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`Case 3:21-cv-00209-FM Document 1-3 Filed 09/08/21 Page 2 of 16
`Skip to Main Content Logout My Account Search Menu New Civil Search Refine Search Back
`Location : All Courts Help
`R A
`C N . 2021DCV2611
`
`Case Type: Wrongful Termination
`Date Filed: 07/29/2021
`Location: 327th District Court
`
`§§§§§
`
`P I
`
`Mirelle Devenney vs Empower Behavioral Health, LLC
`
`Defendant
`
`Plaintiff
`
`Empower Behavioral Health, LLC
`
`Devenney, Mirelle
`
` OTHER EVENTS AND HEARINGS
`
`07/29/2021 Original Petition (OCA) Index # 1
`07/29/2021 E-File Event Original Filing
`07/29/2021 Other Pleading Index # 2
`Citation
`08/02/2021
`Empower Behavioral Health, LLC
`
`
`09/07/2021 Answer Index # 4
`
`E O C
`
`Served
`Response Due
`Returned
`
`08/10/2021
`09/06/2021
`08/20/2021
`
`Lead Attorneys
`
`ENRIQUE CHAVEZ, Jr.
` Retained
`915-351-7772(W)
`
`
`
`Case 3:21-cv-00209-FM Document 1-3 Filed 09/08/21 Page 3 of 16
`El Paso County - 327th District Court
`Filed 7/29/2021 9:40 AM
`Norma Favela Barceleau
`District Clerk
`El Paso County
`2021DCV2611
`
`MIRELLE DEVENNEY,
`Plaintiff,
`
`v.
`
`Cause No.
`
`EMPOWER BEHAVIORAL HEALTH, LLC,
`Defendant.
`
`PLAINTIFF'S ORIGINAL PETITION AND JURY DEMAND
`
`TO THE HONORABLE JUDGE OF SAID COURT:
`
`Plaintiff MIRELLE DEVENNEY ("Employee Devenney" or "Plaintiff") now files her
`
`Original Petition against Defendant EMPOWER BEHAVIORAL HEALTH, LLC ("Employer
`
`EBH" or "Defendant") and respectfully shows as follows:
`
`I. DISCOVERY LEVEL
`
`1.
`
`Discovery is intended to be conducted under level 2 of Rule 190 of the Texas Rules of
`
`Civil Procedure.
`
`II. PARTIES
`
`2.
`
`3.
`
`Plaintiff, Mirelle Devenney, is a natural person residing in El Paso County, Texas.
`
`Defendant, Empower Behavioral Health, LLC, is a domestic limited liability company
`
`organized under the laws of the State of Texas, and may be served with process by
`
`serving its registered agent, Natesh Kumar, at 95 10 Leopard Street, Corpus Chrisd, Texas
`
`78410, or wherever Defendant may be found.
`
`in. VENUE
`
`4.
`
`Pursuant to Texas Civil Practice and Remedies Code Section 15.002, venue is proper in
`
`El Paso County, Texas because all or a substantial part of the events or omissions giving
`
`rise to Employee Autry's claims occurred in El Paso County, Texas.
`
`Page 1 of 8
`
`
`
`Case 3:21-cv-00209-FM Document 1-3 Filed 09/08/21 Page 4 of 16
`
`IV CHRONOLOGY OF FACTS
`
`5.
`
`Employers must never treat employees differently just because of their race to protect
`
`employees,
`
`like us all,
`
`from emotional
`
`traumas and financial
`
`losses
`
`from illegal
`
`discrimination.
`
`6.
`
`Employers must prevent racial discrimination and harassment in the workplace to protect
`
`employees,
`
`like us all,
`
`from emotional
`
`traumas and financial
`
`losses from illegal
`
`discrimination.
`
`7.
`
`Employers must prevent job retaliation against employees who, in good faith, oppose and
`
`report
`
`illegal
`
`racial discrimination at work to protect employees,
`
`like us all,
`
`from
`
`8.
`
`9.
`
`emotional trauma and financial losses due to job terminations.
`
`Defendant Empower Behavioral Health, LLC is an employer.
`
`Employer EBH must never treat employees differently just because of their race to protect
`
`employees,
`
`like us all,
`
`from emotional
`
`traumas and financial
`
`losses from illegal
`
`discrimination.
`
`10.
`
`Employer EBH must prevent racial discrimination and harassment in the workplace to
`
`protect employees,
`
`like us all, from emotional traumas and financial
`
`losses from illegal
`
`discrimination.
`
`11.
`
`Employer EBH must prevent job retaliation against employees who, in good faith, oppose
`
`and report illegal racial discrimination at work to protect employees,
`
`like us all, from
`
`emotional trauma and financial losses due to job terminations.
`
`12.
`
`On August 2020, Employer EBH hires an Employee as a Board Certified Behavior
`
`Analyst in Employer EBH's El Paso clinic.
`
`13.
`
`The Employee is Hispanic/Mexican-American.
`
`Page 2 of 8
`
`
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`Case 3:21-cv-00209-FM Document 1-3 Filed 09/08/21 Page 5 of 16
`
`14.
`
`On or about October 2020, Employer EBH terminates its Clinical Director for Employer
`
`EBH's El Paso clinic, does not replace the Clinical Director, and the Employee begins
`
`performing the Clinical Director's duties.
`
`15.
`
`Employer EBH has the Employee work directly with Employer EBH's students - special
`
`needs children with autism — and their families.
`
`16.
`
`Employer EBH chooses to not provide the Employee with a company cell phone,
`
`requiring the Employee to use her personal cell phone to communicate with the families
`
`of Employer EBH's special needs autistic students.
`
`17.
`
`Employer EBH is aware the Employee communicates with the families of Employer
`
`EBH's special needs autistic students daily through her personal cell phone.
`
`18.
`
`On February 2021, due to the the Employee's good performance, Employer EBH raises
`
`the Employee's salary by $10,000.00.
`
`19.
`
`On March 202 1 , Employer EBH hires Bianca Sanchez, whom is Caucasian, as a Board
`
`Certified Behavior Analyst.
`
`20.
`
`Beginning in March 202 1 , and continuing through July 202 1 , Employer EBH's Behavior
`
`Analyst Bianca Sanchez makes racist statements directed at Hispanics and Mexican-
`
`Americans, including:
`
`a.
`
`"You guys [Employee and other employees] have really heavy accents."
`
`b. Complaining that "all the menus in El Paso are in Spanish."
`
`c. Complaining because the Employee and other employees sometimes play
`"Spanish" music.
`
`d. Excoriating the Employee and others because they sometimes speak Spanish,
`including times when Employee and others speak Spanish to communicate with
`parents and special needs children whom only speak Spanish.
`
`e. Telling the Employee -- in regards to a Hispanic/Mexican-American special
`needs autistic student — "take the child out of the sun before he gets darker."
`
`Page 3 of 8
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`
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`Case 3:21-cv-00209-FM Document 1-3 Filed 09/08/21 Page 6 of 16
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`f. Complaining that her children will get beat up in El Paso schools, where the
`student population is primarily Hispanic/Mexican-American.
`
`21.
`
`In April 2021, Employer EBH's Human Resources Department receives the
`
`Employee's good faith complaint of racial discrimination that Bianca
`
`Sanchez' comments and actions,
`
`inter alia described above, are
`
`discriminatory statements against Employee, and other employees, as well
`
`as EBH clients and their children.
`
`22.
`
`Employer EBH does not take action to prevent Bianca Sanchez from making racist,
`
`racially discriminatory statements or to prevent racial discrimination in the workplace.
`
`23.
`
`Rather, Employer EBH's Behavior Analyst Bianca Sanchez continues to make racist and
`
`discriminatory statements in the workplace.
`
`24.
`
`On July 2 1 , 202 1 , Employer EBH's Behavior Analyst Bianca Sanchez asks Employee
`
`about why other employees seem not to like her (Sanchez) and Employee responds by
`
`reporting to her that the racist and discriminatory statements she (Sanchez) makes are off-
`
`putting and then, in opposition to Sanchez' continuing racially discriminatory actions and
`
`statements, Employee tells her (Sanchez) that she (Sanchez) should stop making them.
`
`25.
`
`On July 26, 2021, Employer EBH's Human Resources Director Erin Gierlowski and
`
`Supervisor Emily Treadway retaliate against Employee by terminating the Employee,
`
`telling the Employee she acted unprofessionally by reporting, complaining about, and
`
`opposing racial discrimination in the workplace.
`
`26.
`
`Evidently, Employer EBH considers it unprofessional
`
`to report, oppose and complain
`
`about
`
`racial discrimination in the workplace or
`
`to speak the truth about
`
`racial
`
`discrimination in the workplace.
`
`27.
`
`Employer EBH is aware terminating the Employee jeopardizes the treatment of its special
`
`Page 4 of 8
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`
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`Case 3:21-cv-00209-FM Document 1-3 Filed 09/08/21 Page 7 of 16
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`needs autistic students, as children with autism have severe difficulty dealing with change,
`
`and it takes a BGBA months of working with autistic students to develop a working
`
`relationship with them.
`
`28.
`
`Employer EBH is aware the Employee has a professional responsibility to contact the
`
`families of her special needs autistic students to explain that the Employee will not arrive
`
`to work with their children that day, as the families expect to see and work with the
`
`Employee that day.
`
`29.
`
`Employer EBH receives notice the Employee tells the families of Employer EBH's special
`
`needs autistic students to not interrupt the students' treatment with Employer EBH.
`
`30.
`
`In addition,
`
`that same day, July 26, 2021, Employer EBH further retaliates against
`
`Employee for engaging in protected conduct under the law — Employee's reporting about,
`
`complaining against and opposing racial discrimination in the work place — by directing
`
`its law firm, Branscomb Law, and attorney Keith B. Sieczkowski to send a retaliatory
`
`letter to the Employee, falsely accusing the Employee of defamation, tortious interference,
`
`and unspecified violations of the Health Insurance Portability and Accountability Act
`
`("HIPAA").
`
`31.
`
`Incredibly, in the retaliatory letter, which Employer EBH directs Branscomb Law and
`
`Keith B. Sieczkowski
`
`to send to the Employee, Employer EBH threatens to sue the
`
`Employee if she does not agree to prepare written statements retracting her truthful
`
`reports and complaints of racial discrimination in the workplace.
`
`32.
`
`That Employee is Mirelle Devenney.
`
`Page 5 of 8
`
`
`
`Case 3:21-cv-00209-FM Document 1-3 Filed 09/08/21 Page 8 of 16
`
`V. CAUSES OF ACTION
`
`Race Discrimination
`
`33.
`
`As described above, Employer EBH, by and through its agents,
`
`including Behavior
`
`Analyst Bianca Sanchez, Human Resources Director Erin Gierlowski, and Supervisor
`
`Emily Treadway,
`
`intentionally and knowingly discriminated against and harassed
`
`Employee Devenney, a United States citizen, merely because of her race, in violation of
`
`42 U.S.C. §1981.
`
`34.
`
`Thus, Employer EBH sponsored, encouraged and condoned its agents'
`
`racial
`
`discrimination and harassment of Employee Devenney.
`
`Retaliation
`
`35.
`
`As described above, Employer EBH, by and through its agents,
`
`including Behavior
`
`Analyst Bianca Sanchez, Human Resources Director Erin Gierlowski, and Supervisor
`
`Emily Treadway, intentionally and knowingly retaliated against and harassed Employee
`
`Devenney, in violation of 42 U.S.C. §1981, merely because she reported, opposed and
`
`witnessed racial harassment and discrimination in the workplace.
`
`36.
`
`Thus, Employer EBH sponsored, encouraged and condoned its agents' retaliation and
`
`harassment of Employee Devenney.
`
`VI. DAMAGES AND LOSSES
`
`37.
`
`As a direct and proximate result of Defendant's discrimination, retaliation and conduct
`
`against Plaintiff as described above, Plaintiff has suffered harms and losses. Plaintiff's
`
`harms and losses include in the past and the future: lost wages and benefits; employment
`
`opportunities; lost income; loss of earning capacity; mental anguish; emotional pain and
`
`suffering; inconvenience; loss of enjoyment of life; and other non-pecuniary losses.
`
`Page 6 of 8
`
`
`
`Case 3:21-cv-00209-FM Document 1-3 Filed 09/08/21 Page 9 of 16
`
`VII. ATTORNEY'S FEES
`
`38.
`
`Pursuant
`
`to 42 U.S.C. § 1 988(b), Plaintiff is entitled to reasonable attorney's fees and
`
`reasonable expert fees as costs in prosecuting this lawsuit.
`
`VIII. JURY DEMAND
`
`39.
`
`Plaintiff requests that this case be decided by a jury.
`
`Page 7 of 8
`
`
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`Case 3:21-cv-00209-FM Document 1-3 Filed 09/08/21 Page 10 of 16
`
`40.
`
`Plaintiff
`
`respectfully prays that she recover
`
`from Defendant actual damages over
`
`IX. PRAYER
`
`$200,000.00 but not more than $1,000,000.00, including but not limited to, past and
`
`future lost earnings, mental anguish and inconvenience, emotional pain and suffering, loss
`
`of enjoyment of life, bodily injury pain and suffering, economic damages and benefits in
`
`the past and future, compensatory damages, punitive damages,
`
`reinstatement,
`
`prejudgment interest, post judgment interest, costs and such other and further relief to
`
`which she may show herself to be justly entitled, in law and in equity. Such damages
`
`sought by Plaintiff are within the jurisdictional limits of the court.
`
`SIGNED on July 29, 2021.
`
`Respectfully submitted,
`
`Chave2 Law Firm
`2101 N. Stanton Street
`El Paso, Texas 79902
`(915) 351-7772
`
`By: /s/Enrique Chavez, Jr.
`Enrique Chavez, Jr.
`State Bar No.: 24001873
`enriquechavezj r@chavezlawpc .com
`Michael R. Anderson
`State Bar No.: 24087103
`manderson@chavezlawpc.com
`Attorneysfor Plaintiff
`
`Page 8 of 8
`
`
`
`Case 3:21-cv-00209-FM Document 1-3 Filed 09/08/21 Page 11 of 16
`El Paso County - 327th District Court
`Filed 9/7/2021 8:42 AM
`Norma Favela Barceleau
`District Clerk
`El Paso County
`2021DCV2611
`
`
`
`CAUSE NO. 2021DCV2611
`
`MIRELLE DEVENNEY,
`
`
`
`Plaintiff,
`
`
`V.
`
`
`
`EMPOWER BEHAVIORAL HEALTH,
`LLC
`
`
`
`
`Defendant.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`IN THE DISTRICT COURT
`
`EL PASO COUNTY, TEXAS
`
`327TH JUDICIAL DISTRICT
`
`DEFENDANT’S ORIGINAL ANSWER AND SPECIAL EXCEPTIONS TO DISMISS
`PLAINTIFF’S ORIGINAL PETITION
`
`
`TO THE HONORABLE JUDGE OF SAID COURT:
`
`COMES NOW Defendant Empower Behavioral Health, LLC (hereinafter “Defendant” or
`
`“EBH”) in the above-entitled and numbered cause, and files this its Original Answer and Special
`
`Exceptions to Dismiss Plaintiff’s Original Petition, and respectfully shows the Court as follows:
`
`SPECIAL EXCEPTIONS
`
`
`
`As to each of the special exceptions numbered below, EBH respectfully requests that this
`
`Court order Plaintiff to amend her Original Petition to conform with the noted exceptions, or
`
`alternatively that the pleadings be stricken.
`
`0.
`
`Defendant specially excepts to paragraph 4 of Plaintiff’s Original Petition because
`
`it does not relate to any party to this action.
`
`1.
`
`Defendant specially excepts to paragraphs of Plaintiff’s Original Petition 5-7, and
`
`9-13, as merely containing argument without any facts. There is no identification of “Employee”
`
`or any other connection to the case.
`
`2.
`
`Defendant specially excepts to paragraphs 14-31 of Plaintiff’s Original Petition
`
`because “Employee” is not identified.
`
`{C2519297.DOCX:3}
`
`1
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`
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`Case 3:21-cv-00209-FM Document 1-3 Filed 09/08/21 Page 12 of 16
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`
`
`3.
`
`Defendant specially excepts to paragraph 32 of Plaintiff’s Original Petition because
`
`it is unclear as to what “employee” is being referenced.
`
`4.
`
`Defendant specially excepts to paragraph 33 of Plaintiff’s Original Petition because
`
`there are no facts alleged to support any claim of harassment or discrimination by Erin Gierlowski
`
`or Emily Tredway, and the allegations fail to support a severe or pervasively hostile work
`
`environment.
`
`5.
`
`Defendant specially excepts to paragraph 34 of Plaintiff’s Original Petition because
`
`there are no facts alleged to support any claim that EBH sponsored, encouraged or condoned any
`
`acts of discrimination or harassment of Plaintiff.
`
`6.
`
`Defendant specially excepts to paragraph 35 of Plaintiff’s Original Petition because
`
`there are no facts alleged to support any claim that Bianca Sanchez committed any acts of
`
`retaliation.
`
`7.
`
`Defendant specially excepts to paragraph 36 of Plaintiff’s Original Petition because
`
`there are no facts alleged to support any claim that EBH sponsored, encouraged or condoned any
`
`acts of discrimination or harassment of Plaintiff.
`
`GENERAL DENIAL
`
`8.
`
`Pursuant to Texas Rule of Civil Procedure 92, Defendant generally denies each and
`
`every, all and singular, of the allegations contained in Plaintiff’s Original Petition and demands
`
`strict proof thereof.
`
`REQUEST FOR DISCLOSURE
`
`9.
`
`Under Texas Rule of Procedure 194, Defendant requests Plaintiff disclose, within
`
`thirty (30) days of the service of this request, the information or material described in Rule 194.2.
`
`{C2519297.DOCX:3}
`
`2
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`
`
`Case 3:21-cv-00209-FM Document 1-3 Filed 09/08/21 Page 13 of 16
`
`
`
`AFFIRMATIVE DEFENSES
`
`The following affirmative and additional defenses and/or avoidances are alleged on
`
`information and belief and, except as expressly stated otherwise, each defense applies to the
`
`entirety of Plaintiff’s Original Petition and to each purported cause of action or claim for relief
`
`therein. HEI reserves the right to amend or withdraw any and all defenses or to raise any and all
`
`additional defenses as or after they become known during or after the course of investigation,
`
`discovery, or trial.
`
`No assertion of any affirmative or additional defense, or any matter claimed in avoidance
`
`shall constitute either an admission that Plaintiff does not bear the burden of proof or the burden
`
`of producing evidence on any element of any cause of action or claim for relief or on any issue as
`
`to which Plaintiff bears the burden of proof or the burden of producing evidence as a matter of
`
`law, or a waiver of any of HEI’s rights to require that Plaintiff satisfy any burden of proof or burden
`
`of producing evidence.
`
`10.
`
`11.
`
`Plaintiff has failed to exhaust administrative remedies, in whole or in part.
`
`Plaintiff has wrongfully destroyed information on Defendant’s computer.
`
`Defendant is entitled to a presumption of misconduct and that the information deleted contained
`
`exculpatory information as to Defendant and/or information as to Plaintiff’s misconduct.
`
`Defendant is entitled to appropriate jury instructions relating to same.
`
`12.
`
`Plaintiff’s claims for damages are barred due to post-employment misconduct
`
`including violation of HIPAA regulations.
`
`13.
`
`Plaintiff’s claims for damages, in whole or in part, are not authorized by applicable
`
`law.
`
`{C2519297.DOCX:3}
`
`3
`
`
`
`Case 3:21-cv-00209-FM Document 1-3 Filed 09/08/21 Page 14 of 16
`
`
`
`14.
`
`Plaintiff’s claims and/or damages are barred, in whole or in part, by failure to
`
`mitigate.
`
`15.
`
`Plaintiff’s claims and/or damages are barred and/or limited, in whole or in part, by
`
`statute.
`
`16.
`
`Plaintiff’s claims and/or damages are barred and/or limited because at all times
`
`Defendant had in place a policy forbidding discrimination and retaliation and Plaintiff failed to
`
`follow Defendant’s procedures.
`
`17. Without agreeing that Plaintiff is entitled to any damages whatsoever, to the extent
`
`that a finder of fact determines otherwise, Defendant is entitled offset of all amounts received or
`
`which could have been received by Plaintiff with reasonable diligence.
`
`18.
`
`19.
`
`20.
`
`Plaintiff’s allegations fail to state a claim of discrimination or harassment.
`
`Plaintiff’s claims and/or damages are barred due to Plaintiff’s misconduct.
`
`Plaintiff’s claims are barred because EBH took immediate and reasonable measures
`
`to prevent and address any potential discriminatory conduct.
`
`21.
`
`Defendant would have taken the same action in the absence of any complaint or
`
`report of discrimination. Plaintiff was separated for legitimate non-discriminatory or retaliatory
`
`reasons.
`
`
`
`PRAYER
`
`WHEREFORE, PREMISES CONSIDERED, Defendant prays that Plaintiff take nothing
`
`and that Defendant recover its costs and attorney’s fees herein expended and for such other and
`
`further relief to which it may be entitled.
`
`Respectfully submitted,
`
`BRANSCOMB PLLC
`802 North Carancahua, Suite 1900
`
`{C2519297.DOCX:3}
`
`4
`
`
`
`Case 3:21-cv-00209-FM Document 1-3 Filed 09/08/21 Page 15 of 16
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`
`
`
`
`
`
`
`
`
`
`Corpus Christi, Texas 78401
`Telephone: (361) 886-3800
`Facsimile: (361) 886-3805
`
`By: /s/ Keith B. Sieczkowski
`Keith B. Sieczkowski
`State Bar No. 18341650
`ksieczkowski@branscomblaw.com
`Emily K. Arnold
`State Bar No. 24105441
`earnold@branscomblaw.com
`
`
`
`
`
`
`
`
`
`ATTORNEYS FOR DEFENDANT
`EMPOWER BEHAVIORAL HEALTH, LLC.
`
`
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on September 7, 2021, a copy of the foregoing document was sent in
`accordance with the Texas Rules of Civil Procedure to all known counsel of record as follows:
`
`Enrique Chaves, Jr.
`Michael R. Anderson
`Chavez Law Firm
`2101 N. Stanton Street
`El Paso, Texas 79902
`Tel: (915) 351-7772
`E-Mail: enriquechavezjr@chevezlawpc.com
`
` manderson@chavezlawpc.com
`
`
`
`
`
`
`
`
`
`
`/s/ Keith B. Sieczkowski
`Keith B. Sieczkowski
`
`
`
`
`
`
`{C2519297.DOCX:3}
`
`5
`
`
`
`Case 3:21-cv-00209-FM Document 1-3 Filed 09/08/21 Page 16 of 16
`
`Automated Certificate of eService
`This automated certificate of service was created by the efiling system.
`The filer served this document via email generated by the efiling system
`on the date and to the persons listed below. The rules governing
`certificates of service have not changed. Filers must still provide a
`certificate of service that complies with all applicable rules.
`Katie Ruvalcaba on behalf of Keith Sieczkowski
`Bar No. 18341650
`kruvalcaba@branscomblaw.com
`Envelope ID: 56990505
`Status as of 9/7/2021 9:34 AM MST
`
`Associated Case Party: Mirelle Devenney
`
`Name
`
`BarNumber Email
`
`TimestampSubmitted
`
`Status
`
`Enrique Chavez Jr.
`
`chavezlawfirm@chavezlawpc.com
`
`9/7/2021 8:42:33 AM
`
`SENT
`
`Case Contacts
`
`Name
`
`BarNumber Email
`
`TimestampSubmitted
`
`Status
`
`Keith BSieczkowski
`Emily KArnold
`Donna Collins
`Katie Ruvalcaba
`Sandy Lee
`
`ksieczkowski@branscomblaw.com
`earnold@branscomblaw.com
`dcollins@branscomblaw.com
`kruvalcaba@branscomblaw.com
`slee@branscomblaw.com
`
`9/7/2021 8:42:33 AM
`9/7/2021 8:42:33 AM
`9/7/2021 8:42:33 AM
`9/7/2021 8:42:33 AM
`9/7/2021 8:42:33 AM
`
`SENT
`SENT
`SENT
`SENT
`SENT
`
`
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