Case 3:21-cv-00428-BJB Document 1-1 Filed 07/02/21 Page 1 of 14 PageID #: 7
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`Exhibit
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`Exhibit
`A
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`f a
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`PresidingJudge:HON.CHARLESL.CUNNINGHAM(630297)
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`COM:000001of000013
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`Case 3:21-cv-00428-BJB Document 1-1 Filed 07/02/21 Page 2 of 14 PageID #: 8
`Case 3:21-cv-00428—BJB Document 1-1 Filed 07/02/21 Page 2 of 14 PageID #: 8
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`Filed
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`21-(‘1—003
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`COMMONWEALTH OF KENTUCKY
`JEFFERSON CIRCUIT COURT
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`DIVISION ___
`CASE NO.
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`CRISTIE ROBBINS
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`-
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`‘
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`PLAINTIFF
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`v.
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`COMPLAINT
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`WALGREEN CO.
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`Serve:
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`DEFENDANT
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`Walgreen Co.
`c/o The Prentice-Hall Corporation System, Inc.
`liiili‘fiafigéi‘
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`JURY FEE PAID
`Frankfort, Kentucky 40601
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`it
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`*
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`*I
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`*
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`Ill
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`Comes now the Plaintiff, Cristie Robbins, and for her Complaint against Walgreen Co.
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`states as follows:
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`' PARTIES
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`1.
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`The Plaintiff, Cristie Robbins (hereinafter “Mrs. Robbins”), is domiciled in New Albany,
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`Indiana. At all times during Mrs. Robbins’ employment with the Defendant, she worked in
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`the Commonwealth of Kentucky. Mrs. Robbins’ employment with the Defendant was
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`illegally terminated on March 2, 2021.
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`2:
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`is a for-profit corporation
`The Defendant, Walgreen Co. (hereinafier “Walgreens”),
`headquartered in Deerfield, Illinois and doing businessthroughout the Commonwealth of
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`Kentucky, including in Jefferson County, Kentucky. Walgreens may be served via its
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`Registered Agent at The Prentice-Hall Corporation System,
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`Inc. 421 W. Main St.
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`Frankfort, Kentucky 40601.
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`JURISDICTION AND VENUE
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`1
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`Filed
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`21 {1-003154
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`[la-"0132021
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`David L. Nicholson. J effersen Circuit Clerk
`6:.»
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`Case 3:21-cv-00428-BJB Document 1-1 Filed 07/02/21 Page 3 of 14 PageID #: 9
`Case 3:21-cv-00428—BJB Document 1-1 Filed 07/02/21 Page 3 of 14 PageID #: 9
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`3.
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`This Court has jurisdiction over Plaintiffs claims pursuant to 29 U.S.C. § 2617(a)(2), KRS
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`§ 344.450, KRS 23A.010(l), and KRS 454.2100).
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`-
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`Plaintiff‘s claims for relief are in excess of the minimum required for jurisdiction in this
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`COuit.
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`Venue is proper in the Jefferson Circuit Court pursuant to, inter alia, KRS 452.450 and
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`KRS 454.210(4).
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`UNDERLYING FACTS
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`At the time of her termination on March 2, 2021, Plaintiff Mrs. Robbins had been a
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`Walgreens employee for sixteen (16) years. Since November of 2016 Mrs. Robbins was
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`employed by Walgreens as a District Manager (“DM”). As a BM, Mrs. Robbins oversaw
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`the operations of the Walgreens stores in her area. At the time of her termination Mrs.
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`Robbins oversaw thirteen (13) Walgreens stores in Kentucky. twelve (12) of which were
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`located in Louisville.
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`Throughout-Mrs. Robbins’ Walgreens career she had Consistently received positive
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`performance reviews and had never been issued any form of discipline.
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`In May of 2020, Mrs. Robbins began reporting to a new supervisor, Aaron West
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`(hereinafter “Mr. West"), the Director of Pharmacy & Retail.
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`I A1m05t immediately, Mrs. Robbins observed Mr. west favoring his male subordinates. For
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`instance, when one of Mrs. Robbins’ female peers left her position, there were multiple,
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`highly qualified female employees ready for a promotion based on succession-planning.
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`Mr. West bypassed these female employees and instead first offered the jobto multiple
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`Presldlng'Judge:HON.CHARLESL.CUNNINGHAM(630297)
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`Filed
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`21£14303154
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`06/011’2021
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`Druid L. Nicholson, Jefferson Circuit C lerk
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`COM:000002of000013
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`Case 3:21-cv-00428-BJB Document 1-1 Filed 07/02/21 Page 4 of 14 PageID #: 10
`Case 3:21-cv-00428—BJB Document 1-1 Filed 07/02/21 Page 4 of 14 PageID #: 10
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`men. It was only after these men did not accept Mr. West’s offers that one ofthe eminently
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`qualified female employees was effectively placed in the position by default.
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`10.
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`The newly-promoted female DM had to travel several hours to her new area. Mr. West did
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`not permit her to work remotely. Atthe same time, however, Mr. West allowed a male DM
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`who also lived several hours from his district to work almost entirely remotely. This male
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`DM was only required to conduct one in-person visit to his stores each month, despite a
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`recent documented final warning.
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`11.
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`In another situation, Mr. West’s female area administrator informed him that she was
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`pregnant. After being allowed to work remotely for just a few weeks, Mr. West
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`inexplicably told the area administrator that she could no longer work remotely and forced
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`her to take extended, unpaid leave for the remainder of her pregnancy. A male was
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`promptly installed to take over the female area administrator’s duties.
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`12.
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`With little to no contact with Mrs. Robbins during his first twomonths as her supervisor,
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`Mr. West gave Mrs. Robbins the first below average yearly performance review of her
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`career.
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`13.
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`In the background of MI. West’s unjustified review, Mrs. Robbins’ District, which is
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`primarily comprised of stores in Louisville’s West End, was experiencing unprecedented
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`upheaval and challenges. The West End of Louisville is a proud but impoverished area that
`was hit disproportionately hard by the COVlD-l 9 global pandemic. Moreover, around the
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`same time thatMr. West arrived, there was widespread rioting and looting in Mrs. Robbins’
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`District related to Breonna Taylor and the deaths of several other African-Americans. Mr.
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`PresldlngJudge:HON.CHARLESL.CUNNINGHAM(630297)
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`Filed
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`21—Cl-00315-I
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`061012021
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`David L. Xicholson, Jefferson Cirtuit Clerk
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`COM:000003of000013
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`Case 3:21-cv-00428-BJB Document 1-1 Filed 07/02/21 Page 5 of 14 PageID #: 11
`Case 3:21-cv-00428—BJB Document 1-1 Filed 07/02/21 Page 5 of 14 PageID #: 11
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`West's willful ignorance of the serious issues faced by Mrs. Robbins’ stores can be
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`summed up in one interaction.
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`14.
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`At the height of the riots that took place in the Summer of 2020, Mr. West made his first
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`visit to one of Ms. Robbins’ stores in the West End of Louisville. The Store Manager had
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`been working all day and all night for several. days in a row. The employees, most ofwhom
`were West End residents, were exhausted. 'The store had suffered property damage and
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`looting. Personally and professionally, everyone was drained. Enter Mr. West. Wearing a
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`suit and tie, he looked around the store, taking in the weary faces and disheveled aisles. In
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`a moment that Called for leadership and compassion, Mr. West giddily bragged to anyone
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`within earshot how “cool” it .was that he had just had a phone call with the Mayor. He went
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`on in a self-important manner and failed to recognize any of the selfless actions taken by
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`the store’s employees.
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`15.
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`16.
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`On January 20, 2021, Mrs. Robbins informed Mr. West that she was pregnant. Importantly,
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`Mrs. Robbins told Mr. West that she had previously lost several pregnancies, and, at forty-
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`four (44) years of age, her pregnancy would be extremely high risk.
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`Rather than explore ways to accommodate Mrs. Robbins’ high-risk pregnancy, Mr. West
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`went on the attack. He ramped up his unfair and unjustified scrutiny of her work in ways
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`that he admitted he was not doing towards Mrs. Robbins’ male peers.
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`- 17.
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`By the end of February 2021, Mrs. Robbins’ blood. pressure was spiking, putting her
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`pregnancy in even more risk. Her doctor ordered her to be off from work. Mrs. Robbins
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`promptly notified Walgreens and Sedgwick, Walgreens’ third-party leave provider.
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`Filed
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`21-CI—003154
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`06;”012021
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`Dan’d L. Nicholson, Jefferson C intuit Clerk
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`PresldlngJudge:HON.CHARLESL.CUNNINGHAM(630297)
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`COM1000004of000013
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`Case 3:21-cv-00428-BJB Document 1-1 Filed 07/02/21 Page 6 of 14 PageID #: 12
`Case 3:21-cv-00428—BJB Document 1-1 Filed 07/02/21 Page 6 of 14 PageID #: 12
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`18.
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`At the time of her request for leave, Mrs. Robbins met all of the requirements to qualify
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`for job-protected leave under the Family and Medical Leave Act (“FMLA”).
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`I9.
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`On March 1, 2021, Mrs. Robbins emailed Mr. West: “Aaron, I’ll be on leave due to
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`concerns with my high risk pregnancy. Everything is being finalized by Sedgwick. You
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`should be receiving information via email soon.”
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`20.
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`The following day, on March 2, 2021, Mr. West called Mrs. Robbins and told her that she
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`was being terminated, effective immediately. He claimed it was for “unsatisfactory
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`performance. She received a letter in the mail a few days later stating the same thing.
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`CLAIMS
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`COUNT I: FMLA RETALIATION
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`2].
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`Plaintiff reiterates and reincorporates the allegations contained in Paragraphs 1-20 of this
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`Complaint as if set forth at length herein.
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`22.
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`23.
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`This is a claim made pursuant to 28 U.S.C. § 2617(a)(2)(A) for violation of 28 U.S.C.
`§2615(a)(2).
`'
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`Defendant Walgreens is an employer subject to the FMLA, in that it is a corporate entity,
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`engaged in commerce, employing fifty or more employees for each working day during
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`twenty or more workweeks in the current or preceding calendar year.
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`24.
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`Plaintiff Mrs. Robbins is an eligible employee under the FMLA, in that at the time of her
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`termination, she had worked for Defendant Walgreens continuously for at least twelve
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`months and had worked at least 1,250 hours during the twelve months prior to the start of
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`her request for FMLA leave.
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`Filed
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`214314103154
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`flfiffllflflll
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`David 1.. Nicholson, Jefferson Circuit Clerk
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`PresldlngJudge:HON.CHARLESL.CUNNINGHAM(630297)
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`COM:000005of000013
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`Case 3:21-cv-00428-BJB Document 1-1 Filed 07/02/21 Page 7 of 14 PageID #: 13
`Case 3:21-cv-00428—BJB Document 1-1 Filed 07/02/21 Page 7 of 14 PageID #: 13
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`25.
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`Mrs. Robbins experienced a serious health condition in that she had an extremely high-risk
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`pregnancy, which was exacerbated by, among other things, increased blood pressure and
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`maternal age. Mrs. Robbins’ doctor ordered her to take medical leave due to her serious
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`health condition.
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`26.
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`Mrs. Robbins engaged in activities protected under the FMLA,
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`including, without
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`limitation, her lawful request for FMLA leave.
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`27.
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`Defendant Walgreens had actual knowledge of Mrs. Robbins’ exercise (or,
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`in the
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`alternative, her attempted exercise)‘ofrights under the FMLA prior to the taking of adverse
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`employment actions against Mrs. Robbins,
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`in that, without limitation, Mrs. Robbins
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`notified Walgreens on January 20, 2021 of her serious health condition and requested
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`medical leave protected under the FMLA on March 1, 2021.
`As a direct result ofMrs. Robbins’ exercise (or, in the alternative, her attempted exercise)
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`28.
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`or her rights under the FMLA, Mrs. Robbins suffered an adverse employment action,
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`including, without limitation, her termination in March 2, 2021.
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`29.
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`There is a causal connection between Mrs. Robbins’ exercise (or, in the alternative, her
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`attempted exercise) of rights under the FMLA and the adverse employment action taken
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`against her, in that, without limitation, the adverse employment action was taken in acute
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`temporal proximity to Mrs. Robbins’ exercising (or, in the alternative, attempting to
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`exercise) her rights under the FMLA.
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`30.
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`Mrs. Robbins’ protected activities under the FMLA were at least a motivating factor in the
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`determination to terminate Mrs. Robbins’ employment.
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`Filed
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`21—(71—003154
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`0.6!0L’2021
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`David 1.. Sicholson. Jefferson Cirtuit Clerk
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`PresldlngJudge:HON.CHARLESL.CUNNINGHAM(630297)
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`COM:000006of000013
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`Case 3:21-cv-00428-BJB Document 1-1 Filed 07/02/21 Page 8 of 14 PageID #: 14
`Case 3:21-cv-00428—BJB Document 1-1 Filed 07/02/21 Page 8 of 14 PageID #: 14
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`31.
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`Plaintiff reiterates and reincorporates the allegations contained in Paragraphs 1-30 of this
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`Complaint as if set forth at length herein.
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`32.
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`This is a claim made pursuant to 28 U.S.C. § 26l7(a)(2)(A) for violation of 28 U.S.C.
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`§26I5(a)(1).
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`33.
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`Defendant Walgreens is an employer subject to the FMLA, in that it is a corporate entity,
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`engaged in commerce, employing fifty or more employees for each working day during
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`twenty or more workweeks in the current or preceding calendar year.
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`34.
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`Plaintiff Mrs. Robbins is an eligible employee under the FMLA, in that at the time of her
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`termination, she had worked for Defendant Walgreens continuously for at least twelve
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`months and had worked at least 1,250 hours during the twelve months prior to the start of
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`her request for FMLA leave.
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`35.
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`Mrs. Robbins experienced a serious health condition in that she had an extremely high-risk
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`pregnancy, which was exacerbated by, among other things, increased blood pressure and
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`maternal age. Mrs. Robbins’ doctor ordered her to take medical leave due to her serious
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`health condition.
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`36.
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`Mrs. Robbins gave notice of her intention to take leave by notifying her supervisor of her
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`serious health condition on January 20, 2021 and by notifying Walgreens and its third—
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`party leave provider of her intention to take medical leave covered by the FMLA on
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`February 25, 2021.
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`PresidingJudge:HON.CHARLESL.CUNNINGHAM(630297)
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`Filed
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`ll-CI-GDSIS-i
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`0601:2021
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`David L. Nicholson, Jefferson Circuit Clerk
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`COM3000007of000013
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`Case 3:21-cv-00428-BJB Document 1-1 Filed 07/02/21 Page 9 of 14 PageID #: 15
`Case 3:21-cv-00428—BJB Document 1-1 Filed 07/02/21 Page 9 of 14 PageID #: 15
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`37.
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`Defendant Walgreens denied Mrs. Robbins of FMLA benefits to which she was entitled,
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`in that, without limitation, Defendant denied her use of FMLA benefits by terminating her
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`employment the day afier she requested medical leave protected by the FMLA.
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`38.
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`39.
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`COUNT III: VIOLATION OF THE KENTUCKY PREGNANT WORKERS ACT
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`Plaintiff reiterates and reincorporates the allegations contained in Paragraphs 1-37 of this
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`Complaint as if set forth at length herein.
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`On July 27, 2019, Kentucky’s Pregnant Worker’s Act (“KWPA”) officially became law.
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`This law updated the definition of “reasonable accommodations” under KRS Chapter 344,
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`et seq., the Kentucky Civil Rights Act (“KCRA”) to greatly expand its protections of
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`pregnant employees in Kentucky, such as Ms. Robbins. This updated definition requires
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`reasonable accommodations specific to an employee’s limitations caused by pregnancy,
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`childbirth, and related medical conditions, including, but not limited to: (l) temporary
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`transfer to a less strenuous or less hazardous position; (2) job restructuring; (3) light duty;
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`(4) modified work schedule; and,
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`(5)
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`time off to recover from childbirth.
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`(KRS
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`344.030(6)(b)), see also KRS 344.040 (Making it an unlawful practice to fail to make
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`reasonable accommodations for any employee with limitations related to pregnancy,
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`childbirth, or a related medical condition.)
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`40.
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`Under the KWPA, upon finding out that an employee is pregnant, the PWA requires the
`employer to engage in in a timely, good faith interactive process to determine effective
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`reasonable accommodations for the employee’s pregnancy.
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`PresldlngJudge:HON.CHARLESL.CUNNINGHAM(630297)
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`Filed
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`21421003151
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`Milli/2021
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`David L. Nicholson. Jefferson Cinuit Clerk
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`COM:000000of000013
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`Case 3:21-cv-00428-BJB Document 1-1 Filed 07/02/21 Page 10 of 14 PageID #: 16
`Case 3:21-cv-00428—BJB Document 1-1 Filed 07/02/21 Page 10 of 14 PageID #: 16
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`41.
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`The KWPA further provides explicit guidance to employers regarding what considerations
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`must be made when accomr‘nodating a pregnant employee. For example, an employee
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`“shall not be required to take leave from work if another reasonable accommodation can
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`be provided.”
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`42.
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`43.
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`As an employer operating in Kentucky, Defendant Walgreens is subject to the requirements
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`of the KWPA.
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`As a pregnant employee, Mrs. Robbins was protected by the KWPA.
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`Walgreens violated the KWPA with regard to the terms and conditions of Mrs. Robbins’
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`employment.
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`45.
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`When Mrs. Robbins informed Walgreens, beginning on January 20, 201 , that she was in
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`the midst of a high-risk pregnancy, Walgreens had a duty to engage in the interactive
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`process to assess what reasonable accommodations would be available to allow Mrs.
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`Robbins to continue as a Walgreens employee. Walgreens violated the KWPA by failing
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`to engage in the required interactive process.
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`46.
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`Walgreens further iviolated the KWPA by failing to provide reasonable accommodations
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`for Mrs. Robbins’ pregnancy, including, but not limited to, modifying her job duties, light
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`duty, modifying her work schedule, and/or providing her with leave.
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`47.
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`By reason-of the Defendant’s violation of the KWPA, Mrs. Robbins is entitled to legal and
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`equitable remedies, pursuant to KRS 344.040, et seq,
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`including, but not
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`limited to,
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`compensatory damages in the form of past and present lost wages and past, present, and
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`future emotional distress damages as well as her reasonable attomey’s fees and costs
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`incurred in bringing this action.
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`Filed
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`ZICI-003154
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`06.50120 21
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`Druid L. Xitholsun, Jefferson Circuit Clerk
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`PresidingJudge:HON.CHARLESL.CUNNINGHAM(630297)
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`COM2000009of000013
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`Case 3:21-cv-00428-BJB Document 1-1 Filed 07/02/21 Page 11 of 14 PageID #: 17
`Case 3:21-cv-00428—BJB Document 1-1 Filed 07/02/21 Page 11 of 14 PageID #: 17
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`COUNT 1V: KRS 344.280 RETALIATION
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`48.
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`Plaintiff reiterates and reincorporates the allegations contained in Paragraphs 1-47 of this '
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`Complaint as if set forth at length herein.
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`49.
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`Defendant Walgreens retaliated against Mrs. Robbins because she engaged in legally
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`protected activity under the Kentucky Civil Rights Act (“KCRA”).
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`50.
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`Mrs. Robbins engaged in the legally protected activity described above, which includes,
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`but is not limited to, requesting reasonable accommodations under the KWPA.
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`51.
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`As a result of engaging in legally protected activity, Mrs. Robbins has suffered adverse
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`treatment from the Defendant, including, but not limited to, the'illegal termination of her
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`employment.
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`52.
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`Defendant Walgreens had no legitimate reason to subject Mrs. Robbins to the above-
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`described adverse treatment.
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`53.
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`By participating in the above actions, the Defendant has committed against Mrs. Robbins
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`the unlawful practice of retaliation under KRS 344.280, et seq.
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`54.
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`I
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`By reason of the Defendant’s retaliation, Mrs. Robbins'is entitled to legal and equitable
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`remedies, pursuant to KRS 344.040, et seq, including, but not limited to, compensatory
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`damages in the form ofpast and present lost wages and past, present, and future emotional
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`distress damages as well as her reasonable attorney’s fees and costs incurred in bringing
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`this action.
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`COUNT V: GENDER DISCRIMINATION
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`55.
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`Plaintiff reiterates and reincorporates the allegations contained in Paragraphs 1-54 of this
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`Complaint as if set forth at length herein.
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`10
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`Filed
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`214314103154
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`053013021
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`David L. Nicholson, Jefferson Circuit Clerk
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`PresidingJudge:HON.CHARLESL.CUNNINGHAM(630297)
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`COM:000010of000013_
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`Case 3:21-cv-00428-BJB Document 1-1 Filed 07/02/21 Page 12 of 14 PageID #: 18
`Case 3:21-cv-00428—BJB Document 1-1 Filed 07/02/21 Page 12 of 14 PageID #: 18
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`56.
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`KRS 344.040 makes it illegal for an employer to fail or refuse to hire, or to discharge any
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`individual, or otherwise to discriminate against an individual with respect to compensation,
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`terms, conditions, or privileges of employment, because of the individual’s sex.
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`57.
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`Walgreens violated. KRS 344.040, et seq. by subjecting her to an adverse employment
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`action - termination of her employment — because of her gender, female.
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`58.
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`Mrs. Robbins requested leave from Walgreens related to her pregnancy. Walgreens
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`terminated her the next day.
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`59.
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`By terminating Mrs. Robbins’ employment because she requested pregnancy-related
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`medical leave, Walgreens treated Mrs. Robbins disparately worse than individuals outside
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`of the protected category — i.e., males who cannot become pregnant.
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`60.
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`By reason of the Defendant’s illegal discrimination, Mrs. Robbins is entitled to legal and
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`equitable remedies, pursuant to KRS 344.040, et seq,
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`including, but not limited to,
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`compensatory damages in the form of past and present lost wages and past, present, and
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`future emotional distress damages as well as her reasonable attomey’s fees and costs
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`incurred in bringing this action.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff Cristie Robbins, hereby demands judgment against
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`the
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`Defendant, Walgreens Co. for violation of her rights pursuant to the Family and Medical
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`Leave Act on Counts I and II as follows:
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`(a) a trial by jury;
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`(b) compensatory damages,
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`including, without limitation, past and present lost wages
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`pursuant to 29 U.S.C. §2617(a)(1)(A)(i);
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`ll
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`Filed
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`21—CI—003154
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`061018021
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`David L. Nicholson. Jefferson (”intuit Clerk
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`PrasldlngJudge:HON.CHARLESL.CUNNINGHAM(630297)
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`COM:000011of000013
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`Case 3:21-cv-00428-BJB Document 1-1 Filed 07/02/21 Page 13 of 14 PageID #: 19
`Case 3:21-cv-00428—BJB Document 1-1 Filed 07/02/21 Page 13 of 14 PageID #: 19
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`(c) interest calculated at the prevailing rate pursuant to 29 U.S.C. §26l7(a)(1)(A)(ii);
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`(d) liquidated damages pursuant to 29 U.S.C. §26l7(a)( l)(A)(iii);
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`(e) equitable relief by this Court as may be appropriate pursuant
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`to 29 U.S.C.
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`§2617(a)(1)(B),
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`including without
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`limitation
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`employment,
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`reinstatement
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`to
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`employment, or promotion, or in the alternative, front pay;
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`(f) reasonable attomey’s fees, reasonable expert witness fees, and other costs of the action
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`pursuant to 29 U.S.C. §2617(a)(3); and
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`(g) any and all other such reliefto which she may be entitled, including, without limitation,
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`damages for emotional distress.
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`Plaintiff Cristie Robbins, hereby demands judgment against the Defendant, Walgreens Co.
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`for violation of her rights pursuant to the Kentucky Civil Rights Act on Counts III, IV
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`and V as follows:
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`(*0 a tfial by jury;
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`(i) compensatory damages, including, without limitation, past and present lost wages,
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`humiliation and embarrassment, emotional distress and anxiety, and other non-
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`pecuniary damages allowed by law 'for the unlawful retaliation against Plaintiff,
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`including her reasonable attorneys’ fees and expenses, all in excess of the jurisdictional
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`limits of this Court; '
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`(j) for equitable relief in the form of reinstatement, or, in the alternative, an award of
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`damages for front pay;
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`(k) reasonable attorney’s fees, reasonable expert witness fees, and other costs of the action
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`12
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`Filed
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`ZI-CI—GOSIS-l
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`fifllfllflflll
`
`David L. Nicholson, Jefferson Circuit Clerk
`
`
`
`
`
`PresidingJudge:HON.CHARLESL.CUNNINGHAM(630297)
`
`
`
`
`
`
`
`COM:000012of000013
`
`
`
`Case 3:21-cv-00428-BJB Document 1-1 Filed 07/02/21 Page 14 of 14 PageID #: 20
`Case 3:21-cv-00428—BJB Document 1-1 Filed 07/02/21 Page 14 of 14 PageID #: 20
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`pursuant to the KRS Chapter 344, et seq.;
`
`(1)
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`interest calculated at the prevailing rate; and
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`(m) any and all other relief to which he may be entitled.
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`Respectfully submitted,
`
`ROARK & KORUS, PLLC
`
`/s/ Tyler Z. Korus
`Robert L. Roark, Esq.
`Tyler Z. Korus, Esq.
`401 Lewis Hargett Circle, Suite 210
`Lexington, Kentucky 40503
`Telephone: 859-203-2430
`Facsimiie: 859-523-6351
`
`RobmJ-roarkkoruscom
`Tyler§i13roarkkoruscom
`COUNSEL FOR PLAINTIFF
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`
`
`
`
`PresldlngJudge:HON.CHARLESL.CUNNINGHAM(630297)
`
`
`
`
`
`
`
`13
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`COM:000013of000013
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`Wed
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`210—06315:
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`06:01:202‘1
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`David L. Nicholson. Jefferson Circuit Clerk
`
`
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