plummer v. richmond

Plummer v. City of Richmond, et al., No. C14-03962 NC First Amended Complaint 1

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DAN SIEGEL, SBN 56400 KEVIN J. BRUNNER, SBN 271510 SONYA Z. MEHTA, SBN 294411 SIEGEL & YEE 499 14th Street, Suite 300 Oakland, CA 94612 Telephone: (510) 839-1200 Facsimile: (510) 444-6698 [email protected] [email protected] Attorneys for Plaintiff STACIE PLUMMER

UNITED STATES DISTRICT COURT FOR THE

NORTHERN DISTRICT OF CALIFORNIA

STACIE PLUMMER, Plaintiff, vs. CITY OF RICHMOND; BILL LINDSAY, LISA STEPHENSON, KATY CURL, and LESLIE KNIGHT in their official and individual capacities, Defendants.

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case No. C14-03962 NC FIRST AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF (Civil Rights) Demand for Jury Trial

Plaintiff STACIE PLUMMER complains against defendants City of Richmond, BILL

LINDSAY, LISA STEPHENSON, KATY CURL, and LESLIE KNIGHT as follows:

PRELIMINARY STATEMENT

1. Plaintiff Stacie Plummer is employed as a Finance Manager for the City of

Richmonds Library and Cultural Services Department.

Case3:14-cv-03962-VC Document39 Filed11/21/14 Page1 of 16


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2. Ms. Plummer witnessed systemic corruption, gross mismanagement and waste,

financial malfeasance, and abuse of authority by the highest City officials, and reported it to

her superiors and to outside agencies. She refused to obey her superiors orders to

participate in, and not report, the misconduct.

3. Ms. Plummer reported improper charges to a federal grant and theft of City monies

through the use of the CAL Card. She reported defendant Leslie Knights misuse of City

vehicles, staff time, and resources, estimated at hundreds of thousands of dollars, as well as

other misconduct. Ms. Plummer reported misconduct at the Library that has cost the public

books, materials, library budget funds, and the possible loss of all federal funding for the

Citys libraries.

4. In retaliation against Ms. Plummers efforts to expose and fix the corruption

afflicting the City, defendants have systematically and forcefully retaliated against her.

Defendants have denied her promotions, docked her pay, transferred her several times,

denied her leave benefits, sabotaged her work, and offered her a promotion in exchange for

her silence about the misconduct.

5. Defendant Library Director Katy Curl removed all job duties from her and froze her

out of financial and programmatic information. Curl thus left one of the Citys most valuable

and diligent finance employees to sit in the corner with no work as the City faces a deficit in

the millions, due in part to gross mismanagement and waste.

6. Ms. Plummer brings a claim under 42 U.S.C. 1983 for retaliation based upon

protected First Amendment conduct. She brings a claim under California Civil Code 52.1.

She also brings a claim for retaliation based upon protected whistleblower conduct under

California Labor Code 1102.5.

JURISDICTION

7. This action arises under 42 U.S.C. 1983, to redress deprivations, under color of

law, of the plaintiff's rights under the First Amendment of the United States Constitution.

The Court has jurisdiction over this matter under 28 U.S.C. 1331.



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8. The state law claims in this action are so related to claims in the action within the

Courts original jurisdiction that they form part of the same case or controversy under

Article III of the United States Constitution. The Court has supplemental jurisdiction over

the related state law claims under 28 U.S.C. 1367.

VENUE

9. Venue is proper in the Northern District of California because the events or

omissions giving rise to the claim occurred in this District.

PARTIES

10. At all times relevant to this controversy, plaintiff STACIE PLUMMER was a Finance

Manager and employee of the City of Richmond, and a resident of Richmond, and then

Hercules, California.

11. At all times relevant to this controversy, defendant CITY OF RICHMOND was a

public agency that governs the City of Richmond.

12. At all times relevant to this controversy, defendant BILL LINDSAY was the City

Manager of the City of Richmond and was acting in said capacity. He is sued in his official

and individual capacities.

13. At all times relevant to this controversy, defendant LISA STEPHENSON was Labor

Relations Manager/Human Resources Personnel Officer, and then Human Resources

Director, and was acting in said capacity. She is sued in her official and individual

capacities.

14. At all times relevant to this controversy, defendant KATY CURL was the Director of

the Library of the City of Richmond and was acting in said capacity. She is sued in her

official and individual capacities.

15. At all times relevant to this controversy, defendant LESLIE KNIGHT was the

Human Resources Director of the City of Richmond and Assistant City Manager of the City

of Richmond and was acting in said capacity. She is sued in her official and individual

capacities.



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STATEMENT OF FACTS

16. Plaintiff Stacie Plummer was born, raised, and works in Richmond, California. She

has been a hardworking and conscientious employee of the City of Richmond for 27 years,

garnering excellent performance evaluations.

17. Since at least 2008, defendant former City Human Resources Director and Assistant

City Manager Leslie Knight spent up to 30 percent of each work day running a personal

business, using five City staff people to assemble trinkets in her City Hall office. She also

used City vehicles while collecting a monthly City car allowance. Knight was the second

highest in command in the City, second only to City Manager Bill Lindsay.

18. In October 2008, Knight asked Ms. Plummer to design marketing materials for

Knights business, on work time and at City Hall. Ms. Plummer refused. After her refusal,

Knight then changed Ms. Plummers title, with more work for the same pay.

19. From 2009-2011, in retaliation for Ms. Plummers refusal to help Knight, Knight

changed Ms. Plummers position title four times, added the financial work of two extra

departments to her job duties, with no additional pay; attempted to add a third extra

department, and put Ms. Plummer on the layoff list.

20. In October 2009, Knight and Lindsay denied Ms. Plummer a promotion. In

February 2010, Lindsay and Knight again denied Ms. Plummer a promotion in spite of a

recommendation from the outgoing Library Director, two outstanding performance

evaluations, and a January 2010 evaluation concluding that Ms. Plummers responsibilities

were above her classification.

21. In December 2011, Ms. Plummer reported her concerns about false financial

statements in a report concerning a federal grant through Portland State University to the

Library to her superior, Library Director Katy Curl, and to the Finance Department. The

grant was to increase broadband services and digital literacy for Richmonds poor and low

income residents.



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22. Shortly thereafter, Curl told Ms. Plummer that Knight had blamed Ms. Plummer for

the library's misstatements regarding the federal grant and for allowing the improper use of

the CAL Card.

23. From December 2011 to March 2012, Ms. Plummers supervisor Curl continuously

requested that Ms. Plummer be promoted to Administrative Librarian, Senior Management

Analyst, and Finance Manager II. Each of these requests was denied by the City, Lindsay,

and Knight, with no explanation.

24. On March 28, 2012, Knight and Stephenson agreed with Ms. Plummers union

representative Pam Covington to promote Ms. Plummer.

25. On or around May of 2012, Plummer was informed that Lindsay, Knight,

Stephenson, and Curl withdrew the agreed upon promotion. Instead, Knight made efforts to

laterally transfer Ms. Plummer into a position with the same pay, but more work. Shortly

after, Curl received an unprecedented seven percent raise and approval to hire two more

staff for her Department.

26. On August 24, 2012, Stephenson admitted to Ms. Plummers union representative

Pam Covington that Knight had been blocking Ms. Plummers promotions all along.

27. In that meeting, Stephenson offered Ms. Plummer a promotion in exchange for her

silence about City misconduct. Ms. Plummer refused. On September 7, 2012, the City,

Lindsay, Knight, Stephenson, and Curl denied the promotion.

28. On August 27, 2012, in the wake of this wrongful quid pro quo offer, Ms. Plummer

delivered to Lindsay a 212 page report of Knights improper conduct, evidence of the

falsification of the Portland State University federal grant report approved by Curl and

improper use of the Citys CAL Card.

29. On August 31, 2012, the Portland State University federal grant official contacted

Curl to discuss misstatements in the submitted grant report. Curl ordered Ms. Plummer to

contact the Portland State University federal grant official and justify the false statements.

30. On September 2, 2012, Ms. Plummer refused because she reasonably believed

reporting false information to the federal government was illegal.



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31. In September 2012, Curl stopped direct communications with Ms. Plummer, and

removed Ms. Plummers job duties until March 2014, when she then demanded Ms.

Plummer do a years worth of work within a month.

32. On September 4, 2012, Ms. Plummer filed the first grievance she had ever filed. She

filed a retaliation grievance against Curl because of Curls demand that Ms. Plummer

legitimize what Ms. Plummer reasonably believed was federal stimulus grant fraud and

mismanagement, and Ms. Curls neglect of duty in rectifying the CAL Card misuse within

the Library.

33. On September 7, 2012, the City, Lindsay, Stephenson, and Knight issued their

decision to not promote Ms. Plummer.

34. On September 7, 2012, Curl threatened discipline against Ms. Plummer because of

the tone of Ms. Plummers emails refusing to call the Portland State University federal

grant official and state that there were no financial misstatements in the grant reports.

35. On September 8, 2012, Knight and Stephenson ordered staff to allow them access to

Ms. Plummers emails.

36. Also in September 2012, Ms. Plummer went to the Contra Costa Grand Jury and the

Contra Costa District Attorneys Office to report on misconduct by City officials.

37. In September and October 2012, Ms. Plummer detailed City misconduct through

several email exchanges and in two separate interviews with City hired

attorney/investigator Sue Ann Van Dermyden.

38. In October 2012, Ms. Plummer found that the City, Lindsay, Knight and Stephenson

had promoted less qualified Finance Department employees without review, while they

again denied Ms. Plummer her promotion.

39. In October 2012, Knight used City Hall cameras to spy on Ms. Plummer and asked

staff to report her conversations back to Knight and Stephenson. In addition, emails show

that Knight and Stephenson searched Ms. Plummers email, without authorization, for

allegations against them.



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40. In October 2012, Curl admitted to the Bay Citizen newspaper that the Library could

not account for about $57,000 that it claimed to receive through the Portland State

University federal grant.

41. In N0vember 2012, Ms. Plummer went in person to the Federal Bureau of

Investigation and the California State Attorney Generals Office to report on misconduct by

City officials.

42. In January 2013, Lindsay, Knight, Stephenson, and Curl issued Ms. Plummer a

Letter of Reprimand for insubordination for refusing to legitimize mismanagement of the

Portland State University federal grant.

43. At this point, many of Ms. Plummers fellow employees began to avoid her.

However, a group of City employees supported Ms. Plummer. These employees have also

experienced retaliation, including termination, for whistle blowing. The highest officials of

the City of Richmond, who have final policymaking authority under state law, adopted a

pattern and practice and policy of adverse actions against whistle blowers that wrongfully

deprived plaintiff and others of their free speech rights guaranteed under the United States

Constitution.

44. In March 2013, Ms. Plummer, and other City of Richmond employees Stan Fleury,

Gautam Manandhar, Lalo Herrera, and James Walker participated in a City of

Richmond City Council meeting, as well as a City of Richmond Human Rights and Human

Relations Commission (HRHRC) meeting, to speak out about the mismanagement of the

City by top City administrators, and retaliation against employees for their protected acts.

45. After Mr. Fleury participated in the City Council meeting and HRHRC meeting, the

City, Lindsay, and Stephenson suspended Mr. Fleury and engaged in other retaliation

against him.

46. After Mr. Manandhar participated in the City Council meeting and HRHRC meeting,

the City, Lindsay, Stephenson, issued a reprimand against Mr. Manandhar, cut his pay to

the lowest of his department, although he is the most senior member of his department; and

engaged in other retaliation against him.



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47. After Mr. Herrera participated in the City Council meeting and HRHRC meeting, the

City, Lindsay, and Stephenson placed Mr. Herrera, and only Mr. Herrera, on the layoff list;

have constantly forced him to work out of classification, and engaged in other retaliation

against him.

48. After Mr. Walker participated in the City Council meeting and HRHRC meeting, the

City, Lindsay, and Stephenson removed his job duties and engaged in other retaliation

against him.

49. The actions against these individuals are part of a pattern and practice on behalf of

the city of Richmond to retaliate against people who speak out on matters of public concern,

as well as a policy approved by the Citys highest official, Mr. Lindsay.

50. In May of 2013, due to public outrage, Knight resigned from her position effective

July 2013 after having cost the City hundreds of thousands of dollars.

51. From the end of May 2013 to about October 2013, Ms. Plummer took a medically

advised stress leave due to the continual retaliation. Stephenson denied her the attendant

salary and benefits to her accepted workers compensation claim. Ms. Plummer was forced

to use all her accrued leave, including vacation.

52. In September 2013, Ms. Plummer returned to work. Curl continued to deny Ms.

Plummer her job duties and financial operations information.

53. On September 27, 2013, Curl issued a Letter of Reprimand to Ms. Plummer, stating

that Ms. Plummers emails about Curls improper practices were unprofessional,

disrespectful, and discourteous.

54. In October 2013, Curl revoked Ms. Plummers ability to work from home on

occasion as was the pattern and practice of the Library.

55. Also in October 2013, Curl refused Ms. Plummer a reasonable accommodation of

temporarily providing a half day work schedule for Ms. Plummers recovery from disability.

Curl stated her intent to dock Ms. Plummers pay, which the City Risk Manager Kim Greer

carried out. Greer stated in writing that the pay deduction was because Ms. Plummer

requested a reasonable accommodation.



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56. In November 2013, Ms. Plummer found her personnel records were not kept in

compliance with the law because her file was missing documents.

57. Also in November 2013, Ms. Plummer found that Curl had finance department staff

attempt to legitimize the librarys CAL Card misuse, in response to a city residents inquiry

regarding the issue. Ms. Plummer had reported this city funded credit card misuse for

months. Curl refused to investigate the issue. Ms. Plummer refused to authorize the misuse

of government funds.

58. On November 4, 2013, Ms. Plummer resigned as a signatory for the CAL Card

because she could not knowingly be a party to or condone improper activity.

59. Also in this time period, Ms. Plummer informed City of Richmond Council Member

Tom Butt that City staff and Council members, including Nat Bates and Corky Booze, had

taken trips to China under the auspices of the Port of Richmond, and that there appeared to

be financial improprieties in relation to this trip.

60. Ms. Plummer informed Tom Butt that Lindsay was also invited to these trips, and

received cash to do so, but never went on the trips. Ms. Plummer reported that there

appeared to be financial improprieties in relation to this.

61. Shortly after these revelations about Port trips were made public, Ms. Plummer

received a Notice of Unpaid Suspension from the City, Lindsay, and Stephenson.

62. On November 27, 2013, the City, Lindsay, and Stephenson issued Ms. Plummer a

Notice of Unpaid Suspension for one week, charging her with insubordination and

unprofessional emails. The Citys Suspension letter says that the insubordination and

unprofessionalism are because Ms. Plummer refused to sign off on the CAL Card

expenses, and for refusing to contact the grantor to answer the grantors questions. Ms.

Plummers emails also reported the Citys violation of wage and hour laws, and her refusal

to approve unlawful CAL Card expenditures. She had also reported other improprieties as

described above.

63. Ms. Plummer was thus suspended for one week without pay.



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64. In January 2014, upon threat of lawsuit, the City rescinded the Suspension, and paid

Ms. Plummer backpay for the weeklong suspension, but maintained the Letter of

Reprimand against Ms. Plummer.

65. Ms. Plummer was informed by the Richmond City Attorney's office that she could

not appeal matters to the Citys Personnel Board unless it was regarding a demotion,

suspension, termination or reduction in pay. No other matters of retaliation could be

brought before the Personnel Board. Such issues could only be decided by appeals to the

City Manager Lindsay.

66. In January 2014, more of Curls misconduct emerged. The City has a library vendor

resolution requiring City Council approval for library procurement exceeding $10,000 to a

single vendor. In 2012, Curl stated she would request that City Council change the

resolution, but she did not.

67. Ms. Plummer reminded Curl and her other Library superiors about the resolution

numerous times. In response, Curl sent an email to all Ms. Plummers library superiors

admonishing Ms. Plummer.

68. Following this, Ms. Plummer alerted Curl that Library vendors were sending her

many emails about unpaid bills.

69. In January 2014, Curl directed Ms. Plummer to violate local laws and send unlawful

partial payments to vendors without approval. Ms. Plummer notified Curl, Lindsay, and the

City Attorney that this was a violation of the law and refused to do it.

70. On January 17, 2014, Curl temporarily gave Ms. Plummer her long withheld job

duties back. Curl required her to complete the severely delayed vendor resolutions, accrued

over one year, in three days.

71. On January 19, 2014, Ms. Plummer filed a grievance against Curl for her misconduct

and retaliation in the violation of municipal law with regards to the library vendor

resolution.

72. On April 17, 2014, Ms. Plummer was made aware for the first time in a staff meeting

that Curls freezing of Ms. Plummers job duties and excluding her from information had



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resulted in a complete financial breakdown in Library services. Curl had stripped the task of

library procurement and invoice processing from Ms. Plummer, and assigned those tasks to

her Executive Secretary.

73. Curls Executive Secretary, untrained for library procurement and invoice

processing tasks and overwhelmed, broke down in tears at a staff meeting with Ms.

Plummer, Curl, and others. At this meeting, it came out that Curl had failed to ensure City

Council approval to pay library expenses for almost the entire 2013-2014 fiscal year.

74. This failure resulted in no new childrens materials of any kind; no new magazines,

DVDs, adult/reference books; no new books for the Bookmobile; no new books for two

library branches; a forfeit of $60,000 in the book budget because the money was going

unused; at least $80,000 in unpaid vendor bills; and nonpayment of $15,000 in

membership dues to the Pacific Library Partnership consortium; all for over 10 months and

counting. Curl was forced to return Ms. Plummers long withheld job duties. Curl then had

all the unpaid bill files dumped on Ms. Plummers desk, while Curl denied Ms. Plummer use

of the automated batch payment process in completing this Herculean task.

75. In or around April 2014, City librarians attended a Personnel Board meeting en

masse to speak about the lack of materials at the library. Some Library staff testified that

they brought magazines from home to supply the public library.

76. On April 24, 2014, the Mayors office asked for a report about library functions from

Curl and Ms. Plummer. Ms. Plummer responded that she could not provide this information

as Curl had stripped her of her job duties.

77. On May 6, 2014, Curl issued a Letter of Reprimand to Ms. Plummer for (1) her

disrespectful email to the Mayors office that Curl had frozen Ms. Plummer out of essential

information; and (2) for her email to the Finance Director exposing Curls retaliatory

disallowance of the use of the batch payment process and the many unpaid invoices.

78. On May 21, 2014, the federal Institute of Museum and Library Services (IMLS)

sent Curl and Ms. Plummer notice that the Library would be cut off from federal funding

due to delinquent reporting. Ms. Plummer had not been aware of the issue due to Curls



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freezing her out of her job, though she had inquired about it in the past without response.

Ms. Plummer sent the IMLS email to the City Council.

79. Shortly thereafter, Ms. Plummer wrote an extension letter to IMLS and was able to

gain another six months for the Library to submit reports.

80. One week later, on May 28, 2014, Ms. Plummer was notified of her transfer out of

the Library. On June 4, 2014, the City of Richmond, Lindsay, Stephenson, and Curl

transferred Ms. Plummer out of the Library and to the Finance Department.

81. In July 2014, Plummers new supervisor in the Finance Department, Jim Goins,

stated that Curl and Stephenson were trying to figure out what to do with Ms. Plummer

before moving her to Finance.

82. In August 2014, the City, Lindsay, and Stephenson, transferred Ms. Plummer from

the second floor to the first floor. Goins told Ms. Plummer that Lindsay had stated that the

transfer was because Ms. Plummer was assisting other City employees, including Lalo

Herrera, with their whistleblower and retaliation complaints against the City.

83. In August 2014, Goins stated that Curl refused to complete Ms. Plummers

performance evaluation, which was necessary for the consideration of her promotion to

Finance Manager II.

84. Ms. Plummer has filed grievances and other formal complaints of misconduct, and

retaliation for her protected disclosures, with City Manager Lindsay, Interim Human

Resources Director Stephenson, City Attorney Goodmiller, Risk Manager Greer, and Library

and Cultural Services Director Curl.

85. Ms. Plummer brought these concerns to her chain of command, and then outside

her chain of command to the City Manager, City Attorney, City Council, the public, the

Federal Bureau of Investigation, the Contra Costa County Grand Jury, the Contra Costa

District Attorneys Office, the State Attorney Generals office, and the Federal Governments

Office of the Inspector General. She refused unlawful orders in contravention of her

superiors orders several times. She reported widespread and systemic corruption.



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86. Invariably, following each protected disclosure, defendants took adverse action

against Ms. Plummer, including multiple transfers, suspension, and denying a

recommended promotion while secretly promoting less qualified employees. Defendants

have docked Ms. Plummers pay several times, and denied her leave salary and benefits.

These adverse actions have chilled Ms. Plummers speech, and that of other employees.

87. The City has no whistleblower administrative procedure. Ms. Plummer followed the

internal City procedure for general grievances by complaining to her superior, filing

grievances, and filing complaints. Ms. Plummer has filed complaints with local agencies

such as the Citys Personnel Board, the Citys Human Resources Department and the City

Attorneys Office. She filed complaints under penalty of perjury with state agencies the

Department of Fair Employment and Housing and the Public Employment Relation Board.

Ms. Plummer has filed a Government Torts Claim Act (GTCA) with the local agency, the

City Clerks Office. Ms. Plummer made a good faith effort to exhaust administrative

remedies before filing this lawsuit, and any other complaints.

88. Ms. Plummer has been a tireless advocate for the public. In each grievance and

complaint, she has asked only for an Ethics Committee in Richmond that can properly

investigate the gross misconduct there, and to be made whole after the exhausting and

grueling retaliation she has suffered, simply for speaking up for the people of Richmond.

EXHAUSTION OF ADMINISTRATIVE REMEDIES

89. Plaintiff has exhausted all administrative remedies by filing a Government Torts

Claim Act claim with the City of Richmond on March 27, 2014. The City denied that claim on

April 2, 2014. California Labor Code 1102.5 does not require administrative exhaustion.

FIRST CLAIM - VIOLATION OF FREE SPEECH RIGHTS

(against defendants City of Richmond, Bill Lindsay, Katy Curl,

Leslie Knight, and Lisa Stephenson in their individual capacities)

(42 U.S.C. 1983)

90. Plaintiff incorporates by reference paragraphs 1 through 90 above as though fully set

forth herein.



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91. By virtue of the foregoing, defendant City of Richmonds highest officials, who have

final policymaking authority under state law, adopted a policy of adverse actions against

whistleblowers that wrongfully deprived plaintiff of her free speech rights guaranteed under

the Constitution of the United States.

92. Defendants Bill Lindsay, Katy Curl, Leslie Knight, and Lisa Stephenson, acting under

color of state law, wrongfully deprived plaintiff of her free speech rights guaranteed under

the Constitution of the United States by participating in adverse employment actions against

plaintiff in retaliation for her speech addressing issues of public concern and refusing to

participate in unethical and unlawful conduct by defendants.

SECOND CLAIM VIOLATION OF

CALIFORNIA LABOR CODE 1102.5

(against defendant City of Richmond)


forth herein.

94. By virtue of the foregoing, defendant City of Richmond retaliated against plaintiff for

disclosing what she reasonably believed were violations of federal, state, and municipal laws

to her supervisors and others, and for refusing to take part in unlawful activities in violation

of Labor Code 1102.5.

THIRD CLAIM VIOLATION OF

CALIFORNIA BANE ACT

(against defendants City of Richmond, Bill Lindsay, Katy Curl,

Leslie Knight, and Lisa Stephenson)

(California Civil Code 52.1)


forth herein.

96. By virtue of the foregoing, defendants Bill Lindsay, Katy Curl, Leslie Knight, Lisa

Stephenson, and DOES 1 through 10 inclusive, interfered by threats, intimidation, or



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coercion with the rights of the plaintiff secured by the Constitution of the United States and

the Constitution of the State of California.

97. By virtue of the foregoing, all defendants acted with malice and oppression and with

the intent to deprive, and did deprive, plaintiff of her rights to the exercise of free speech by

retaliating against the plaintiff for publicly speaking out on matters of public concern.

DAMAGES

98. As a result of the actions of defendants, plaintiff has been injured and has suffered

damages as follows:

a. She has lost compensation and other employment-related benefits to which she has

been entitled and will lose such compensation and benefits in the future;

b. She has suffered from emotional distress, embarrassment and humiliation, and has

suffered damage to her professional reputation and standing;

c. She has incurred out-of-pocket expenses for health care benefits.

PUNITIVE DAMAGES

99. In taking the actions alleged above, defendants Bill Lindsay, Leslie Knight, Katy

Curl, and Lisa Stephenson engaged in the conduct alleged herein with malice, oppression,

and reckless disregard of plaintiffs right to be free of retaliation for engaging in protected

free speech, and to report gross mismanagement and abuse. Accordingly, plaintiff is entitled

to punitive damages against defendants Bill Lindsay, Leslie Knight, Katy Curl, and Lisa

Stephenson in this action.

WHEREFORE, plaintiff requests that this Court grant her relief as follows:

(1) Injunctive relief to require defendant City of Richmond to promote plaintiff

to the appropriate classification together with all pay, benefits, seniority, and emoluments of

that position; and treat her without retaliation;

(2) Injunctive relief to require City of Richmond to cease retaliation against

employees who engage in protected activity;

(3) Compensatory damages for past and future lost wages and benefits, in an

amount to be determined;



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(4) Interest at the legal rate;

(5) General damages for emotional distress, pain and suffering, in an amount to

be determined;

(6) Special damages for out-of-pocket expenses;

(7) Punitive damages, in an amount to be determined;

(8) Attorney fees;

(9) Costs of suit; and

(10) Such other and further relief as the Court may deem proper.

DEMAND FOR JURY TRIAL

In accordance with the Federal Rules of Civil Procedure, Rule 38(b), and

Northern District Local Rule 3-6(a), Stacie Plummer hereby demands a jury trial.

Dated: November 21, 2014

SIEGEL & YEE

By: _/s/ Sonya Z. Mehta_____ Sonya Z. Mehta Attorneys for Plaintiff STACIE PLUMMER


plummer v. richmond

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