IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO ) MARY ADDI ) CASE NO. 11040 Indian Hollow Road ) Elyria, Ohio 44035, ) JUDGE In Pro Se ) ) Plaintiff, ) ) COMPLAINT vs. ) ) HORIZON SCIENCE ACADEMY ) (Jury Demand Endorsed Hereon) DENISON MIDDLE SCHOOL ) 1700 Denison Road ) Cleveland, Ohio 44109, ) ) and ) ) MURAT SAGNAK ) C/O Gateway Academy South ) 6651 Gravois Avenue ) Saint Louis, MO 63116 ) ) and ) ) CONCEPT SCHOOLS, NFP ) 2250 E. Devon Ave. Ste. 215 ) Des Plaines, Illinois 60018 ) ) Defendants. ) Now comes Plaintiff, Mary Addi, by and in pro se and for her Complaint against Defendants, Horizon Science Academy, Murat Sagnak, and Concept Schools, alleges and states the following:
PARTIES 1. Plaintiff Mary Addi (Ms. Addi) is an individual who resides in Lorain County, Ohio, and is an employee as defined by R.C. Chapter 4112. All action alleged in this complaint that pertains to Plaintiff Mary Addi took place in Cuyahoga County, Ohio. 2. Defendant Horizon Science Academy Denison Middle School ( Horizon ) is a charter school and does business in Cuyahoga County, Ohio. Defendant Horizon is an employer as defined by R.C. Chapter 4112. 3. Defendant Murat Sagnak (Sagnak) is an individual who was employed by Defendant Horizon in Cuyahoga County, Ohio. At all times relevant Defendant Sagnak was a supervisor of Plaintiff and he is an employer as defined by R.C. Chapter 4112. 4. Defendant Concept Schools, NFP is the company that runs Defendant Horizon Science Academy. At all times relevant, Defendant Concept Schools operated Defendant Horizon Science Academy which is Plaintiff s employer as defined by R.C. Chapter 4112. VENUE 5. Whereas the anticipated amount of damages exceeds the jurisdictional amount of the municipal courts of Ohio under R.C. 1901.17, jurisdiction in this action rests in the court of Common Pleas under 2306.01 of the Ohio Revised Code. 6. Whereas this cause of action arose in Cuyahoga County, this Court is the proper venue for this action under Rule 3(B)(3) of the Ohio Rules of Civil Procedure.
STATEMENT OF FACTS 7. Plaintiff Mary Addi is a 61 year old Caucasian, female, and American citizen, and was employed by Defendants from August 2006 through February 12, 2009. Ms. Addi has a bachelor s degree in education, a graduate degree in teaching, and a Master s degree in business administration, and is licensed to teach in both California and Ohio. Ms. Addi was employed by the Horizon Science Academy Denison Middle School 1700 Denison Ave., Cleveland Ohio 44109 (Horizon). 8. Ms. Addi was terminated from her job in a retaliatory action because of complaints she made regarding discrimination, disparate pay, and retaliation. Ms. Addi was terminated for being a Caucasian female, a Christian, and an American citizen married to a Turkish national who was a member of the Gulen movement. 9. During Plaintiff s employment with Defendants, she and other employees who were similarly situated were subjected repeatedly to disparate pay, discrimination based on their gender, and discrimination based on national origin, and discrimination based on religion. 10. The Gulen movement is an Islamic movement that follows a Turkish imam named Fethullah Gulen. The movement has approximately 140 schools operating in 25 United States. Horizon employs numerous male Turkish nationals who are here in the United States on H-1B visas, and who are likewise followers of the Gulen movement. An H-1B visa is a non-immigrant visa in the United States. It allows U.S. employers to temporarily employ foreign workers in specialty occupations. If a foreign worker in H-1B status quits or is dismissed from the sponsoring employer, the worker must either apply for and be granted a change of status to
another non-immigrant status, find another employer (subject to application for adjustment of status and/or change of visa), or leave the United States. 11. These Turkish nationals hold both teaching and administrative positions at Horizon. From the beginning of her employment, Ms. Addi learned that nearly every administrator and some of the math and science teachers were male Turkish nationals in the United States on H1B visas. These Turkish males are under qualified for the positions that they hold. The majority of these teachers do not hold teaching credentials or teaching licenses other than substitute licenses. Many of the administrators do not have graduate degrees. Despite these deficiencies, these Turkish males command significantly higher salaries and positions than their more qualified American co-workers and female co-workers. 12. The disparity in pay is significant, as much as $12,000 per year. During the 2006-2007 school year, while Ms. Addi, as a licensed, experienced teacher with a graduate degree made $30,000, Mustafa Emanet, an unlicensed and less experienced teacher made $42,000. Mr. Emanet was brought to the United States to be an IT administrator but was thrust into a teaching position with absolutely no teaching experience. Turkish males with little teaching experience and without licenses were consistently paid significantly higher salaries than their more qualified female American counterparts. 13. During her time at Horizon, Ms. Addi worked as an English teacher, a secretary, a special education teacher, and a grant writer. Despite her impressive qualifications, undergraduate and graduate degrees in teaching, Ms. Addi was nonetheless happy to fill in wherever she was needed. Ms. Addi was initially
hired by Murat Sagnak as an English teacher, August 15, 2006 for the 2006-2007 school year at the rate of $30,000. Ms. Addi completed her $30,000 English teacher contract for the 2006-2007 school year. Ms. Addi was offered and accepted a contract with Horizon to teach English for the 2007-2008 school year at the rate of $32,100. Ms. Addi instead decided to work for the Cleveland Municipal School District (CMSD) for the 2007-2008 school year and was subsequently released from her contract with Horizon. Ms. Addi decided to leave CMSD halfway through the year and received a contract with Horizon on January 15, 2008 as a per diem special education teacher. Ms. Addi, while a licensed teacher and administrator in Ohio, does not have a special certification in special education. The per diem contract was to end on June 6, 2008. 14. Ms. Addi s problems at Horizon increased in the late spring of 2008 after she began to complain about instances of discrimination and unequal treatment. In April or May of 2008, Ms. Addi complained to her supervisor, Director/Dean of Academics Murat Sagnak, about instances of workplace gender and national origin discrimination. Plaintiff complained to Defendant Sagnak in or about the month of April 2008. Plaintiff complained that she was not offered a chance to apply for an open Dean of Students position. Ms. Addi also complained about the fact that she was not offered an interview for an open Associate Dean of Academics position despite her extensive qualifications. 15. On June 2, 2008, school officials learned that Ms. Addi had married her Turkish coworker, Mustafa Emanet in January 2008. On the same day administrators learned of her marriage, June 1, 2008, Ms. Addi was terminated. Ms. Addi s
contract was to end on June 6, 2008. 16. Defendants failed to take prompt or adequate remedial action in response to Plaintiffs complaints, in terms of disparate treatment, and discrimination toward Plaintiff and other similarly situated employees continued and increased after Plaintiff s complaints about such conduct. Said conduct of Defendants in this regard constitutes retaliation upon the Plaintiff in response to her complaints. 17. On June 3, 2008 the President of Concept School (Concept School oversees Horizon and other Gulen charter schools), Hussein Kara, flew in for a meeting with Mr. Sagnak and Plaintiff s husband, Mr. Emanet. Mr. Emanet was told in no uncertain terms that he would lose his job if Ms. Addi filed any further discrimination complaints. Mr. Emanet was also told he would no longer have a job if he refused to divorce Ms. Addi because she was not a Muslim, was a Christian, and did not belong to the Gulen Movement. 18. Plaintiff filed a timely complaint with the EEOC, following her first separation from Horizon on or about June 2, 2008. Ms. Addi filed a complaint with the Ohio Civil Rights Commission (OCRC) that the Equal Employment Opportunity Commission (EEOC) investigated on or about July 23, 2008. The complaint alleged gender discrimination, age discrimination, national origin discrimination, disparate pay, and retaliation. 19. After the complaint was filed, Ms. Addi retained counsel (Anthony Lazzaro) who wrote a letter of representation to Horizon. After Horizon received the letter, Ms. Addi was finally interviewed twice by Angela Ross for the vacant Associate Dean position. The dean position was ultimately filled by a less qualified male, Mr.
Terry. Ms. Addi and her husband were both offered contracts, and as negotiated by Mr. Lazzaro, for the 2008-2009 school year. Horizon even created a grant writer position just for Ms. Addi. Per the contract, Ms. Addi was to make $40,000 per year payable in 23 semi-monthly payments beginning August 2008 and ending July 31, 2009. 20. While Ms. Addi was willing and able to fully perform her contract for 2008-2009, she was prevented from doing so because on February 12, 2009, Ms. Addi s position was terminated. Horizon repudiated the contract. Plaintiff s employment contract was terminated by the Defendants on February 12, 2009 in a retaliatory action. At the time of the termination, Ms. Addi was employed under contract as a grant writer. Ms. Addi s employment was terminated by the Dean of Academics, Murat Sagnak. 21. Horizon defends the termination on the grounds that Ms. Addi was working concurrently as a substitute teacher in the Keystone Local School District. Horizon claimed this work as a substitute teacher was interfering with Ms. Addi s contractual duties as a grant writer at Horizon. This justification for termination is merely pretext. 22. Ms. Addi s required duties as a grant writer allowed her great latitude to work from home at her convenience. Ms. Addi was free to work at night and on the weekends if she so desired. Ms. Addi was in fact instructed by Mr. Sagnak to only meet with Horizon administrators after the school day ended. Ms. Addi was merely to meet with Mr. Sagnak at Horizon once a week after the normal school day was over and the staff had left the building. Ms. Addi s contractual duties at
Horizon were not adversely affected by her work as a substitute teacher. 23. Ms. Addi was terminated because she is a female Caucasian American citizen married to a Turkish national, because she reported the discrimination, and because she filed an EEOC complaint to protect her rights. Ms. Addi anticipated finishing the 2008-2009 contract and teaching at Horizon for 5 more years, since she was close to retirement. 24. Ms. Addi believes that administrators at Horizon tortiously interfered with her subsequent efforts to seek gainful employment as a teacher. After her position was terminated, Ms. Addi applied for other teaching jobs and despite her extensive qualifications and experience, she was not hired. Ms. Addi believes that Horizon was giving potential employers bad references about her job performance. This tortious interference prevented Ms. Addi from obtaining a position in her desired field of teaching. 25. Plaintiff and her husband were repeatedly harassed and threatened by Horizon school representatives, both at Horizon Denison and Plaintiff s husband while visiting his family in Turkey. Plaintiff s husband was told that he should divorce Plaintiff Addi because she was not a Muslim or a member of the Gulen organization. 26. On or about June 3, 2008, agents of Horizon contacted Mustafa s family in Turkey and began a pattern of harassment and intimidation both here and in Turkey. Mr. Emanet s brother was contacted via email by a former Horizon board member, Mr. Altunas, and told that Mr. Emanet was in trouble and married to an American, Caucasian, and Christian woman (Mr. Emanet s family was
unaware of Ms. Addi and Mr. Emanet s nuptials). Mr. Emanet s mother was recovering from open heart surgery and this news greatly upset her. After receiving this email, Mr. Emanet s family asked him to return to Turkey to help care for his mother. While in Turkey, Mr. Emanet s brother received a visit from a member of the Gulen movement suggesting that Mr. Emanet not return to the United States because he would no longer have a job when he returned to the United States Despite these threats Mr. Emanet returned to the United States and his wife in July 2008. Mr. Emanet was not offered a contract with Horizon for the 2008-2009 school year and was not rehired until Plaintiff hired an attorney to negotiate a contract for Mr. Emanet. 27. Plaintiff Mary Addi complained to the Horizon Board of Directors about such hostility, disparate treatment, and discrimination based on her gender and national origin on or about September 8, 2008. Ms. Addi felt that neither the EEOC investigation nor her complaint from the spring of 2008 to her supervisor, Mr. Sagnak, produced results. 28. In fact, Ms. Addi found a large number of derogatory emails addressing both her marriage to Mr. Emanet and her complaints of discrimination. Plaintiff complained to Defendant Sagnak on or about September 4, 2008 about discriminatory behavior and derogatory emails. Defendant Mr. Sagnak did not address this complaint. Ms. Addi wrote a letter to Mr. Sagnak providing evidence of the discriminatory and derogatory emails and asking for some type of resolution. In the letter Ms. Addi states that she will involve the school Board of Directors if no action is taken. The letter produced no results. Next Ms. Addi
wrote a letter to the Board of Directors of Horizon asking for Mr. Sagnak s resignation and an investigation into the discrimination at Horizon. The derogatory emails were provided to the Board as evidence of discrimination. The Board initiated an investigation and a written report was submitted to the Board by investigator Mark White. The report acknowledged misconduct and recommended a training session for faculty staff and administrators to help prevent further instances of workplace harassment and discrimination. 29. Ms. Addi s two (2) complaints to her boss, a complaint to the school board, and a complaint to the OCRC ultimately led to the retaliatory termination of her employment. Ms. Addi s desire to work in a discrimination free environment, a statutorily provided right by O.R.C 4112.02 (A), led directly to the termination of her employment. 30. Despite the complaints of Ms. Addi and others, Mr. Sagnak remained in a supervisory position, in spite of his track record of discrimination. In addition to Ms. Addi s claim, Horizon and Mr. Sagnak had at least two other discrimination claims filed against them. Don Gehrlein and Gloria Catalusci both former employees of Horizon, both filed discrimination lawsuits against Horizon. Mr. Gehrlein and Ms. Catalusci are both American citizens and were both employed as associate deans at Horizon prior to bringing their discrimination claims. 31. The EEOC closed its file on the charges that Ms. Addi alleged. The investigation ended on July 30, 2010 because the EEOC was unable to establish the violation of any statutes and issued a Notice of Right to Sue. 32. Defendants attempted to prevent Plaintiff s husband from testifying on her behalf
and as testimony directly related to her discrimination claims. In the summer of 2009, while Mr. Emanet was again visiting his family in Turkey, Horizon Science Academy Denison Middle School employee Hasan Akkaya met with Plaintiff s husband, Mr. Emanet, and instructed him to sign a false document stating that he had manufactured evidence that had been turned over to federal authorities/agencies for investigation into Horizon Science Academy s discriminatory practices and business dealings. Mr. Akkaya informed Mr. Emanet that if he signed the documents that the Gulen organization, and through Horizon Science Academy Denison, would find him suitable employment in another foreign country, pay his medical expenses for treatment for alopecia, and find a Muslim woman to marry. 33. Ms. Addi s estimated damages include: A two- year pay discrepancy of $6,000 - $12,000 per year for a total of $12,000 - $24,000. Ms. Addi anticipated 10 more years of teaching until her retirement at a salary of at least $40,000 a year = $400,000 plus. Ms. Addi lost her medical insurance and benefits. As a result of her termination, Ms. Addi suffers from mental anguish including; depression, anxiety, and nervousness. Horizon s tortious interference prevented Ms. Addi from obtaining a teaching position with a different school district thereby limiting Ms. Addi s income and preventing COUNT ONE (Gender Discrimination) 34. Plaintiff hereby reaffirms and reasserts all of the allegations raised in the previous paragraphs of this complaint as if fully re-written herein.
35. The action of Defendants as alleged herein constitutes discrimination against Plaintiff based on her gender in violation of R.C. 4112.02(A) with respect to the tenure, terms, conditions, privileges of employment, and other matters directly and/or indirectly related to their employment, by treating them differently than similarly-situated Caucasian co-workers, and by other means to be determined at trial. 36. The aforementioned conduct of Defendants was done maliciously and/or intentionally or with reckless disregard for the rights of Plaintiffs. 37. Defendants conduct as herein alleged constituted a conscious disregard for the rights and/or safety of Plaintiff that had a great probability of causing, and did cause, substantial damage to her, thereby rendering Defendants liable for punitive damages. 38. As a direct and proximate result of Defendants discriminatory conduct as alleged herein, Plaintiff has been damaged in an amount in excess of Twenty-Five Thousand Dollars. 39. As a further direct and proximate result of Defendants conduct, Plaintiff has incurred severe economic damages (including, but not limited to loss of income and other benefits), pain and suffering, humiliation, severe emotional distress, and the loss of enjoyment of life for which Plaintiff asserts a claim against Defendants as authorized under R.C. 4112.99. COUNT TWO (National Origin Discrimination) 40. Plaintiff hereby reaffirms and reasserts all of the allegations raised in the previous
paragraphs of this complaint as if fully re-written herein. 41. Plaintiff is an American citizen and is a member of a protected class. 42. Plaintiff was treated differently than similarly-situated Turkish nationals. 43. Plaintiff was denied opportunities that were offered to similarly situated Turkish nationals. 44. The action of Defendants as alleged herein constitutes discrimination against Plaintiff based on her national origin in violation of R.C. 4112.02(A) with respect to the tenure, terms, conditions, privileges of employment, and other matters directly and/or indirectly related to their employment, by treating them differently than similarly-situated Caucasian co-workers, and by other means to be determined at trial. 45. The aforementioned conduct of Defendants was done maliciously and/or intentionally or with reckless disregard for the rights of Plaintiffs. 46. Defendants conduct as herein alleged constituted a conscious disregard for the rights and/or safety of Plaintiff that had a great probability of causing, and did cause, substantial damage to her, thereby rendering Defendants liable for punitive damages. 47. As a direct and proximate result of Defendants discriminatory conduct as alleged herein, Plaintiff has been damaged in an amount in excess of Twenty-Five Thousand Dollars. 48. As a further direct and proximate result of Defendants conduct, Plaintiff has incurred severe economic damages (including, but not limited to loss of income and other benefits), pain and suffering, humiliation, severe emotional distress, and
the loss of enjoyment of life for which Plaintiff asserts a claim against Defendants as authorized under R.C. 4112.99. COUNT THREE (Religious Discrimination) 49. Plaintiff hereby reaffirms and reasserts all of the allegations raised in the previous paragraphs of this complaint as if fully re-written herein. 50. Plaintiff is an American citizen and is a member of a protected class. 51. Plaintiff was treated differently than similarly-situated Muslims. 52. Plaintiff was denied opportunities that were offered to similarly situated Muslims. 53. The action of Defendants as alleged herein constitutes discrimination against Plaintiff based on her religious beliefs. 54. In violation of R.C. 4112.02(A)(1) with respect to the tenure, terms, conditions, privileges of employment, and other matters directly and/or indirectly related to their employment, by treating them differently than similarly-situated Christian co-workers, and by other means to be determined at trial. 55. The aforementioned conduct of Defendants was done maliciously and/or intentionally or with reckless disregard for the rights of Plaintiff. 56. Defendants conduct as herein alleged constituted a conscious disregard for the rights and/or safety of Plaintiff that had a great probability of causing, and did cause, substantial damage to her, thereby rendering Defendants liable for punitive damages. 57. As a direct and proximate result of Defendants discriminatory conduct as alleged herein, Plaintiff has been damaged in an amount in excess of Twenty-Five
Thousand Dollars. 58. As a further direct and proximate result of Defendants conduct, Plaintiff has incurred severe economic damages (including, but not limited to loss of income and other benefits), pain and suffering, humiliation, severe emotional distress, and the loss of enjoyment of life for which Plaintiff asserts a claim against Defendants as authorized under R.C. 4112.99 COUNT FOUR (Discrimination in Pay) 59. Plaintiff hereby reaffirms and reasserts all of the allegations raised in the previous paragraphs of this complaint as if fully re-written herein. 60. In violation of Ohio Revised Code 4112.2(2), Defendants did Discriminate against, limit the employment opportunities of, or otherwise adversely affect the employment status, wages, hours, or employment conditions of any person as an employee because of race, color, religion, sex, military status, national origin, disability, age, or ancestry. Defendant Horizon paid Plaintiff disproportionately less than her similarly situated male Turkish national co-workers. 61. Plaintiff and her similarly-situated American Caucasian male and female coworkers held the same job title, performed jobs which required equal skill, effort, and responsibility, and which were performed under similar working conditions. 62. Plaintiff held the same or higher educational qualifications as her male Turkish national coworkers and was as, if not more, qualified than her male Turkish national coworkers.
63. As a direct and proximate result of Defendants wrongful actions, conduct, and/or failure to act, Plaintiff has suffered and in all likelihood will continue to suffer severe damages, including but not limited to, lost wages, mental anguish and emotional distress, stress, anxiety, and inability to engage in her usual activities, all to her detriment. 64. As a further direct and proximate result of the foregoing conduct, Plaintiff has suffered damages, including punitive damages, for the outrageous conduct of Defendants in an amount to be determined at trial. As a result of Defendants action as set forth above, Plaintiff asserts a claim against Defendants as authorized under R.C. 4112.2(2). As a result of Defendants action as set forth above, Plaintiff is entitled to recover in addition to compensatory damages, punitive damages, including attorney s fees and the costs of this action, in an amount to be determined at trial. COUNT FIVE (Intentional Infliction of Emotional Distress) 65. Plaintiff hereby reaffirms and reasserts all of the allegations raised in the previous paragraphs of this complaint as if fully re-written herein. 66. Defendants owed a duty to the Plaintiff to refrain from intentional and/or negligent injury to her. The wrongful conduct of Defendants as alleged herein resulted in the intentional infliction of emotional distress to Plaintiffs for which Defendants are liable. 67. Defendants breached their duty to the Plaintiff based on their conduct as alleged herein, and Defendants intentionally and proximately caused injury to Plaintiffs in
the form of embarrassment, mental anguish, loss of reputation, loss of selfesteem, harm to Plaintiff s relationship with her spouse and family, and other emotional distress with physical injury in form of adverse health effects. Said injuries caused extreme pain and suffering in the past and will likely continue to cause pain and suffering in the future. 68. Defendants conduct as alleged herein was outrageous and had proximately caused damage to Plaintiffs arising from their intentional infliction of serious emotional distress upon them for which they are entitled to judgment and recovery under Ohio law. 69. Defendants conduct as described herein was willful, malicious, with spite and ill will, and/or with a reckless disregard for Plaintiffs legal rights. 70. As a direct and proximate result of Defendants conduct, Plaintiff has been damaged in an amount in excess of Twenty-Five Thousand Dollars. 71. As a further direct and proximate result of the foregoing conduct, Plaintiff has suffered damages, including punitive damages, for the outrageous conduct of Defendants in an amount to be determined at trial. As a result of Defendants action as set forth above, Plaintiff is entitled to recover in addition to compensatory damages, punitive damages, including attorney s fees and the costs of this action, in an amount to be determined at trial. COUNT SIX (Negligent Retention and Supervision) 72. Plaintiff hereby reaffirms and reasserts all of the allegations raised in the previous paragraphs of this complaint as if fully re-written herein.
73. Defendant Sagnak was incompetent as an agent of Defendant Horizon because of his failure to prevent and/or eliminate discrimination at Defendant Horizon and/or failure to take reasonable steps to do so.. 74. Defendant Horizon owed a duty to their employees to properly supervise Defendant Sagnak to prevent discrimination in the workplace upon Plaintiff and others. 75. Defendant Horizon knew or, with the exercise of reasonable diligence, should have known of the conduct of Defendant Sagnak. 76. Defendant Horizon breached the foregoing duty when it failed to take reasonable steps to prevent and/or stop Defendant Sagnak s conduct against Plaintiff as described herein. 77. As a direct and proximate result of the foregoing conduct, Plaintiff has suffered severe economic damages by the loss of her job (including, but not limited to, the loss of income and other benefits), pain and suffering, humiliation, severe emotional distress, the loss of enjoyment of life, and was otherwise damaged. Said injuries caused extreme pain and suffering in the past and will likely continue to cause pain and suffering in the future. Plaintiff has been damaged in an amount in excess of Twenty-Five Thousand Dollars. 78. As a further direct and proximate result of the foregoing conduct, Plaintiff has suffered damages, including punitive damages, for the outrageous conduct of Defendants in an amount to be determined at trial. As a result of Defendants action as set forth above, Plaintiff is entitled to recover in addition to compensatory damages, punitive damages, including attorney s fees and the costs
of this action, in an amount to be determined at trial. COUNT SEVEN (Unlawful Retaliation) 79. Plaintiff hereby reaffirms and reasserts all of the allegations raised in the previous paragraphs of this complaint as if fully re-written herein. 80. Plaintiff s complaints to their employer about hostility, disparate treatment, and discrimination based on their gender and national origin and that of similarly situated employees constitutes opposition to an unlawful discriminatory practice under R.C. 4112.02(I). 81. Defendants continued and increased hostility, disparate treatment, and discrimination based on Plaintiff s national origin and gender after she complained to her employer constitutes an adverse employment action by the Defendants against the Plaintiff, and further discrimination and/or retaliation against the Plaintiff. 82. Defendants ultimate termination of the Plaintiff on February 12, 2009 was a retaliatory reaction for the complaint the Plaintiff filed with the school s Board of Directors in September 2008, and for the EEOC complaint that Plaintiff filed in July 2008, and for the Plaintiff and her husband s cooperation with a Department of Labor Investigation into Horizon Denison s activities. 83. As a direct and proximate result of Defendants discriminatory conduct as alleged herein, Plaintiff has been damaged in an amount in excess of Twenty-Five Thousand Dollars. 84. As a further direct and proximate result of Defendants conduct, Plaintiff has
incurred severe economic damages (including, but not limited to loss of income and other benefits), pain and suffering, humiliation, severe emotional distress, and the loss of enjoyment of life for which Plaintiff asserts a claim against Defendants as authorized under R.C. 4112.99. As a result of Defendants action as set forth above, Plaintiff is entitled to recover in addition to compensatory damages, punitive damages, including attorney s fees and the costs of this action, in an amount to be determined at trial. COUNT EIGHT (Aid, Abet, Incite, Compel, or Coerce Discriminatory Acts) 85. In violation of R.C 4111.17(J), the Defendants and through their assigned agents, attempted numerous times to Aid, abet, incite, compel, or coerce the doing of any act declared by this section to be an unlawful discriminatory practice, to obstruct or prevent any person from complying with this chapter or any order issued under it, or to attempt directly or indirectly to commit any act declared by this section to be an unlawful discriminatory practice. 86. Through their numerous and intimidating contacts with Plaintiff s husband by their designated agents, Defendants repeatedly engaged in acts aimed at obstructing and coercing Plaintiff s husband into not testifying or participating in Plaintiff s anti-discrimination actions and complaints against the Defendants. The Defendants employed agents to aid and abet in obstructing Plaintiff s right to prove and defend discrimination claims against the Defendants. 87. As a direct and proximate result of the foregoing conduct, Plaintiff has suffered severe economic damages by the loss of her job (including, but not limited to, the
loss of income and other benefits), pain and suffering, humiliation, severe emotional distress, the loss of enjoyment of life, and was otherwise damaged. Said injuries caused extreme pain and suffering in the past and will likely continue to cause pain and suffering in the future. Plaintiff has been damaged in an amount in excess of Twenty-Five Thousand Dollars. 88. As a further direct and proximate result of the foregoing conduct, Plaintiff has suffered damages, including punitive damages, for the outrageous conduct of Defendants in an amount to be determined at trial. As a result of Defendants action as set forth above, Plaintiff is entitled to recover in addition to compensatory damages, punitive damages, including attorney s fees and the costs of this action, in an amount to be determined at trial. PRAYER FOR RELIEF WHEREFORE, PLAINTIFF DEMANDS JUDGMENT AS FOLLOWS: As to All Claims: That this Honorable Court award Plaintiff Addi compensatory damages for her loss of income and benefits, including past economic loss and pay, future economic loss and pay, and/or the loss of opportunity to earn future income, effects of financial strain, physical injury, loss to reputation, embarrassment, depression, emotional distress, and other personal injury in an amount in excess of $25,000.00 to be determined at trial; and That this Honorable Court award Plaintiff Addi punitive damages in an amount to be determined at trial; and
That this Court award Plaintiff Addi, costs and interest as to all Claims in an amount to be determined at trial; and That this Court award Plaintiff Addi costs per statute as applicable in an amount to be determined at trial; and That this Honorable Court grant Plaintiff Addi such other and further relief as may be just and equitable. Respectfully submitted, Mary Addi Mary Addi In pro se 11040 Indian Hollow Rd. Elyria, OH 44035 Telephone: (440) 281-8127 JURY DEMAND Plaintiff hereby demands a trial by jury in this case by the applicable amount of jurors allowed by law.