SUPERIOR COURT FOR THE DISTRICT OF COLUMBIA CIVIL DIVISION CHELSEA J. ANDREWS c/o 11260 Roger Bacon Drive, #201 Reston, Virginia 20190 Plaintiff, V. DISTRICT OF COLUMBIA HOUSING AUTHORITY 1133 North Capitol Street, NE. Washington, D.C. 20002 Serve: Tyrone Garrett, Executive Director/ CEO Office of the General Counsel 1133 North Capitol Street, NE. Washington, D.C. 20002 and TYRONE GARRETT 1133 North Capitol Street, NE. Washington, D.C. 20002 Defendants. Case No. COMPLAINT Filed D.C. Superior Court 07/29/2020 Clerk of the Court Plaintiff Chelsea J. Andrews (?Ms Andrews?), by counsel, hereby moves this Court for Judgment in her favor, and against DISTRICT OF COLUMBIA HOUSING AUTHORITY (DCHA) and TYRONE GARRETT, as Executive Director of DCHA, jointly and severally, and in support thereof, states as follows: SUMMARY OF ARGUMENT A nation can survive its fools, and even the ambitious. But it cannot survive treason from within. An enemy at the gates is less formidable, for he is known and carries his banner openly. But the traitor moves amongst those within the gate freely, his sly whispers rustling through all the alleys, heard in the very halls of government itself. Taylor Caldwell, A Pillar oflron DCHA and Mr. Garrett (as the Executive Director) are responsible for providing and maintaining safe and secure public housing for those D.C. residents and families in need of affordable housing. DCHA maintains housing for the most vulnerable of DC. families many of whom are senior citizens and/or those with pre-eXisting conditions. Director Garrett has failed Washington, DC, the Mayor, the 900 team members who work for DCHA, and the 40,000 residents of DCHA by putting all at risk without conducting the appropriate steps to ensure the safety and health of DC. residents during At the same time, Mr. Garrett terminated Ms. Andrews simply because she was taking all necessary measures to protect the health and safety of the residents and workers of DCHA and at a time when the stakes were literally a matter of life and death, and in the midst of a global health pandemic. D.C. residents living in DCHA housing were the most vulnerable and at the highest risk of exposure to Just two weeks after terminating Ms. Andrews, Mr. Garrett knowing what he had done publicly claimed in a statement: ?The safety and security of all of our residents is of paramount importance to Washington Post, 02 0/ 06/ 09/ 5b2db468-aa69- 1 lea-868b- 93d63cd833b2_story.html. Yet, DCHA and Mr. Garrett had engaged in conduct that would impact D.C. Housing residents in every aspect of their lives and as they sat and slept in their own homes; as well as the DCHA workers (and their families) who were simply carrying out their job duties. Both the residents and the workers had every reason to believe they would be protected from one another through use of protective gear, and speci?cally, masks worn by the workers when entering into the housing units. Mr. Garrett and DCHA were so desperate to silence Ms. Andrews that they pushed her out of DCHA immediately, in breach of her employment contract. Even after Ms. Andrews left the DCHA, Mr. Garrett asked of?cers reporting to him to continue to punish Ms. Andrews by refusing to allow her to continue to work through her notice period, and then refused to pay her during the notice period or for the severance that DCHA was contractually obligated to pay. DCHA even delayed providing Ms. Andrews? required notices regarding the status of her health care and clear information about her health care (or any pay) in the midst of a health pandemic crippling the Washington area in an effort to scare and punish a single-mother it knew was caring for herself and for a school-aged child. NATURE OF ACTION 1. This action is brought under the District of Columbia Whistleblower Protection Act, DC WPA, DC. Code 1-6155, et seq, the DC. Wage Payment and Wage Collection Law DC. Code 32-1301, et seq, and under the common law of the District of Columbia 2. This action states claims for breach of contract. 3. This action also states a claim for negligent supervision/retention of employee, and tortious interference with business expectancies against the individual Defendant, Tyrone Gane?. PARJIES 4. Plaintiff Chelsea J. Andrews Andrews?) worked in Washington, DC. At all times relevant hereto, Ms. Andrews was employed as the Senior Executive Vice President and General Counsel of the DC. Housing Authority, holding the role as the second highest Executive in the Agency. Prior to that, she served as the Deputy Director to the Executive Director, also serving as the second in command for the Agency, with numerous direct reports. Ms. Andrews began her career at DCHA in 2012 as the Associate General Counsel and was successful in serving the Board, the Executive Director and the Staff as evidenced by her consistent promotions based on merit and exceeding the expectations of her position. 5. Defendant District of Columbia Housing Authority or ?the Agency?) is an independent government agency whose mission it is to provide quality affordable housing to extremely low- through moderate-income households, foster sustainable communities, and cultivate opportunities for residents to improve their lives. 6. Defendant Tyrone Garrett Garrett?) is a resident and citizen of the District of Columbia. Since his appointment by the DCHA Board of Commissioners in October 2012, he entrusted Ms. Andrews to oversee major operational departments and critical agency initiatives. Mr. Garrett is, and was at all times relevant hereto, the CEO/Executive Director of DCHA. JURISDICTION AND VENUE 7. The amount in controversy exceeds the jurisdictional minimum amount for this Court. 8. This Court has jurisdiction over Ms. Andrews? claims under the DC. Whistleblower Protection Act, DC. Code 1-615.5, et seq, the DC. Wage Payment and Wage Collection Law, DC. Code 32-1301, et seq, and under the common law of the District of Columbia. 9. DCHA was Ms. Andrews? ?employer? within the meaning of DC. Code 32- 13 01(1). 10. Ms. Andrews was an ?employee? of DCHA within the meaning of DC. Code 1- and DC. Code 11. DCHA is present in and conducts business in the District of Columbia, is an agency of the District of Columbia government, and as such, is subject to the personal jurisdiction of this Court. 12. Mr. Garrett is subject to the personal jurisdiction of this Court pursuant to DC. Code 13-422 and 13-423. 13. Jurisdiction and venue are proper in this Court. BACKGROUND 14. Ms. Andrews began her employment with DCHA in October, 2012, in the position of Associate General Counsel in the Of?ce of the General Counsel. 15. At all times relevant hereto, Ms. Andrews performed her job in an exemplary manner, as evidenced by her steady career progression within DCHA. 16. In October 2014, Ms. Andrews was promoted to Chief Advisor to the General Counsel; to Deputy General Counsel in January 2016; and to Deputy Executive Director and Special Counsel in September 2017. As Deputy Executive Director and Special Counsel reporting to Tyrone Garrett, Executive Director/ CEO of DCHA, Ms. Andrews had nine departments reporting to her, and she created and lead multiple task forces and initiatives. 17. In this position, Ms. Andrews received the Agency?s ?rst ?Game Changer? award for her stellar leadership of the DCHA Environmental and Lead Initiative. 18. Throughout her employment, Ms. Andrews received positive performance reviews (all verbal) from Mr. Garrett, and full bonus payouts. She was proactive about soliciting feedback, and was never criticized, counseled or reprimanded for any performance based issues. 19. Ms. Andrews did, however, receive periodic pushback when she provided her thoughts relating to personnel issues involving Mr. Garrett?s personal friends in particular Larry Williams Williams?) (a close, personal friend of Mr. Garrett and Director of Property Management Operations), and Bandele McQueen McQueen?) (Mr. Garrett?s college roommate and Senior Advisor to the Executive Director). 20. In November 2019, Ms. Andrews received another merit based promotion from Mr. Garrett, and was elevated to the position of Senior Executive Vice President and General Counsel, continuing to report to Mr. Garrett. The terms of employment for Ms. Andrews? new position were set forth in an Employment Contract, effective November 18, 2019. 21. In her new role, Ms. Andrews had several large departments reporting to her (the General Counsel?s Of?ce (including the Risk Team), the Of?ce of Fair Hearing, the Of?ce of Administrative Services, and the Of?ce of and Language Access, and she continued to lead the same task forces and initiatives she had been leading in her prior position. 22. Ms. Andrews also provided business advice and operations advice to DCHA especially regarding COVID related matters. 23. Recently, in response to the worldwide COVID-19 pandemic, Ms. Andrews helped the Of?ce of General Counsel and ADA 504/Language Access divisions in becoming fully remote within two days creating new protocols, obtaining appropriate technology, communication methods, publishing external communication on new policies and developing systems to ensure optimal productivity. 24. Ms. Andrews also lead the Risk Team in the swift development of Health and Safety Protocols, including but not limited to, an agency implemented comprehensive Infection Control Plan, a Respirator Protection Plan and a COVID Risk Assessment, including training of staff. Ms. Andrews proactively introduced a Board Resolution to ensure the ability to conduct agency business remotely, taking into consideration procedural and operational issues, amending the Bylaws and conducting a Special Emergency Board Meeting. 25. On March 31, 2020, in response to the worldwide pandemic and the urgency of purchases needed during the pandemic, the United States Department of Housing and Urban Development issued guidelines related to sole sourcing (116., not requiring a prolonged competitive bid process), and indicated sole sourcing would be permitted if all requirements set forth in the guidelines were met and agencies maintained certain documentation and followed con?ict of interest requirements. 26. Required conditions for sole sourcing set forth in the HUD guidelines included: i) An item is available only from a single source; ii) A public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation; HUD expressly authorizes noncompetitive proposals in response to a written request from a PHA [Public Housing Authority]; or iv) Competition is determined inadequate after solicitation of a number of sources. 27. The HUD guidelines state that must maintain in their ?les, however, a rationale of the single source proposal and cost analysis . . . and, of interest requirements continue to apply in this situation.? 28. N95 is the designation for masks that meet the U.S. standards for respirator masks, meaning the surgical masks that are used to protect the wearer from airborne particles and from liquid contaminating the face. 29. DCHA workers wear N95 masks if they are entering housing units where a resident is likely to be, or con?rmed to be, infected with Workers often move from infected units to non-infected units, as they believe they are protected by the N95 and would not be spreading the transmission of 30. KN95 masks are masks produced in China which comply with the US. standards for N95 respirator masks. The US. National Institute for Occupational Safety and Health requires manufacturers to meet its standards in order to label their masks as N95s (or KN95 31. NIOSH has issued guidelines for detecting counterfeit N95 respirator masks, warning that counterfeit respirators are products that are falsely marketed and sold as being NIOSH-approved and may not be capable of providing appropriate respiratory protection to workers. 32. Easily observable signs that a respirator masks may be counterfeit include: No markings at all on the ?ltering facepiece respirator; No approval (TC) number on filtering facepiece respirator or headband; 0 No NIOSH markings; NIOSH spelled incorrectly; 0 Presence of decorative fabric or other decorative add-ons sequins); 0 Claims for the of approval for children WIOSH does not approve any type of respiratory protection for children); and Filtering facepiece respirator has ear loops instead of headbands. 33. Defective or counterfeit masks would endanger the lives of the DCHA staff using the masks, as well as the residents, employees, families, and building tenants with whom the mask- wearing staff would interact. 34. On April 15, 2020, Ms. Andrews learned that on April 8, 2020, DCHA sole sourced KN95 masks without following proper procurement rules and that the masks were purchased through a referral by Mr. McQueen (Mr. Garrett?s college roommate and Senior Advisor to Mr. Garrett). 35. The invoice was vague and did not reference the purchase of masks. 36. Ms. Andrews requested a photograph of the masks. After making the request, she received a phone call from Mr. Williams, who was upset that she had requested a picture, and defensive about the masks being questioned. 37. That same day, or shortly thereafter, Kyle Clements Clements?), an Industrial Hygienist at DCHA, communicated directly with the CDC and the FDA about the masks. He also contacted Mr. Williams and Harold Brown (the Warehouse Manager) about the masks and was met with a hostile response. Mr. Williams was upset and defensive about the masks being questioned. 38. On Wednesday, April 22, 2020, Mr. Williams sent an email to Ms. Andrews, Bandele McQueen, Kyle Clements and Mary Grace Folwell, attaching what he claimed to be was certi?cation of authenticity of the masks from the FDA, bearing the FDA logo. 39. The next day, Thursday, April 23, 2020, the Risk team learned from an email sent by the FDA that the manufacturer of the masks was not on the list of approved vendors, and even more signi?cant that the FDA did not issue registration certi?cates to medical device establishments meaning that the Certi?cate of Authenticity provided by Mr. Williams was a falsi?ed Government document. Falsi?cation of documents is a crime that violates 18 U.S.C. ?1519 and is punishable by ?ne and up to 20 years of prison. 40. Mr. Williams continued to express his displeasure that the authenticity of the masks was being questioned, and he told Ms. Andrews that he did not appreciate her team contacting the CDC since his own team was already (allegedly) in contact with the CDC. 41. Ms. Andrews also received a phone call from Mr. Garrett during which he admonished that she had ?gone too far with the masks.? 42. On April 30, 2020, after speaking to Ed Kane, Deputy General Counsel, Ms. Andrews called Mr. Williams so they could forge a path forward on the mask issue. Mr. Williams was amenable to the call, and they seemed to be in agreement when the call ended. 43. The next morning, Friday, May 1, 2020, Ms. Andrews, Mr. Williams, Mr. Garrett and Mr. McQueen were scheduled to have a video conference call, but Mr. Garrett did not attend. During the call, Mr. McQueen was extremely upset and angry. He stated that no one had spoken to him about this issue and that the masks were purchased from his personal acquaintance, and that discussions should have been held internally before contacting the FDA. Mr. Williams abruptly left the meeting, expressing frustration as well. 44. Later that day, Ms. Andrews had a phone conference with Lorry Bonds, Vice President of Administrative Services (responsible for the agency?s procurement of goods and 10 services) and Joanne Wallington, Vice President of Audit and Compliance, and briefed them on hostility she was encountering with Mr. Garrett, Mr. Williams and Mr. McQueen. 45. After Ms. Andrews raised her concerns, Mr. Garrett stopped returning Ms. Andrews? messages, canceled meetings with her, and was very curt during any interactions with Ms. Andrews. 46. On or about Wednesday, May 6, 2020, Maryland Governor Larry Hogan held a press conference commending his team for recognizing counterfeit masks and reporting it to the Department of Justice and the United States Attomey?s Office. 47. On Wednesday, May 6, 2020, after watching Governor Hogan?s press conference, Ms. Andrews contacted Ms. Wallington. After the call, Ms. Wallington never responded to Ms. Andrews. 48. During this timeframe, Ms. Andrews held daily managers? meetings and expressed concerns regarding the hostility she was receiving from Tyrone Garrett, Larry Williams and Bandele McQueen. Included on those calls were Mr. Kane (Deputy General Counsel), Andrea Powell (Chief Counsel of Real Estate), David Rosen (Chief of Litigation), and Ms. Folwell (Chief Counsel of Risk and Policy). 49. Ms. Andrews then scheduled a meeting with Ms. Bonds, Ms. Wallington and Ms. Folwell, and on Wednesday, May 13, 2020 and presented a proposed a set of Standard Operating Procedures to be followed on any future orders of KN95s. Ms. Andrews stated that because she was concerned that the roll-out of the proposed guidelines would be contentious, she was seeking their opinions and input. In advance of the meeting, Ms. Andrews sent the proposed SOPs to everyone for review and input. 11 50. Between May 18, 2020 and May 21, 2020, Ms. Andrews followed up on multiple occasions with Ms. Bonds, Ms. Wallington and Kenneth Slaughter (Mr. Slaughter), Senior Vice President and Corporate Counsel, for input on the proposed SOPs. 51. On Thursday, May 21, 2020, at 4:00 pm, Ms. Andrews was abruptly terminated, without cause, effective immediately. Ms. Andrews was completely shocked and taken aback, since she had received absolutely no indication or forewaming that her job was in jeopardy, for any reason. In addition, no reason was given for the ?immediate? urgency of her termination. 52. Ms. Andrews was informed of her termination by former Director of HR, Paulette Campbell, not the Vice President of HR, Natasha Campbell, who was the signatory on Ms. Andrews? termination notice, nor Tyrone Garrett, the Contract Administrator per the Employment Contract. Ms. Campbell had been hired as a Consultant. 53. According to Paulette Campbell, Mr. Garrett contacted her and said that he wanted her ?red immediately. Mr. Garrett asked Ms. Campbell to assist with issuing the termination notice and negotiating severance. 54. Ms. Campbell contacted Ms. Andrews and said that she would be sending the termination notice and severance agreement, and stated that Ms. Andrews should indicate she had resigned. 55. On May 22, 2020, Ms. Andrews received a Memorandum of Termination from Paulette Campbell, signed by Natasha Campbell, indicating that her termination was effective immediately, and that in lieu of the 60 day notice period set forth in her Employment Contract, DCHA would pay Ms. Andrews for the 60 days, in addition to the six months? severance set forth in Mr. Andrews? Contract. 12 56. Pursuant to Article VI, Section A of Ms. Andrews? Employment Contract, Mr. Garrett was the designated ?Contract Administrator? for Ms. Andrews? Employment Contract, and as such, Ms. Andrews? termination notice should have been signed by Mr. Garrett, and not by Natasha Campbell, the Vice President of HR, and then presented by the former Director of HR, Paulette Campbell, simply so they could both shirk their duties and avoid having to face Ms. Andrews and carry out Mr. Garrett?s retaliatory termination. 57. When Ms. Andrews received the severance package which included the terms she was entitled to under her contract in exchange for the termination being classi?ed as a resignation and release of all claims against the agency, Paulette Campbell indicated that Mr. Garrett was ?open to negotiating.? In response, Ms. Andrews told Paulette Campbell about the controversy surrounding the masks, and that she believed her termination was in retaliation for her pursuing the investigation and raising issues related to the masks. 58. Despite Paulette?s Campbell?s instruction to Ms. Andrews to characterize her departure as a resignation, on May 22, 2020, Mr. Garrett announced to the Senior Team that he had decided not to renew Ms. Andrews? contract and that her termination was effective immediately. 59. DCHA unilaterally made the decision to indicate that it would pay Ms. Andrews for the 60 day notice period instead of allowing her to work through the 60 day notice period. By doing so, DCHA deprived Ms. Andrews of other bene?ts she would have accrued while working though the 60 day notice period, including avoiding her sudden removal from the of?ce, and affording her the opportunity to transition matters and leave her of?ce with dignity after eight (8) years of working for DCHA. 60. Additionally, Mr. Garrett deprived the agency of the bene?t of a proper transition from the role of General Counsel, Ethics Of?cer and Risk Of?cer during a worldwide pandemic and 13 put the Agency in greater risk of not having stable, consistent and thorough COVlD-related advice, legal and risk advice and support during a worldwide pandemic. Moreover, there was extreme lack of regard of any pending legal or ethics opinions or investigations that were being handled in con?dence by Ms. Andrews. 61. Mr. Garrett told others that he had concerns that Ms. Andrews may ?whistle blow? about the illegal and unethical procurement of the counterfeit masks. 62. DCHA had no legitimate business reason or justification for Ms. Andrews? immediate termination, for refusing to allow her to work out the 60 day notice period provided in her contract, or for not allowing her to properly transition her duties, say goodbye to her staff, address her professional obligations on multiple Boards and Committees in various industry-wide associations WAHRO, CLPHA and HAIG) and provide a mutually agreed upon message to her team regarding her departure. Ms. Andrews was not fired for ?cause? and posed no threat or danger of property or other damages to DCHA. 63. DCHA terminated Ms. Andrews in the midst of a worldwide pandemic, at time DCHA knew would be dif?cult for Ms. Andrews to obtain another (yet alone, a comparable) position with the nation facing its highest unemployment rate in history. 64. On the day she was terminated, Ms. Andrews spoke to Neil Albert, the DCHA Board Chair, who expressed surprise to learn of her termination and the fact that DCHA had not allowed for a proper transition of her duties. Ms. Andrews told Mr. Albert she believed her termination was in retaliation for her questioning the authenticity of the improperly procured masks, and for bringing light to the many breaches of policy and protocol surrounding the masks. l4 65. Pursuant to Article V, Section 1 of Ms. Andrews? Employment Contract: ?The DCHA may terminate this Contract and the Employee's employment at any time with or without cause; provided that, if the DCHA terminates the Contract without cause, the DCHA shall provide the Employee with no less than sixty (60) days written notice.? 66. By terminating Ms. Andrews? employment, ?effective immediately,? DCHA breached the terms of Ms. Andrews? Employment Agreement by failing to provide Ms. Andrews with the ?no less than sixty (60) days written notice? as required by the Agreement. 67. After Ms. Andrews noti?ed DCHA of her claims, DCHA refused to provide her a COBRA notice or a clear answer regarding when her health care would end, in order to retaliate against her. DCHA further retaliated by stopping Ms. Andrews? pay without notice and refusing to pay the 60 day notice period and six months of severance as promised to her in her contract and termination notice. 68. Knowing she was a single mother, DCHA hoped it could create a ?nancial hardship on Ms. Andrews, in terms of her bene?ts and promised pay, and intentionally impose extreme distress related to medical insurance coverage for Ms. Andrews and her minor child during a health pandemic, in order to try to silence her regarding her claims. In fact, DCHA stated it would only provide pay for annual leave and retirement contributions she would have received during the 60 day notice period if she agreed to drop all of her claims against Mr. Garrett. 69. In further retaliation, even though departing employees were often allowed to pick up their belongings after termination, DCHA refused for two months to allow Ms. Andrews to retrieve her personal belonging. At the time of refusal, it was well aware that Ms. Andrews had several religious and personal items at work that were irreplaceable. 15 70. In June 2020, after Mr. Garrett had terminated Ms. Andrews, he made the following statement as reported by the Washington Post: ?The safety and security of all of our residents is of paramount importance to Washington Post, 202 0/ 06/ 09/ 5b2 db468-aa69-l lea- 71. Yet, DCHA had engaged in far more egregious conduct that would impact D.C. Housing residents as they sat and slept in their own homes, as well as the DCHA workers (and their families) who were simply carrying out their job duties. Both the residents and the workers had every reason to believe they would be protected from one another through use of protective gear, and speci?cally, masks that were worn by the workers when entering into their units. It was known the masks would be used in units where there were suspected coronavirus cases and that the workers would also then move on to service units with no cases. COUNT ONE RETALIATION (TERMINATION) IN VIOLATION OF THE DISTRICT OF COLUMBIA WHISTLEBLOWER PROTECTION ACT, D.C. CODE 6 1-6155, et sea. (against District of Columbia Housing Authority) 72. The foregoing allegations are incorporated as if realleged herein. 73. The District of Columbia Whistleblower Protection Act, DC. Code Ann. 1- 615.51 et seq, prohibits the District of Columbia and its agencies, including the DCHA, from taking a prohibited personnel action, including termination, or otherwise retaliating against a District of Columbia employee because of the employee?s protected disclosures made to any person, including but not limited to a supervisor or other agency, that the employee reasonably believes evidences gross mismanagement, gross misuse or waste of public resources or funds, 16 abuse of authority in connection with the administration of a public program, or a violation of a federal, state, or local law, rule, or regulation. 74. For employees in the public sector, such as Ms. Andrews, a ?protected disclosure? includes, among other things, any disclosure of information not speci?cally prohibited by statute, by any employee to a supervisor or a public body that the employee reasonably believes evidences a substantial and speci?c danger to the public health, safety, or protection of the environment. 75. Ms. Andrews was an employee of the District of Columbia, and as such, held the rights guaranteed by the District of Columbia Whistleblower Protection Act to freely express her opinions on all public issues and to engage in protected disclosures as de?ned by the DC WPA. 76. Ms. Andrews? right to engage in protected disclosures and speak publicly on matters of public concern was clearly established under relevant law at all times relevant to this Complaint. 77. Ms. Andrews indicated her intent to engage in protected disclosures under the District of Columbia Whistleblower Protection Act (1) even while meeting resistance and opposition from Mr. Williams, and her supervisor, Mr. Garrett. 78. After Ms. Andrews discovered that DCHA had sole sourced KN95 masks without following proper procurement rules, without maintaining proper documentation, without following con?ict of interest requirements. Ms. Andrews? team discerned from a photograph (requested by Ms. Andrews, to the dismay of Mr. Williams) that the masks had ?ear loops,? which was an indication that the masks were not compliant with US. KN95 standards. 17 79. Mr. Williams continued to object and express his displeasure to Ms. Andrews about her team?s attempts to verify the authenticity of the masks, and whether they met the US. ?lter standards for classi?cation as KN95 masks. 80. As Ms. Andrews and her team continued to press forward, she was met with increasing opposition by Mr. Williams, Mr. McQueen and Mr. Garrett, who told Ms. Andrews that she had ?gone too far? with investigating the masks. 81. Mr. Williams even provided what he claimed to be a certi?cation of authenticity from the FDA, bearing the FDA logo. However, Ms. Andrews and her team learned, from an email sent by the FDA, that the manufacturer of the masks was not on the list of approved vendors, and even more signi?cant that the FDA did not issue registration certi?cates to medical device establishments meaning that the Certi?cate of Authenticity provided by Mr. Williams was fake. 82. Due to the resistance and hostility Ms. Andrews was facing from Mr. Williams and Mr. Garrett over her team?s investigation of the masks, and fearing retaliation while possessing the very real and reasonable belief that the counterfeit masks posed a substantial and speci?c danger to public health and safety during the pandemic, Ms. Andrews sought guidance and advice from Mr. Kane (Deputy General Counsel), Ms. Bonds (Director of Administrative Services) and Ms. Wallington (Director of Audit Compliance) on how to deal with Mr. Williams and Mr. Garrett concerning the masks, and to voice her fear of retaliation. 83. Shortly thereafter, Ms. Andrews was abruptly terminated, without cause, effective immediately. Ms. Andrews? termination was not performance based, and there was no justi?cation for her immediate termination and for not affording her the 60 days written notice as provided for in her Employment Contract. 18 84. DCHA, and in particular, Mr. Williams and Mr. Garrett, wanted Ms. Andrews removed immediately so that she could no longer pursue the investigation into the illegally procured counterfeit masks, and so she would be unable to access her DCHA computer, which contained communications and documentation of the investigation, which she would need to report and prove the illegal procurement of the counterfeit masks. 85. Ms. Andrews? investigation and intent to make protected disclosures about the counterfeit masks, which posed a substantial and specific danger to public safety, led to retaliation against her the termination of her employment. 86. The adverse action taken against Ms. Andrews was undoubtfully retaliatory and entirely unjustified and unwarranted by her performance and track record at DCHA. 87. DCHA and Tyrone Garrett?s retaliatory intent is evidenced by the fact that the abrupt ?same-day? termination of the agency?s General Counsel and Risk Officer, the role responsible for providing guidance and protecting the agency in the midst of an extreme health and safety crisis and global pandemic, was completely unwarranted and created signi?cant negative exposure and implications for DCHA operations, its staff and residents. 88. Defendant?s retaliation against Ms. Andrews has stopped her career advancement with DCHA, and in general, and has led to economic damages, loss of bene?ts, signi?cant emotional distress and public and professional humiliation and has resulted in professional reputational damages that will follow her throughout her career. 89. By retaliating against Ms. Andrews, Defendant exhibited an extreme reckless disregard of, and callous indifference to, her rights under the DC. Whistleblower Protection Act. Defendant?s actions described above were in willful and wanton disregard of plaintiff?s rights, and taken in order speci?cally to injure her for her disclosures of illegal actions. 19 90. Ms. Andrews suffered harm as a result of retaliatory termination, including loss of advancement and career opportunities and the attendant employment bene?ts. 91. As a direct and proximate result of actions, Ms. Andrews has suffered and continues to suffer injury, physical and emotional distress, pain, suffering, inconvenience, embarrassment, mental anguish, anxiety, depression, insomnia, loss of enjoyment of life, past and future loss of income and benefits of employment, lost career and business opportunities and advancement, other past pecuniary losses, future pecuniary losses, and other nonpecuniary losses. 92. Pursuant to the DC WPA, Ms. Andrews is entitled to injunctive relief, reinstatement, restoration of lost bene?ts, back pay for lost wages, bonus pay, compensatory damages, and litigation costs including attomey?s fees. COUNT TWO- BREACH OF CONTRACT (EMPLOYMENT CONTRACT) (against District of Columbia Housing Authority) 93. The allegations of the foregoing paragraphs are incorporated in this count as if they were repeated here in full. 94. The Employment Contract between Ms. Andrews and DCHA sets forth the terms of Ms. Andrews? employment as Senior Executive Vice President and General Counsel of DCHA. 95. The Employment Contract constitutes a contract between Ms. Andrews and DCHA. 96. The Employment Contract was signed by Tyrone Garrett, President and CEO of DCHA, and Mr. Garrett was designated by the Contract as the Contract Administrator. 20 97. Pursuant to Article V, Section 1 of Ms. Andrews? Employment Contract: ?The DCHA may terminate this Contract and the Employee's employment at any time with or without cause; provided that, if the DCHA terminates the Contract without cause, the DCHA shall provide the Employee with no less than sixty (60) days written notice.? 98. Pursuant to Article V, Section 3 of Ms. Andrews? Employment Contract: If this Contract is terminated or not renewed by the DCHA for any lawful reason other than for grossly negligent, willful, intentional, or criminal conduct, or any other conduct which could adversely affect the DCHA, or its mission, the Employee shall receive a severance payment equal to six (6) months of Employee's then current salary. 99. By terminating Ms. Andrews? employment, ?effective immediately,? DCHA breached the terms of Ms. Andrews? Employment Contract by failing to provide Ms. Andrews with the ?no less than sixty (60) days written notice? as required by the Agreement, and by indicating its intent to pay (and then refusing to pay) Ms. Andrews for the 60 day notice period rather than allowing her to work through the 60 day notice period, which also deprived Ms. Andrews of other benefits that would have accrued during that time, including but not limited to, and Trust Account benefits, accrued annual and sick leave, bonus pay, life insurance coverage, medical and dental insurance coverage. 100. DCHA further breached the terms of Ms. Andrews? Employment Contract by refusing to pay Ms. Andrews the six month severance to which she is entitled under the contract. 101. As a direct and proximate result of the breaches by DCHA, Ms. Andrews has suffered and continues to suffer damages including the speci?c amounts due as set forth above, loss of use of income; loss of opportunities and bene?ts; and other past and future pecuniary losses. 21 COUNT THREE VIOLATION OF THE D.C. WAGE PAYMENT AND WAGE COLLECTION LAW (D.C. CODE 32-1301, et seq.) 102. The allegations of the foregoing paragraphs are incorporated as if realleged herein. 103. By terminating Ms. Andrews? employment, ?effective immediately? and failing to provide Ms. Andrews with the ?sixty (60) days written notice,? refusing to allow her to work through the 60 day notice period and failing to pay Ms. Andrews for the 60 day notice period (unless she dropped her claims against Mr. Garrett), and by failing to pay Ms. Andrews the siX months severance to which she is entitled and had earned pursuant to her Employment Contract, DCHA is in violation of the DC. Wage Payment and Wage Collection Law. 104. Ms. Andrews is entitled to injunctive relief prohibiting DCHA from interfering with her notice pay, severance payment and health benefits. 105. As such, Ms. Andrews is entitled to payment for the 60 day notice period and six months? severance, plus quadruple/ statutory damages, attorney?s fees and costs, and appropriate injunctive relief COUNT FOUR NEGLIGENT OF EMPLOYEE (TYRONE GARRETT) (Against District of Columbia Housing Authority) 106. The allegations of the foregoing paragraphs are incorporated in this count as if rc- alleged here in full. 107. DCHA had a duty to its employees, including Ms. Andrews, not to retain employees whom it knew or should have known were likely to harm its employees and/or to violate laws designed to protect the public. 22 108. DCHA had, or should have had, actual and constructive knowledge that Mr. Garrett had a personal animus against Ms. Andrews, who had reported the purchase of potentially counterfeit KN95 masks, which involved Mr. Williams and Mr. McQueen personal friends of Mr. Garrett. 109. After Ms. Andrews started questioning the source and authenticity masks, and the manner in which they were purchased, Mr. Garrett started acting in a hostile manner towards her, including not attending a briefing to discuss the illegal purchase, failing to call and/or return calls to Ms. Andrews, canceling meetings with Ms. Andrews, and overall acting in a curt and hostile manner towards Ms. Andrews when he was forced to interact with her. 110. Ms. Andrews reported Mr. Garrett?s conduct to Mr. Kane (Deputy General Counsel), Andrea Powell (Chief Counsel of Real Estate), David Rosen (Chief of Litigation), and Ms. Folwell (Chief Counsel of Risk and Policy). 111. Despite this knowledge, DCHA retained Mr. Garrett in a position of superiority and supervisory authority over Ms. Andrews, and retained him in his position, which he used to terminate Ms. Andrews immediately, without cause to do so, and eliminate her job security and livelihood. 112. DCHA retained Mr. Garrett in a position in which he could, and did, use his position to protect his friends, to threaten and harm, Ms. Andrews, and to terminate Ms. Andrews in order to stop her from further questioning the illegal, sole source purchase of the counterfeit KN95 masks. Mr. Garrett even eliminated Ms. Andrews? 60 day notice period as provided for in her Employment Contract, not allowing her to work through the 60 days, in order to remove her from the workplace immediately and cut off her access to her DCHA computer, so that she could not pursue the investigation further. 23 113. In fact, DCHA, after becoming aware of the conduct of Mr. Garrett, continued to retain Mr. Garrett as a supervisory employee in a position to direct and in?uence Ms. Andrews? employment, severance, and other decisions effecting Ms. Andrews? employment, which he did, to her detriment. 114. In addition, DCHA made clear its knowledge of Mr. Garrett?s animus towards Ms. Andrews, and its intent to protect Mr. Garrett in the fact of his animus against her, by refusing to provide Ms. Andrews the 60 days promised pay unless she agreed to drop all of her claims against Mr. Garrett. 115. DCHA was negligent in supervising and retaining Mr. Garrett after it learned, or should have learned, the he was engaging in these behaviors. 116. Had DCHA and properly removed Mr. Garrett from the workplace, he would not have had the opportunity to continue to engage in this conduct, or to harm Ms. Andrews. 117. This conduct by Defendant was actuated by malice, spite, and ill will; was willful and wanton; and evinced conscious disregard for the rights of Ms. Andrews. 118. Ms. Andrews suffered harm as a result of negligent supervision and retention of Mr. Garrett, including loss of advancement and career opportunities and the attendant employment bene?ts. 119. retention of Mr. Garrett, in the face of knowledge of his illegal conduct, constituted gross negligence and evinced a conscious disregard for the rights of Ms. Andrews. 120. retention of Mr. Garrett as an employee, and its failure to protect Ms. Andrews from Mr. Garrett, was willful and wanton in that it exhibited a conscious disregard for the rights of Ms. Andrews, and the general public at large. DCHA was aware of the propensity 24 of Mr. Garrett to engage in illegal conduct that would harm Ms. Andrews and the public, including ignoring and covering up Ms. Andrews? serious and very real concerns that counterfeit masks posed a substantial and speci?c danger to public health and safety during the pandemic. 121. DCHA exhibited a reckless indifference in its failure to protect Ms. Andrews, and the public or anyone who came in contact with, was issued, or believed themselves to be protected by genuine KN95 masks, by retaining Mr. Garrett. DCHA was aware from the existing circumstances that its failure to act to protect Ms. Andrews (by terminating Mr. Garrett and discontinuing his illegal conduct and/or by removing Mr. Garrett from a position of supervision over Ms. Andrews), and by acting upon Ms. Andrews? reports of the counterfeit masks, would likely result in harm to Ms. Andrews and the general public. Mr. Garrett exhibited a reckless disregard for the US. standards for N95 respirator masks which requires manufacturers to meet its standards in order to label their masks as N95s or KN95s, and therefore, a reckless and shocking disregard for the health and well being of the general public, health care workers, or anyone thinking they were properly protected by KN95 masks meeting the US. standards. 122. DCHA ratified and condoned the conduct of Mr. Garrett by refusing to take any action to prevent him from taking further action against Ms. Andrews, and by leaving him in Ms. Andrews? chain of command and continuing to allow him to be in a position of authority over her, and terminating her without cause to do so. 123. DCHA is further responsible for the actions of Mr. Garrett because, as he was acting in the scope of his employment, and with the express authority over Ms. Andrews that was granted to him as agent. 25 124. As a direct and proximate result of actions and failures to act, Ms. Andrews has suffered and continue to suffer emotional distress, mental anguish, medical expenses, past and future loss of income and bene?ts of employment, lost career and business opportunities and advancement, other past pecuniary losses, future pecuniary losses, and other non-pecuniary losses. 125. Due to the character and severity of conduct, Ms. Andrews is entitled to punitive damages. COUNT FIVE - TORTIOUS INTERFERENCE WITH BUSINESS EXPECTANCY (against Tyrone Garrett) 126. The foregoing allegations are incorporated as if realleged herein. 127. Ms. Andrews was enjoying a promising career at DCHA, as evidenced by her performance and commitment to her ob. 128. During all times relevant hereto, Ms. Andrews performed her job duties in an exemplary manner. 129. As part of Ms. Andrews? employment with DCHA, Ms. Andrews possessed a business expectancy with DCHA of continued employment, compensation, performance bonuses, bene?ts and contract renewal. 130. The retaliatory actions taken by Mr. Garrett against Ms. Andrews were taken to prevent Ms. Andrews from continuing to pursue the investigation into the illegally procured counterfeit KN95 masks, and to prevent her from ?blowing the whistle? about the masks, which would implicate Mr. Williams and Mr. Garrett, since Mr. Williams spearheaded the improper and illegal purchase of the masks, violating DCHA policies and procedures Garrett supported and condoned the action and attempted to halt Ms. Andrews? investigation by telling her she and her team had ?gone too far? in investigating the masks. 131. These actions taken by Mr. Garrett were intentional, and evinced ill will, recklessness, and willful disregard of Ms. Andrews? rights, as well as wantonness, oppressiveness, maliciousness, and a spirit of mischief, and did not further any legitimate business interest of DCHA. 132. Mr. Garrett employed improper methods including, but not limited to terminating Ms. Andrews? employment when he became concerned that she might ?whistle blow? about the masks, even though there was no cause for her termination, and telling Ms. Andrews that she would be paid for the 60 day notice period, rather than allowing her to work out the 60 day notice period and properly transition her duties, so that Ms. Andrews would no longer have access to her DCHA computer and the information she had compiled regarding the masks, including the fake FDA certi?cate of authentication presented by Mr. Williams in an attempt to cover up his actions, and overall treating Ms. Andrews in a hostile manner and differently from the manner in which he treated other employees who had not reported, or threatened to report, the illegal conduct. 133. But for the improper interference of Mr. Garrett, Ms. Andrews would continue to realize the business expectancies as set forth in this Complaint. 134. As a direct and proximate result of the actions of Mr. Garrett, Ms. Andrews has suffered and will suffer in the future great damages, including loss of retirement bene?ts, loss of income, loss of employment bene?ts, lost career and business opportunities and advancement, litigation expenses including attorneys? fees, other past pecuniary losses, emotional pain, 27 embarrassment, humiliation, inconvenience, severe mental anguish, stress, pain, suffering, loss of enjoyment of life and other nonpecuniary injury. 135. Due to the severity of Mr. Garrett?s conduct, Ms. Andrews is also entitled to punitive damages. PRAYER FOR RELIEF WHEREFORE, Plaintiff CHELSEA ANDREWS requests that this Court enter judgment in her favor, against the Defendants, DISTRICT OF COLUMBIA HOUSING AUTHORITY and TYRONE GARRETT, jointly and severally, on the above Counts; and further: (C) (6) Award Ms. Andrews compensatory damages to be determined by a jury, and in no event to exceed Twelve Million Dollars ($12 million), plus demonstrated past and future pecuniary damages on each of the above-stated Counts One through Five (including pre-judgment interest); and in addition Award Ms. Andrews reinstatement of her position, back pay, interest on the back pay, and compensation for any damages sustained because of the retaliation on Count One; Award Ms. Andrews quadruple damages on Count Three; and in addition Award Ms. Andrews punitive and exemplary damages, to be determined by a jury on Counts One and Two through Five; and in addition Award Ms. Andrews an injunction prohibiting DCHA from further engaging in the illegal practices that have deprived Ms. Andrews of her pay and bene?ts; and in addition 28 Award Ms. Andrews reinstatement, including reinstatement of her employee seniority status and attendant rights and bene?ts, and restoration of her lost bene?ts; and in addition Award Ms. Andrews attorneys? fees and costs, and such other and further relief as may be appropriate under the circumstances. JURY DEMAND PLAINTIFF CHELSEA J. ANDREWS DEMANDS A TRIAL BY JURY. July 29, 2020 Respectfully submitted, CARLA D. BROWN Carla D. Brown, D.C. Bar No. 474097 CHARLSON BREDEHOFT COHEN BROWN, P.C. 11260 Roger Bacon Drive, Suite 201 Reston, VA 20190 (703) 318-6800 Telephone (703) 318-6808 Facsimile Counsel for Plaintiff Chelsea J. Andrews 29 Superior Court of the District of Columbia CIVIL DIVISION Civil Actions Branch 500 Indiana Avenue, N.W., Suite 5000 Washington, D.C. 20001 Telephone: (202) 879-1133 Website: Plaintiff VS. Case Number DISTRICT OF COLUMBIA HOUSING Defendant SUMMONS To the above named Defendant: You are hereby summoned and required to serve an Answer to the attached Complaint, either personally or through an attorney, within twenty one (21) days after service of this summons upon you, exclusive of the day of service. If you are being sued as an officer or agency of the United States Government or the District of Columbia Government, you have sixty (60) days after service of this summons to serve your Answer. A copy of the Answer must be mailed to the attorney for the plaintiff who is suing you. The attorney?s name and address appear below. If plaintiff has no attorney, a copy of the Answer must be mailed to the plaintiff at the address stated on this Summons. You are also required to file the original Answer with the Court in Suite 5000 at 500 Indiana Avenue, N.W., between 8:30 am. and 5:00 Mondays through Fridays or between 9:00 am. and 12:00 noon on Saturdays. You may file the original Answer with the Court either before you serve a copy of the Answer on the plaintiff or within seven (7) days after you have served the plaintiff. If you fail to file an Answer, judgment by default may be entered against you for the relief demanded in the complaint. {cl-3151a 1), Clerk offhe Court Name of Plaintiff?s Attorney IIZBO Roger Bacon Dr., By Address Deputy Clerk Reston, VA 20190 Date Telephone (202) 8?9?4828 Veuillez appeler au (202) 8794828 pour une traduction co mot bat dich, hay gel (202) 879-4828 sites-g gatat?mozmramz?sgnatwg mace any? aerate (202) 879-4828 exam IMPORTANT: IF YOU FAIL TO FILE AN WITHIN THE TIME STATED ABOVE, OR IF, AFTER YOU ANSWER, YOU FAIL TO APPEAR AT ANY TIME THE COURT NOTIFIES YOU TO DO SO, A JUDGMENT BY DEFAULT MAY BE ENTERED AGAINST YOU FOR THE MONEY DAMAGES OR OTHER RELIEF DEMANDED IN THE COMPLAINT. IF THIS OCCURS, YOUR WAGES MAY BE ATTACHED OR OR PERSONAL PROPERTY OR REAL ESTATE YOU OWN MAY BE TAKEN AND SOLD TO PAY THE JUDGMENT. IF YOU INTEND TO OPPOSE THIS ACTION, DO .NOTFAIL TO ANSWER WI HLN THE REQUIRED TIME. If you wish to talk to a lawyer and feel that you cannot afford to pay a fee to a lawyer, contact one of the of?ces of the Legal Aid Society (202-628-1161) or the Neighborhood Legal Services (202-279-5100) for help or come to Suite 5000 at 500 Indiana Avenue, N.W., for more information concerning places where you may ask for such help. See reverse side for Spanish translation Vea al dorso la traduccion a1 espa?ol ll)- [Rev June 2017] Super. Ct. Civ. :1 TRIBUNAL SUPERIOR DEL DISTRITO DE COLUMBIA DIVISION CIVIL 888811111 118 Acciones CiViIes 500 Indiana Avenue, N.W., Suite 5000, Washington, D.C. 20001 Tel?fono: (202) 879-1133 Sitio web: Demandante contra Numero dc Caso: Demandado CITATORIO Al susodicho Demandado: Por la presente se le cita a comparecer se le require entregar una Contestacion a la Demanda. adjunta, sea en persona por medio de un abogado, en el plazo de veintiun (21) dias contados despu?s que uStedhaya recibido este citatorio, excluyendo el dia mismo de la entrega del citatorio. Si usted esta siendo demandado en 'calidad de o?cial agente del Gobierno de los Estados Unidos de Norteam?rica 0 del Gobierno del 'Distrito de'Columbia, tiene usted sesenta (60) d1as,contados despu?s que usted haya rec1b1do este citatorio para entregar su Contestacion.T1ene que enviarle por correo una copia de su Contestaci?n al abogado de la parte demandante. El nombre direccion del abogado aparecen al ?nal de este documento S1 el demandado no tiene abogado tiene que enViarle al demandante una copia de la Contestaci?n p01 correo a la direccion que aparece en este Citatorio A usted tambi?n se le require presentar la Contestacion o1igi11a-1 a1 Tribunal en la O?cina 5000 sito en 500 Indiana Avenue, N. W., entre las 8: 30 a 5:00 p. m. de lunes a Viernes entre las del mediodia los sabados. Usted puede presentar la Contestaci?ri original ante. el Juez ya sea antes que usted le entregue al demandante una copia de la ontestacion 0 en el plazo de siete (7) (1188 de haberle hecho la entrega a1 demandante. Si usted incumple con presentar una Contestaci?n,pod11a dictarse un fallo en rebeldia contra usted para que se haga efectivo el desagrav10 que se busca en la demanda - - SECRETARIO DEL TRIBUNAL Nombre del abogado del Demandante Por: Direcci?n 1' Subsecretario Fecha Tel?fono . yn??a? Veuillez appelerau (202)879?4828 pour une traduction 118 C0 111818.111 111811, hay goi (202)878-4828 4828i?1?m 12101121 111:1er were (202)879-4828 mm IMPORTANTE: SI USTED INCUMPLE CON PRESENTAR UNA CONTESTACION EN EL PLAZO ANTES MENCIONADO 0, SI LUEGO DE CONTESTAR, USTED NO COMPARECE CUANDO LE AVISE EL JUZGADO, PODRIA DICTARSE UN FALLO EN REBELDIA CONTRA USTED PARA QUE SE LE COBRE LOS DANOS PERJUICIOS OTRO DESAGRAVIO QUE SE BUSQUE EN LA DEMANDA. SI ESTO OCURRE, PODRIA RETENERSELE SUS INGRESOS, PODRIA TOMARSELE SUS BIENES PERSONALES BIENES RAICES SER VENDIDOS PARA PAGAR EL FALLO. SI USTED PRETENDE OPONERSE A ESTA ACCION, N0 DEJE DE CONTESTAR LA DENTRO DEL PLAZO EXIGIDO. Si desea conversar con un abogado le parece que no puede pagarle a uno, llame pronto a una de nuestras o?cinas del Legal Aid Society (202-628-1161) 0 e1 Neighborhood Legal Services (202-279-5100) para pedir ayuda venga a la O?oina 5000 del 500 Indiana Avenue, para informarse sobre otros lugares donde puede pedirayuda a1 respecto. Vea a1 dorso 81 original en ingl?s See reverse side for English original 10 [Rev June 2017] Super. CL Civ. R. 4 Superior Court of the District of Columbia CIVIL DIVISION Civil Actions Branch 500 Indiana Avenue, N.W., Suite 5000 Washington, D.C. 20001 Telephone: (202) 879-1133 Website: Plaintiff VS. Case Number Defendant SUMMONS To the above named Defendant: You are hereby summoned and required to serve an Answer to the attached Complaint, either personally or through an attorney, within twenty one (21) days after service of this summons upon you, exclusive of the day of service. If you are being sued as an officer or agency of the United States Government or the District of Columbia Government, you have sixty (60) days after service of this summons to serve your Answer. A copy of the Answer must be mailed to the attorney for the plaintiff who is suing you. The attorney?s name and address appear below. If plaintiff has no attorney, a copy of the Answer must be mailed to the plaintiff at the address stated on this Summons. You are also required to file the original Answer with the Court in Suite 5000 at 500 Indiana Avenue, N.W., between 8:30 am. and 5:00 Mondays through Fridays or between 9:00 am. and 12:00 noon on Saturdays. You may file the original Answer with the Court either before you serve a copy of the Answer on the plaintiff or within seven (7) days after you have served the plaintiff. If you fail to file an Answer, judgment by default may be entered against you for the relief demanded in the complaint. Carla 1), Clerk offhe Court Name of Plaintiff?s Attorney 11260 Roger Bacon Dr., #qu By Address Deputy Clerk Reston, VA 20190 (?03)3l8m6800 Dm Telephone (202) 8?9?4828 Veuillez appeler au (202) 8794828 pour une traduction co mot bat dich, hay gel (202) 879-4828 sites-g mace any? aerate (202) 879-4828 exam IMPORTANT: IF YOU FAIL TO FILE AN WITHIN THE TIME STATED ABOVE, OR IF, AFTER YOU ANSWER, YOU FAIL TO APPEAR AT ANY TIME THE COURT NOTIFIES YOU TO DO SO, A JUDGMENT BY DEFAULT MAY BE ENTERED AGAINST YOU FOR THE MONEY DAMAGES OR OTHER RELIEF DEMANDED IN THE COMPLAINT. IF THIS OCCURS, YOUR WAGES MAY BE ATTACHED OR OR PERSONAL PROPERTY OR REAL ESTATE YOU OWN MAY BE TAKEN AND SOLD TO PAY THE JUDGMENT. IF YOU INTEND TO OPPOSE THIS ACTION, DO .NOTFAIL TO ANSWER WI HLN THE REQUIRED TIME. If you wish to talk to a lawyer and feel that you cannot afford to pay a fee to a lawyer, contact one of the of?ces of the Legal Aid Society (202-628-1161) or the Neighborhood Legal Services (202-279-5100) for help or come to Suite 5000 at 500 Indiana Avenue, N.W., for more information concerning places where you may ask for such help. See reverse side for Spanish translation Vea al dorso la traduccion a1 espa?ol ll)- [Rev June 2017] Super. Ct. Civ. :1 TRIBUNAL SUPERIOR DEL DISTRITO DE COLUMBIA DIVISION CIVIL 888811111 118 Acciones CiViIes 500 Indiana Avenue, N.W., Suite 5000, Washington, D.C. 20001 Tel?fono: (202) 879-1133 Sitio web: Demandante contra Numero dc Caso: Demandado CITATORIO Al susodicho Demandado: Por la presente se le cita a comparecer se le require entregar una Contestacion a la Demanda. adjunta, sea en persona por medio de un abogado, en el plazo de veintiun (21) dias contados despu?s que uStedhaya recibido este citatorio, excluyendo el dia mismo de la entrega del citatorio. Si usted esta siendo demandado en 'calidad de o?cial agente del Gobierno de los Estados Unidos de Norteam?rica 0 del Gobierno del 'Distrito de'Columbia, tiene usted sesenta (60) d1as,contados despu?s que usted haya rec1b1do este citatorio para entregar su Contestacion.T1ene que enviarle por correo una copia de su Contestaci?n al abogado de la parte demandante. El nombre direccion del abogado aparecen al ?nal de este documento S1 el demandado no tiene abogado tiene que enViarle al demandante una copia de la Contestaci?n p01 correo a la direccion que aparece en este Citatorio A usted tambi?n se le require presentar la Contestacion o1igi11a-1 a1 Tribunal en la O?cina 5000 sito en 500 Indiana Avenue, N. W., entre las 8: 30 a 5:00 p. m. de lunes a Viernes entre las del mediodia los sabados. Usted puede presentar la Contestaci?ri original ante. el Juez ya sea antes que usted le entregue al demandante una copia de la ontestacion 0 en el plazo de siete (7) (1188 de haberle hecho la entrega a1 demandante. Si usted incumple con presentar una Contestaci?n,pod11a dictarse un fallo en rebeldia contra usted para que se haga efectivo el desagrav10 que se busca en la demanda - - SECRETARIO DEL TRIBUNAL Nombre del abogado del Demandante Por: Direcci?n 1' Subsecretario Fecha Tel?fono . yn??a? Veuillez appelerau (202)879?4828 pour une traduction 118 C0 111818.111 111811, hay goi (202)878-4828 4828i?1?m 12101121 111:1er were (202)879-4828 mm IMPORTANTE: SI USTED INCUMPLE CON PRESENTAR UNA CONTESTACION EN EL PLAZO ANTES MENCIONADO 0, SI LUEGO DE CONTESTAR, USTED NO COMPARECE CUANDO LE AVISE EL JUZGADO, PODRIA DICTARSE UN FALLO EN REBELDIA CONTRA USTED PARA QUE SE LE COBRE LOS DANOS PERJUICIOS OTRO DESAGRAVIO QUE SE BUSQUE EN LA DEMANDA. SI ESTO OCURRE, PODRIA RETENERSELE SUS INGRESOS, PODRIA TOMARSELE SUS BIENES PERSONALES BIENES RAICES SER VENDIDOS PARA PAGAR EL FALLO. SI USTED PRETENDE OPONERSE A ESTA ACCION, N0 DEJE DE CONTESTAR LA DENTRO DEL PLAZO EXIGIDO. Si desea conversar con un abogado le parece que no puede pagarle a uno, llame pronto a una de nuestras o?cinas del Legal Aid Society (202-628-1161) 0 e1 Neighborhood Legal Services (202-279-5100) para pedir ayuda venga a la O?oina 5000 del 500 Indiana Avenue, para informarse sobre otros lugares donde puede pedirayuda a1 respecto. Vea a1 dorso 81 original en ingl?s See reverse side for English original 10 [Rev June 2017] Super. CL Civ. R. 4 Superior Court of the District of Columbia CIVIL DIVISION- CIVIL ACTIONS BRANCH INFORMATION SHEET CHELSEA J. ANDREWS Case Number: vs DISTRICT OF COLUMBIA HOUSING AUTHORITY Date: JULY 29> 2020 and TYRONE GARRETT One of the defendants is being sued in their of?cial capacity. Name: (Please Print) CARLA D, BROWN Firm Name: CHARLSON BREDEHOFT COHEN BROWN, PC Relationship to Lawsuit Attorney for Plaintiff El Self (Pro Se) Telephone No.: Six digit Uni?ed Bar No.: (703) 318-6800 474097 Other: TYPE OF CASE: El Non-Jury 6 Person Jury El 12 Person Jury Demand: $12 Million Other: PENDING RELATED TO THE ACTION BEING FILED Case No.: Judge: Calendar Case No.2 Judge: Ca1endar#: NATURE OF SUIT: (Check One Box Only) A. CONTRACTS COLLECTION CASES El 01 Breach of Contract El 14 Under $25,000 Pltf. Grants Consent El 16 Under $25,000 Consent Denied 02 Breach of Warranty 17 OVER $25,000 Pltf. Grants Consentl:l 18 OVER $25,000 Consent Denied El 06 Negotiable Instrument 27 Insurance/Subrogation El 26 Insurance/Subrogation 07 Personal Property Over $25,000 Pltf. Grants Consent Over $25,000 Consent Denied 13 Employment Discrimination 07 Insurance/Subrogation El 34 Insurance/Subrogation El 15 Special Education Fees Under $25,000 Pltf. Grants Consent Under $25,000 Consent Denied El 28 Motion to Con?rm Arbitration Award (Collection Cases Only) B. PROPERTY TORTS El 02 Conversion El 04 Property Damage 07 Shoplifting, DC. Code 27-102 El 01 Automobile El 03 Destruction of Private Property El 05 Trespass C. PERSONAL TORTS El 01 Abuse of Process 10 Invasion of Privacy 02 Alienation of Affection El 11 Libel and Slander 03 Assault and Battery El 12 Malicious Interference El 04 Automobile- Personal Injury El 13 Malicious Prosecution 05 Deceit (Misrepresentation) 14 Malpractice Legal El 07 False Arrest 16 Negligence- (Not Automobile, 08 Fraud Not Malpractice) Personal Injury? (N ot Automobile, Not Malpractice) 18Wrongful Death (Not Malpractice) El 19 Wrongful Eviction 20 Friendly Suit 06 False Accusation Malpractice Medical (Including Wrongful Death) El 21 Asbestos El 22 Toxic/Mass Torts 23 Tobacco 24 Lead Paint SEE REVERSE SIDE AND CHECK HERE IF USED CV?496/June 2015 Information Sheet, Continued C. OTHERS El 01 Accounting El 17 Merit Personnel Act (OEA) El 02 Att. Before Judgment (DC. Code Title 1, Chapter 6) 05 Ejectment 18 Product Liability El 09 Special Writ/Warrants (DC Code 11-941) 24 Application to Con?rm, Modify, El 10 Traf?c Adjudication Vacate Arbitration Award (DC Code 16-4401) El 11 Writ of Replevin 1:1 29 Merit Personnel Act (OHR) El 12 Enforce Mechanics Lien 1:1 31 Housing Code Regulations El 16 Declaratory Judgment El 32 Qui Tam 33 Whistleblower 11. 1:1 03 Change of Name 1:1 15 Libel of Information 1:1 21 Petition for Subpoena El 06 Foreign Judgment/Domestic El 19 Enter Administrative Order as [Rule 28-1 1:1 08 Foreign Judgment/International Judgment DC. Code 1:1 22 Release Mechanics Lien 13 Correction of Birth Certi?cate 2-1802.03 or 32-151 9 El 23 Rule 27(a)(1) 14 Correction of Marriage 1:1 20 Master Meter (DC. Code (Perpetuate Testimony) Certi?cate 42-3301, et seq.) 1:1 24 Petition for Structured Settlement El 26 Petition for Civil Asset Forfeiture (Vehicle) El 25 Petition for Liquidation 27 Petition for Civil Asset Forfeiture (Currency) 1:1 28 Petition for Civil Asset Forfeiture (Other) D. REAL PROPERTY El 09 Real Property-Real Estate El 08 Quiet Title 12 Speci?c Performance 1:1 25 Liens: Tax Water Consent Granted 04 Condemnation (Eminent Domain) 1:1 30 Liens: Tax Water Consent Denied 10 Mortgage Foreclosure/Judicial Sale 1:1 31 Lien Bid Off Certi?cate Consent Granted 11 Petition for Civil Asset Forfeiture (RP) CARLA D. BROWN 07/29/2020 Attorney?s Signature Date June 2015