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 27 of 31
clear ndmission thnt respondent violated the statute for federal job discrimination law.
B- Defendant denied public access right which protected by civil right law duringjob fair open for
public which advertised by Chsnnel 7 local news by plaintifs employer / defendant who are the number
six of largest schools district in USA. Respondent failure to enforce the law and code of conduct against
some employees who provided false evaluations and proven to be legally false by respondent in
2002,2006, 2007,=d 2008. Respondent caused encouragement for others who has snme desire to expand
their misconduct against plaintiff to another level to be a physical act while respondent snme failure not
only remain the same but also failed to provide a copy from the entire evaluations as required by law
rather respondent unlawfully and wrongfully issued termination on April 28,2010 not reiected the
provision of sub-teacher position nling for termination and plaintims right for fak and reasonable
position where she was seeking based in her qualitkations.
C- Defendant failed to proceed with accordance with the 1aw by considering false evaluation from
places plaintiffnever worked with nor applied the law consequences against school employees who
provided information proven to be false which punishable by law under US Code j 3729 false elaim as
indicated in (a) for liabilitr for certain act: (1)(B). Also defendant failed to #nk'e action against
other employtes who committed misconduct and unethical behavior on April 18,2010 which could
prevented further falsification and negativities by enforcing the district and law code of conduct.
D- Defendant considered false evaluations issued on 2006 but never disclosed to plaintiff for
response even when plaintifwas requestcd later aher til Oct. 05,2010 and aher the wrongful
termination was done on April 28.2010 and plaintiffa temptation as a matter of law.
E- Defendant failed to comply with the Fair Labor Standards Act to provide equal salary as $ l 5 /
hour for plaintiff current position paid for other sub-teachers or reasonable promotion or any other
reasonable and fair accommodation when plaintiffofficially requested in writing on basis of law. But
defendant attempted to keep plaintif working in classroom pedbrming teachers' task with $10 an hours
without any benefits while same classmate as graduate student offered promotion when both gradated in
same times. ln addition to plaintims factuality of her qualifkation for B.S. science, Valid teacher
certitkation science, MS in management and administration / educational leadership and up to 10 years
experiences in classroom. Defendant other employees with same qualitkation who were selected paid
$35-$50 / hour with ful beneflts.
F- Defendant failed to accommodate plaintiFon basis of equal protection clauses and fair standards
l
27 r
l
k
f
1
l