IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION GRETCHEN RACHEL HAMMOND, Plaintiff, No. v. 1' SURVIVORS NETWORK OF THOSE ABUSED BY PRIESTS, an Illinois not- I. for-pro?t corporation, JURY DEMANDED Defendant. Plaintiff Gretchen Rachel Hammond (?Plaintiff?), by her undersigned attorneys, for her Complaint against Defendant Survivors Network Of Those Abused By Priests states as follows: NATURE OF THE CASE 1. This is an action for retaliatory discharge. In summer 2011, Plaintiff obtained employment with SNAP as a director of development. SNAP, a non-pro?t organization, represents itself to be a self-help network for survivors of sexual abuse at the hands of the clergy, particularly the clergy of the Catholic Church. Plaintiff was deeply excited to apply her professional experience in non-profit fundraising to the noble endeavor of helping victims who had suffered sexual assaults at the hands of trusted clergy members. 2. As Plaintiff came to learn, however, SNAP does not focus on protecting or helping survivors?it exploits them. SNAP routinely accepts ?nancial kickbacks from attorneys in the form of ?donations.? In exchange for the kickbacks, SNAP refers survivors as potential clients to attorneys, who then file lawsuits on behalf of the survivors against the Catholic Church. These cases often settle, to the ?nancial bene?t of the attorneys and, at times, to the ?nancial bene?t of SNAP, which has received direct payments from survivors? settlements. 3. SNAP also regularly communicates with attorneys about their lawsuits on behalf of survivors, receiving drafts of pleadings and other privileged information. The attorneys and SNAP work together in developing the legal theories and strategies of survivors? lawsuits. Attorneys and SNAP base their strategy not on the best interests of the survivor, but on what will generate the most publicity and fundraising opportunities for SNAP. 4. When Plaintiff discovered that SNAP was colluding with survivors? attorneys, she confronted her superiors to report her discovery. In return, SNAP began taking retaliatory actions against Plaintiff, which resulted in Plaintiff suffering from stress and depression that manifested in health problems. retaliation ultimately culminated in Plaintiff?s discharge from SNAP in February 2013. As a result of retaliation and discharge, Plaintiff has been forced to accept employment for substantially lower wages than she earned at SNAP. Moreover, betrayal of its mission and its harsh treatment of Plaintiff has robbed Plaintiff of the joy she once held for her chosen profession in non-pro?t fundraising. 5. Accordingly, Plaintiff asserts a claim for retaliatory discharge and seeks compensatory damages, plus pre- and post-judgment interest. JURISDICTION AND VENUE 6. This Court has personal jurisdiction over SNAP because it is a resident of the State of Illinois and therefore subject to general jurisdiction. This Court also has personal jurisdiction over SNAP under the Illinois long-arm statute, 735 ILCS 5/2-209, because a substantial portion of the wrongdoing alleged in this Complaint took place in and/or was directed toward the State of Illinois, and because this action arises ?'om tortious actions within the State of Illinois. 7. Venue is proper in Cook County pursuant to 735 ILCS 50-101, because Cook County is the county of residence of SNAP, and a substantial part of the events or omissions giving rise to this claim occurred in Cook County. PARTIES Plaintiff 8. Plaintiff is an individual domiciled in Cook County, Illinois. Defendant 9. Defendant SNAP is organized as a not-for-pro?t corporation under the laws of Illinois, and has its principal place of business located at 330 South Wells Street, Chicago, Illinois 60606. 10. Barbara Blaine (?Ms Blaine?) is the founder of SNAP. She is president and sits on board of directors. David Clohessy Clohessy?) is the executive director of SNAP, and sits on board of directors. Mr. Clohessy oversees public relations. 12. Barbara Dorris (?Ms Dorris?) is the outreach director of SNAP. FACTUAL BACKGROUND 1. Background On Operations 13. SNAP claims status as a tax-exempt organization under 26 U.S.C. 501(c)(3). To attain this tax-exempt status, SNAP must be organized and operated exclusively for religious, charitable, scienti?c, testing for public safety, or educational purposes, or to foster national or international amateur Sports competition . . . or for the prevention of cruelty to children or animals[.] 26 501(c)(3) (emphasis added). 14. In contravention of this statutory directive, SNAP is organized and operated substantially for non-exempt, commercial puiposes. 15. SNAP claims in its federal tax returns that its primary exempt purpose ?is to provide support for men women who have been sexually victimized by members of the clergy,? and that its ?mission is to meet the needs of membership through moral support, information advocacy.? 16. In Statement of Program Service Accomplishments in its federal tax returns, SNAP states, ?This organization attempts to reach out to as many survivors of clergy abuse as possible and prevent further abuse through public education advocacy. The organization established 50 regional chapters throughout the country and holds local regular self- help support meetings.? 17. In reality, SNAP is a commercial operation motivated by its directors? and officers? personal and ideological animus against the Catholic Church. 18. commercial operation is premised upon farming out abuse survivors as clients for attorneys, who then ?le lawsuits on behalf of the survivors and collect settlement checks from the Catholic Church. 19. In return for client referrals, attorneys reward SNAP with ?nancial kickbacks in the form of donations. 20. SNAP then manipulates and exploits media publicity surrounding survivors? lawsuits against the church to raise its own publicity and drive ?Jndraising efforts. SNAP callously disregards the real interests of survivors, using them instead as props and tools in furtherance of own commercial fundraising goals. Instead of recommending that survivors pursue what is in their best personal, emotional, and ?nancial interests, SNAP pressures survivors to pursue costly and stressful litigation against the Catholic Church, all in order to further own publicity and fundraising interests. SNAP Neglects Survivors 0f Clergy Sexual Abuse 22. SNAP claims that it exists to provide support to survivors of clergy sexual abuse. However, at all relevant times, SNAP did not have a single grief counselor or rape counselor on its payroll. 23. Moreover, at all relevant times, SNAP never reached out to, or communicated with, grief counselors or rape counselors for the purpose of providing counseling to survivors through network. 24. SNAP would even ignore survivors that reached out to SNAP in search of assistance and counseling. 25. Plaintiff routinely received telephone calls at work from distressed survivors. Even though Plaintiff informed the survivors that she was a fundraiser, not a counselor, Plaintiff would listen as the survivors con?ded to her about their trauma. 26. When Plaintiff told Ms. Dorris that she was receiving these phone calls and was unsure how to handle them, Ms. Dorris told Plaintiff to simply not answer phone calls from survivors seeking assistance and counseling. 27. work with survivors is substantially subordinate to extensive publicity and fundraising operations. SNAP Sqaanders ands Meant or Survivors 28. DeSpite collecting funds ostensibly for counseling and aiding survivors of clergy sexual abuse, SNAP squanders those funds on advancing its own interests and the interests of its leadership. 29. leadership, including the individuals named herein, periodically travel in the course of operations. 30. For example, in 2011, Plaintiff oversaw the fundraising for trip to The Hague, where SNAP ?led charges against Pope Benedict in the International Criminal Court. 31. However, SNAP used the funds raised by Plaintiff to pay for lavish hotels and other extravagant travel expenses for its leadership. 32. SNAP also uses funds meant to assist survivors on its own legal troubles. SNAP ?5 Conduct Leads 0 Legal Scrutiny And Sanctions 33. In 2011 and 2012, SNAP was ordered to produce documents in a case ?led in Jackson County, Missouri, involving a Kansas City priest accused of sexual abuse. 34. In that case, the trial judge issued a gag order after defense attorneys highlighted ?that when a lawsuit was ?led against [the priest] in June, SNAP made statements in a news release ?that seriously jeopardize [the priest?s] ability to receive a fair trial in this case.m1 35. The trial judge subsequently ordered SNAP to produce documents that defense attorneys sought ?as evidence that the accuser?s attorney violated [the] gag order by giving 1 Judy L. Thomas, Judge issues gag order in suit against KC priest, THE WICHITA EAGLE (Aug. 5, 201 l, 12:00 AM), -6- details of the case to which SNAP then printed in a press release issued before the case was ?led.2 36. Shortly thereafter, Mr. Clohessy sat for a deposition in which he repeatedly refused to answer questions. 37. In his deposition, Mr. Clohessy was asked, ?Has SNAP to your knowledge ever issued a press release that contained false information?? 38. Mr. Clohessy responded, ?Sure.? 39. After his deposition, Mr. Clohessy and SNAP still refused to produce documents the Court had ordered SNAP to produce. Mr. Clohessy adopted a combative stance, telling media sources that ?a judge could fme him and SNAP, or possibly jail him, though no such requests have been made.?3 40. After SNAP was again ordered to produce documents relating to the alleged violation of the gag order, Mr. Clohessy sent an email to Ms. Blaine and attorneys, stating, ?in terms of public relations, it might help and can?t hurt, eSp [sic] if we try to get coverage (as i [sic] hope we will) on our otherwise somewhat predictable and non-newsworthy motion for 41. Rather than comply with the Missouri trial court?s orders regarding discovery, SNAP spent $35,000?money that should have gone to aiding and supporting survivors of clergy 2 Jim Salter, SNAP Zeader vows to?ght records disclosure order, THE SAN DIEGO UNION- TRIBUNE (Jan. 3, 2012, 1:36 PM), 3 Brian Fraga, Judge ?3 order has victims organizalion reeling, OSV NEWSWEEKLY (Jan. 18, 2012), 3 567/ ArticleID/487 udge -7- sexual abuse?on: defending repeated efforts to obstruct discovery; and generating publicity therefrom.4 42. More recently, in June 2015, a Catholic priest brought a lawsuit against SNAP and several other defendants in a St. Louis federal court for allegedly conspiring to falsely accuse the priest of sexually abusing a minor. Jiang v. Porter et a1. No. (ED. 43. In the course of that lawsuit, SNAP was asked to produce information regarding contributions from attorneys at a plaintiff?s law ?rm. SNAP re?lsed, forcing the plaintiff to rely on ?disclosures and productions from other parties and non-parties, which include communications with the SNAP defendants that the SNAP defendants themselves never produced despite plaintiff?s discovery requests.? Jiang v. Porter, Case No. 4:15-cv-1008 (CEJ), 2016 WL 4430188, at *1 (ED. Mo. Aug. 22, 2016) (emphasis added). 44. The Court rejected assertion of a ?meritless? rape crisis center privilege, but SNAP still refused to comply with the Court?s discovery orders. Id. Indeed, SNAP ?concede[d] that they have willfully disobeyed the Court?s discovery orders,? despite the Court?s warning that ?failure to comply could result in the imposition of sanctions under Federal Rule of Civil Procedure Id. 45. Accordingly, the Court found that ?the SNAP defendants? refusal to comply with the Court?s discovery orders has been willful and in bad faith.? Id. at The Court also found that ?the SNAP defendants? defiance of the Court?s orders and refusal to provide documents and information in discovery has impaired plaintiff?s ability to litigate his claims against them.? Id. 4 See Brian Fraga, Judge "5 order has victims organization reeling, OSV NEWSWEEKLY (Jan. 18, 2012), 3 567/A11icleID/487l/Judge -3- 46. ?For example,? the Court explained, ?the SNAP defendants are withholding documents that evidence communications among them and with friends or relatives of persons who have accused plaintiff of sexual abuse and plaintiffs? attorneys who have received referrals from Id. (emphasis added). 47. As a result of ?deliberate and willful refusal to comply with the Court?s discovery orders and other discovery abuses,? the Court levied sanctions against SNAP in the form of: directing that the facts alleged to support the elements of the plaintiff?s claims against SNAP were established for purposes of the action; and ordering SNAP to pay the plaintiff attorneys? fees. Id. at 48. In particular, the Court ordered that: ?with respect to plaintiff?s civil rights conspiracy claim, the Court will direct that it has been established that the SNAP defendants conspired with one another and others to obtain plaintiff?s conviction on sexual abuse charges and that they entered into this conspiracy due to discriminatory animus against plaintiff based on his religion, religious vocation, race and national origin?; and ?[w]ith respect to plaintiff?s defamation claim, the Court will direct that it has been established that the SNAP defendants? public statements about plaintiff were false and that they did not conduct any inquiry into the truth or falsity of these public statements, but instead made these statements negligently and with reckless disregard for the truth.? Id. at Animus Against The Ch arch 49. While SNAP claims that it is motivated by the interests of survivors, in fact, SNAP is motivated largely by the personal animus of its directors and of?cers against the Catholic Church. 50. On April 26, 2011, Mr. Clohessy sent an email to a survivor recommending that the victim pursue a claim in the bankruptcy proceeding involving the Archdiocese of Milwaukee. 51. In that email, Mr. Clohessy stated, ?i [sic] sure hope [sic] DO pursue the WI bankruptcy . . . every nickle [sic] they don?t have is a nickle [sic] that they can?t spend on defense lawyers, PR staff, gay-bashing, women-hating, contraceptive-battling, etc.? 52. In his April 26, 2011 email to the survivor, Mr. Clohessy stated, ?re i [sic] know [a prominent attomey]?s doin [sic] a bunch in milwaukee SNAP Receives Substantial Contributions From Attorneys 53. In 2003, SNAP received approximately $439,577 in total contributions. 54. Of that amount, ?fty?four percent were donations made by plaintiff 3 sex abuse attorneys. 55. In 2003, a prominent Minnesota attorney that represents clergy abuse survivors donated $179,100 to SNAP?over forty percent of total contributions for 2003. 56. Two prominent California attorneys that represented clergy abuse survivors also donated $35,000 and $10,800, respectively, to SNAP in 2003. 57. In 2007, SNAP received approximately $43 7,407 in total contributions. 58. More than eighty-one percent of 2007 contributions were donations made by attorneys. 59. In 2007, the same Minnesota attorney donated $169,716.67 to SNAP?over thirty?eight percent of total contributions in 2007. 60. Also in 2007, a prominent California attorney that represented clergy abuse survivors (and who had donated $35,000 to SNAP in 2003) donated $100,000 to SNAP?over -10- twenty-two percent of total contributions in 2007. Another prominent California attorney that represents clergy abuse survivors donated $20,000 to SNAP in 2007. 61. A prominent Chicago attorney that represents clergy abuse survivors donated $50,000 to SNAP in 2007. 62. In 2008, SNAP received approximately $753,596 in total donations. 63. Sixty-?ve percent of 2008 contributions were donations made by plaintiffs attorneys. 64. In 2008, the same Minnesota attorney donated a whopping $415,140 to some ?fty-?ve percent of total contributions in 2008. 65. The same Chicago attorney who donated $50,000 to SNAP in 2007 also donated $42,500 to SNAP in 2008. 66. The same California attorney that donated $20,000 to SNAP in 2007 also donated $25,000 to SNAP in 2008. 67. In 2011, SNAP received approximately $676,923 in total contributions. 68. Over ?fty?six percent of 2011 contributions were donations made by plaintiffs attorneys. 69. In 2011, the same Minnesota attorney donated $275,000 to SNAP?over forty percent of total contributions in 2011. 70. A prominent Seattle attorney that represents clergy abuse survivors also donated $25,000 to SNAP in 2011. 71. A prominent Delaware attorney that represents clergy abuse survivors donated $25,000 to SNAP in 2011. -11- 72. A prominent California attorney who represented clergy abuse survivors (and who had made substantial donations to SNAP in 2003 and 2007) also donated $17,000 to SNAP in 201]. 73. Tellingly, at one time during 201 1 and 2012, SNAP even concocted a scheme to have attorneys make donations to a front foundation, styled the ?Minnesota Center for Philanthropy,? and then have the Minnesota Center for Philanthropy make a grant to SNAP in order to provide a subterfuge for, and to otherwise conceal, the plaintiff? attorneys? kickbacks to SNAP. SNAP Receives Payments From Settlements Between Victims And The Church 74. In 2002 and 2003, Ohio attorney William Crosby Crosby?) represented clergy abuse survivors in a lawsuit in Ohio against the Catholic Church. 75. In 2012, Mr. Crosby was disbarred for the actions he took in that lawsuit, which included Mr. Crosby misappropriating settlement funds belonging to his client. Disciplinary Counsel v. Crosby, 132 Ohio St.3d 387, 2012-Ohi0-2872, 972 574. 76. On June 15, 2011, a Senior Assistant Disciplinary Counsel from the Supreme Court of Ohio?s Of?ce of Disciplinary Counsel sent an email to Mr. Clohessy, with the subject header ?William Crosby,? to ?follow up on our telephone conversation earlier today regarding suspended Ohio Attorney William Crosby.? 77. In that email, the Senior Assistant Disciplinary Counsel referenced Mr. Crosby?s lawsuit against the Catholic Church and stated, ?The court case settled in June 2003 and settlement documents created by Crosby indicate that some amount of the settlement payment was paid to -12- 78. The email then stated, ?Is there any way that you can con?rm whether any payments were actually made to SNAP on behalf of these fellows? The payments would have been made between June 2003 and May 2004. Any payment would have come from Crosby.? SNAP Uses Publicity Surrounding Victims Lawsuits 0 Drive undraising 79. Mr. Clohessy regularly communicates with attorneys representing victims regarding the victims? lawsuits prior to the ?ling of those lawsuits. 80. Mr. Clohessy routinely involves himself in deve10ping the legal theories and litigation strategies of victims? lawsuits. 81. Attorneys would often provide Mr. Clohessy, Ms. Blaine and Ms. Dorris with drafts of complaints and other pleadings prior to ?ling, along with other privileged information. 82. SNAP would use those drafts to generate sensational press releases on the survivors? lawsuits. 83. SNAP would then issue the press releases to media outlets and schedule a press conference on the day a survivor?s lawsuit was ?led. 84. SNAP and survivors? attorneys would often base their case ?ling strategy on what would generate the most publicity for SNAP?instead of the best interests of the survivors. 85. In an email exchange between Mr. Clohessy, Ms. Blaine, and Ms. Dorris on January 31, 2013, one email discussed a subpoena issued to SNAP and stated, ?putting it in the newsletter may prompt more even though ?on the other hand, it?ll also upset more survivors. . . 86. Ms. Blaine responded to that email and stated, ?My initial response is that we err on the side of using it to raise money.? -13- 87. Another person responded to Ms. Blaine, stating, ?Think that is a good point? besides don?t think we gain much by keeping it quiet. We can ?upset? people now or later?? nothing really changes.? 88. And in a ?nal email another SNAP employee responded, cautioning, ?careful [sic] what we put in e?mails, 0k?? SNAP Attempts 0 Enlist Attorneys 0 Defend SNAP ?5 Reputation 89. On March 9, 2012, Mr. Clohessy sent an email to an attorney representing a survivor. In that email, Mr. Clohessy quoted a blogger? who wrote, have also spoken extensively to a victim of priest sexual abuse and he told me how SNAP receives much of its funding by class action law ?rms where they refer victims. He said the group also asks victims to donate money won in lawsuits back to SNAP. I really have a problem with SNAP publicly outing priests for publicity and then trying to prove the allegations. It has ruined many innocent pe0ple.? 90. In his email, Mr. Clohessy asked the attorney to submit a response (drafted by Mr. Clohessy) to the KC blogger. Mr. Clohessy stated in this email to the attorney, ?why you and not me? b/c he?ll prob. [sic] google [sic], see you are an attny [sic], and maybe outta [sic] fear become more temperate in his comments in the future (he?s attacked us 92. Mr. Clohessy also indicated in the email that he knew the ?victim? that the blogger Spoke with. 93. The attorney responded to Mr. Clohessy?s email and stated, am very hesitant to make any statement that could come in play in any case in which I am involved.? The attorney stated further, however, ?Let me run this across [another attorney] to see what he thinks.? -14- SNAP Admits It Refers Survivors To Attorneys Who Donate To SNAP 94. On April 13, 2012, Ms. Blaine sent an email to Mr. Clohessy with a draft of material that Ms. Blaine was thinking of sending to a reporter for a prominent newspaper, who was writing a story about SNAP. 95. In the draft, Ms. Blaine stated, ?How did you ?nd [a prominent victims? attorney]? (told via snap/blame) I trust you are asking ?when? snap referred them to [the prominent attorney]. Also, it made sense for us to tell people about [the prominent attorney] he was the most successful atty [sic] working for victims.? 96. Ms. Blaine also stated in the draft, ?Did [the prominent attorney] ask you to make a donation to (told ?yes?) [the prominent attorney] makes donations to snap and he asks others to do likewise.? II. Plaintiff?s Employment And Discharge At SNAP 97. Plaintiff joined SNAP in July 2011 as director of development. Her main responsibility was to implement and oversee fundraising operations. Exemplary Performance Of Her Employment Obligations 98. Two months after Plaintiff joined SNAP, SNAP visited several locations in Europe to publicize the ?ling of charges for crimes against humanity against the Pope in the International Criminal Court at The Hague. Plaintiff raised some $1 million dollars during and after the European trip for public relations campaign premised on the Pope?s purported crimes against humanity charges. 99. Prior to Plaintiff joining SNAP, SNAP had difficulty managing its unwieldy software platform that it used to keep track of donations. -15- 100. Plaintiff worked extensively to successfully streamline donation-tracking software. 10]. Plaintiff also streamlined donor list that, prior to Plaintiff?s employment at SNAP, was neglected and disorganized. 102. Prior to Plaintiff joining SNAP, the Better Business Bureau had given SNAP a low non?pro?t rating. 103. low rating for SNAP was based partially on a con?ict of interest arising from Ms. Blaine and Mr. Clohessy sitting on board of directors. Because Ms. Blaine and Mr. Clohessy sat on the board of directors, twenty percent of board was occupied by SNAP of?cers. 104. The also based its low rating on a wide range of additional issues regarding how SNAP operated. 105. Plaintiff implemented remedial measures to resolve all of the issues identi?ed with operations (with the sole exception of the con?ict of interest arising from SNAP of?cers sitting on board). 106. As a result of Plaintiff?s efforts, the raised rating. 107. In an August 2012 employee review, SNAP increased Plaintiff?s salary from $60,000 a year to $66,000 a year as a result of Plaintiff?s exemplary performance. Plaintg'? Becomes Concerned About SNAP ?5 Operations 108. Plaintiff ?rst became concerned about operations when SNAP engaged an accounting ?rm to perform internal audit for 201 1. -16- 109. In Plaintiff?s experience working in non-pro?t development, the director of development typically is directly involved with the auditing process. Accordingly, Plaintiff expected to participate in the internal audit for 201 l. 110. However, Plaintiff was excluded entirely ?'om the auditing process, and was not allowed to participate in any aspect of the audit. Plaintiff responsibilities as director of development included writing and submitting grants. To assist with the grant-writing process, Plaintiff sought to attend programmatic operations, such as survivors? meetings, group therapy sessions, and counseling sessions. 112. SNAP refused to allow Plaintiff to attend any of programmatic operations. When Plaintiff asked Ms. Dorris when survivors? meetings were last held, Ms. Dorris responded that she did not know. 113. As part of her fundraising responsibilities, Plaintiff was given access to a list of attorneys who donated regularly to SNAP. 114. leadership ordered Plaintiff to refer to this list of attorneys who donated to SNAP using a moniker, which Plaintiff deemed ?Rose?s list.? leadership further ordered Plaintiff not to reveal to anybody that SNAP received donations ?om attorneys. Plaintiff Discovers And Reports Kickback Scheme To Her Superiors 115. Mr. Clohessy gave SNAP employees?including Plaintiff?the log-in and password for his SNAP email account to assist him in his work. Accordingly, Plaintiff had permissive access to Mr. Clohessy?s SNAP email account. -17- 116. In November 2012, Plaintiff was accidentally cc?d on an email sent by Mr. Clohessy to a prominent attorney who represents survivors in lawsuits against the Catholic Church. 117. In that email, Mr. Clohessy provided information regarding a survivor to the attorney for the purposes of ?ling a lawsuit on behalf of the survivor. 118. Also in that email, Mr. Clohessy asked the attorney when SNAP could expect a donation. 1 19. After reviewing the email, Plaintiff confronted Ms. Blaine in Ms. Blaine?s of?ce, and asked her about the email and whether SNAP was referring potential clients to attorneys in exchange for donations. 120. Plaintiff noted to Ms. Blaine that Plaintiff had explicitly stated to potential donors that SNAP did not engage in kickback schemes. 121. Ms. Blaine told Plaintiff that ?this is nothing,? then abruptly shut the door to her of?ce in Plaintiff face. 122. Plaintiff then called Ms. Dorris to ask about Plaintiff?s suspicions. Plaintiff considered Ms. Dorris as a ?confidant? in which Plaintiff could con?de. 123. However, Ms. Dorris simply told Plaintiff not to worry because Plaintiff was ?doing a great job.? SNAP Retaliates Against Plaintiff" 124. After Plaintiff reported her suspicions to Ms. Blaine and Ms. Dorris, the atmosphere changed at SNAP for Plaintiff. 125. Prior to Plaintiff con?onting Ms. Blaine and Ms. Dorris, Plaintiff operated autonomously in executing her employment obligations. But afterwards, Ms. Blaine suddenly -13- demanded that Plaintiff report to her with respect to every minute detail of Plaintiff?s work activities. 126. For instance, Ms. Blaine. ordered Plaintiff to report to Ms. Blaine daily on Plaintiffs activities. Ms. Blaine also demanded that she be cc?d on every single email Plaintiff sent. 127. Prior to confronting Ms. Blaine and Ms. Dorris, Plaintiff would arrive at of?ces at 7 a.m.?two hours before Ms. Blaine typically arrived at 9 am. 128. After the confrontation, however, Ms. Blaine ordered Plaintiff to arrive at of?ces at 9 am. and leave at 5 pm. so that Plaintiff would never be in the of?ce when Ms. Blaine was absent. 129. At that point, Plaintiff began gathering incriminating documents from SNAP and storing them on a hard drive. 130. As she gathered and downloaded incriminating documents from SNAP, Plaintiff began thinking about how she could expose scheme of accepting kickbacks from attorneys in exchange for client referrals. 131. Plaintiff considered going to the press to expose scheme. 132. SNAP was aware that Plaintiff was gathering documents on an external hard drive that she used to work from home. 133. On information and belief, SNAP believed that Plaintiff was planning on publicly exposing acceptance of kickbacks. 134. On information and belief, SNAP believed that Plaintiff was planning on reporting acceptance of kickbacks to government authorities. -19- 135. Beginning in November 2012, the stress caused by treatment of Plaintiff manifested in health problems, resulting in Plaintiff visiting a hospital four times between November 2012 and January 2013. 136. Plaintiff?s health problems included liver problems, blood pressure, and weight gain resulting from Plaintiff 3 stress and depression. 137. Plaintiff?s stress and depression stemmed from retaliatory actions against her, in spite of Plaintiff?s exemplary performance of her employment obligations. 138. While Plaintiff was on bed rest in February 2013, Ms. Blaine demanded that Plaintiff return all of the copies of the hard drive in Plaintiff?s possession. 139. SNAP also sent a purported volunteer to Plaintiff?s apartment to personally confront her. SNAP retrieved the external hard drive from Plaintiff, but was unaware that Plaintiff had made a duplicate of the external hard drive. SNAP Terminates Plaintz?" 140. Two days after the SNAP volunteer was sent to Plaintiff? apartment to confront her, Ms. Blaine called Plaintiff. 14]. Ms. Blaine asked Plaintiff how she was doing. Plaintiff responded that she was still ill, but was cleared to return to work the following Tuesday. 142. Ms. Blaine told Plaintiff that ?it?s not working out,? and stated that neither Plaintiff nor SNAP was happy. 143. Plaintiff asked Ms. Blaine whether SNAP was laying Plaintiff off. Ms. Blaine did not respond. Plaintiff again asked whether SNAP was ?ring her, and requested that SNAP state in writing that it was terminating her employment. 144. Ms. Blaine told Plaintiff ?good luck,? and hung up the phone. -20- 145. The following day, Plaintiff ?led for unemployment. 146. Plaintiff received three months of unemployment, which SNAP did not resist or challenge. Plaintiff Sustains Damages Resulting From Her Discharge 147. Plaintiff attempted to ?nd a comparable job in fundraising and non-pro?t development. 148. In May 2013, Plaintiff began working as a fundraiser for the Reeling Film Festival for a substantially lower salary than she earned at SNAP. 149. In September 2013, Plaintiff obtained employment with Lambda Publications as a journalist for the Windy City Times. 150. Plaintiff currently earns $24,000 a year in her position at the Windy City Times. 151. The average salary for a chief development of?cer of a non-pro?t organization is between $60,000 a year and $80,000 a year. CLAIMS ALLEGED Retaliatory Discharge 152. Plaintiff repeats the allegations of the preceding paragraphs of this Complaint as though fully alleged herein. 153. Plaintiff was an employee of SNAP from July 20] 1 to February 2013. 154. Plaintiff was discharged from her employment with SNAP in February 2013. 155. Plaintiff?s discharge was in retaliation for, and proximately caused by, Plaintiff?s activities of: reporting acceptance of kickbacks from attorneys to Plaintiff's superiors at and collecting documents in preparation of publicly exposing acceptance of kickbacks from attorneys. -21- 156. Plaintiff?s discharge violated and undermined a clear mandate of public policy arising from failure to comply with the terms of the Internal Revenue Code, 26 U.S.C. 501(c)(3), and regulations promulgated by the Department of the Treasury. 157. Compliance with the terms of the Internal Revenue Code and its regulations strike at the heart of Plaintiff?s social duties and responsibilities. 158. Plaintiff had a good-faith belief that SNAP was violating the law. 159. Plaintiff sustained damages as a result of her discharge in the form of: lost wages during her time of unemployment; and diminished wages resulting from Plaintiff necessary acceptance of lower-paying positions after she was discharged from SNAP. 160. SNAP acted willfully with actual malice, indicating a wanton disregard for the rights of others such that an award of punitive damages is appropriate. JURY DEMAND Plaintiff demands a trial by jury of all claims in this complaint so triable. PRAYER FOR RELIEF WHEREFORE, Plaintiff Gretchen Rachel Hammond prays that this Court: A. Enter judgment in her favor against Defendant Survivors Network Of Those Abused By Priests for all compensatory damages provided by law, plus pre? and post-judgment interest; B. Award Plaintiff her reasonable attorneys? fees and expenses; and C. Grant such other and further relief as this Court deems just and prOper. -22- Dated: January 17, 2017 -23- Respectfully submitted, GRETCHEN RACHEL HAMMOND Mun-?n?: Bruce C. Howard bhoward@siprur.com Richard S. Wilson milson@siprut. com SIPRUT PC 17 North State Street Suite 1600 Chicago, Illinois 60602 Phone: 312.236.0000 Fax: 312.878.1342 Firm ID: 48038 Attorneys or Plaintiff