Law/Employment Law

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA

DOROTHY A. ARTIS, )

Plaintiff, )

v. )

) Civil Action No. 1:18-CV-04620-ODE-LTW

ENGLAND ASSOCIATES, LP )

d/b/a NEW LONDON HEALTH CENTER )

)

Defendant,

PLAINTIFF’S INITIAL DISCLOSURE STATEMENT

(l) Unlawful Race Discrimination Ms. Artis, the plaintiff begin working for the above-named employer in October of 2014 as a Certified Licensed Nurse Assistant. On April 20, 2015 Ms. Artis reported “C type terminal misconduct against Zena Slater (Jamaican) a senior employee. Ms. Artis was exposed to harassment and complained of a racially derogatory comment “Lazy-N word, you people in this country are lazy made directly to Ms. Artis and her race in reference to a particular culture to Jeanie Hermes the Director of Nursing and to Joan Johnson, Human Resource Assistant Manager. The Superiors Jeanie Hermes and Joan Johnson, who are both decision makers and trusted member of the Open Door Policy of fairness reference Zena Slater a CNA 10 year senior employee as a favorite employee and labeled Ms. Artis as troublemaker. Ms. Artis states that each time she complained about harassment or mandated reporting laws such as unlawful elderly abuse in the care delivery by unskilled foreign workers or unlicensed foreign care providers her complaints were not taking seriously and superiors Joan Johnson, Jeanie Hermes, Joan Bernard leaked confidential open door policy reporting information back to her coworkers that Ms. Artis complained about. Ms. Artis complained about multiple harassment incidents, racial name calling she received no actions were taken and later colleagues would call her more racial slurs, but nothing was done about it. Ms. Artis alleges that Jeanie Hermes Assistant Director of Nursing, Joan Johnson, Human Resource Manager and Joan Bernard, new Intern Director of Nursing instructed her colleagues to harass her in retaliation for her complaint and to make false allegations to lead the demise of her long-term employment. On May 7, 2015 Ms. Artis reported to Maissa Kamara the 2nd shift manager a severe work injury involving a pt./employee. Ms. Kamara electronic records show that she immediately reported to Joan Johnson, Human Resource Manager. Ms. Artis requested immediate medical attention ad a reasonable modified work accommodation after being injured on the job, but was denied. Ms. Artis asked Joan Bernard for a FLMA in which Joan Bernard stated that nothing was available and she would have to let her go home and just to let her go. On July 1, 2015, Ms. Artis again asked for a modified duty because she was experiencing left extremity weakness, but denied. On July 1, 2015, Ms. Artis was subjected to harassment and verbal racial derogatory name calling and was maliciously and unlawfully discharged. Ms. Artis was exposed to a hostile work environment when Zena Slater left her position and job duty and came into Ms. Artis personal work space and attacked her. Ms. Artis was given work orders by Zena to force-feed a frail patient the remaining 5% of her remaining food. Ms. Was subjected again to being called the “N, word, bodily harm and physical threats made by Zena. Ms. Artis immediately reported this misconduct code that cause for immediate termination and no action was taken. On July 1, 2015, Ms. Artis was maliciously discharged for not taking orders from a same titled CNA, foreign employee that Joan Bernard referenced as her people based on a particular race. Rosemary a regular employee titled as a secretary and who also engaged in harassment and misconduct on July 1, 2015, also participated in my unlawful termination, engaged in the decision making process and sat in on the complete termination process. Rosemary accessed my confidential files and employment records and called my phone mocking my termination. I later learned that my former employer Joan Bernard, Director of Nursing and Joan Johnson, Human Resource Assistant Director submitted false documentation to the Department of Labor, and other government agencies.

(II)The reason given for my discharge insubordination, which the New London Health Center Employee Handbook contradicts as a “C type immediate termination for a “No call, No show.

(III) Ms. Artis believes that she has been discriminated against because of her race (African-American), and in retaliation for opposing unlawful employment practices, in violation of Title VII of the Civil Rights Act of 1964, as amended. Ms. Artis further believe that she has been discriminated against because of her disability, and in retaliation for seeking a reasonable accommodation, in violation of Title I of Americans with Disabilities Act of 1990, as amended. Ms. Artis asked verbally for the new job position, by word of mouth, and was also retaliated against in the promotion process in which she was verbally told by her superior Jessica Shroder, the current scheduler she could have the Scheduler job title that was vacant, because no other employee was interested in it. Ms. Artis was propositioned $2,000.00 by Jeanie Hermes, Director of Nursing and Joan Johnson, HR Assistant Director to drop the Workers Comp claim in exchange for the scheduler position, but declined the offer for medical treatment. Ms. Artis told her friend Lynn Logan, who identifies as African American and she completed the application for the same position. The Scheduler position was awarded to a foreign employee, Rosemary, who Joan Bernard previously referenced and favored as her people on July 1, 2015 after Ms. Artis harassment complaint and unlawful termination.

Plaintiff Dorothy A. Artis brings forth the following causes of action and alleges the following:

The Plaintiff, Dorothy A. Artis is an African American womann.

2. The plaintiff, Dorothy A. Artis was a long-term employee of New London Health Center from October 2014 until July 1, 2015.

3. The Plaintiff. Dorothy A. Artis filed for Unemployment Insurance after being wrongfully fired or “maliciously terminated” from her employment with her employer, New London Health Center on July 1, 2015. Her claim was denied as the court ruled in favor of “With the greater weight” to the employer New London Health Center. Ms. Artis employer willfully committed fraudulent activity and insurance fraud to keep Ms. Artis from receiving benefits and to cause great harm and financial hardships. Ms. Artis cared for her 86 year old mother and son who is a college student. Ms. Artis provided 50% of her income to support her family members.

4. The plaintiff, Dorothy A. Artis, appealed the decision made by the Department of Labor through the Department of Labor Appeals process four times and each time was denied her claim based on the results of a shoddy investigation or no investigation at all by Lakeisha Hudson, Investigator. Lakeisha Hudson violated the 14th Amendment and erred in judgement without a thorough investigation to check for clarity, validity of the New London Employee Handbook protocol policy violation of a “No call no show”, and failure to check former employees terminated for the same protocol. Ms. Lakeisha Hudson, negligence and failure to efficiently do her job further violates Ms. Artis Due Process of Law. Ms. Artis was denied UI benefits based on evidence of (4) Appeals filed and denied with factual evidence of an immediate manufactured malicious termination for a “No call no show” policy violation and negligence of another flawed investigation committed by Honorable Judge Karen Byers, Gwinnett County Superior Court (New London Employee handbook “C Type “protocol violation pg. 21-22). The physical evidence of the employee handbook contradicts their all-inclusive investigation and false oral and documented statements. Both government officials failed Ms. Artis miserably by being unqualified in the investigative decision making process of law and according to the rules.

5. In February 29, 2016, the Honorable Judge Karen Byers, Gwinnett County submitted her rulings which stated that her ruling was based on an all-inclusive investigation, which led her to the same decision as Investigator Lakeisha Hudson. Both government superiors failed to do their job and a thorough investigation as documented their negligence and actions further discriminated and violated Ms. Artis civil rights to due process of law. Upon further review of evidence it is clear that neither government superior took Ms. Artis or the law serious. Government agencies made their decision based on false statements and documents that are not valid in the court of law and punishable by law.

6. In (2015), plaintiff, Ms. Artis filed a claim under the Workers’ Compensation Act as a part of the claim for injuries she sustained on the job while performing care duties on the clock and premises of her employer and as an employee of New London Health Center.

7. Employees for New London Health Center falsely testified under administrative oath and submitted fraudulent evidence during Ms. Artis Workman’s Compensation hearing and produced fraudulent documentation that caused Ms. Artis’ W/C claim to be denied with serious injuries. According to Ms. Artis the injury document clearly shows that superiors tampered with evidence with a visible later revision date removing her as a severely injured employee to just being a witness. The work injury document was rearranged and with evidence of fraud based on evidence tampering. Ms. Artis also addressed the fact that Ms. Joan Johnson made a statement “That she was the only one with the keys to the confidential employee files.” However, she blamed a former Director for tampering with the incident injury document. Ms. Artis also states that according to New London legal counsel Attorney Mark Irby he states, and documented while under administrative oath, “Ms. Artis had a whole section on “how to report a work injury in her personal file”, Ms. Artis questioned why she is the only employee who confidential employment file was molested with these documents. This clearly shows fraud to the 3rd degree in which government employees, Judge Mason and Judge Elizabeth Gobeil, Appeals Judge one-sided judgments intentionally overlooked. Ms. Artis was reprimanded for her Attorney Melvin Price entering the wrong date and apologized repeatedly. Yet, New London had no insurance on file, which caused Ms. Artis Attorney Melvin Price to abandon the case. New London unlawful actions and tampering with evidence was never a factor or documented in Hon. Judge Johnny Mason or Hon. Judge Elizabeth final rulings. Again, both Judges documented a thorough investigation and supported in agreement of both mirrored decision, giving the final judgement to the credible witnesses testimonies. Again, according to the physical evidence and the New London Employee Handbook, which clearly contradicts that work injury reporting documents should not be in Ms. Artis personal employment file. The witness’s false testimony, illegal documents and tampered evidence clearly outweighs and contradicts the Hon. Judges statement of an independent thorough investigation. Both Honorable Judge Johnny Mason and Hon. Judge Elizabeth Gobeil failed to do their jobs and wrongfully judged Ms. Artis claim for Workers’ Compensation Benefits and further violated her rights to fairness and Due Process of Law.

8. In August 2015, plaintiff, Ms. Artis filed a claim with the EEOC against New London Health Center. Due to the timing of the suit, the EEOC deferred to not conduct an investigation into the claims or check employee files that Ms. Artis alleged against the defendant, New London Health Center. Ms. Artis was repeatedly told on multiple visits that there was nothing that the EEOC was willing to do.

9. Plaintiff, Ms. Artis filed a Civil Rights Discrimination lawsuit against New London Health Center. Case No. 17-10303-AA

Plaintiff, Dorothy A. Artis, brings forth the following counts and allegations supporting her cause of action:

COUNT 1 – FOURTEENTH AMENDMENT VIOLATIONS

Plaintiff, Dorothy A. Artis asserts that throughout her various litigations with her former employer, New London Health Center, that her rights through the Fourteenth Amendment were violated. In particular, the plaintiff, Ms. Artis feels as though she was deprived of her right to life, liberty, and property without the due process of law.

Ms. Artis’ former employer, New London Health Center was allowed to bring falsified documents, perjured statements, and other malicious and false statements against Ms. Artis repeatedly throughout their long litigation process and felt very violated and dehumanized when law breakers were not prosecuted for their willful actions. Ms. Artis watch the court pook fun of her extenuating circumstances, rush the court process with no respect for her extenuating disability and losses, and saw comments in the docket where 3 Hon. Judges made and signed off on a racial profiling statement towards her as an African American as “Just wanting money.” This comment clearly shows that African Americans even with laws to protect them continues to be victimized in the justice system. This colorism race card and personal judgement clearly violates Ms. Artis Civil Rights, Federal Laws and her equality to the justice system based on target racial profiling. Ms. Artis did receive a wrongful judgement based on a broken system, Hon. Judge Steve Jones personal judgement, character flaws that contradicts his final ruling and the Constitution. Ms. Artis states “She felt like she did not belong and was treated like a bum instead of a human being with rights.” It was the duty of the court to fully investigate the claims made by both Ms. Artis and New London Health Center in fairness, however, Ms. Artis’ inability to afford a lawyer means that she presented all of her cases pro se and felt that her lack of knowledge of the law allowed for her to be continuously mistreated, one-sided, and watch criminal activity being overlooked and not prosecuted throughout court proceedings. The court claimed to have investigated the claims by both parties and ruled in favor of the plaintiff’s former employer New London based on those shoddy investigations if any at all. The courts repeatedly ruled swiftly against Ms. Artis and in their swift decision making further discriminated against her and violated her civil rights, denied justice, no civil rights protection and defamed her character and good name, while allowing willful uncontentious “no tolerance major law breakers” to leave the court process as above the law without prosecution. However, a quick look through the court proceedings and paperwork shows the inconsistent testimony, illegal manufactured documents that contradicts the New London Health Center 2014 Employee Handbook for a No call No Show, W/C tampered illegal documents with a later revision date of Ms. Artis former employer. The testimony goes against other testimony from people at the same place and the paperwork does not match up with anything that was said. Yet the judgment was found in their favor based on this “investigation”. The Judges/Appeal Judges/Investigators also made false statements, documented and signed that they had all done a thorough investigation yet, not one government official made statements concerning criminal activity, former employees rightfully terminated for the same protocol policy violation or addressed why any employer would negligently override and violate their own policy protocol for 30 days in the termination process other than to comfortably and willfully defraud the government to show compliance. This clearly shows that the Justice System is extremely broken and the laws designed for African American are flawed as well. The federal laws based on protected class designed for Africa Americans did not apply to Ms Artis. The US Government and its Government Agencies clearly did not do a good job to protect Ms. Artis Civil Rights. Unqualified Government superiors, judges and employees completely failed Ms. Artis miserably and defamed her name by making false frivolous documentations without clarity, discriminated, humiliated, degraded and destroyed Ms. Artis, her civil rights and her rights to fairness and to be heard in the legal process. Ms. Artis states “A mountain of physical evidence was present and not one of the judgements she received was in accordance to the federal laws and the Constitution. UNFAIR UNEQUAL JUSTICE DENIED

COUNT 2 – RETALIATION UNLAWFUL/UNFAIR COURT PROCESS

Defendant,

COUNT 3 –RULINGS BASED ON INSUFFICIENT INVESTIGATIONS

DEFAMATION

DAMAGES

WHEREFORE, Plaintiff seeks compensatory damages in the amount of general damages amounting to $ 200,000. She also claims $ 300,000 for compensatory damages $300,000 for lost wages, medical costs, lost employment opportunities, loan payments, interest payments, employment income, future wages, unemployment benefits and worker’s compensation benefits. She also requests that punitive damages, defamation of character, pain and suffering, total losses evictions, repossessions and homeless amounting to $500,000 be awarded for the illegal conduct condoned in the institution. The plaintiff, therefore seeks $1, 300,000 in total damages. Ms. Artis seeks a swift resolution and monetary settlement or a Jury Trial of her peers.

Dated this 6th day of March, 2020.

Dorothy A. Artis

Claim for Relief

The Plaintiff, an African American has now and at all times been a resident of New London/Snellville, GA.

II.

The Defendant, is and has always been a resident at New London.

III.

The plaintiff was the defendant’s long-term employee until she was wrongfully terminated

IV.

First Claim for Relief

Unlawful Race Discrimination

Plaintiff Dorothy A. Artis brings forth the following causes of action and alleges the following:

I began working in a long-term employment at my New London Health Center on October 11, 2014, as a certified Nurse Assistant. On April 20, 2015, I complained of a racially derogatory comment made to me and referenced my particular race using the ‘N-word”, to Joan Johnson, HR Assistant Director and Jeanie Hermes, Assistant Director of Nursing. I reported this misconduct against a senior employee Zena Slater, CNA, and she was referenced as favored and Ms. Artis was labeled as a lesser and a trouble maker. No action was taken.

1. The plaintiff, Dorothy A. Artis witnessed many state and federal law violations and acted in accordance with the defendant, New London Health Center’s employee handbook which required that she report the violations that she witnessed within the company, which she did.

Malicious Termination/Failure to Protect

Plaintiff was maliciously terminated by the defendant without a good legitimate reason. The defendant had a duty to conduct Due Process of Law, Due Diligence and Title VII, and protect Ms. Artis before the termination of the employee and in the court process. The upper level Superiors (Joan Bernard, Director of Nursing and Joan Johnson, HR Administrators malicious act of terminating the employee and releasing false statements, manufactured forged documents and tampering with evidence breached their employment contract. The upper level Superiors also violated their Professional responsibilities to be Trusted Members of the Open Door Policy and abandoned the Federal Laws, Constitutional Laws and Ms. Artis Civil Rights to be protected in a safe place of employment free of harassment, bullying and retaliation. Ms. Artis was left unprotected in the legal system court process where her rights to Due Process of Law was further denied and Ms. Artis was further victimized by being denied her basic rights to Due Process of Law, Due Diligence and Title VII.

As a result of the defendant’s action, the plaintiff suffered damages that amounted and not limited to lost wages, medical insurance payments and retirement plan benefits.

Second Claim for Relief

Malicious Defamation of Character

A protected class African American Plaintiff’ character was willfully defamed to cover up illegal wrong doing and discrimination when the defendant launched their defense. The defendant molested Ms. Artis personal confidential employment file and included a whole section of workers’ comp reporting, provided falsified documents and tampered with evidence to the Department of Labor, Department of Labor Appeals (4), Gwinnett County Superior Court, Equal Employment Opportunity Commissioner (EEOC), State Board of Workers’ Compensation, State Board of Workers’ Compensation Appeals, District Court, Federal Court and the Federal Court of Appeals with the sole purpose and intent to destroy the plaintiff’s character and credibility. The defendant’s intent of gross negligence and criminal activity was to cover up noncompliance with laws to show compliance with employment laws, state/local/federal laws/Constitution TitleVll.

As a result of the defendant’s action, the plaintiff’s reputation was affected denying her new employment opportunities. The damages to the plaintiffs include the loss of income from lost job opportunities, no income for an extensive years, mental trauma, repossessions, evictions and total losses.

VI.

Third Claim for Relief

Willful Illegal Denial of Unemployment Benefits

The plaintiff was denied unemployment benefits even after their employment was terminated. The defendant failed to serve their duty of releasing the employment benefits to the employee and abiding by federal laws.

As a result of the defendant’s action, the plaintiff was unable to pay their immediate bills. Damages to the employee include lost unemployment benefits, loans and interest on loans undertaken by the plaintiff to pay for their immediate bills. The Defendants illegal actions totally destroyed Ms. Artis mentally and physically.

VII.

Fourth Claim for Relief

Willful Malicious Denial of Worker’s Compensation Benefits

Plaintiff was denied worker’s compensation benefits for the injuries incurred at the workplace. The defendant had a duty to provide for the plaintiff for the injuries incurred while performing their duties.

As a result of the defendant’s action, the plaintiff’s injuries were not treated leading to extended days of lost productivity and medical cost. Damages to the plaintiff include and are not limited to lost wages, front wages and past and future medical costs.

VIII.

Willful Wrongful Judgements, Failure to Protect in the Employment/ Legal System, Failure to follow their own Rules, Protocols, Policy & Federal Laws

The Defendant did not have Security on the premises and Ms. Artis was not provided a safe place to work. The Defendants did not allow Ms. Artis to exercise her rights to the Open Door Policy nor did they take actions against favored employees who committed immediate termination according to the New London 2014 Handbook Policy. Ms. Artis was subjected to multiple encounters of unwanted verbal attacks and instigated bullying that she did try to avoid. The employer’s superiors granted same titled employees (CNA) authority to lead to Ms. Artis long-term termination and it lead to violence towards against Ms. Artis in her personal workspace, fear, bullying in an unsafe employment setting. The actions of Ms. Artis superiors that are listed as upper management clearly shows the level of mental trauma she suffered on a daily basis. Ms. Artis solely supported her mother and a son attending college, while dealing with medical issues, evictions, repossessions, depression, Anxiety Attacks and Post-Traumatic Disorder (PTSD)

Damages

Total damages claimed are for monetary relief Compensatory punitive $1, 300,000 for lost wages, medical costs, lost employment opportunities, loan payments, interest payments, employment income, future wages, unemployment benefits and worker’s compensation benefits and defamation. And Punitive damages for pain and suffering $2, 000,000 total damages

$3, 300,000. If the agreement is not met in a timely manner Ms. Artis is seeking a speedy Jury Trial of her peers, court fees and attorney’s fees to be awarded in the final settlement.

Dorothy A. Artis

Signature_____________

herein files a Motion Not to Dismiss the First and Second Amended Complaints against New London Health Center.

New London Health Center has always gotten their way in every effort I put forward to seek for justice. In their Motion to Dismiss, the defendant terms the claims as “allegations that are no more than opinions or mere legal conclusions”. The fact the Ms. Artis does not have any legal representation in this case due to financial constraints and further lacks adequate background in law practice cannot be the reason for concluding the complaints are vague, and incoherent. To the best of my understanding, the employment termination by New London Health Center was wrongful and done with malice due to the following reasons.

(1) Ms. Artis has always followed the right channels in reporting all the incidences at work. However, the superiors took no action despite the clear guidelines stipulates in New London Health Center’s handbook policy.

(2) On several occasions, the EEOC denied Ms. Artis a fair investigations into the matters and even showed no interest in the case. This leaves Ms. Artis at a crossroad and disadvantaged at the same time.

(3) While under administrative oath, New London Health Center submitted fraudulent and forged documents to Department of Labor, Department of Labor Appeals, Gwinnett Superior Court, Equal Employment Opportunity Commissioner (EEOC), State Board of Workers Compensation, State Board of Workers Compensation Appeals, District Court and Federal Court of Appeals during investigations and hearings. This action by the defendant further clogged the prevalence of justice for Ms. Artis.

(4) Undeniably, Ms. Artis was never shown same consideration as other employees at New London Health Center. For every report Ms. Artis Made to the relevant superiors on abuse or racial discrimination, a retaliation was directed to and in some instances, she was the one faulted. Most of the abusers would openly brag to Ms. Artis and call her the n-word without being reprimanded by the superiors even after filing an incident report on the same. Under such circumstances, the hostility of the work environment created.

(5) The termination of employment for Ms. Artis came when she needed medical attention from a work-related injury. Even after being requesting for modified duties that would enable Ms. Artis to continue undertaking her duties despite the injury, the management told her she would rather go home. This comes after Ms. Artis’ compensation claim was not honored even after sustaining an unintentional injury at the workplace.

(6) Ms. Artis was further victimized by the justice system on every level. In the employment setting anyone could make a false statement against Ms. Artis an adverse action would be taken without a 24 hour investigation according to the employee handbook. In the court process the defendants violated federal laws and constitutional law. The defendants committed unlawful illegal acts against Ms. Artis and caused her to lose everything she owns and destroyed her life. The defendants also violated federal laws and constitutional law, misrepresented factual information on Ms. Artis’ conduct at work and forged documents submitted while under administrative oath both written and oral.

(7) he defendants then continues to manipulate the justice system by failing to admit to their unlawful actions then continue to maliciously leave Ms Artis unprotected in the employment setting where she was unfairly treated and leave Ms. Artis unprotected in the Justice system on multiple levels of malicious intentions and actions. New London has never been held accountable for their malicious actions and violations.

(8) All the government agencies violated policy, did not check for clarification and transparency not did they do a thorough all out independent investigation as stated. This is a direct violation of Ms. Artis constitutional civil rights and the due process of law. Some of the government agencies (EEOC) acted unprofessionally and failed to do an independent investigation as stated.

(9) The Justice system was biased to Ms. Artis and subjecting her to racial discrimination and racial profiling. Ms. Artis should not have been subjected to a degrading note from 3 judges in agreement that "just looking for money" that don't belong in the justice system. The note don't belong and the judges don't either. Ms. Artis would like for the policies and practices to be examined in our justice system to reinforce racial disparities. Ms. Artis seeks change to reinforce federal laws and constitutional law and to the point that the Constitution is not just an inactive piece of paper but rather an equality law in action and enforced.

Let me remind the courts Ms. Artis is the victim and every little mistake she makes she is threatened with her case being closed and no justice from the justice system. On the other hand the defendant’s unlawful fraud and forgery to the third degree has never been addressed or held accountable for. Ms. Artis recently just loaded her mother July 30, 2019. January 2020 Ms. Artis youngest brother passed away and just recently her 2 year old niece passed away 2/2020. Ms. Artis is now dealing with failing health physical and mental disability among other extenuating circumstances and dire needs with no resources.

Ms. Artis further understands that there are regulations guiding the proceedings and due to lack of a professional background in law and further lacking legal representation on the case, the defendants take the advantage of pointing out the mistakes in her complaints to suppress her quest for justice. For every mistakes she make, she is judged and her case risk being closed. Although the motion lacks legal citations, the information presented herein is to the best of the understanding of Ms. Artis.

Because of lacking legal representation in court, Ms. Artis has been left vulnerable and unprotected. First off, shoddy investigations have been done in her cases previously. EEOC even declined to provide all the files to Ms. Artis at some point and this shows the extent of her mistreatment and discrimination. The defendants are using such shortcomings to shortchange the justice process for the plaintiff.

In conclusion, for the foregoing reasons, Ms. Artis requests this court not to grand the Motion to Dismiss with prejudice to New London Health Center. Ms. Artis further confirms that she has not abused any judicial process as claimed by the defendants in their Motion to Dismiss. She is only seeking for justice for unfair termination of her employment and being racially discriminated and no action was taken by the New London Health Center management, an indication that the superiors also were racially discriminating Ms. Artis. As claimed by the defendant, Ms. Artis is not “shopping” for judges but rather seeking relief for the wrongdoings the defendants have done to her.

Respectively Submitted

_______________________

Dorothy A. Artis