CIVIL DISTRICT COURT FOR THE PARISH OF ORLEANS . STATE OF LOUISIANA it t- 35 D1 181 - DOCKET NO: A CIVIL I.- BRIAN GIBSON ?1 VERSUS NEW BEGINNINGS SCHOOLS FOUNDATION AND RUNELL J. KING FILED: DEPUTY CLERK PETITION FOR DAMAGES EMOTIONAL DISTRESS NOW INTO COURT, through undersigned counsel, comes plaintiff, Brian Gibson, a person of the full age of majority and domiciled in the Parish of Orleans, State of Louisiana, who respectfully asserts as follows: I. Made defendants herein are: 1. New Beginnings Schools Foundation, (herein after NBSF), is a non-pro?t corporation registered in, and authorized to do, and doing business in the State of Louisiana, Parish of Orleans 2. Runell J. King, a person believed tO be of the full age Of majority and domiciled in the State of Louisiana, Parish of East Baton Rouge. II. On or about May 24, 2019 Plaintiff Brian Gibson, while serving as Principal of John F. Kennedy High School at Lake Area received correspondence from Michael L. Washington, Director Of Human Resources for NB SF, terminating his employment with New Beginnings Schools oundation (attached exhibit 1). Principal Gibson?s school assignment with NBSF began on July 9, 2018 extending until the end Of the NBSF 2018- 2019 academic calendar school year (attached exhibit 2 Offer letter). During said term Principal Gibson was to receive total compensation from NB SF in the cash amount of one hundred eighteen thousand run-1 administration leader. Principal Gibson has received many awards and accolades for his performances in those various jobs. 111. Pursuant to employee handbook Principal Gibson performed all duties incumbent upon him faithfully and efficiently. Additionally, Principal Gibson abided by all of the laws of the State'of Louisiana, rules and regulations of the State Board of Elementary and Secondary Education, State Department of Education, New Beginnings Schools Foundation Board, New Beginnings Schools CEO. IV. On or about February 1, 2019 defendant, Runell King orchestrated and alleged an improper/inaccurate grade adjustment scheme at John F. Kennedy High School at Lake Area. Carelessly, recklessly and in bad faith implicating Principal Gibson and the leadership team prior to proper due diligence or proper investigation. At all times material herein defendants NB SF and King knew or had reason to know that Principal Gibson had no knowledge or role whether actual or attributable to any alleged improper grade adjustments. V. Defendant King?s allegations caused NBSF and Orleans Parish School Board to Launch two (2) separate investigations into said allegations of improper conduct. Both investigations were concluded with no findings to substantiate King?s baseless allegations. In fact, King was disciplined by NBSF for failure to provide accurate or truthful data to support his allegation of improper grade adjustments. X. WHEREFORE, plaintiff prays that the Petition for Damages for Emotional Distress be ?led, that defendants, NEW BEGINNINGS SCHOOLS FOUNDATION AND RUNELL J. KING be duly cited and served with a certi?ed copy of same, and that after due proceedings are had herein that there be judgment in favor of plaintiff and. against defendants, jointly, severally, and in solido for any and all damages sustained by plaintiff, Brian Gibson, with legal interest, from the date of judicial demand and for all attorney?s fees and costs of these proceedings. Plaintiffs further prays for all general and equitable relief to include compensatory and consequential damages. Respectfully submitted by: THE LAW OFFICES OF KENYA JAMAR ROUNDS, LLC KENYA JAMAR OUND a 27871) 2475 Canal Stre' Suite 0 - New Orleans, LA 70119 Telephone: (504) 821-7999 Facsimile: (504) 821-7995 PLEASE SERVE: New Beginnings Schools Foundation Through their agent of Service: Raphael Gang, Finance Department 5800 St. Roch Avenue, New Orleans, Louisiana 70122 Runell J. King Through his attorney of record Madison C. Pitre Scott, Vicknair, Hair Checki, LLC 909 Poydras Street, Suite 1100 New Orleans, Louisiana 70112 Or wherever he may be found ., CIVIL DISTRICT COURT FOR THE PARISH OF ORLEANS g? ED STATE OF LOUISIANA NO. DIVISION DOCKET NO: a M, Cii?ii BRIAN GIBSON eggs? VERSUS NEW BEGINNINGS SCHOOLS FOUNDATION AND RUNELL J. KING FILED: DEPUTY CLERK STATE OF LOUISIANA PARISH OF ORLEANS BEFORE ME, the undersigned Notary Public, personally came and appeared: BRIAN GIBSON Who, being duly deposed and sworn, stated that the foregoing allegations of fact are true and correct to the best Of his knowledge, information and belief. ?ab/A, BRIAN AND SUBSCRIBED BEFORE ME, THIS DAY OF r, 2020. NOTAEI 7T KENYA JAMAH ROUNDS NOTARY PUBLIC #66740 State of Louisiana My Commission is issued for life 2018 2019 Offer Letter Dear Brian Gibson: On behalf of New Beginnings Schools Foundation we are excited to extend you an offer for a position at New Beginnings Schools Foundation (?New Beginnings" or beginning on July 9. 2018 for the 2018 2019 school year and ending on the speci?ed date listed on the jet SQOI 9 NBSF Academic (iatendg according to your months of employment. Our offer is based on the following terms and condit ions nicluding the salary listed below: School Assiginnent at. Base Salary Total Years of Teaching Experience Certi?cate 3018-2019 position offered 3 Effective Date of Certi?cate Expiration Date Assignment The above?mentioned salary is payable in equal installments over a 12-month period. paid on the 15?]1 and last day of each month. You will receive payment only for services rendered. You mayr also receive paid time off. Please refer to your Employee Hand book for more information. All compensation provided to you by NBSF shall be subject to applicable payroll taxes and withholdings in accordance with federal. state, and local law. Further. you will be eligible to participate in New Beginnings? benefit plans as they are established or amended from time to time. as well as health. dental- and vision benefits. Your signatm?e on this offer doennient confirms that you are aware and accept that all duties incumbent upon you must be peiformed faithfully and ef?ciently. Additionally. your signature acknowledges your awareness of the requirement to observe and abide by the law-s of the State of Louisiana, rules and regulations of the State Board of Elementary and Secondary Education. State Department of Education. New Beginnings Schools Foundation Board. New Beginnings Schools CEO, and the Principal of me assigned school, provided such rules and regulations are within the role of these authorities. In your capacity. you will work closely with key members of the team including the teachers, school leader. assistant principal and the entire New Beginnings" staff. Employment with New Beginnings is tat?will and not for a speci?ed term. This means that the CEO or her designee may remove a teacher for any reason includ ing a violation of Federal, State and local laws or the policies. procedures. rules and regulations of the New Beginnings Schools Foundation in the manner provided by law. Further. this means that Ne Beginnings can terminate employment at any time and an employee can terminate employment with New Begimungs at any time. Any contrary representations or agreements that may have been made to you are superseded by this Offer. Any modi?cation or alteration of the at-will nature of your employment can be made only in writing signed by the Chief Executive O?icer and you. Upon the completion of employment with the for any reason. you understand that you are required to return all New Beginnings property obtained during your employment, including but not limited to. ?les. business plans and forecasts, ?nancial information. tangible property including. but not limited to, computers. credit cards. entry cards. identification badges and keys] and any materials of any kind that contain or embody any proprietaryor con?dential information of the School and all reproductions thereof. This offer is contingent upon your providing New Beginnings with a background check with the legally required proof of your identity and authorization to work in the United States. It is understood am agreed that you will perform the duties assigned to you to the best of your ability and will abide by the rules and regulations of the Louisiana Board of Elementary and Secondary Education. and as may be determined {or hereafter adopted} by the School andi?or the SchoolLeader, Please affirm your acceptance of tins offer by signing below. Acceptance of this offer does not change the atvwill nature of your employment, It is also, by no means. a guarantee of employment. Should a signi?cant change oceur. such as, but not limited to. a change in eru'ollment, the NBSF School Principal will ad ust its staff accordingly. We are honored to welcome you to TEAM NBSF for the 2018?20l9 school year. and We look forward to Working with you. Respecrfully. 71 -922; by if; ?fl-131:0 5 Michelle Bloom-Williams . accept this offer ofemployment With New Begiimings Foundation for the. 2018 - 2-019 school year. May 24' 2019 Ce ed Ma'land/orEmail Brlan Gibson 70056 Dear Ml: Glbson' As you are aware. NBSF leadership requesled an inresrrgatlon into several alleganons made against John Kennedy School at lake Area. Those allegations rneluded, hul were nol limited my the allegation of improper/inaccurate grade adjustments. During ille 11 became clear illal you engaged in actlvules ihal violated your dunes in the and violated school policies and procedures as it relates Io grading and grade adjustments, Accordingly, effeclivc May 24, 2019, you are lerrninared from your employmenl with New Beginnings Schools Foundation. Your l'rnal paycheck be provided in Ihe delays allowed by law Thai paycheck will lnclude nny and all amounrs due in you per NBSF policy. Yuur llcallh insurance coverage will be erreelive until May 31, 2019' ifyou have elected caverage. Please be advrsed that you and your eligible may continue pamcipaliun in the organization's group medical and plans through (he Consolidated Omnibus Budgel Reconciliation Act (COBRA). Plense coniaet Human Resourees for more You should also receive inronnation in the marl regarding your coverage. Please note. there are deadlines 10 up! inlo Cobra coverage Immediate review and acceptance nfyour Cobra herrefirs will ensure that you retain your elrgioility Additionally. you are required lo relum all of the school's propefly dorained during your employmenl including, bu| nol lo, properly (which includes cornpulers. rdentificauon badges and keys) and any materials of any kind lhal or embody any proprlelary or confidential informalion oflhe New Schools Foundaliun and/or JFK High School a! Lake Area. "ems are be lumed in lo Mlchacl Washington, the Direcior ofHuman Resources or no later than llre close of business, Tuesday May 23, 2019. WW Michael L. M. A of Human Resources 05' Employee mam,- unaware new . MEDAFUN IA :u 1r, H11: mum 7 VIww.NasFNolArcoM