throbber
Case: 2:21-cv-05622-ALM-KAJ Doc #: 1 Filed: 12/07/21 Page: 1 of 16 PAGEID #: 1
`Case: 2:21-cv-05622-ALM-KAJ Doc #: 1 Filed: 12/07/21 Page: 1 of 16 PAGEID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF OHIO
`EASTERN DIVISION
`
`CASE NO.
`
`JUDGE:
`
`COMPLAINT FOR DAMAGES
`AND INJUNCTIVE RELIEF
`
`JURY DEMAND ENDORSED
`HEREIN
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`
`JOCELYN MCDONALD
`5161 Westerville Road
`Columbus, Ohio 43231,
`
`Plaintiff,
`
`v.
`
`CENTENE MANAGEMENT COMPANY
`LLC
`4349 Easton Way, Suite 200
`Columbus, Ohio 43219
`
`Serve Also:
`Centene Management Company LLC
`CT Corporation System
`4400 Easton Commons Way
`Suite 125
`Columbus, Ohio 43219
`
`Centene Management Company LLC
`c/o Buckeye Community Health Plan
`Inc.
`7700 Forsyth Blvd, Ste. 800
`St. Louis, MO 63105
`
`Defendant.
`
`Plaintiff, Jocelyn McDonald, by and through undersigned counsel, as her Complaint
`
`against Defendant Centene Management Company LLC (“Centene”), states and avers the
`
`following:
`
`PARTIES, VENUE, & JURISDICTION
`
`1. McDonald is a resident of the city of Columbus, Franklin County, Ohio.
`
`2. Atall times herein, McDonald was acting in the course and scope of her employment.
`
`

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`. Centene is a foreign limited liability company that does business at 4349 Easton Way, Suite
`
`200, Columbus, Franklin County, Ohio 43219 (“Easton Location”).
`
`. Centeneis and, atall times herein, was an employer within the meaning of R.C. § 4112.01 e¢
`
`seq.
`
`. This court has subject matterjurisdiction pursuantto 28 U.S.C.§ 1331 in that McDonaldis alleging
`
`a Federal Law Claim under the Age Discrimination in Employment Act (“ADEA”), 29 U.S.C. §
`
`621 et seq.; and the Americans with Disabilities Act, as amended (“ADA”), 42 U.S.C. § 12101 et
`
`seq.
`
`. All material events alleged in this Complaint occurred in Franklin County, Ohio.
`
`. This Court has supplemental jurisdiction over McDonald’s state law claims pursuant to 28
`
`U.S.C. § 1367 as McDonald’s state law claimsare so closely related to her federal law claims
`
`that they form part of the same case or controversy under Article III of the United States
`
`Constitution.
`
`. Venueis proper in this Court pursuant to 28 U.S.C. § 1391.
`
`. Within 300 days of the conduct alleged below, McDonald filed a Charge of Discrimination with
`
`the Equal Employment Opportunity Commission (‘EEOC’), Charge No. 532-2020-02286
`
`against Centene (“McDonald EEOC Charge”).
`
`. McDonald dually filed the McDonald EEOC Charge with the EEOC and the Ohio Civil Rights
`Commission.
`
`—_
`
`. On or about September 20, 2021, the EEOC issued a Notice of Right to Sue letter to McDonald
`
`regarding the Charges of Discrimination brought by McDonald against Centene in the
`
`McDonald EEOC Charge.
`
`

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`. McDonald received her Right to Sue letter from the EEOC in accordance with 42 U.S.C. §
`
`2000e-5(f)(1), which has been attached hereto as Plaintiff's Exhibit A.
`
`. McDonaldhas filed this Complaint within 90 days of the issuance of the Notice of Right to
`
`Sueletter.
`
`. McDonald has properly exhausted her administrative remedies pursuant to 29 C.F.R. §
`
`1614.407(b).
`
`FACTS
`
`. On or about February 22, 2016, McDonald began working for Centene.
`
`. Centeneinitially employed McDonald as a PDM administrator.
`
`. Most recently, Centene employed McDonald as a referral specialist.
`
`. Centene was, at all times hereinafter mentioned, engaged in commerce or in an industry or
`
`activity affecting commerce and employed 50 or more employees for each working day during
`
`each of20 or more calendar work weeksin the current or preceding calendar year and therefore
`
`is an employeras defined in 29 U.S.C § 2611(4).
`
`19.
`
`At all times relevant herein, McDonald was employed by Centeneforat least 12 months and
`
`had at least 1,250 hours of service with Centene and therefore was an “eligible employee”
`
`under FMLA,as that term is defined in 29 U.S.C. § 2611(2)(A).
`
`20
`
`. McDonaldis 60 years old.
`
`—
`
`. At all times herein, McDonald was a memberofa protected class on the basis of her age.
`
`2.
`
`Onor about July 6, 2020, Katrina Edwards became McDonald’s supervisor.
`
`2 2
`
`3.
`
`Edwards is under age 50.
`
`4.
`
`Edwards was not involved in the decision to hire McDonald.
`
`2 2
`
`2
`
`ws
`
`. In or about July 2020, Edwards told McDonaldthat she had a “problem” with McDonald.
`
`

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`26.
`
`In or aboutthe fall of 2020, Edwards took job duties away from McDonald and madeher only
`
`answer phones.
`
`27.
`
`Edwards treated McDonald unfavorably compared to McDonald’s similarly-situated younger
`
`coworkers.
`
`28.
`
`For example, Edwards subjected McDonaldto hostile questioning.
`
`29.
`
`Edwards gave McDonald unfavorable work assignments, compared to McDonald’s similarly-
`
`situated younger coworkers.
`
`30.
`
`In or about October 2020, McDonald reported to Centene’s ethics hotline that Edwards was
`
`discriminating against her on the basis of her age (“Report of Discrimination”).
`
`31.
`
`Centene has a policy against discrimination (“Discrimination Policy”).
`
`32.
`
`Centene’s Discrimination Policy precludesretaliation against employees who complain about
`
`discrimination.
`
`33.
`
`Alternatively, retaliation against employees who complain about discrimination is permitted
`
`by Centene.
`
`34.
`
`Centene’s Discrimination Policy precludes intimidation against employees who complain
`
`aboutdiscrimination.
`
`35.
`
`Alternatively, intimidation against employees who complain about discrimination is permitted
`
`by Centene.
`
`36.
`
`Centene’s Discrimination Policy requires employees to report what they reasonably believeis
`
`a violation of the Discrimination Policy.
`
`37.
`
`Centene’s Discrimination Policy precludes retaliation against employees who report a
`
`violation of the Discrimination Policy.
`
`

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`38. Alternatively, retaliation against employees whoreport a violation ofthe Discrimination Policy
`
`is permitted by Centene.
`
`39. Centene’s Discrimination Policy precludes intimidation against employees who report a
`
`violation of the Discrimination Policy.
`
`40. Alternatively, intimidation against employees who report a violation of the Discrimination
`
`Policy is permitted by Centene.
`
`41. Edwards’s discriminatory treatment of McDonald violates the Discrimination Policy.
`
`42. Centene has a policy to investigate reports of violations of its Discrimination Policy.
`
`43. An investigation should include interviewing the complainant.
`
`44. An investigation should include interviewing the subject of the complaint.
`
`45. An investigation should include interviewing the subject of the reported discrimination.
`
`46. An investigation should include interviewing witnesses to the reported discrimination.
`
`47. An investigation should include getting a written statement from the complainant.
`
`48. An investigation should include getting a written statement from the subject of the complaint.
`
`49. An investigation should include getting a written statement from the subject of the reported
`
`discrimination.
`
`50. In response to McDonald’s Report of Discrimination, Centene did not interview McDonald.
`
`51. In response to McDonald’s Report of Discrimination, Centene did not interview Edwards.
`
`52. In response to McDonald’s Report of Discrimination, Centene did not interview witnesses.
`
`53. In response to McDonald’s Report of Discrimination, Centene did not get a written statement
`
`from McDonald.
`
`54. In response to McDonald’s Report of Discrimination, Centene did not get a written statement
`
`from Edwards.
`
`

`

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`55.
`
`In response to McDonald’s Report of Discrimination, Centene did not get a written statement
`
`from witnesses.
`
`56.
`
`Centene did not investigate McDonald’s Report of Discrimination.
`
`57.
`
`Centene did not give Edwards a verbal warning as a result of McDonald’s Report of
`
`Discrimination.
`
`58.
`
`Centene did not give Edwards a written warning as a result of McDonald’s Report of
`
`Discrimination.
`
`59.
`
`Centene did not give Edwards a final warning as a result of McDonald’s Report of
`
`Discrimination.
`
`60.
`
`Centene did not give Edwards a suspension as a result of McDonald’s Report of
`
`Discrimination.
`
`61.
`
`Centene did not give Edwards a demotion as a result of McDonald’s Report of Discrimination.
`
`62.
`
`Centene did not terminate Edwards’s employment as a result of McDonald’s Report of
`
`Discrimination.
`
`63.
`
`Centene did not give discipline Edwards at all as a result of McDonald’s Report of
`
`Discrimination.
`
`64.
`
`McDonald suffers from anxiety, depression, post-traumatic stress disorder, and bipolar
`
`disorder (“McDonald’s Conditions”).
`
`65.
`
`McDonald’s Conditions are a physical and/or mental impairment.
`
`66.
`
`McDonald’s Conditions significantly limit her in one or more majorlife activities, including
`
`working.
`
`67.
`
`McDonald has a record of physical and/or mental impairment.
`
`68.
`
`Centene perceived McDonald as disabled.
`
`

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`69,
`
`McDonaldis disabled within the meaning of ADA.
`
`70.
`
`McDonaldis disabled within the meaning of R.C. § 4112.01 et seq.
`
`71.
`
`Edwards’s negative treatment of McDonald exacerbated McDonald’s Conditions.
`
`72.
`
`In or about October 2020, McDonald requested to be transferred to a different supervisor
`
`(“Accommodation Request”).
`
`73.
`
`McDonald made the Accommodation Request because of McDonald’s Conditions.
`
`74.
`
`Centene denied the Accommodation Request.
`
`75.
`
`Centene could have transferred McDonaldto a different supervisor.
`
`76.
`
`Centene did not engage in the interactive process to determine whether a reasonable
`
`accommodation was available.
`
`77.
`
`Centene’s denial of the Accommodation Request was an adverse employmentaction.
`
`78.
`
`Centene’s denial of the Accommodation Request was an adverse action.
`
`79.
`
`On or about October 28, 2020, McDonald went on leave due to McDonald’s Conditions.
`
`80.
`
`On or
`
`about February 26,
`
`2021, Centene
`
`terminated McDonald’s
`
`employment
`
`(“Termination”).
`
`81.
`
`The Termination was an adverse employmentaction.
`
`82.
`
`The Termination was an adverse action.
`
`83.
`
`Centene replaced McDonald with an employee who was younger and/or not a memberofthe
`
`same protected classes as McDonald.
`
`84.
`
`Centene has a progressive disciplinary policy (“Discipline Policy”).
`
`85.
`
`A verbal warningis the lowest level of discipline in the Discipline Policy.
`
`86.
`
`McDonald did not receive a verbal warning before the Termination.
`
`87.
`
`A written warning is a higher level of discipline than a verbal warning in the Discipline Policy.
`
`

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`88. McDonald did not receive a written warning before the Termination.
`
`89. A termination is the highest level of discipline in the Discipline Policy.
`
`90. Centene knowingly skipped progressive disciplinary steps in terminating McDonald.
`
`91. Centene knowingly terminated McDonald’s employment.
`
`92. Centene knowingly took an adverse employmentaction against McDonald.
`
`93. Centene knowingly took an adverse action against McDonald.
`
`94. Centene intentionally skipped progressive disciplinary steps in terminating McDonald.
`
`95. Centene intentionally terminated McDonald’s employment.
`
`96. Centene intentionally took an adverse employmentaction against McDonald.
`
`97. Centene intentionally took an adverse action against McDonald.
`
`98. Centene knew that skipping progressive disciplinary steps in terminating McDonald would
`
`cause McDonald harm,including economic harm.
`
`99. Centene knew that terminating McDonald would cause McDonald harm, including economic
`
`harm.
`
`100. Centene willfully skipped progressive disciplinary steps in terminating McDonald.
`
`101. Centene willfully terminated McDonald’s employment.
`
`102. Centene willfully took an adverse employment action against McDonald.
`
`103. Centene willfully took an adverse action against McDonald.
`
`104. On or about February 26, 2021, Centene terminated McDonald’s employment becauseofher age.
`
`105. On or about February 26, 2021, Centene terminated McDonald’s employment because of her
`
`disability.
`
`106. On or about February 26, 2021, Centene terminated McDonald’s employment because she
`
`opposed discrimination.
`
`

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`107.On or about February 26, 2021, Centene terminated McDonald’s employment because she
`
`requested a disability accommodation.
`
`108. On or about February 26, 2021, Centene terminated McDonald’s employment because she used
`
`qualified FMLAleave.
`
`109. As a direct and proximate result of Centene’s conduct, McDonald suffered and will continue
`
`to suffer damages, including economic, emotional distress, and physical sickness damages.
`
`COUNT I: DISABILITY DISCRIMINATION IN VIOLATION OF ADA
`
`110. McDonald restates each and every prior paragraph of this Complaint, as if it were fully
`
`restated herein.
`
`111. Centene treated McDonald differently than other similarly-situated employees based on her
`
`disabling condition.
`
`112. Centene treated McDonald differently than other similarly-situated employees based on her
`
`perceived disabling condition.
`
`113. On or about February 26, 2021, Centene terminated McDonald’s employment without just
`
`cause.
`
`114. Centene terminated McDonald’s employment based onherdisability.
`
`115. Centene terminated McDonald’s employment based on herperceived disability.
`
`116. Centene violated ADA whenit discharged McDonald based on herdisability.
`
`117. Centene violated ADA whenit discharged McDonald based on her perceived disability.
`
`118. Centene violated ADAbydiscriminating against McDonald based onher disabling condition.
`
`119. Centene violated ADA bydiscriminating against McDonald based onher perceiveddisabling
`
`condition.
`
`120. McDonald informed Centene ofher disabling condition.
`
`

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`121.
`
`McDonald requested accommodations from Centeneto assist with her disabilities, including
`
`moving to a different supervisor.
`
`122.
`
`McDonald’s requested accommodations were reasonable.
`
`123.
`
`There was an accommodation available that would have been effective and would have not
`
`posed an undue hardship to Centene.
`
`124.
`
`Centene failed to engage in the interactive process of determining whether McDonald needed
`
`an accommodation.
`
`125.
`
`Centene failed to provide an accommodation.
`
`126.
`
`Centene violated ADAbyfailing to provide McDonald a reasonable accommodation.
`
`127.
`
`Asa direct and proximate result of Centene’s conduct, McDonald suffered and will continue
`
`to suffer damages, including economic, emotional distress, and physical sickness damages.
`
`COUNTII: DISABILITY DISCRIMINATION IN VIOLATION OFR.C.§ 4112.01 ef
`seq.
`
`128.
`
`McDonald restates each and every prior paragraph of this Complaint, as if it were fully
`
`restated herein.
`
`129.
`
`Centene treated McDonald differently than other similarly-situated employees based on her
`
`disabling condition.
`
`130.
`
`Centene treated McDonald differently than other similarly-situated employees based on her
`
`perceived disabling condition.
`
`131.
`
`On or about February 26, 2021, Centene terminated McDonald’s employment without just
`
`cause.
`
`132.
`
`Centene terminated McDonald’s employmentbased onherdisability.
`
`133.
`
`Centene terminated McDonald’s employmentbased on her perceived disability.
`
`134.
`
`Centene violated R.C. § 4112.02 whenit discharged McDonald based onherdisability.
`
`10
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`

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`135. Centene violated R.C. § 4112.02 when it discharged McDonald based on her perceived
`
`disability.
`
`136. Centene violated R.C. § 4112.02 by discriminating against McDonald based onher disabling
`
`condition.
`
`137. Centene violated R.C. § 4112.02 by discriminating against McDonald based onher perceived
`
`disabling condition.
`
`138. McDonald informed Centene of her disabling condition.
`
`139. McDonald requested accommodations from Centene to assist with her disabilities, including
`
`moving to a different supervisor.
`
`140. McDonald’s requested accommodations were reasonable.
`
`141. There was an accommodation available that would have been effective and would have not
`
`posed an undue hardship to Centene.
`
`142. Centene failed to engage in the interactive process of determining whether McDonald needed
`
`an accommodation.
`
`143. Centene failed to provide an accommodation.
`
`144. Centene violated R.C.
`
`§ 4112.02 by failing to provide McDonald a reasonable
`
`accommodation.
`
`145. Asa direct and proximate result of Centene’s conduct, McDonald suffered and will continue
`
`to suffer damages, including economic, emotional distress, and physical sickness damages.
`
`COUNT Ill: AGE DISCRIMINATION IN VIOLATION OF ADEA
`
`146. McDonald restates each and every prior paragraph of this complaint, as if it were fully
`
`restated herein.
`
`147. McDonaldis 60 years old.
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`11
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`148.
`
`At all times relevant, McDonald was a memberofa statutorily-protected class under ADEA.
`
`149.
`
`Centene treated McDonald differently from other similarly-situated employees based on her
`
`age.
`
`150.
`
`McDonald was fully qualified for her position and employment with Centene.
`
`151.
`
`McDonald, at age 59, was a memberofa statutorily-protected class under ADEAat the time
`
`she was terminated from her employment with Centene.
`
`152.
`
`After terminating McDonald, Centene replaced McDonald with a person who was
`
`significantly younger and/or not belonging to the protected class under ADEA.
`
`153.
`
`Centene violated ADEAby discriminating against McDonald based on herage.
`
`154.
`
`Asa direct and proximate result of Centene’s conduct, McDonald suffered and will continue
`
`to suffer damages, including economic, emotionaldistress, and physical sickness damages.
`
`COUNTIV: AGE DISCRIMINATIONIN VIOLATION OF R.C. § 4112.01 et seq.
`
`155.
`
`McDonald restates each and every prior paragraph of this complaint, as if it were fully
`
`restated herein.
`
`156.
`
`McDonald is 60 years old.
`
`157.
`
`At all times relevant, McDonald was a memberofa statutorily-protected class under R.C. §
`
`4112.14(B).
`
`158.
`
`Centene treated McDonald differently from other similarly-situated employees based on her
`
`age.
`
`159.
`
`McDonald was fully qualified for her position and employment with Centene.
`
`160.
`
`McDonald,at age 59, was a memberofa statutorily-protected class under R.C. § 4112.14(B)
`
`at the time she was terminated from her employment with Centene.
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`12
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`161. After
`
`terminating McDonald, Centene replaced McDonald with a person who was
`
`significantly younger and/or not belonging to the protected class under R.C. § 4112.14(B).
`
`162. Centene violated R.C. § 4112.02 and R.C. § 4112.99 by discriminating against McDonald
`
`based on herage.
`
`163. As a direct and proximate result of Centene’s conduct, McDonald suffered and will continue
`
`to suffer damages, including economic, emotionaldistress, and physical sickness damages.
`
`COUNT V: RETALIATION IN VIOLATION OF ADEA & ADA
`
`164. McDonald restates each and every prior paragraph of this complaint, as if it were fully
`
`restated herein.
`
`165. As a result of Centene’s discriminatory conduct described above, McDonald complained
`
`about the discrimination she was experiencing.
`
`166. McDonald requested a disability accommodation.
`
`167. Subsequent to McDonald’s reporting of discrimination, Centene denied her request for
`
`accommodation.
`
`168. Subsequent to McDonald’s reporting of discrimination, Centene terminated her employment.
`
`169. Centene’s actions wereretaliatory in nature based on McDonald’s opposition to the unlawful
`
`discriminatory conduct.
`
`170. Pursuant to ADEA,it is an unlawful discriminatory practice to retaliate against an employee
`
`for opposing age discrimination.
`
`171. Pursuant to ADA,it is an unlawful discriminatory practice to retaliate against an employee
`
`for requesting a disability accommodation.
`
`172. As a direct and proximate result of Centene’s conduct, McDonald suffered and will continue
`
`to suffer damages, including economic, emotional distress, and physical sickness damages.
`
`13
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`COUNT VI: RETALIATION IN VIOLATION OF R.C.§ 4112.01 ef seq.
`
`173. McDonald restates each and every prior paragraph of this complaint, as if it were fully
`
`restated herein.
`
`174. As a result of Centene’s discriminatory conduct described above, McDonald complained
`
`about the discrimination she was experiencing.
`
`175. McDonald requested a disability accommodation.
`
`176. Subsequent to McDonald’s reporting of discrimination, Centene denied her request for
`
`accommodation.
`
`177. Subsequent to McDonald’s reporting ofdiscrimination, Centene terminated her employment.
`
`178. Centene’s actions wereretaliatory in nature based on McDonald’s opposition to the unlawful
`
`discriminatory conduct.
`
`179. Pursuant to R.C. § 4112.02(I), it is an unlawful discriminatory practice “to discriminate in
`
`any manner against any other person because that person has opposed any unlawful
`
`discriminatory practice definedin this section...”
`
`180. As a direct and proximate result of Centene’s conduct, McDonald suffered and will continue
`
`to suffer damages, including economic, emotional distress, and physical sickness damages.
`
`COUNT VIL: RETALIATION IN VIOLATION OF FMLA
`
`181. McDonald restates each and every prior paragraph of this Complaint, as if it were fully
`
`restated herein.
`
`182. During her employment, McDonald utilized FMLA leave.
`
`183. After McDonald utilized her qualified FMLA leave, Centene retaliated against her.
`
`184. Centene retaliated against McDonald by terminating her employment.
`
`185. Centene willfully retaliated against McDonaldin violation of 29 U.S.C. § 2615(a).
`
`14
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`

`

`Case: 2:21-cv-05622-ALM-KAJ Doc #: 1 Filed: 12/07/21 Page: 15 of 16 PAGEID #: 15
`Case: 2:21-cv-05622-ALM-KAJ Doc #: 1 Filed: 12/07/21 Page: 15 of 16 PAGEID #: 15
`
`186. As a direct and proximate result of Centene’s wrongful conduct, McDonaldis entitled to all
`
`damages provided for in 29 U.S.C. § 2617,
`
`including liquidated damages, costs, and
`
`reasonable attorney’s fees.
`
`DEMAND FOR RELIEF
`
`WHEREFORE,Plaintiff McDonald respectfully requests that this Honorable Court grant the
`
`followingrelief:
`
`(a) Issue a permanentinjunction:
`
`(i)
`
`(ii)
`
`Requiring Centene to abolish discrimination, harassment, and retaliation;
`
`Requiring allocation of significant funding and trained staff to implementall changes
`
`within two years;
`
`(iii)|Requiring removal or demotionofall supervisors who have engagedin discrimination,
`
`harassment, or retaliation, and failed to meet their legal responsibility to investigate
`
`complaints promptly and/ortake effective action to stop and deter prohibited personnel
`
`practices against employees;
`
`(iv)
`
`Creating a process for the prompt investigation of discrimination, harassment, or
`
`retaliation complaints; and
`
`(v)
`
`Requiring mandatory and effective training for all employees and supervisors on
`
`discrimination, harassment, and retaliation issues,
`
`investigations, and appropriate
`
`corrective actions;
`
`(b) Issue an order requiring Centene to restore McDonaldto oneofthe positions to which she was
`
`entitled by virtue of her application and qualifications, and expunge her personnelfile ofall
`
`negative documentation;
`
`15
`
`

`

`Case: 2:21-cv-05622-ALM-KAJ Doc #: 1 Filed: 12/07/21 Page: 16 of 16 PAGEID #: 16
`Case: 2:21-cv-05622-ALM-KAJ Doc #: 1 Filed: 12/07/21 Page: 16 of 16 PAGEID #: 16
`
`(c) An award against Defendant of compensatory and monetary damages to compensate
`
`McDonald for physical injury, physical sickness, lost wages, emotional distress, and other
`
`consequential damages, in an amountin excess of $25,000 per claim to be provenattrial;
`
`(d) An award of punitive damages against Defendant in an amount in excess of $25,000;
`
`(e) An award of reasonable attorneys’ fees and non-taxable costs for McDonald claims as
`
`allowable underlaw;
`
`(f) An award ofthe taxable costs of this action; and
`
`(g) An award of such otherrelief as this Court may deem necessary and proper.
`
`Respectfully submitted,
`
`/s/ Trisha Breedlove
`Trisha Breedlove (0095852)
`PaulFilippelli (0097085)
`THE SPITZ LAW FIRM, LLC
`1103 Schrock Road, Suite 307
`Columbus, Ohio 43229
`Phone: (216) 291-4744
`Fax:
`(216) 291-5744
`Email: trisha.breedlove@spitzlawfirm.com
`Email:
`paul. filippelli@spitzlawfirm.com
`Attorneysfor PlaintiffJocelyn McDonald
`
`JURY DEMAND
`
`Plaintiff McDonald demandsa trial by jury by the maximum numberofjurors permitted.
`
`/s/ Trisha Breedlove
`Trisha Breedlove (0095852)
`Paul Filippelli (0097085)
`
`16
`
`

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