intent to disparage Ms. Galvis’s reputation. Due to Ms. Galvis’s visibility with Holy Yoga for

several years in the Dallas community, Ms. Galvis elected to make her separation from the

Company known through social media; however, with her announcement, Ms. Galvis was

intentionally vague concerning the incidents preceding her separation. Nonetheless, Holy Yoga

efforted to craft a social media narrative that placed full responsibility for her departure on

Ms. Galvis, and attempted to leave the impression that she engaged in some corporate malfeasance

prior to her departure.

28. Left with no other recourse, Ms. Galvis responded with the truth, that the Company failed

her, that it refused to remedy the illegal conduct brought against her by another Holy Yoga

employee, and she was essentially forced out in retaliation for engaging in protected activity by

reporting the unwelcome sexual harassment that Ms. Galvis felt should not be condoned by her

employer, especially one based on Christian principles.

29. Holy Yoga has continued to engage in untruthful, public statements meant to smear her

public reputation and image in a manner that causes harm to her, her reputation, and standing in

the community. In fact, the Company has publicly asserted that Ms. Galvis settled her claims

PLAINTIFF’S ORIGINAL COMPLAINT PAGE 8
Case 3:18-cv-02081-M Document 1 Filed 08/09/18 Page 9 of 13 PageID 9

against the Company through a compromise agreement and any of her false allegations are now

moot.

30. Based on Holy Yoga’s conduct, Ms. Galvis has suffered significant emotional, mental and

spiritual anxiety and stress that has significantly altered her life, her family life, and her ability to

grow the public standing she once enjoyed, separate and distinct from the personal financial

hardship the demotion and loss of her former employment has wrought on her ability to continue

in a similar position.

IV. CAUSES OF ACTION

Count One—Sex Discrimination

31. Plaintiff re-alleges and incorporates the allegations contained in Paragraphs 1 through 30

as if fully stated herein.

32. Plaintiff has satisfied all jurisdictional prerequisites in connection with her claim under

Title VII.

33. Defendants are an “employer” as defined by Title VII, and Defendants employ more than

15 individuals.

34. When the Plaintiff worked for Defendants, she was an “employee” as defined by Title VII.

35. Plaintiff has timely filed her charge of discrimination with the EEOC. All conditions

precedent to filing this action for discrimination under Title VII has been met. Plaintiff received

her Notice of Right to Sue on or about June 1, 2018.

36. Defendants violated Title VII by creating a hostile work environment and constructively

discharging Plaintiff and/or discriminating against Plaintiff in connection with the compensation,

terms, conditions, or privileges of employment because of Plaintiff’s sex. Defendants have

PLAINTIFF’S ORIGINAL COMPLAINT PAGE 9
Case 3:18-cv-02081-M Document 1 Filed 08/09/18 Page 10 of 13 PageID 10

engaged in a course of conduct of discrimination against Plaintiff because of her sex, and by

creating a hostile work environment.

37. Such discrimination against Plaintiff was intentional. Accordingly, Plaintiff is entitled to

recover damages for back pay, front pay, past and future pecuniary losses, emotional pain and

suffering, inconvenience, loss of enjoyment of life, and other non-pecuniary losses. Further, this

discrimination was done by Defendants with malice or with reckless indifference to Plaintiff’s

federally protected rights. Plaintiff is therefore also entitled to punitive damages in a sum which

is in excess of the minimum jurisdictional limit of this Court. Plaintiff is also entitled to recover

all costs of court, attorneys’ fees and expert fees as allowed by Title VII.

Count Two—Retaliation

38. Plaintiff re-alleges and incorporates the allegations contained in Paragraphs 1 through 37

as if fully stated herein.

39. Plaintiff placed Defendants on notice of a complaint of unlawful sex harassment in the

workplace.

40. Plaintiff’s complaint was based upon a good faith belief and evidence that she had been

sexually harassed in violation of Title VII and therefore constitutes a protected conduct under Title

VII.

41. Defendants unlawfully retaliated against Plaintiff for engaging in protected conduct by

creating a further hostile work environment and denying Plaintiff certain privileges of her position.

Defendants further retaliated against Plaintiff by forcing her, against her will, to resign her

employment.

42. Such retaliation against Plaintiff was intentional. Accordingly, Plaintiff is entitled to

recover damages for back pay, front pay, past and future pecuniary losses, emotional pain and

PLAINTIFF’S ORIGINAL COMPLAINT PAGE 10
Case 3:18-cv-02081-M Document 1 Filed 08/09/18 Page 11 of 13 PageID 11

suffering, inconvenience, loss of enjoyment of life, and other non-pecuniary losses. Further, this

retaliation was done by Defendants with malice or with reckless indifference to Plaintiff’s federally

protected rights. Plaintiff is therefore also entitled to punitive damages in a sum which is in excess

of the minimum jurisdictional limit of this Court. Plaintiff is also entitled to recover all costs of

court, attorneys’ fees and expert fees as allowed by Title VII.

Count Three—Defamation

43. Plaintiff re-alleges and incorporates the allegations contained in Paragraphs 1 through 42

as if fully stated herein.

44. Defendants published statements of fact referring to Plaintiff that were defamatory and

false. With regard to the truth of the statements, Defendants were: (1) acting with actual malice;

(2) negligent; and/or, (3) liable without regard to fault. As a result of Defendants’ defamation,

Plaintiff has suffered pecuniary injury.

45. Plaintiff has suffered actual and consequential damages in an amount that is within the

jurisdictional limits of this Court, for which Plaintiff now brings this lawsuit and seeks the recovery

of exemplary damages, interests and costs.

Count Four—Attorneys’ Fees

46. Plaintiff re-alleges and incorporates the allegations contained in Paragraphs 1 through 45

as if fully stated herein.

47. As a result of the actions of Defendants, it was necessary for Plaintiff to employ the services

of the undersigned counsel to conduct this litigation. Plaintiff is entitled to recover a sum equal to

all reasonable attorneys’ fees and costs of court incurred in processing this lawsuit, as well as all

post-judgment proceedings and appellate proceedings, in accordance with Chapter 38 of the Texas

Civil Practice and Remedies Code.

PLAINTIFF’S ORIGINAL COMPLAINT PAGE 11
Case 3:18-cv-02081-M Document 1 Filed 08/09/18 Page 12 of 13 PageID 12

Count Five—Exemplary Damages

48. Plaintiff re-alleges and incorporates the allegations contained in Paragraphs 1 through 47

as if fully stated herein.

49. The acts complained of herein were committed knowingly, willfully, intentionally, with

actual awareness, or with actual malice. In order to punish Defendants for such unconscionable

overreaching and to deter such actions and/or omissions in the future, Plaintiff seeks recovery

against Defendants for exemplary damages as provided by Chapter 41 of the Texas Civil Practice

and Remedies Code.

V. JURY DEMAND

50. Plaintiff demands trial by jury for all claims made herein.

VI. PRAYER FOR RELIEF

Wherefore, Plaintiff Danette Galvis prays that Defendants Holy Yoga Foundation and Holy

Yoga Global, LLC be cited to appear and answer herein, and that upon final hearing, Plaintiff have

and recover the following relief against Defendants:

1) Judgment for actual damages in the amount of past and future lost earnings and

benefits and damages to past and future earnings capacity;

2) Judgment for past and future pecuniary losses, emotional pain and suffering,

inconvenience, loss of enjoyment of life, and other non-pecuniary losses;

3) Exemplary damages in an amount to be determined by the trier of fact;

4) An order by the Court reinstating Plaintiff as an employee of Defendants in a

similar position with similar pay and benefits to that from which she was

wrongfully terminated, or in the alternative, future pay in an amount to be

determined by the Court;

PLAINTIFF’S ORIGINAL COMPLAINT PAGE 12
Case 3:18-cv-02081-M Document 1 Filed 08/09/18 Page 13 of 13 PageID 13

5) Prejudgment and post-judgment interest at the maximum legal rate;

6) Attorneys’ Fees;

7) Expert fees;

8) All costs of court; and

9) Such other and further relief to which Plaintiff may be justly entitled.

Dated: August 9, 2018

Respectfully submitted,

BELL NUNNALLY & MARTIN LLP

By: /s/ Sonja J. McGill
Sonja J. McGill
Texas Bar No. 24007648
smcgill@bellnunnally.com

Katie R. Beaird
Texas Bar No. 24092099
kbeaird@bellnunnally.com

3232 McKinney, Suite 1400
Dallas, TX 75204
Telephone: (214) 740-1400
Facsimile: (214) 740-1499

ATTORNEYS FOR PLAINTIFF
DANETTE GALVIS
4018465_4.docx

PLAINTIFF’S ORIGINAL COMPLAINT PAGE 13
Case 3:18-cv-02081-M Document 1-1 Filed 08/09/18 Page 1 of 1 PageID 14

A
JS 44 (Rev. 06/17) - TXND (Rev. 06/17) CIVIL COVER
Case 3:18-cv-02081-M Document SHEET
1-2 Filed 08/09/18 Page 1 of 1 PageID 15
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS
Danette Galvis Holy Yoga Foundation and Holy Yoga Global, LLC

(b) County of Residence of First Listed Plaintiff Dallas County, TX County of Residence of First Listed Defendant Maricopa County, AZ
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Sonja J. McGill, Katie R. Beaird, Bell Nunnally & Martin LLP, 3232 McKinney
Avenue, Suite 1400, Dallas, TX 75204

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
u 1 U.S. Government u 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State u 1 u 1 Incorporated or Principal Place u 4 u 4
of Business In This State

u 2 U.S. Government u 4 Diversity Citizen of Another State u 2 u 2 Incorporated and Principal Place u 5 u 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a u 3 u 3 Foreign Nation u 6 u 6
Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
u 110 Insurance PERSONAL INJURY PERSONAL INJURY u 625 Drug Related Seizure u 422 Appeal 28 USC 158 u 375 False Claims Act
u 120 Marine u 310 Airplane u 365 Personal Injury - of Property 21 USC 881 u 423 Withdrawal u 376 Qui Tam (31 USC
u 130 Miller Act u 315 Airplane Product Product Liability u 690 Other 28 USC 157 3729(a))
u 140 Negotiable Instrument Liability u 367 Health Care/ u 400 State Reapportionment
u 150 Recovery of Overpayment u 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS u 410 Antitrust
& Enforcement of Judgment Slander Personal Injury u 820 Copyrights u 430 Banks and Banking
u 151 Medicare Act u 330 Federal Employers’ Product Liability u 830 Patent u 450 Commerce
u 152 Recovery of Defaulted Liability u 368 Asbestos Personal u 835 Patent - Abbreviated u 460 Deportation
Student Loans u 340 Marine Injury Product New Drug Application u 470 Racketeer Influenced and
(Excludes Veterans) u 345 Marine Product Liability u 840 Trademark Corrupt Organizations
u 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY u 480 Consumer Credit
of Veteran’s Benefits u 350 Motor Vehicle u 370 Other Fraud u 710 Fair Labor Standards u 861 HIA (1395ff) u 490 Cable/Sat TV
u 160 Stockholders’ Suits u 355 Motor Vehicle u 371 Truth in Lending Act u 862 Black Lung (923) u 850 Securities/Commodities/
u 190 Other Contract Product Liability u 380 Other Personal u 720 Labor/Management u 863 DIWC/DIWW (405(g)) Exchange
u 195 Contract Product Liability u 360 Other Personal Property Damage Relations u 864 SSID Title XVI u 890 Other Statutory Actions
u 196 Franchise Injury u 385 Property Damage u 740 Railway Labor Act u 865 RSI (405(g)) u 891 Agricultural Acts
u 362 Personal Injury - Product Liability u 751 Family and Medical u 893 Environmental Matters
Medical Malpractice Leave Act u 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS u 790 Other Labor Litigation FEDERAL TAX SUITS Act
u 210 Land Condemnation u 440 Other Civil Rights Habeas Corpus: u 791 Employee Retirement u 870 Taxes (U.S. Plaintiff u 896 Arbitration
u 220 Foreclosure u 441 Voting u 463 Alien Detainee Income Security Act or Defendant) u 899 Administrative Procedure
u 230 Rent Lease & Ejectment u 442 Employment u 510 Motions to Vacate u 871 IRS—Third Party Act/Review or Appeal of
u 240 Torts to Land u 443 Housing/ Sentence 26 USC 7609 Agency Decision
u 245 Tort Product Liability Accommodations u 530 General u 950 Constitutionality of
u 290 All Other Real Property u 445 Amer. w/Disabilities - u 535 Death Penalty IMMIGRATION State Statutes
Employment Other: u 462 Naturalization Application
u 446 Amer. w/Disabilities - u 540 Mandamus & Other u 465 Other Immigration
Other u 550 Civil Rights Actions
u 448 Education u 555 Prison Condition
u 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
u 1 Original u 2 Removed from u 3 Remanded from u 4 Reinstated or u 5 Transferred from u 6 Multidistrict u 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e et seq.
VI. CAUSE OF ACTION Brief description of cause:
Sexual harassment, discrimination, and retaliation by employer
VII. REQUESTED IN u CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: u Yes u No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
08/09/2018 /s/ Sonja J. McGill
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE