throbber
Case 2:21-cv-00905-WSS Document 1 Filed 07/14/21 Page 1 of 16
`Case 2:21-cv-00905—WSS Document 1 Filed 07/14/21 Page 1 of 16
`
`UNITED STATES DISTRICT COURT FOR
`
`THE WESTERN DISTRICT OF PENNSYLVANIA
`
`SAINATH SINDHE,
`
`Plaintiff,
`
`1
`
`2:21-cv-905
`2:21-cv-905
`
`HM HEALTH SOLUTIONS, INC.,
`
`Defendant.
`
`Electronically Filed
`
`JURY TRIAL DEMANDED
`
`COMPLAINT
`
`AND NOW, this 13th day of July, 2021, Plaintiff Sainath Sindhe, by and through his
`
`undersigned attorneys, files the within Complaint against Defendant HM Health Solutions, and
`
`in support thereof avers as follows:
`
`Jurisdiction and Venue
`
`1.
`
`This is an action under Title VII of the Civil Rights Act of 1964, 42 U.S.C. §
`
`2000c, et seq., the Pennsylvania Human Relations Act, 43 PS. § 951, et seq., and Pennsylvania
`
`Common Law.
`
`2.
`
`This Court has subject matter jurisdiction over Plaintiff s Title VII claims
`
`pursuant to 28 U.S.C. § 1331.
`
`3.
`
`This Court has supplemental jurisdiction over Plaintiffs related state-law claims
`
`pursuant to 28 U.S.C. § 1367.
`
`4.
`
`Venue is appropriate in this judicial district pursuant to 28 U.S.C. § 1391(b),
`
`because the events giving rise to this claim occurred in this judicial district.
`
`

`

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`Case 2:21-cv-00905-WSS Document 1 Filed 07/14/21 Page 2 of 16
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`Parties
`
`5.
`
`Plaintiff Sainath Sindhe (“Plaintiff’ or “Mr. Sindhe”) is an adult individual
`
`currently residing at 815 Mulberry Court, Wexford, PA 15090. At all times relevant to this
`
`Complaint, Plaintiff resided in Allegheny County, Pennsylvania.
`
`6.
`
`Defendant HM Health Solutions, Inc. (“Defendant” or “HMHS”) is a
`
`Pennsylvania business corporation with a regular place of business located at 120 Fifth Avenue,
`
`Pittsburgh, PA 15222.
`
`7.
`
`HMHS employs more than 15 employees and is a covered employer under both
`
`Title VII and the PHRA.
`
`Exhaustion of Administrative Remedies
`
`8.
`
`Sindhe filed a charge of discrimination with the Pittsburgh branch of the Equal
`
`Employment Opportunity Commission (EEOC) on or about September 3, 2020.
`
`9.
`
`Sindhe’s charge of discrimination was dual-filed with the Pennsylvania Human
`
`Relations Commission (PHRC).
`
`10.
`
`On May 13, 2021, Mr. Sindhe received a Notice of Right to Sue from the EEOC.1
`
`Factual Background
`
`A. Sindhe worked as a Vice President for HMHS reporting directly to an ever-
`changing number of supervisors.
`
`11.
`
`Sindhe was hired as HMHS’s Vice President of Product Development and
`
`Management on or about July 2, 2018.
`
`12.
`
`As HMHS’s VP of Product Development, Sindhe was responsible for the
`
`organization’s Claims Department, their Software Application platform.
`
`1
`
`A true and correct copy of Mr. Sindhe’s EEOC charge and Notice of Right to Sue is
`included with this Complaint, collectively, as Exhibit A.
`
`2
`
`

`

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`Case 2:21-cv-00905—WSS Document 1 Filed 07/14/21 Page 3 of 16
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`13.
`
`Sindhe is Indian. He became a naturalized United States Citizen in August 2013.
`
`14.
`
`During Sindhe’s employment, HMHS underwent significant changes,
`
`reorganizations, and layoffs. As a result of these reorganizations, Sindhe’s reporting structure
`
`changed several times throughout his employment with HMHS.
`
`15.
`
`In just over two years, Sindhe had four different direct supervisors at HMHS: Mr.
`
`Balajee Sethuraman, Mr. Michael Malec, Ms. Sandra Stefanic, and Ms. Gloria Romeo.
`
`16.
`
`Stefanie and Romeo are both white, non-immigrants.
`
`B. Sindhe uproots his family to move them from Atlanta to Pittsburgh based upon
`assurances from HMHS COO Michael Malec about Plaintiff’s position with HMI-IS.
`
`17.
`
`For the first several months of his employment, Sindhe worked for HMHS in
`
`Pittsburgh, Pennsylvania while his family lived in Atlanta, Georgia.
`
`18.
`
`In early 2019, HMHS went through a series of reorganizations and layoffs and his
`
`then-supervisor, Mr. Balaj ee Sethuraman, decided to leave the organization.
`
`19.
`
`In April 2019, Sindhe approached his then-supervisor Michael Malec to discuss
`
`Sindhe’s work performance, job security, and fiiture with the company.
`
`20.
`
`In that conversation, Malec assured Sindhe that he was doing well at the company
`
`and that he needed Sindhe’s help in rebuilding the company following its reorganization.
`
`21.
`
`During this discussion, Malec encouraged Sindhe to move his family from
`
`Atlanta, Georgia to Pittsburgh, Pennsylvania.
`
`22.
`
`At that time, Sindhe and his wife owned a home in Atlanta, where their son was
`
`enrolled in middle school.
`
`23.
`
`In reliance on Malec’s assurance about his job security and his expected retention
`
`with the company, Sindhe and his wife planned the move of his family to Pittsburgh in June
`
`2019 after his son finished middle school.
`
`

`

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`24.
`
`Sindhe and his wife sold their home in Atlanta and purchased a home in
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`Pittsburgh to accommodate their family’s needs.
`
`25.
`
`In April 2019, Sindhe was approached with an offer for a Vice President position
`
`with a New Jersey—based life insurance technology platform, SE2.
`
`26.
`
`Sindhe turned down this offer for employment following his conversation with
`
`Malec about his job security and prior positive job performance reviews from his supervisors.
`
`C. Sindhe performs satisfactorily under Sandra Stefanie.
`
`27.
`
`In July 2019, HMHS changed Sindhe’s direct-report to Ms. Sandra Stefanie.
`
`28.
`
`Over the next several months, Sindhe met one-on—one with Stefanic for “check-
`
`in” meetings and less formal one-on—one meetings to discuss Sindhe’s professional objectives
`
`and his team’s performance.
`
`29.
`
`During these meetings, Stefanic never told Sindhe that his performance was
`
`considered “Off-Track,” that he had any performance problems, or that he required any sort of
`
`performance improvement plan to address deficiencies in his work.
`
`30. While she was his supervisor, Stefanie never provided Sindhe with a verbal or
`
`written performance assessment indicating that there were problems with his personal work
`
`performance or the performance of his department team members.
`
`D. Without any prior warning, Gloria Romeo gives Sindhe an “Off-Track”
`performance rating.
`
`31.
`
`On November 1, 2019, Sindhe’s direct-report was changed once more to Ms.
`
`Gloria Romeo.
`
`32.
`
`Sindhe continued to meet with Romeo, as he had with his previous supervisors,
`
`for “check in” meetings and other one-on—one conferences.
`
`

`

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`Case 2:21-cv-00905—WSS Document 1 Filed 07/14/21 Page 5 of 16
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`33.
`
`On December 10, 2019, Sindhe and Romeo had their first “check in” meeting to
`
`discuss ongoing initiatives and filture plans for HMHS.
`
`34.
`
`During this meeting, Romeo did not raise any concerns about Sindhe’s personal
`
`work performance, the work performance of the team of individuals Sindhe led, or any
`
`outstanding concerns raised by Sindhe’s former supervisors.
`
`35.
`
`Over a month later, in Sindhe’s annual performance review on January 23, 2020,
`
`Romeo informed Sindhe that his work performance for 2019 was considered “Off-Track.”
`
`36.
`
`During the January 23 meeting, Romeo indicated that Sindhe’s “Off-Track” rating
`
`was based on input from Sindhe’s prior supervisor Sandra Stefanie.
`
`37.
`
`Following this meeting, Sindhe sought out Stefanie and asked why she had never
`
`mentioned any performance concerns while she was his direct supervisor.
`
`38.
`
`Stefanie told Sindhe that she had mentioned some unspecified concerns in the
`
`past, but she confirmed that these concerns were never documented while she was his supervisor.
`
`39.
`
`Sindhe disagreed with the “Off-Track” rating and told Romeo so, emailing her his
`
`and his team’s achievements during 2019 and justifying why his performance should not be
`
`considered as “Off-Track”.
`
`40.
`
`On February 13, 2020, Sindhe discussed his disagreement with his “Off-Track”
`
`rating with former supervisor Michael Malec. Malee agreed to look into the assessment for
`
`Sindhe.
`
`41.
`
`Several weeks later, Malee told Sindhe that his “Off-Track” rating would not be
`
`changed.
`
`

`

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`E. Gloria Romeo places Sindhe on a Corrective Action Plan.
`
`42.
`
`On March 2, 2020, Romeo placed Sindhe on a 30-day Corrective Action Plan
`
`(“CAP”).
`
`43.
`
`While HMHS typically uses CAPS to address recurring deficiencies and periodic
`
`supervisor meetings to address specific incidents, the “Areas of Concern” implicated in the CAP
`
`include nothing but specific incidents that occurred in 2019, when Sindhe was not reporting to
`
`Romeo.
`
`44.
`
`Areas of Concern identified in the CAP include:
`
`a.
`
`Minor spelling and grammar mistakes in a draft presentation made
`
`by a member of Sindhe’s department for a Claims Community of Practice
`
`Meeting;
`
`b.
`
`Uncertainty among Sindhe’s team members regarding potential
`
`restructuring or elimination of the Team Manager role in his department;
`
`0.
`
`References to several unspecified “critical defects” in the Claims
`
`platform in 2019; and
`
`d.
`
`An incident from February 12, 2020 regarding the delayed
`
`issuance of paper checks and Explanations of Benefits for 21 Wyoming client.
`
`45.
`
`Sindhe’s CAP specified that he was to meet with Romeo on a weekly basis to
`
`review his progress on the identified CAP goals.
`
`46. While the CAP identified specific incidents that occurred at HMHS in the past,
`
`the plan detailed very few objectives about Sindhe’s performance going forward beyond vague
`
`directives that Sindhe needed to “complete this plan immediately,” “demonstrate accountability,”
`
`and “make improvements.”
`
`

`

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`47.
`
`HMHS’s CAP did not contain any metrics or objective criteria to measure
`
`Sindhe’s performance going forward.
`
`F. HMHS fails to engage in a transparent CAP process.
`
`48.
`
`After Romeo placed Sindhe on his CAP, he sought to meet with her on a weekly
`
`basis to discuss his progress on the improvement plan.
`
`49.
`
`During the four weeks after Sindhe was placed on a CAP, Romeo met with
`
`Sindhe only once in person. In addition, Romeo spoke with Sindhe twice over the phone and in
`
`the remaining week did not meet at all for the CAP update meeting.
`
`50.
`
`During this time, Sindhe continued to send Romeo regular status reports about his
`
`department’s performance.
`
`51.
`
`Romeo did not respond substantively to these status reports.
`
`52.
`
`Neither Romeo nor Nathan Timm, HMHS Senior HR Manager, offered any
`
`assistance or mentor Sindhe during the CAP period.
`
`53.
`
`Over the four-week CAP period, there were no “critical defects” relating to
`
`Sindhe’s performance or the performance of the Claims Department.
`
`54.
`
`Despite his objectively fair performance during the course of the CAP, in a call
`
`with Romeo and Timm, HMHS terminated Sindhe on April 7, 2020.
`
`55.
`
`At the time of his termination, Sindhe had completed all possible CAP
`
`requirements.
`
`56.
`
`Upon information and belief, neither the Areas of Interest identified in Plaintiff s
`
`CAP nor his professional accomplishments during the last months of his employment with IHNC
`
`resulted in HMHS losing clients.
`
`

`

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`57.
`
`Upon information and belief, while Sindhe was singled out for his alleged
`
`performance concerns, other white and/or non-immigrant executives were not disciplined for
`
`performance problems that were similar or worse than those incidents identified in Sindhe’s
`
`CAP.
`
`58.
`
`For instance, on multiple days in February 2020, HMHS’s Customer Service Call
`
`Center experienced unplanned, hours-long shut-downs. Upon information and belief, Mr.
`
`Christopher Atkinson, the employee responsible for the call center’s service interruptions, was
`
`not placed on a CAP because of these failures.
`
`59.
`
`Instead, Mr. Atkinson was actually promoted to Sindhe’s position following his
`
`termination.
`
`60.
`
`Although African-American employee M.G. Berhe acknowledged to Sindhe that
`
`his team was responsible for the service disruption on February 12, 2020 to HMHS’s Wyoming
`
`client (a disruption which was documented in Plaintiffs CAP as Sindhe’s responsibility), Berhe
`
`was not disciplined or placed on a CAP because of this issue.
`
`61.
`
`Sindhe repeatedly told Romeo that the February 12 incident was caused by
`
`Berhe’s department and that Berhe had admitted as much.
`
`62.
`
`As a result of his termination, Sindhe has suffered and is suffering loss of future
`
`salary and benefits.
`
`G. HMHS’s pretextual termination deprives Sindhe of contractual payments.
`
`63.
`
`The terms and conditions of Sindhe’s employment with HMHS are outlined in
`
`Defendant’s written policies and procedures regarding employee bonuses, incentives, and
`
`severance payments .
`
`

`

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`64.
`
`Both the provisions regarding the HMHS’s Annual Employee Incentive Program
`
`and Severance policies applied to Sindhe at the time of his termination.
`
`65.
`
`The terms of HMHS’s Annual Employee Incentive Program and Severance
`
`Package are fully described in Defendant’s job offer letter to Sindhe.2 HMHS’s Offer Letter
`
`includes the following:
`
`a. Sindhe was eligible for an “Annual Employee Incentive Program” that provided
`
`an annual bonus to employees, contingent upon the company’s achievement of
`
`established performance metrics; and
`
`b. Sindhe was eligible for up to 12 months of severance in the event that HMHS
`
`eliminated his position after 12 months of active employment.
`
`66.
`
`Pursuant to HMHS’s internal operating policies, if an employee is on a CAP at
`
`the end of the year, the employee is ineligible for an annual bonus and pay raise.
`
`67.
`
`Thus, as a result of Romeo’s “Off-Track” rating, Plaintiff was deprived of his
`
`Annual Employee Incentive Program bonus and, upon his termination, contractually-required
`
`severance payments.
`
`Count I: Title VII of the Civil Rights Act of 1964
`Race and/or National Origin Discrimination
`
`68.
`
`The averments contained in the preceding paragraphs are incorporated herein as
`
`though set forth at length.
`
`69.
`
`Title VII of the Civil Rights Act of 1964 prohibits employers from subjecting
`
`employees to disparate treatment because of their race and/or national origin. To establish a
`
`prima facie case of employment discrimination under Title VII, one must show: “(1) [h]e is a
`
`2 A true and correct copy of HMHS’s May 30, 2018 Offer Letter is included with this Complaint
`as Exhibit B.
`
`

`

`Case 2:21-cv-00905-WSS Document 1 Filed 07/14/21 Page 10 of 16
`Case 2:21-cv-00905-WSS Document 1 Filed 07/14/21 Page 10 of 16
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`member of a protected class; (2) [h]e was qualified for the position he sought to attain or retain;
`
`(3) [h]e suffered an adverse employment action; and (4) the action occurred under circumstances
`
`that could give rise to an inference of intentional discrimination.” Makky v. Chertofl, 541 F.3d
`
`205, 214 (3d Cir.2008).
`
`70.
`
`Defendant HMHS is a covered employer under Title VII, as it is engaged in an
`
`industry affecting commerce and employed more than 15 employees in 2019 and 2020. 42
`
`U.S.C.A. § 20006.
`
`71.
`
`Sindhe was a qualified employee and an immigrant of Indian descent.
`
`72.
`
`Defendant HMHS took the following adverse employment actions against Sindhe:
`
`giving Sindhe an “Off-Track” rating for his 2019 work performance, placing Sindhe on the
`
`March 2020 Corrective Action Plan, failing to meet with Sindhe to regularly discuss his progress
`
`on the CAP goals, and terminating Sindhe for pretextual reasons.
`
`73.
`
`Defendant HMHS’s Corrective Action Plan was objectively unwarranted and
`
`based on incidents that were either (1) not tied to the performance of Sindhe or his department,
`
`or (2) trifling and disproportionate to the disciplinary measures HMHS employed.
`
`74.
`
`HMHS subjected Sindhe to the negative employment actions above because of his
`
`race and national origin.
`
`75.
`
`Upon information and belief, similarly situated employees who were American
`
`and/or white were not subject to negative employment actions by HMHS for the types of
`
`incidents identified in Sindhe’s CAP.
`
`76.
`
`As a result of HMHS’s discriminatory employment practices, Sindhe has suffered
`
`a significant loss of income, including an Annual Employee Incentive Program bonus and
`
`contractually-required severance payments, filture salary, and benefits.
`
`10
`
`

`

`Case 2:21-cv-00905-WSS Document 1 Filed 07/14/21 Page 11 of 16
`Case 2:21-cv-00905-WSS Document 1 Filed 07/14/21 Page 11 of 16
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`WHEREFORE, Sindhe hereby requests that this Honorable Court consider the above and
`
`grant relief in his favor. Specifically, Sindhe respectfully requests this Court award Back Pay,
`
`Front Pay, Pre—Judgrnent and Continuing Interest, and any other Compensatory and Punitive
`
`damages that this Court sees fit.
`
`Count II: The Pennsylvania Human Relations Act
`Race and/or National Origin Discrimination
`
`77.
`
`The averments contained in the preceding paragraphs are incorporated herein as
`
`though set forth at length.
`
`78.
`
`Defendant HMHS is a covered employer under the PHRA, as it is engaged in an
`
`industry affecting commerce and employed more than 4 employees in 2019 and 2020. 43 PS. §
`
`954.
`
`79.
`
`Defendant HMHS took the following adverse employment actions against Sindhe:
`
`giving Sindhe an “Off-Track” rating for his 2019 work performance, placing Sindhe on the
`
`March 2020 Corrective Action Plan, failing to meet with Sindhe to regularly discuss his progress
`
`on the CAP goals, and terminating Sindhe for pretextual reasons.
`
`80.
`
`The PHRA’s prohibitions on employment discrimination based on race and/or
`
`national origin is generally interpreted in accordance with the same claims arising under Title
`
`VII. Dici v. Commonwealth ofPennsylvania, 91 F.3d 542 (3d. Cir.l996).
`
`81.
`
`The PHRA prohibits any employer “because of the race, color, .
`
`.
`
`. national origin
`
`.
`
`.
`
`.
`
`to bar or to discharge from employment such individual or independent contractor, or to
`
`otherwise discriminate against such individual or independent contractor with respect to
`
`compensation, hire, tenure, terms, conditions or privileges of employment or contract, if the
`
`individual or independent contractor is the best able and most competent to perform the services
`
`required.” 43 PS. § 955.
`
`11
`
`

`

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`Case 2:21-cv-00905—WSS Document 1 Filed 07/14/21 Page 12 of 16
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`82.
`
`Defendant HMHS subjected Sindhe to the negative employment actions above
`
`because of his race and national origin.
`
`83.
`
`Upon information and belief, similarly situated employees who were American
`
`and/or white were not subject to negative employment actions for the types of incidents
`
`identified in Sindhe’s CAP.
`
`84.
`
`As a result of Defendant HMHS’s discriminatory employment practices, Sindhe
`
`has suffered a significant loss of income, including an Annual Employee Incentive Program
`
`bonus and contractually-required severance payments, future salary, and benefits.
`
`WHEREFORE, Sindhe hereby requests that this Honorable Court, in consideration of
`
`these facts, award Back Pay, Front Pay, remuneration to account for his lost annual bonus, raise,
`
`and severance owed under the terms of Sindhe’s employment agreement, Pre—Judgment and
`
`Continuing Interest, and any and all other appropriate compensatory and punitive damages that
`
`this Court may allow.
`
`COUNT III: Breach of Contract
`
`Pennsylvania Common Law
`
`85.
`
`The averments contained in the preceding paragraphs are incorporated herein as
`
`though set forth at length.
`
`86.
`
`Defendant HMHS labeled Sindhe’s work performance as “Off-Track” for 2019
`
`without legitimate justification.
`
`87.
`
`Despite Sindhe’s demonstration that this “Off-Track” rating was unwarranted, the
`
`rating remained in place and HMHS placed Sindhe on a Corrective Action Plan.
`
`88.
`
`Both the “Off-Track” rating and the Corrective Action Plan were implemented as
`
`pretext for Sindhe’s termination, as more fully described above.
`
`12
`
`

`

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`89.
`
`The terms of Defendant’s Annual Employee Incentive Program and Severance
`
`Package are fillly described in Defendant’s job offer letter to Plaintiff. Defendant’s Offer Letter
`
`includes the following provisions:
`
`a.
`
`“Annual Employee Incentive Program As a participant in the company’s
`
`Annual Employee Incentive Program (the AEIP) you may be eligible to receive
`
`an annual award, payment of which is contingent upon the company’s
`
`achievement of established performance metrics as approved by the Board of
`
`Directors. If your starting date commences before July 4, 2018, you may be
`
`eligible to receive an annual award under the company’s 2018 Annual Employee
`
`Incentive Program (the AEIP). Such an award is contingent upon the company’s
`
`achievement of established performance metrics as approved by the Board of
`
`Directors. AEIP awards are calculated using only eligible wages received during
`
`the applicable plan year and would be paid in March 2019.”
`
`“Severance - If Highmark Health eliminates your position, you may be eligible
`
`for severance under the Severance Plan for Vice Presidents of Highmark. Under
`
`the Severance Plan for Vice Presidents, you may be eligible for a maximum of 12
`
`months of severance. Eligibility for this plan begins after 12 months, provided
`
`you remain in active employment. “
`
`90.
`
`Absent Defendant’s unwarranted and pretextual disciplinary actions, Plaintiff
`
`would have been entitled to a contractually-mandated Annual Employee Incentive Program
`
`bonus, pay raise and, upon his termination without cause, contractually-required severance
`
`payments.
`
`13
`
`

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`91.
`
`Defendant HMHS’s unwarranted and pretextual disciplinary actions, described
`
`more fully above, constitute a breach of their contractual obligations towards Sindhe.
`
`WHEREFORE, Sindhe hereby requests that this Honorable Court, in consideration of
`
`these facts, award Sindhe remuneration to account for his lost annual bonus, raise, and severance
`
`owed under the terms of Sindhe’s employment agreement, and any and all other appropriate
`
`consequential damages.
`
`COUNT IV: Breach of Implied Employment Contract
`Pennsylvania Common Law
`
`92.
`
`The averments contained in the preceding paragraphs are incorporated herein as
`
`though set forth at length.
`
`93.
`
`In April 2019, Sindhe expressed hesitation about uprooting and moving his family
`
`from Atlanta to Pittsburgh without assurances from his employer that he was going to be retained
`
`by HMHS following the company’s reorganization.
`
`94.
`
`In response to his concerns, Sindhe’s then-supervisor Michael Malec assured
`
`Sindhe that he was doing well at the company and that he needed Sindhe’s help in rebuilding the
`
`company following its reorganization.
`
`95.
`
`Until January 23, 2020, Sindhe’s various direct reports never expressed any
`
`concerns about his work performance or the work performance of his team.
`
`96.
`
`In addition to the services Sindhe provided to HMHS, Sindhe gave additional
`
`consideration when he accepted his Vice President position and decided to remain with HMHS
`
`by:
`
`a.
`
`Uprooting and moving his family from their home of over six years and
`
`changing his child’s school system; and
`
`14
`
`

`

`Case 2:21-cv-00905-WSS Document 1 Filed 07/14/21 Page 15 of 16
`Case 2:21-cv-00905—WSS Document 1 Filed 07/14/21 Page 15 of 16
`
`b.
`
`Turning down the job offer in April 2019 from New Jersey life insurance
`
`technology platform SE2.
`
`97.
`
`Based upon the additional consideration provided by Sindhe, an implied
`
`employment contract for a reasonable term was created.
`
`98.
`
`Under such an implied contract, Sindhe could not be fired without cause until the
`
`expiration of the reasonable term of employment.
`
`99.
`
`Defendant breached this contract when it terminated Sindhe on April 7, 2020
`
`under dubious claims of alleged performance problems, less than one year after HMHS
`
`encouraged Sindhe to complete the move of his family to Pittsburgh.
`
`100. Defendant breached the implied obligation of good faith and fair dealing within
`
`the implied employment contract by capriciously terminating Mr. Sindhe for pretextual reasons.
`
`101. Defendant had no cause to terminate Sindhe or otherwise breach the implied
`
`employment contract.
`
`102. As a result of Defendant HMHS’s discriminatory employment practices, Sindhe
`
`has suffered a significant loss of income, in the form of his salary for the remainder of his
`
`implied employment contract with HMHS.
`
`WHEREFORE, Sindhe hereby requests that this Honorable Court, in consideration of the
`
`above facts, grant relief in his favor and as damages Sindhe’s remaining salary under the implied
`
`contract.
`
`Date:
`
`July 13, 2021
`
`Respectfully submitted,
`
`/s/ Marcus B. Schneider
`
`Marcus B. Schneider, Esquire
`PA ID. No. 208421
`
`15
`
`

`

`Case 2:21-cv-00905-WSS Document 1 Filed 07/14/21 Page 16 of 16
`Case 2:21-cv-00905-WSS Document 1 Filed 07/14/21 Page 16 of 16
`
`Nicholas Pahuta, Esquire
`PA ID. No. 324355
`
`STEELE SCHNEIDER
`
`420 Ft. Duquesne Blvd., Suite 500
`Pittsburgh, PA 15222
`(412) 235-7686
`(412) 235-7693/facsimile
`marcschneider@steeleschneider.com
`nickpahuta@steeleschneider.com
`
`Counselfor Plaintifl
`
`16
`
`

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