JEFFERSON CIRCUIT COURT CIVIL DIVISION JUDGE. LISA CLINTON-GARCES 546 Birchwood Circle Shelbyville, KY 40065

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1 NO. JEFFERSON CIRCUIT COURT CIVIL DIVISION JUDGE LISA CLINTON-GARCES 546 Birchwood Circle Shelbyville, KY PLAINTIFF VS. COMPLAINT SHEREE THOMPSON JEFFERSON COUNTY PUBLIC SCHOOLS 3332 NEWBURG ROAD LOUISVILLE, KY JENNIFER CAVE, PRINCIPAL NOE MIDDLE SCHOOL 121 WEST LEE STREET LOUISVILLE, KY AMY DENNES REGIONAL ADMINISTRATOR 3332 NEWBURG ROAD LOUISVILLE, KY DEFENDANTS ***************************** Comes the Plaintiff, LISA CLINTON-GARCES, and for her cause of action states as follows: 1. That the Plaintiff, LISA CLINTON-GARCES was a substitute teacher for the Jefferson County Public Schools while awaiting placement as a teacher in the Jefferson County Public Schools

2 2. That Plaintiff had enjoyed her time as a substitute teacher until October 16, 2015 when as a substitute teacher at Noe Middle School, she was placed in the transition class. A verbal altercation erupted between an a permanent employee at Noe Middle and a student in the class causing a security officer to be called. The security officer began to physically assault the student and against the applicable rules and regulations. The security officer told Lisa to leave the room. Fearing harm would befall the student, Plaintiff began filming the incident including numerous screams of pain and anguish from the student. 3. That the student was thereafter physically removed from the class. 4. That upon realizing that Plaintiff had videoed the entire incident, Defendant, Cave summoned plaintiff to her office; and an assistant principal was present. Defendant, Cave called Amy Dennes, regional administrator, on her cell phone who threatened plaintiff that she would never work another day for the Jefferson County Schools unless she deleted the video. Plaintiff deleted the video in their presence. Or al least thought she had. Plaintiff had a new phone and instead of immediately deleting the video, the video was moved to a separate delete file; and is still in existence. 5. That after leaving Noe Middle, Plaintiff became concerned as to the welfare of the student and as required by law, called child protective services to report the incident 6. That allowing a few days to pass, Plaintiff called Child Protective Services back to find out what had happened. CPS advised her that they had called Noe Middle and were advised by the principal that there was nothing had been reported. 7. That soon thereafter, ending on October 27, 2015, plaintiff was called to the office of defendant, Sheree Thompson, Director of substitute teachers; and without due process

3 was advised that they had now received three reports as to her being an ineffective substitute teacher and she was summarily dismissed from ever being a substitute teacher again for the Jefferson County Public Schools. 8. That the actions of the Defendants violated KRS , , et.al. when learning of plaintiff having reported the assault to an appropriate Agency, retaliated against the Plaintiff by wrongfully discharging the Plaintiff; and/or retaliated against the Plaintiff by wrongfully terminating the Plaintiff all in violation of KRS , , et.al.. That plaintiff is blackballed from ever substituting in the Jefferson County School system which would cause her to never be hired as a teacher by the Jefferson County Public School; and said information in her personnel file would prevent her from being hired anywhere as a teacher. 9. That the wrongful actions of the Defendants have prevented her from being employed as a teacher to date, which may cause the default provisions of her student loans to accelerate costing the Plaintiff fifteen thousand dollars in damages. 10. That the actions of the Defendant, Cave and Amy Dennes in demanding plaintiff destroy evidence of wrong doing in order to maintain her employment is a violation of public policy and caused the wrongful termination of the Plaintiff. 10. That the damages complained of herein exceed the jurisdictional limit of the Jefferson Circuit Court. 11. That KRS and et.al. cause punitive damages to be allowed. Wherefore the Plaintiff, LISA CLINTON-GARCES, demand judgment against the Defendants, AMY DENNES, REGIONAL ADMINISTRATER, Dr. JENNIFER CAVE, and SHEREE THOMPSON, jointly and severally liable, as follows:

4 1. Actual damages that exceed the jurisdictional limit of the Jefferson Circuit Court, 2. Punitive damages where allowed by law 3. Reinstatement with back pay to be allowed to substitute again and removal from the blackballed list to be eligible to be a teacher in the Jefferson County Public Schools and elsewhere 4. Removal of all negative information from her personnel file, 5. Damages for wrongful termination violating public policy, 6. Attorney s fees where allowed by law. 7. Her court costs herein expended. 8. A trail by jury herein, 9. Any and all other relief to which the Plaintiff, LISA CLINTON-GARCES, may appear entitled. TEDDY B. GORDON Attorney for Plaintiff 807 W. Market Street Louisville, KY (502) Plaintiff, LISA CLINTON-GARCES states that she has read the allegations of the foregoing Complaint, and the statements contained herein are true and correct as she verily believes. LISA CLINTON-GARCES

5 SUBSCRIBED AND SWORN to before me by LISA CLINTON-GARCES on this day of January, 2016 My commission expires:. NOTARY PUBLIC, State at Large, KY