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Statement of Facts (cont.)

51. When PLAINTIFF returned, PLAINTIFF was prevented from re-joining the Rampart Task Force. Instead, he was returned to RHD, which is the division he was loaned from to the task force.

52. PLAINTIFF was specifically placed behind a desk in the Bank Robbery division. Bored, unchallenged, and feeling `left out to dry', PLAINTIFF requested a transfer to his original unit, the Southbureau Homicide.

53. PLAINTIFF still felt uneasy, ostracized, unconfident, unproductive, that he was being prevented from doing his job, embarrassed. As a result he suffered severe emotional distress, anxiety, and sleeplessness.

54. PLAINTIFF used up a couple of months of sick time under stress leave in order to recuperate.

55. Due to the above, he felt that things would be unlikely to change.

56. In October 1999, PLAINTIFF resigned citing his problems with the department. PLAINTIFF later heard reckless rumors spread in the department, that he resigned prior to DEFENDANT CITY firing him. PLAINTIFF knows this is is not true since his exit paperwork indicated that he was subject to rehire.

57. PLAINTIFF at all times relevant herein alleged, performed all his job duties in a satisfactory manner and received satisfactory or better evaluations and commendations.

Injuries to Plaintiff

58. As a result of the conduct of the Defendants as stated above, plaintiff has suffered and will continue to lose promotional opportunities, severe emotional distress, humiliation, anxiety, sleeplessness, lost wages, employment benefits and loss of sick time.

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