CIVIL DOCKET FOR CASE #: 0:11−cv−62525−WPD - United States ...

Case 0:11-cv-62525-WPD Document 1 Entered on FLSD Docket 11/28/2011 Page 9 of 31
cooperate with FOIA rule to provide me with a copy from my employer response as I requested
or opportunity to seel review my lble the last recent one of several as indicated in exhibit A 5.
But Enaly plaintiffreceived only her employer's response with a11 evaluations letters just few
days ago and plaintiffobligated to this compliant updated accordingly.
Respondentgs Cause Of Action W ith Exhibits W ith
Name. Date. And Plaee Of Eaeh Açtinn Whivh Requirv.d Rdiq.f Bv The Court
plaintift's schedules as substitute teacher was as a full time while I was working every
day nonstop without any benefits since 2000/2001 school year. Any days off l took within 10
years was limited and mandatory to attend court hearings during my divorce and my children's
crises or study for my exams during my part time as graduate smdent for my Mmster degree
between 2002-2007. On 2008 and 2009 during the slmmer vacation I obligated to go to Egypt
for four and one half months each year for medical care due to car accident and medical
malpractice when adequate necessary care 1 couldn't afford it here after my car insurances
become exhausted after on going trea% ent and Sve days on hospital. As a substitute teacher we
have no rule to tnke vacation but l always reported any absentee time through the system
teclmology and oftkialy but automaticaly the system still can call us or not through new
advance technology operated by the sub-teacher department.
2- These discrimination series started only on November 2008 till April 28,2010 by reducing
my work hours when I was available to work which after l chnnged my married name 9om
lbrahim to my father name Arafat. Also after l updated my education status with my employer
and 1 started %king oëcialy for new position and better salary in Cunictlum development in
science education or other reasonable a accommodation to reflect my qualification and
experiences. Recently my position as substihde teacher become controling and depended on a
new advance technology system wllich controlling my work hours and which school the
department want us to go with command from sub-central (substimte teachers department in the
district to al schools). Before Nov. 2008 this reduction to my work hours never occurred for 8
straight years al1 of them in middle schools later I added ligh schools in my list on 2007 to get
answer for some hypotheses on my science project based reseatch. As sub-teacher from very
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