Case 5:25-cv-00739-HNJ Document 1 Filed 05/12/25 Page 1 of 115 FILED

2025 May-12 PM 04:24

U.S. DISTRICT COURT
N.D. OF ALABAMA
IN THE UNITED STATES DISTRICT COURT
FOR NORTHERN DISTRICT OF ALABAMA
NORTHEASTERN DIVISION
KATRINA BRADY, )
)
Plaintiff, )
) Case No.:
vs. )
) JURY DEMAND
CITY OF HUNTSVILLE, ALABAMA, )
KIRK GILES, MICHAEL JOHNSON, )
)
Defendants. )

COMPLAINT

COMES NOW the Plaintiff, Katrina Brady, in the above-styled case, by and

through her undersigned attorney, and files and serves this Complaint against Defendants

City of Huntsville, Alabama, Kirk Giles and Michael Johnson.

INTRODUCTION

This case seeks to redress the harm caused to Plaintiff Brady by Defendant's

violations of federal employment law perpetrated against Plaintiff. Regarding Defendant

City of Huntsville, Alabama, the laws violated include of Title VII of the Civil Rights

Act of 1964, 42 U.S.C. § 2000e, et seq, amended by the Civil Rights Act of 1991

(hereinafter “Title VII"), based on Plaintiff’s sex (female); based on Plaintiff's race,

(Black), and for retaliation perpetrated against Plaintiff after she participated in acts

protected by Title VII and opposed workplace discrimination. Additionally, Defendant

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City of Huntsville violated the Pregnant Workers Fairness Act (42 U.S.C. § 2000gg, et

seq.), and the Providing Urgent Maternal Protections for Nursing Mothers Act for

Nursing Mothers Act of 2023, or “PUMP Act,” (29 U.S.C. § 201, 218d), which requires

covered employers to provide reasonable break time and private space (other than a

bathroom), to express breast milk for a nursing child for 1 year after the child’s birth.

This Complaint also alleges Huntsville Police Chief Kirk Giles and Deputy Police Chief

Michael Johnson violated 42 U.S.C. § 1985(2), which prohibits two or more persons to

conspire to impede, hinder, obstruct, or defeat, the due course of justice when they, Giles

and Johnson, conspired to deny to Plaintiff equal protection of the laws, and/or when

they deprived her of and/or injured her property right (her employment) and impeded

and obstructed her equal protection under the law.

JURISDICTION AND VENUE

1. Jurisdiction of this Court is invoked pursuant to 28 U.S.C.A. §§ 1331 and

1343: Plaintiff brings this action under the laws of the United States; the District Court

has original jurisdiction over this case under § 1331; Plaintiff seeks to recover damages

and to secure equitable relief under one or more Acts of Congress providing for the

protection of civil rights. See § 1343.

2. Venue is proper as the Northern District of Alabama is the judicial district in

which a substantial part of the events or omissions giving rise to Plaintiff’s claims, as

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described below, occurred. See, 28 U.S.C.A. § 1391.

3. Defendant City of Huntsville, a public sector employer, employs fifteen (15) or

more people and is situated in the Northern District of Alabama. Defendants Kirk Giles

and Michael Johnson, both sued in their individual capacities, violated 42 U.S.C. §

1985(2), and both reside in, and the alleged events and unlawful conduct giving rise to

the claims occurred in, this district and division.

4. Plaintiff filed her original Charge of Discrimination with the Equal

Employment Opportunity Commission's (EEOC's) Birmingham, Alabama, District

Office on or around February 26, 2024, then a second EEOC Charge on December 19,

2024 (along with supplements to her December 19, 2024, Charge, filed on January 7,

January 14, and January 27, 2025). Upon Plaintiff's request, the U.S. Department of

Justice issued Notices of Right to Sue, or “Right to Sue” letters to Plaintiff: On her first

Charge, on February 14, and on her second Charge, on February 26, 2025. Copies of

Plaintiff's two (2) Right to Sue letters are attached hereto as Exhibits A and B.

5. Plaintiff files this Complaint within ninety (90) days after receiving her two (2)

Right to Sue letters.

PARTIES
6. Plaintiff Katrina Brady (“Plaintiff,” or “Katrina Brady”) is an adult over the

age of nineteen (19) years of age who resides in Madison County, Alabama.

7. Defendant City of Huntsville, Alabama (“Defendant Huntsville,” or “City”), is a

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municipality incorporated under the laws of the State of Alabama and is situated in

Madison County, Alabama.

8. Defendant Kirk Giles (“Defendant Giles,” “Giles” or “Chief Giles”) is an adult

over the age of nineteen (19) years of age who resides in Madison County, Alabama,

and/or whose herein described acts and omissions perpetrated against Plaintiff occurred

in Madison County, Alabama, which is situated in the Northern District of Alabama.

9. Defendant Michael Johnson (“Defendant Johnson,” “Johnson,” or “Deputy

Chief Johnson,” is an adult over the age of nineteen (19) years of age who resides in

Madison County, Alabama, and/or whose herein described acts and omissions

perpetrated against Plaintiff occurred in Madison, County, Alabama, which is situated in

the Northern District of Alabama.

10. At all times relevant to the events, acts and omissions described herein,

Huntsville Police Department [“HPD”] Police Chief Kirk Giles, Deputy Chief Michael

Johnson, Lt. Michael Danley, Sgt Dana (a male) Springfield, Byron Thomas, as well as

any / all HPD Command Staff, HPD decision-makers, all other HPD police officers

(both named and unnamed), City Human Resources (“HR”) employees, and HPD

Dispatch staff referred to herein, acted within the line, course and scope of their

employment with Defendant Huntsville, with their respective supervisors' approval (or

post-facto ratification), under color of law, in both their official and personal capacities.

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STATEMENT OF FACTS
Plaintiff Katrina Brady

11. Defendant Huntsville hired Plaintiff in or around September 2016, and

employed her as a dispatcher with the Huntsville Police Department (hereafter HPD) for

more than eight (8) years, until the last week of November 2024, when the City

transferred Plaintiff out of HPD Dispatch to a records office.

12. On January 8, 2025, the City fired Plaintiff.

13. Plaintiff is a woman.

14. Plaintiff is Black.

Plaintiff's 2023 Pregnancy

15. Plaintiff became pregnant in or around January 2023.

16. Plaintiff's husband, Officer Michael Brady, is a veteran member of the

Huntsville Police Department.

17. In or around June, 2023, Plaintiff notified her immediate supervisor, Ms.

Amanda Traulsen, and HPD Dispatch Sergeant Dana (a man) Springfield, that she was

expecting.

18. In or around mid-August 2023 Plaintiff's Nurse Practitioner at the Alabama

Women's Wellness Center met with and examined Plaintiff.

19. On or about August 18, 2023, and owing to her pregnancy, Plaintiff submitted

a Request for Reasonable Accommodation to the City's HR Department, including a

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letter of the same date from the Alabama Women's Wellness Center regarding reasonable

accommodations needed at the workplace for Plaintiff during her pregnancy.

20. Based on the advice of the Alabama Women's Wellness Center, Plaintiff's

August 2023 request for reasonable pregnancy accommodation (made to the City

through its HR Department) included “breaks every 2 to 4 hours” or “10 minutes to

hydrate/use the bathroom; no extended hours of work past 40 hours/week; or no more

than 8 hours per day.”

21. On or around September 1, 2023, the City's HR Department granted Plaintiff's

request for reasonable accommodation and her immediate supervisor, Ms. Traulsen,

notifying Plaintiff of this on September 1, 2023.

22. Within a few days of the City's HR Department granting Plaintiff the

reasonable accommodation, Lieutenant Michael Danley, in the HPD Dispatch chain of

command, overruled HR and retaliated against Plaintiff, changing her regular days off –

which she had already taken into account for scheduling OBGYN appointments; and, by

doing so, caused Plaintiff undue hardship, stress, anxiety and humiliation.

23. Lt. Danley did not tell Plaintiff her reasonable accommodation requested

would be an undue burden on the City, but, rather, that HPD Dispatch had “manpower”

and “scheduling” issues such that her regular days off would be changed.

24. In fact, to whatever extent there were “manpower” or “scheduling” issues

during the summer and autumn of 2023, HPD Dispatch had staff – full-time and part-

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time dispatchers – capable of meeting its scheduling needs even with the reasonable

accommodation Plaintiff requested.

25. The reasonable accommodation sought would have neither been significantly

difficult nor expensive for the City to grant.

26. In or around early September 2023, Plaintiff and her husband, Officer Brady,

met with various members of the HPD, and a junior staff member of HR, and the City's

“Equal Employment Opportunity” officer, at City Hall and requested reconsideration of

the denial of the reasonable accommodations sought, but their requests fell on deaf ears:

HPD Deputy Chief Michael Johnson and Lt. Michael Danley prohibited Plaintiff from

maintaining her permanent off days and forced to work an alternative schedule and was

threatened by Deputy Chief Johnson not to ever change her doctor's appointments, with

a vague, but intimidating, “Or else!” (or threatening words to that effect) added by

Johnson.

27. At the aforementioned early September 2023 meeting Plaintiff and her

husband, Officer Michael Brady, they also alleged the City and/or persons above

Plaintiff in her HPD Dispatch chain of command were retaliating against her for

requesting pregnancy-related reasonable accommodations. This allegation constituted

opposition to workplace discrimination and a protected activity. The allegation was

ignored and no investigation of the allegation ever occurred.

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28. During or around this time, Lt. Danley told Plaintiff: “I know how pregnancy

works,” and that her appointments with her OBGYN could be re-scheduled to

accommodate HPD Dispatch's scheduling and that she would “not need long” at any

OBGYN appointment.

29. Lt. Danley is not, in fact, a midwife, obstetrician or medical doctor.

30. Around this time Sgt. Springfield told Plaintiff she should stay home and take

care of her baby – in other words, quit – because at the time Plaintiff and her husband

both worked night shift and in order for Plaintiff to return to work she would need

another accommodation to work on day shift.

31. Sgt. Springfield also told Plaintiff her marriage was horrible and wouldn't

work because Plaintiff and her husband would eventually be working opposite shifts.

32. Plaintiff suffered physical, emotional and economic impacts arising out of Lt.

Danley's, and the City's reversal of the reasonable accommodations previously granted

by the City for Plaintiff's pregnancy.

33. Physically, Plaintiff suffered early labor due to stress proximately caused and

connected to workplace pregnancy discrimination by City and HPD-manufactured

hardships described herein and perpetrated by Defendant City from in or around August

through early October 2023, with her baby girl's due date being October 24, 2023, but

Plaintiff giving birth on October 7, 2023.

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34. Up through the birth of her baby daughter during the first week of October

2023, Plaintiff suffered stress, depression, sleepless nights proximately caused and

connected to the workplace pregnancy discrimination by City and HPD-manufactured

hardships described herein perpetrated by Defendant City from in or around August

through early October 2023.

35. Economically, Plaintiff had time saved up for her maternity leave and all her

doctor's appointments were scheduled for her off days. When the City, through Lt.

Danley, changed her off days, she had use personal time (PTO) to attend those

appointments. Plaintiff also had to request time from other coworkers in City to help

cover her maternity leave, which was also stressful and humiliating. Her leave time was

less than what she had planned on due to this change in off days.

36. Beyond its face value, the money lost was significant for Plaintiff because she

had worked hard for it; the loss was more about the City's intentional creation of

hardships for Plaintiff – for example, having to re-request time off, re-arrange her

doctor's appointments, and the like, while working HPD Dispatch and look after her and

her unborn baby's health.

37. Plaintiff took maternity / Family Medical Leave Act leave, beginning October

10, 2023, but this was earlier than she had wanted to begin her leave. She started early

due to the stress on her emotionally and physically. She lost income, too, owing to her

needing to take maternity leave early.

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38. During or around August 2023 Plaintiff spoke with City HR Analyst II Dylan

Yarbrough (“Yarbrough”), asking him for a copy of her employment file.

39. In or around September 2023 Yarbrough gave Plaintiff a copy of her

employment file.

40. When Plaintiff reviewed the file Yarbrough gave her, she noticed at least five

(5) documents were missing from her personnel file: 2022 and 2023 letters of support

and/or which corroborated that HPD perpetrated disciplinary “double standards” against

Plaintiff; letters Plaintiff had personally given to Chief Giles for both his edification and

her personnel file, to make a record.

41. The missing personnel file letters included a 2022 letter from HPD dispatcher

Sheryl Sief, who is Caucasian, which Plaintiff personally handed to Chief Giles that

included Ms. Sief observing:

Mrs. Brady has proven time and time again that she's just as capable as any
of her coworkers. . . Unfortunately, I've seen her face more adversity than
most of us. . . We've made pleas to fix [HPD Dispatch] issues[,] whether it
is equipment or individuals[,] to no avail. . . [HPD Dispatchers, including
Katrina Brady] should not have to deal with negativity or unfair treatment
because of biases that exist for reasons I'd hate to imagine.

42. The missing personnel file letters included a 2022 letter from HPD dispatcher

James McFarlen, who is Caucasian, which Plaintiff hand-delivered to Chief Giles, which

included Mr. McFarlen observing:

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While I cannot speak directly for some of the issues that impact [some
dispatchers], such as the ones involving race [which] they may experience
that I do not[,] I can say without a doubt that there is a culture of favoritism
within dispatch and certain employees are treated better than others. . .
[T]he department can make sure each and every employee at dispatch feels
[they are] treated fairly, with the respect they deserve for completing a
difficult job. . . .

43. The missing personnel file letters included a 2023 letter from HPD dispatcher

Rosalee Martin, which Plaintiff hand-delivered to Chief Giles, after a supervisor accused

Plaintiff of “yelling” during work, that included Ms. Martin observing:

I have seen Katrina to be what I can only describe as targeted by this [HPD
Dispatch] department. . . The things I have seen her getting called on the
carpet for are things all humans do in dispatch... make mistakes. (Emphasis
added).

44. Ms. Martin's 2023 letter also included the observation that she heard a

supervisor “telling people throughout the [Dispatch] center” that this supervisor “would

do whatever she could to contribute to Katrina losing her job;” “Katrina and myself have

been brought to tears over the comments and overall hostile environment that has

blossomed at dispatch;” and that Ms. Martin fears the department will lose “one of the

best dispatchers here.”

45. The missing personnel file letters included a 2023 letter from HPD dispatcher

and designee (occasional Dispatch supervisor) Matthew Dravecky, a letter Plaintiff hand

delivered to Chief Giles.

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46. Like Ms. Martin, Mr. Dravecky saw Plaintiff on the receiving end of “targeted

harassment” and noted this in his 2023 letter which Plaintiff gave to Chief Giles.

47. Mr. Dravecky's 2023 letter also included his observations that Plaintiff

“continues to dedicate herself to the department and its police officers in the face of

adverse conditions.”

Plaintiff Returns to Work February 2024 – Sgt Springfield Harasses Plaintiff

48. After delivering her baby daughter, Plaintiff returned to work at HPD

Dispatch on or around February 19, 2024.

49. On February 26, 2024, Plaintiff filed an EEOC Charge of Discrimination, in

sum alleging the City's refusal to accommodate her requests for reasonable pregnancy-

related accommodations in violation of the Pregnant Workers Fairness Act, race

discrimination (for City violations of Title VII going back to 2021, and retaliation, both

for protected activities in opposing race discrimination in employment and for requesting

reasonable, pregnancy-related accommodation in the workplace.

50. At work Plaintiff needed to pump breast milk several times a day for her

infant daughter.

51. Sgt. Dana (a male) Springfield gave Plaintiff permission to use his office to

pump breast milk for about two (2) weeks, between her February 19 return and March 5,

2024, saying it was “no trouble” or words to that effect.

52. On March 5, 2024, moments after Plaintiff used Sgt. Springfield's office to

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pump and as Plaintiff was walking back to a break room, Sgt. Springfield confronted her,

called her back into his office, and proceeded to yell at and berate Plaintiff for pumping

breast milk in his office.

53. Plaintiff was so upset that – in the middle of Sgt. Springfield's strange tirade –

she called her husband, HPD Officer Michael Brady, on her cell phone for his moral and

emotional support.

54. Plaintiff tried to make Sgt. Springfield understand, inter alia, that he had

previously given her permission to pump in his office, that the law required employers

(such as the City) to provide places for nursing mothers to pump breast milk, but Sgt.

Springfield was unmoved.

55. Plaintiff later found out that the City's HR Department had received her

EEOC that same day, and that it was reasonable that her HPD Chain of Command,

including Sgt. Springfield, were aware of her EEOC Charge when he berated her for

pumping breast milk.

56. In the alternative, when the City received Plaintiff's EEOC Charge on March

5, 2024, it declined to notify Sgt. Springfield and Lt. Danley of its receipt of the Charge,

the fact that both Springfield and Danley were named in the Charge in association with

Plaintiff's accusations of pregnancy (gender) and race discrimination.

57. On or around March 5, 6 and 12, 2024, Plaintiff submitted several internal

complaints to the City and its HR Department which generally described and notified the

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City about Sgt. Springfield's March 5, 2024, harassment and discrimination perpetrated

against Plaintiff.

58. Plaintiff submitted her March 5, 2024, internal complaint to HPD's Internal

Affairs Department.

59. Plaintiff's March 5, 2024, internal complaint included, but was not limited to,

her accusing Sgt. Springfield of yelling at her for pumping breast milk; not providing her

a place to pump breast milk; and, when upset at Springfield's “repeated yelling” and her

needing to step away, Springfield refusing to allow Plaintiff to leave.

60. As only women can produce breast milk for their nursing babies, Plaintiff's

March 5, 2024, internal complaint was, by definition, a complaint of gender

discrimination.

61. On March 6, 2024, Plaintiff emailed the City HR Department HR Analyst

Yarbrough about “Workplace Harassment,” requesting Yarbrough provide Plaintiff with

“exactly what steps” she needed to take in order to make a complaint of harassment in

the workplace.

62. HR Analyst Yarbrough's response to Plaintiff's March 6, 2024, email said, in

pertinent part, that (a) he would notify the City's HR Director, Byron Thomas and the

City's “EEO Officer; and, (b) “Someone from the Human Resources office will reach out

to you soon to schedule a meeting.”

63. In fact, no one from the City's Human Resources office “reached out” or

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otherwise contacted Plaintiff to schedule a meeting in the wake of Plaintiff's March 6,

2024, email to HR Analyst Yarbrough.

64. On March 12, 2024, Plaintiff submitted another internal complaint, once again

to HPD's Internal Affairs Department and, again, accused Sgt. Springfield of chewing

her out, “yelling at” her for using his office to pump after he had previously given her

permission to do just that; causing her stress to the point that she broke down crying;

refusing to let her leave Springfield's closed office when she asked him to; and,

specifically notifying the City, through HPD's Internal Affairs department, that she

needed to pump breast milk, to do something that is “natural” (for a woman) in a “stress

free” environment in order “to provide for my baby.”

65. Sgt. Springfield's and the City's unlawful, discriminatory, acts included, but

were not limited to, his yelling, blowing up at, harassing Plaintiff for using his office to

express breast milk (which he had previously given Plaintiff permission to use); for

Plaintiff's daring to try to make her case to him as to why she had a right to some proper

place to pump (a protected activity – opposing gender-based discrimination); and his

refusing to provide any place for Plaintiff to express breast milk in compliance with

federal law (a right under federal law).

66. On March 25, 2025, twenty (20) days after Plaintiff submitted her first

internal complaint, two (2) HPD Internal Affairs officers, Jason Clarke and Tyler Nabors,

both Caucasian men, went to HPD Dispatch, summoned Plaintiff to Sgt. Springfield's

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office, and for about a half hour proceeded to interrogate Plaintiff owing to her

previously-submitted Internal Affairs complaints.

67. Clarke's and Nabors' – like Springfield, both Caucasian men – interrogation of

Plaintiff was condescending and adversarial, causing Plaintiff even more stress and

apprehension.

68. Clarke's and Nabors' treatment of Plaintiff was more akin to what a reasonable

person, including a reasonable employee, would expect from police investigators

interrogating a criminal suspect, rather than treatment of a worker who had submitted a

good faith complaint of workplace discrimination.

69. Plaintiff again stated that she needed a place to express, to pump, breast milk,

but Clarke and Nabors met her notice and request with indifference, if not outright

condescension, constituting an adverse employment action that might dissuade a

reasonable employee worker from making or supporting a charge of discrimination.

70. The City's refusal to undertake a prompt, thorough, good faith investigation of

Plaintiff's March internal complaints regarding Sgt. Springfield's discrimination-based

harassment constituted retaliation for Plaintiff engaging in one or more protected

activities, including opposing workplace discrimination based on gender, and constituted

an adverse employment action that might dissuade a reasonable employee worker from

making or supporting a charge of discrimination.

71. The City's refusal to undertake a prompt, thorough, good faith investigation of

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Plaintiff's March internal complaints regarding Sgt. Springfield's discrimination-based

harassment constituted retaliation for Plaintiff engaging in one or more protected

activities, including opposing workplace discrimination based on maternity, that is,

Plaintiff being a nursing mother.

72. The City's refusal to undertake a prompt, thorough, good faith investigation of

Plaintiff's March internal complaints regarding Sgt. Springfield's discrimination-based

harassment constituted retaliation for Plaintiff engaging in one or more protected

activities, including opposing workplace discrimination based on race.

73. The City's refusal to undertake a prompt, thorough, good faith investigation of

Plaintiff's March internal complaints regarding Sgt. Springfield's discrimination-based

harassment constituted retaliation for Plaintiff engaging in one or more protected

activities, including participation in an investigation of employment discrimination by

submitting internal complaints of discrimination on March 5, 6 and 12, 2024.

74. Plaintiff's first-half-of-March 2024 complaints about Sgt. Springfield, his

harassing her in the context of her needing to pump breast milk at work, and City's

discrimination by its refusal to provide a law-compliant space for her to pump, went

unanswered and uninvestigated thoroughly or in good faith – other than the single

superficial, adversarial, interrogation to which she was subjected on March 25 – in

March, in April, in May, and throughout June 2024, by City's HR Department.

75. The City's refusal to respond to Plaintiff's internal complaints – save for a

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single adversarial interrogation on March 25 – left her anxious and emotionally-drained

limbo, which both haunted Plaintiff throughout the spring and into the summer of 2024.

76. Plaintiff's superiors and HR bounced her around from place to place to pump

breast milk, but the City never provided her a private place out of public view with a

working lock on the door, as required by and under federal law.

77. Finally, in or around the second week of April 2024, the City of Madison, a

municipality which shared building space with HPD Dispatch, accommodated Plaintiff

with a law-compliant place to pump; the City, her employer, never did.

78. In or around April 2024 the HPD issued a policy stating, in sum, that it would

comply with the law regarding women's right to pump at work, but, as regards Plaintiff,

the City never honored that new policy HPD policy. Besides Plaintiff's chain of

command and City HR refusing to abide by this new, ad hoc, HPD policy, the City's

deliberate decision not to include any mention of nursing mothers' protection in its

revised and updated April 2024 Policies and Procedures (see Paras. 79-81, infra)

undermined whatever legitimacy the internal, ad hoc HPD policy may have had and

demonstrated the City's ambivalence towards complying with both the Pregnant Workers

Fairness Act and the PUMP Act.

79. In April 2024 the City updated its “Personel [sic] Policies and Procedures

Manual,” but the updated, revised Policies and Procedures Manual made no mention of

the Pregnant Workers Fairness Act, The PUMP Act, or any prohibition on workplace

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discrimination based on pregnancy or becoming a new mother.

80. The City's decision to exclude any mention of the Pregnant Workers Fairness

Act and the PUMP Act from its updated, April 2024, Policies and Procedures Manual

evidences Defendant Huntsville's deliberate decision to (at the least) neglect, or (at the

worst) show contempt for these laws and the City's obligations under them.

81. The City's decision to exclude any mention of the Pregnant Workers Fairness

Act and the PUMP Act from its updated April 2024 Policies and Procedures Manual

evidences sent a message to both the HPD's supervisors and decision makers up and

down the chain of command, as well as to the City's rank and file employees, that

Defendant Huntsville did, and would, show deliberate indifference to its employees

rights set forth by and in these laws.

Plaintiff's 2023 Performance Evaluation – And her Supervisors' Retaliation

82. By the time Plaintiff returned to work in February 2024 following delivery of

her baby daughter, her HPD Performance Evaluation had been completed by Plaintiff's

2023 supervisor Amanda Traulsen 4 to 4½ months earlier, before Plaintiff began her

maternity leave in early October 2023, but Ms. Traulsen claims she did not get around to

providing Plaintiff's evaluation to her before Plaintiff took her maternity leave.

83. None of Plaintiff's supervisors provided her her 2023 Performance Evaluation

in February 2024, after Plaintiff returned from maternity leave.

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84. None of Plaintiff's supervisors provided her her 2023 Performance Evaluation

in March 2024, after Plaintiff returned from maternity leave.

85. Plaintiff received her 2023 Performance Evaluation, in early April 2024, but it

contained negative comments and criticisms of her which she understood were not in the

evaluation completed by Ms. Traulsen in or around September 2023.

86. Ms. Traulsen confided to Plaintiff that in or around March 2024, Sgt.

Springfield directed and/or told Ms. Traulsen that he and Lt. Danley, along with Deputy

Chief Michael Johnson, had to go over Traulsen's previously-completed Performance

Review and modify it.

87. In or around March 2024, Sgt. Springfield, Lt. Danley, and Deputy Chief

Michael Johnson went back into Plaintiff's 2023 Performance Evaluation – evaluation

Amanda Traulsen had written and completed – and edited or revised it to be as negative

as they, Springfield, Danley and Johnson could make it.

88. Between the day Plaintiff returned to work following her maternity leave (on

or about February 19, 2024) and receiving her Springfield-, Danley-, Johnson-modified

Performance Evaluation in or around mid-April 2024, the only significant workplace

occurrences involving Plaintiff were (a) Plaintiff's filing an EEOC Charge on February

26 (received by the City / HPD on March 5); (b) Sgt. Springfield's berating Plaintiff for

using his previously-offered office to pump on March 5; and, (c) Plaintiff's submitting

written complaints / grievances to the City regarding Sgt. Springfield's harassment and

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refusal to allow her a place to pump in peace and in compliance with the law.

89. Sgt. Springfield's, Lt. Danley's and Deputy Chief Johnson's March and/or

April 2024 modification of Plaintiff's already- or mostly-completed Performance

Evaluation (from September 2023) to deride and put down Plaintiff constituted

retaliation for Plaintiff's engaging in one or more protected activities.

90. The modified Performance Evaluation laid partial, and certainly bad faith,

groundwork for Plaintiff to get “disciplined” around / about July 29-30, 2024, which in

turn created the foundation and created the paper trail for HPD Chief Giles and

Huntsville Mayor Tommy Battle to fire Plaintiff on January 8, 2025.

Training.

91. In 2016, when Plaintiff began working as an HPD dispatcher, the City

provided her little-to-no training regarding any City policies and procedures that may

have prohibited workplace discrimination or retaliation.

92. In or around 2019 or 2020, the City had a man whose name Plaintiff cannot

recall, spoke to several of the HPD dispatchers, including Plaintiff, and in sum tell them

that diversity was important to the City, but he did not discuss any City prohibition on

workplace discrimination, retaliation, or what an employee should do in case they feel

they were on the receiving end of workplace discrimination.

93. In or around the summer of 2020 Plaintiff and several other Black HPD

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dispatchers complained up the chain of command about race-based workplace

discrimination, but aside from one (1) meeting with a Lt. Ronnie Dickey, the HPD and

City dismissed these dispatchers' complaints.

94. The aforementioned summer 2020 internal complaint made by Black HPD

dispatchers included previously-made workplace race complaints “dismissed as crying

wolf and pulling the race card;” “double standards on policy and discipline practices

between [ ] black and white employees;” and a plea: “We are not asking for special

treatment, but we are demanding equal treatment.”

95. The foregoing summer 2020 internal complaint made by Black HPD

dispatchers included the example of “a third shift white male dispatcher [who] has been

late [to work] numerous times,” but remained a “designee” (Dispatch shift leader), while

a Black dispatcher who had roughly the same number late-to-work violations got written

up, an unpaid day off, and removed as designee. Other specific examples of Caucasian

dispatchers violating policies without disciplinary action, in contrast to Black

employees, were cited, but no action or re-training was taken.

96. In or around 2021, Lt. Danley, a Caucasian male, harassed and humiliated

Plaintiff and other Black dispatchers for occasionally wearing “Black Lives Matter”

shirts or jewelry, calling them “anti-police,” threatened with disciplinary action, and

ordered to return home to change.

97. When Plaintiff complained to City HR about Danley's harassing her and other

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Black dispatchers for wearing Black Lives Matter shirts and jewelry, one or more HR

officials told Plaintiff wearing “BLM” garments did not violate City or HPD policy, but

Danley was never disciplined for his discriminatory treatment of Black employees.

98. After Plaintiff complained to City HR about Danley's race-based harassment,

Danley began a program of even further heightened scrutiny against Plaintiff, looking

for minor policy infractions to warrant write-ups that Caucasian dispatchers were

allowed to get away with; for example: Caucasian dispatcher Jennifer Matthews was

allowed to use “sick leave” virtually anytime she wished to without needing to provide

any excuse / doctor's note, or without even being sick; Caucasian dispatchers who wore

“Gadsden Flag” T-Shirts (which in recent years have been co-opted by White

Supremacists as totems of their social stand and political proclivities), but were never

singled out, harassed or sent home by Danley or any of the other Caucasian supervisors.

99. In or around 2023, a Ms. Greene, a City “EEO” Officer, spoke to several

dispatchers regarding workplace discrimination, said that, “I am here for you” (or words

to that effect), but never reviewed any specific City policies that prohibited workplace

discrimination within HPD Dispatch.

100. Ms. Green's “I am here for you” promise proved hollow to and non-existent

for Plaintiff, when in 2023, 2024 and 2025, Green, more than once failed or refused to

follow-up with internal workplace discrimination complaints Plaintiff submitted to the

City.

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101. Plaintiff recalls HPD Dispatch supervisors like Kristy Hooper and Sgt.

Springfield notifying dispatchers that they (Hooper and Springfield) would attend City-

sponsored or -arranged “leadership” seminars, but neither of these HPD Dispatch

supervisors, nor any other person in Plaintiff's chain of command, ever commented to

Plaintiff and her colleagues about attending any seminars or other such events to teach or

“refresh” these supervisors in policies or issues regarding workplace discrimination or

any prohibition on it, or regarding any prohibition on retaliation against any City

employee who opposed discrimination in the workplace.

102. At all times pertinent to this action, the City at best gave short-shrift to

training both HPD dispatchers and their supervisors, which signaled and defined the

City's broader policy, to wit: indifference to or contempt for laws prohibiting workplace

discrimination, including but not limited to race, gender, pregnancy and nursing mother

discrimination.

103. At all times pertinent to this action, City Policies, training and/or practices,

or their deficit, sent a de facto message to its employees to the effect: Gender,

maternity-related discrimination will be ignored or tolerated.

104. At all times pertinent to this action, City Policies, with only obligatory, pro

forma mentions of race discrimination prohibitions within its Policies, sent a de facto

message to its employees to the effect: Race discrimination within City government will

not be taken seriously by City decision makers.

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105. In 2023 in the context of HPD Dispatch employees opposing workplace

discrimination, Sgt. Springfield made it known within HPD Dispatch that “Retaliation is

part of the job (for dispatchers)” – City HR, Chief Giles and Springfield's supervisors,

who were put on actual notice of this policy or practice statement (in both February 2024

by Plaintiff in her EEOC Charge and in December 2024 through the sworn testimony of

no less than three (3) HPD dispatchers).

106. Neither Chief Giles nor any person above Springfield in the HPD chain of

command or command staff took any action to discipline or otherwise correct Sgt.

Springfield for proclaiming the policy / practice: “Retaliation is part of the job.”

107. At all times pertinent to this action, City policies and/or Chief Giles's

practices (see, for example, Paras. 233-235, infra) regarding Sgt. Springfield, sent a de

facto message to its employees to the effect: Retaliation for opposing workplace

discrimination will be tolerated, and perhaps encouraged.

May through June 2024

108. April, then May, 2024 came and went without Plaintiff hearing anything

back from either City HR or HPD Internal Affairs regarding her several March 2024

internal complaints of sex / gender / nursing mother discrimination, harassment,

retaliation by Sgt. Springfield.

109. According to Springfield's direct supervisor, Lt. Danley, HPD Internal Affairs

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never interviewed him regarding the March 5, 2024, Springfield incident about which

Plaintiff complained: Not about what Springfield may have told and/or admitted to

Danley; nor about Danley's observations of Springfield's history towards women over

the years; nor about Danley's own understanding of HPD Dispatch policy and practices

regarding women at the workplace or nursing mothers as of March 5, and the like.

110. HPD's Internal Affairs failing or refusing to interview Springfield's direct

supervisor, Danley, about the March 5 incident and circumstances surrounding his own

training and supervision of Springfield demonstrated the City's failing or refusing to

undertake a thorough, good faith, investigation of Plaintiff's internal complaints

regarding sex / gender-based / nursing mother workplace harassment and retaliation.

111. Notwithstanding HR Analyst Yarbrough's March 6, 2024, email to Plaintiff

assuring her “Someone from the Human Resources office will reach out to you soon to

schedule an meeting,” no one from Human Resources “reached out” or otherwise

contacted Plaintiff in March, or from April through June, to schedule a meeting, leaving

Plaintiff hanging, and stressed as to what was happening.

112. Both the City's HR Department and HPD refusing to conduct a thorough,

good faith, investigation of Plaintiff's March 2024 internal complaints / grievances

involving harassment, discrimination, based on sex / gender and Plaintiff's being a

nursing mother constituted ongoing retaliation against her.

113. During the spring of 2024 – roughly April through June, then into July, 2024

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– the City's and its Police Department's ongoing retaliation against Plaintiff put her in a

particularly stressful dilemma: She did not know whether the deafening silence from

City HR and HPD Internal Affairs meant they were, possibly, conducting a thorough and

laborious investigation of Springfield workplace violations and, thus, that she should not

want to “rock the boat;” or, whether the City and and HPD were simply ignoring her

March complaints, along with failing to provide her a place to pump that conformed to

federal law.

114. In a letter from one of Plaintiff's baby's nurses, according to the National

Library of Medicine, “evidence supports a role for psychological distress in multiple

breastfeeding outcomes, including delayed secretory activation and decreased duration

of exclusive breastfeeding. One physiological mechanism proposed to explain these

relationships is that psychological distress may impair the release of oxytocin, a

hormone that plays a critical role in milk ejection during lactation.”

115. During the spring and into the summer of 2024, Plaintiff – and, her infant

daughter – suffered a decrease in breast milk production.

116. According to this same nurse, it was “regrettably reasonable to suggest that

undue stressful situations may have played some role in the premature decrease of Ms

Brady's milk supply. This is significant, as it is well known that human breast milk

contributes to better long term health outcomes for both mother and child.”

117. The decrease in Plaintiff's breast milk production was proximately caused

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and/or contributed to by the stress she was obliged to endure by the City – through HR

and HPD inaction and leaving her hanging regarding her complaints against Springfield

– was proximately caused by the City's refusal to conduct a prompt, thorough, good faith

investigation of Plaintiff's internal complaints regarding Sgt. Springfield, as well as

giving Springfield, Lt. Danley and Deputy Chief Johnson a free hand to negatively edit

Plaintiff's 2023 Performance Evaluation before giving it to her in April 2024.

The July 2024 Disciplinary Hearing

118. On June 28, 2024, HPD Administrative Aide Cindy Green emailed Sgt.

Springfield (with a copy to Lt. Danley, Lt. Jesse Sumlin, Deputy Chief Michael Johnson,

dispatcher Rebecca Bundy, and Dispatch Supervisor Kristy Hooper) that read:

Sgt. Springfield, Chief Giles has requested a Departmental Hearing on

Dispatcher Katrina Brady. Please have her choose from the following. . .

Three July dates were provided. Plaintiff was not copied with the email.

119. On July 2, 2024, then-Dispatch Supervisor Kristy Hooper called Plaintiff

into Sgt. Springfield's office where Springfield was waiting. Springfield and Hooper told

Plaintiff she had to pick from one of the dates given for a “hearing.”

120. Plaintiff had to make sure it lined up with my witness or anything else I had

on my calendar at the time. Within a few days of July 2, Plaintiff spoke with Kristy

Hooper and Sgt. Springfield about the hearing, realizing it was disciplinary hearing

against her, and said she needed to first speak with HR or Chief Giles because she could

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not understand how or why she was being subjected to a disciplinary hearing for

complaining about on Sgt. Springfield for harassing and yelling at her for being a

nursing mother pumping breast milk in a room Springfield had originally designated as a

room for her to do just that. Springfield responded, "Well, that's not how everyone else

sees it Katrina," or words to that effect.

121. Springfield's response shocked Plaintiff, and she replied, “Who is

'everyone?' I haven't heard anything about an investigation of me?” Springfield ignored

Plaintiff and told her to choose one of the listed dates for a hearing.

122. In fact, while Plaintiff surmised the gist of the hearing topic, and that it was a

“disciplinary” hearing aimed at her, neither Springfield nor Hooper actually told Plaintiff

what the hearing was about, just that it was a “hearing.”

123. On July 3, 2024, Sgt. Dana Springfield – about five (5) days after Chief

Giles requested a hearing with Plaintiff as the accused – wrote up an internal complaint

about Plaintiff concerning the March 5, 2024, incident in his office.

124. Plaintiff was not shown nor was she made aware of Springfield's internal

complaint / grievance against her until the next week, on July 9, 2024.

125. On July 5, 2024, still confused about exactly what the upcoming hearing was

actually about, Plaintiff emailed HR Analyst Yarbrough and included the following:

I sent an email to Dylan(HR) March 6 about filing a harassment complaint

on my superviso's [sic] supervisor, Sgt. Springfield, and I never heard back
about it. Somehow, now over 3 months later, I'm being told I have a

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disciplinary hearing for what I assume is about my harassment complaint. I

have no paperwork indicating what I am being charged with, but I was
forced by Sgt. Springfield [to] choose a date for this. It appears my
complaint is somehow turned back on me in retaliation for speaking up
about him harassing me. This is very disheartening and I need to speak to
someone about this.

126. That same day, July 5, 2024, HR Analyst II Dylan Yarbrough responded to

Katrina's email, in pertinent part writing:

I apologize for not responding to your email on 3/6/24 regarding workplace

harassment. I was made aware that you filed a formal harassment complaint
with the federal EEOC on 3/5/2024, and as a result, that complaint was
deferred to City legal an external legal partners. In this situation, [HR EEO
officer Green] and I were removed from the investigation. Due to the nature
of the claim, it has taken several months for fact finding and investigation
to occur by both the Police Internal Affairs division and the external parties
involved. The Police Department has been instructed to move forward with
scheduling a department hearing to discuss any policy violations discovered
during the incident that occurred on 3/5/24.

127. As Plaintiff filed her EEOC Charge on February 26, 2024, and as her first

internal complaint regarding Springfield's harassing her for pumping in his office (as

Springfield had previously authorized and encouraged her to do) on March 5, 2024, in

his July 5, 2024, email to Plaintiff, HR Analyst Yarbrough likely meant that he (and thus

the City and HPD) became “aware” of Plaintiff's EEOC Charge on March 5, 2024.

128. There are layers of City, HPD and HR officials above HR Analyst

Yarbrough, so it is reasonable and likely that several City, HPD and HR employees and

officials had notice of Plaintiff's EEOC Charge before HR Analyst Yarbrough did.

129. As Plaintiff's March 5 (Internal Affairs), 6 (Human Resources) and 12

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(Internal Affairs), 2024 internal complaints regarding Springfield's harassing and yelling

at her in connecting with her federally protected right to express breast milk in a private

room with a lock available, were submitted after and occurred separate and apart from

her February 26, 2024, EEOC Charge, Plaintiff was distressed that the City's HR

“removed” from investigating her March 6, 2024, complaint to Human Resources.

130. According to HR Analyst Yarbrough in his July 5, 2024, email to Plaintiff, it

was the City's Human Resources Department's policy or practice not to investigate

employee allegations of workplace discrimination, if such allegations arose from

incidents that occurred following the City's receipt of an EEOC Charge of

Discrimination.

131. On July 9, 2024, six (6) days after Sgt. Springfield wrote-up his complaint

against Plaintiff (based on the March 5, 2024, incident in his office), and eleven (11)

days after Chief Giles called for a “Departmental Hearing” regarding Plaintiff, the City

Springfield gave Katrina Brady a copy of Sgt. Springfield's internal complaint /

grievance, with Hooper looking on.

132. In sum and substance, Sgt. Springfield's July 3, 2024, internal complaint /

grievance against Plaintiff accused her of: violating City or department rules; habitual

acts of misconduct; a course of conduct directed at a specific person (Springfield) that

caused “substantial emotional distress;” harassing conduct in the workplace;

insubordination; and “untruthfulness.”

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133. The sum and substance of Sgt. Springfield's July 3, 2024, internal

complaint / grievance particulars alleged: Plaintiff used his office without his

permission and locked the door; that when he confronted her she yelled at him, that she

could “use a designated room at the 911 Center for her personal business” (neglecting to

note that such rooms were not legally compliant for expression of breast milk); and that

she used her phone without his permission (she had, in fact, called her husband, Officer

Michael Brady, because Springfield, a large, armed, angry man, disturbed her

tremendously).

134. In his July 3, 2024, internal complaint / grievance against Plaintiff, Sgt.

Springfield also failed to mention that he had, in fact, given Plaintiff permission to use

his office to pump breast milk and that no issue had arisen between Plaintiff's February

19, 2024, return from maternity leave until the March 5, 2024, incident – the date at least

one Human Resources Analyst, Dylan Yarbrough, admitted receipt and notice of

Plaintiff's February 26, 2024, EEOC Charge against the City.

135. While Plaintiff's March 5, 6 and 12, 2024, internal complaints / grievances

against Sgt. Springfield were submitted to her superiors and City HR on the day of

Springfield's harassment, and within a week following same, Springfield's July 3 internal

complaint / grievance against Plaintiff for the March 5, 2024, incident was submitted up

the chain almost four (4) months (right at 120 days) after Springfield allegedly suffered,

inter alia, “habitual or repetitive acts of misconduct,” “harassing conduct in the

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workplace,” and “substantial emotional distress.”

136. According to City Human Resources Director Byron Thomas, matters which

have occurred more than (30) days before a City employee files an internal grievance are

due to be denied; that is, such grievances are due to be denied due to “untimely filing,”

but Chief Giles allowed Springfield's grievance against Plaintiff to go forward, 120 days

following the incident.

137. By definition, Plaintiff's March 5, 2024, incident in Sgt. Springfield's office

was not and could not have been “habitual or repetitive acts of misconduct.”

138. It is farcical that Plaintiff, whom Springfield summoned into his office and

confronted about using his office to pump breast milk, committed “harassing conduct in

the workplace.”

139. It was ludicrous for Springfield – who was armed and who stands about 6'2”,

weighs 250-275 pounds and towers over Plaintiff, who's 5'2” – to claim he suffered any,

let alone “substantial,” “emotional distress” by his ordering Katrina Brady into his office

on March 5 and dressing her down for using his, Springfield's, office to pump breast

milk.

140. To a reasonable, neutral and judiciously-minded Chief of Police desiring to

respect fundamental civil rights, the absurd nature of Springfield's above-described July

3, 2024, complaints against Plaintiff should and would have been diagnostic of the lack

of credibility of all of Springfield's allegations, but not to Chief Kirk Giles.

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141. Sgt. Springfield's July 3, 2024, internal complaint / grievance, which he

showed to Plaintiff on July 9, was written on a single page, but included a second page

which said the following: “After review of the facts submitted by the chain of

command, Chief Giles has agreed and approved a DEPARTMENTAL HEARING for

your (Katrina Brady's) policy violations.” (original capitalization).

142. In fact, according to Chief Giles' Administrative Aide, Chief Giles called for

the Departmental Hearing on June 28, 2024. Chief Giles could not have “reviewed the

facts submitted” in Springfield's July 3, 2024, internal complaint / grievance against

Plaintiff on June 28.

143. On July 9, 2024, when Springfield showed Plaintiff his July 3 internal

complaint / grievance against her, he told her to write a statement about it.

144. Plaintiff told Springfield that she had already written and submitted several

statements back in March about what happened on March 5 in Springfield's office, but

Springfield ignored this and ordered Plaintiff to write another statement, which she did.

145. Plaintiff's July 9, 2024, generally echoed her three (3) statements written and

submitted about Springfield on March 5, 6 and 12, 2024, but on July 9 Plaintiff was

made to write a statement immediately, with Sgt. Springfield and supervisor Kristy

Hooper standing over her. In pertinent part Plaintiff noted she was “being retaliated

against for filing a Harassment complaint against Sgt. Springfield;” that she “was being

disciplined for being yelled at (by Springfield),” but that, according to Springfield,

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“that's not how everybody sees it;” that to Plaintiff “it is obvious [Springfield is being

talked to about an investigation [which] he is the subject on for harassing me and I've

been told nothing;” and that Plaintiff had earlier stated that she “needed to speak to

someone higher than the Chief, because this is not right and yet again, I'm being

retaliated against.” Additionally, Plaintiff wrote that “[Springfield] is now making me

write a statement to dirty me up more and this just is not the case. This isn't all I have to

say about this, but I'm sick, not feeling well and I am unable to finish explaining because

I am writing this all under duress.”

146. Plaintiff's new, July 9, 2024, internal complaint / grievance of retaliation for

opposing workplace harassment (in the context of being a nursing mother, a woman, in

need of a law-compliant space to pump breast milk), and further, additional workplace

harassment, was never investigated by the City or its Police Department.

147. While Plaintiff had still not heard anything about the putative “investigation”

of her internal complaints / grievances against Springfield for sex / gender / nursing

mother harassment, in June and July 2024, Chief Giles conspired with Sgt. Springfield

and/or with others in the HPD pecking order between Giles and Springfield to make up a

“complaint” against Plaintiff in order to put her on the defensive, discredit her and build

a disciplinary paper trail against her as an HPD and City “defense” against Plaintiff's

pending EEOC Charge and pending March 2024 internal complaints against Springfield.

148. Chief Giles initiated a Departmental – and what came to be disciplinary –

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Hearing against Katrina Brady almost a week before Springfield drafted and submitted

his internal complaint / grievance against Plaintiff.

149. Chief Giles initiating a Departmental Hearing against Katrina Brady almost

a week before Springfield even drafted and submitted his internal complaint / grievance

against Plaintiff has all the earmarks of a intentional scheme to discredit and demonize

Plaintiff during her pending EEOC Charge and own complaint against Springfield, as

opposed to exhibiting even a modicum of neutrality of enforcement of City and HPD

policies.

150. Chief Giles initiating a Departmental Hearing against Katrina Brady almost

a week before Springfield even drafted and submitted his internal complaint / grievance

against Plaintiff demonstrates and evidences workplace discrimination and retaliatory

harassment by the City – by and through its authorized agent, Chief Giles – against

Plaintiff during her own pending EEOC Charge and own complaint against Springfield.

151. Deputy Chief Johnson, Chief Giles' right hand man, had actual knowledge of

Chief Giles' bad faith scheme, that Chief Giles called the “Departmental Hearing”

against Plaintiff before Sgt. Springfield even filed his internal complaint / grievance

against Plaintiff, but nevertheless endorsed and participate in Giles' scheme.

152. On July 28, 2024, Chief Giles conducted a Departmental Hearing at the

City's PSC Public Safety Complex in a 2nd floor conference room – with Plaintiff as the

accused and Sgt. Springfield as the absentee accuser.

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153. Besides Chief Giles and Katrina Brady, Deputy Chief Michael Johnson, HPD

Captain Jon Ware, HPD Captain Jesse Sumlin, and Assistant City Attorney Joselyn

Boustani attended the hearing, along with HDP dispatcher Rosalee Martin, whom Ms.

Brady asked to attend as a witness.

154. Katrina Brady's accuser, Sgt. Springfield, did not attend the July 28, 2024,

hearing, but Chief Giles and Deputy Chief Johnson filled-in for Springfield, making

allegations and arguments on Springfield's behalf against Plaintiff.

155. During the July 28, 2024, HPD disciplinary hearing over which Chief Giles

presided, Giles and Johnson cross-examined Plaintiff, acting as both judges and jury.

156. Plaintiff had no opportunity to confront or ask questions of her accuser, Sgt.

Springfield, because Giles allowed Springfield to skip the hearing.

157. Chief Giles' examination of Plaintiff began with his asking if she understood

Springfield's charges against her, to which Plaintiff responded that she was not aware of

where the charges came from, that she honestly did not understand how charges against

her, like “harassment” and “untruthfulness,” came out of the March 5, 2024, incident in

Springfield's office.

158. Chief Giles told Plaintiff to explain herself in response to Springfield's July

3, 2024, internal complaint / grievance against her. She responded noting the March 5

incident, that on March 6 she communicated with HR Analyst Yarbrough about the

proper procedure was to complain about Springfield's harassing her the day before, and

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that she wrote up and submitted a complaint to HR about the previous day's, March 5,

2024, incident.

159. Deputy Chief Johnson asked Plaintiff what had brought about the

“conversation” in Sgt. Springfield's office in the first place, and why “people heard you

yelling?”

160. Plaintiff explained again – as she had done in writing in three (3) separate

internal complaints in March 2024 – that since on or around February 19, 2024,

Springfield had given her permission to pump breast milk, but that on March 5 he more

or less blew up at her for doing so. She also denied yelling at Springfield, stating in sum

that is was Springfield who chewed her out.

161. Plaintiff additionally explained that she had pumped breast milk some

twenty (20) times in Springfield's office (that is, about twice per work day, which is

normal) between February 19 and March 5, 2024, without incident, and that the two (2)

alternate rooms mentioned by Springfield in his incident did not have locks on them.

162. Deputy Chief Johnson cynically asked Plaintiff if before March 5

Springfield had allowed her to use his office “literally any time.”

163. Deputy Chief Johnson was either unaware or dismissive of federal law that

required employers to provide nursing mothers a private room with a lock on the door

that they could use as reasonably-needed to express breast milk.

164. Captain Sumlin asked Plaintiff the same cynical and law-dismissive

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question, to wit, if Plaintiff thought she was allowed to “randomly” use Springfield's

office to pump breast milk.

165. Plaintiff also testified that that two (2) alternate rooms offered by the City to

pump breast milk were not offered until after she submitted her March 2024 complaints.

166. In fact, neither of the alternate rooms offered were law-compliant: One of

them was accessible by employees coming and going and the lock didn't work on the

other.

167. As noted, while the Defendant City of Huntsville never provided Plaintiff a

law-compliant room to express breast milk, fortunately for Plaintiff, a City of Madison

supervisor took pity on Plaintiff and allowed allowed her to use one of Madison's rooms

to pump – The City of Madison rented space in the same building the City of Huntsville

used for its “911 Center.”

168. In fact, on March 5, 2024, Springfield told Plaintiff, “On weekends and

afternoons when I'm not using my office you're more than welcome to use it.”

169. The City, through Sgt. Springfield, only allowing Plaintiff to pump on

weekends and afternoons when Springfield was not using his office was a clear violation

of federal law.

170. Had Chief Giles, Deputy Chief Johnson, HR, Internal Affairs and/or the City

“Administration” bothered to conduct a good faith investigation of Springfield and the

March 5 incident about which Plaintiff complained, it / they would have taken prompt

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and remedial action and – at the least – re-trained Springfield and at the most subjected

him to the disciplinary action he deserved. But none of this happened.

171. Plaintiff additionally testified that Springfield's July 3 accusation against her

did not even make logical sense, adding that she pumped breast milk, was done, left

Springfield's office to store her breast milk and that it was Springfield who called her

back into his office and began yelling at her; that she had no reason to yell. She did

admit to crying, though, after Springfield began berating her, and that she called her

husband, Officer Brady, on the phone for comfort and support.

172. Deputy Chief Johnson then told Plaintiff that “the discipline” to be meted

out to her was not for her use of Springfield's office, but for her reaction to his actions.

But the entire context of Springfield's actions centered on Plaintiff using his office to

pump breast milk and his anger over it.

173. Deputy Chief Johnson parsed words and issues, demonstrating bad faith, an

eagerness to give Chief Giles an “assist,” and to find a path to discipline Plaintiff for

availing herself of her right as a nursing mother, a woman, to use a workplace office to

pump breast milk; and/or for her complaining about Springfield's harassing her for

pumping breast milk at work; and/or for Plaintiff filing an EEOC Charge of

Discrimination against the City, which HR Analyst Yarbrough confirmed the City

received at least on March 5, 2024, if not earlier.

174. Before the Giles's Departmental Hearing was over, Deputy Chief Johnson

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had already made up his mind that the City, through him, would discipline Plaintiff.

175. Deputy Chief Johnson claimed that “multiple witnesses” said Plaintiff yelled

at Springfield in his office during the March 5, 2024, incident.

176. Deputy Chief Johnson declined to name any such witness or produce any

statement which backed up his accusation.

177. Deputy Chief Johnson claiming the City had “multiple witnesses” Plaintiff

was “yelling” was, at best, disingenuous.

178. Deputy Chief Johnson asked Plaintiff, “All the witness statements we have,

all those people are lying?” or words to that effect.

179. In fact, in a statement received by the City HR Department on October 3,

2024, HPD dispatcher Morgan Somerville wrote, in pertinent part:

To Human Resources of the City of Huntsville,

On March 5th of this year an incident occured [sic] with employee Katrina
Brady in Sgt. Springfield's office. I had written a statement and cannot attest
to anyone else's recollection of the encounter, but I did not hear any party
“yelling.” I can say that I did hear Mrs. Brady upset and crying/near crying
but at no time any yelling. My terminal is one of the closest ones to Sgt.
Springfield's office. . .

180. In days or weeks preceding the July 28, 2024, hearing, Deputy Chief

Johnson and/or other persons who “investigated” Sgt. Springfield's July 3, 2024, internal

complaint / grievance against Plaintiff failed or refused to question or re-question

Morgan Somerville, whose work terminal was “one of the closest to Sgt. Springfield's

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office,” indicating Johnson's and the City's bad faith.

181. In fact, neither Chief Giles nor Deputy Chief Johnson called anyone to

testify that Plaintiff “yelled” at Springfield on March 5. The only “evidence” Giles and

Johnson presented that Plaintiff “yelled” was Johnson's testimony (acting as Judge, Jury

and Witness – despite the fact that Johnson was not present in HPD Dispatch on March

5); and Johnson's contention that he had statements from “multiple” witnesses, whom he

never identified or allowed Plaintiff the opportunity to confront and question.

182. Plaintiff stood her ground under Giles's, and Johnson's, and Sumlin's, and

questioning, saying she had no reason to say she wasn't yelling if she yelled back at

Springfield. Katrina Brady repeated that she used the empty office to pump breast milk,

she finished, she left, Springfield called her back into his office, then began yelling at

her; that she had no reason to cry unless given a reason – which she did because

Springfield yelled at her and refused to allow her to leave; and that she called her

husband because she did not feel safe.

183. When Plaintiff again asked where Springfield was coming from accusing

her of “harassment” and “untruthfulness,” Chief Giles responded that he wasn't sure, that

he was “just guessing, because he wasn't the one bringing the charges; that he assumed

Springfield was alleging Plaintiff was “untruthful” as to how the conversation occurred,

and asked Plaintiff if that sounded right to her. In other words, Chief Giles did not even

understand two or more of Springfield's allegations, just “guessed” at them, and asked

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Katrina Brady to speculate about what her absent accuser meant.

184. Deputy Chief Johnson stepped in, to cover for both Chief Giles and Sgt.

Springfield, interjecting: “Disrupting the workplace, being loud when he was trying to

talk to you!” or an accusation to that effect.

185. Plaintiff responded by noting that Springfield was her Sergeant, so it looked

like there was no way she could bring charges against him, but that she felt

uncomfortable and asked HR what to do, and Yarbrough told her she could file a

harassment complaint against Springfield (with HR). But that even to that day, July 28,

2024, she'd heard nothing about any real investigation into her complaint about

Springfield. But Springfield, in contrast, told Plaintiff about how “not everybody sees it

your way,” or words to that effect, thus indicating Springfield's in the loop and Plaintiff

is not.

186 Captain Ware chimed in, telling Plaintiff he could get her a “findings” letter.

Neither Captain Ware nor any other HPD or City employee ever provided a “findings”

letter to Plaintiff in response to her several March 2024 internal complaints / grievances

against Sgt. Springfield.

187. Chief Giles's July 28 Departmental Hearing against Plaintiff ended with

Plaintiff saying that per Standard Operating Procedure she should have been told,

notified, within 30 days about any “investigation” her internal complaints triggered, but

that she never received any such notice, findings. She said that HPD's conduct really

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looked like a “cover up” for Springfield.

188. Chief Giles did not deny Plaintiff's assertion that she should have been

notified of any investigation “findings” within 30 days of her submitting an internal

complaint (she submitted three (3) in March 2024), but denied any cover-up and told

Plaintiff she could believe him or not.

189. Both Chief Chief Giles' and Deputy Chief Johnson's actions towards Katrina

Brady, in sum, their putting his finger on the scale of justice in Sgt. Springfield's favor,

reflected a deliberate attempt to thwart her civil rights, equal protection and due process

– including but not limited to, as a nursing mother, as a woman, and as a City employee

who both opposed workplace discrimination and participated in an investigation

involving workplace discrimination.

190. Following Giles's Departmental Hearing Plaintiff spoke with HPD

dispatcher Rosalee Martin as they walked to their vehicles.

191. Ms. Martin had attended and heard every word said at the hearing, just like

Chief Giles, Deputy Johnson, and the others in attendance had heard.

192. Ms. Martin told Plaintiff that HPD provided no supporting evidence, only

Springfield's “empty accusation.”

193. Ms. Martin also told Plaintiff that she, Ms. Martin, understood that none of

the dispatchers could expect HPD to investigate empty accusations – that details and

supportive evidence, witnesses, would need to be supplied.

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194. Ms. Martin told Plaintiff that as far as she could tell, it was obvious that

those conducting the hearing had no interest in hearing or considering what Plaintiff had

to say; and, additionally, Ms. Martin told Plaintiff it appeared obvious to her that the

Chief and his subordinates at the hearing were “clearly covering” for Springfield.

195. Ms. Martin recalled to Plaintiff that several dispatchers, including Plaintiff,

had recently had a conversation with Deputy Chief Johnson about what a “problem”

Springfield was in HPD Dispatch, but that Johnson appeared unmoved.

Deputy Chief Johnson's “Discipline Notice”

196. On Tuesday, July 30, 2024, and with Chief Giles's authorization, Deputy

Chief Michael Johnson issued a City of Huntsville Office Memorandum in which he

declared Plaintiff Katrina Brady would be subject to “Imposed Probation,” also

characterized by Johnson as “disciplinary notice,” beginning August 3, 2024.

197. Included in his July 30 “Imposed Probation,” “discipline notice,” to Plaintiff

was Deputy Chief Johnson's requirement that she submit she “reply through her chain of

command in writing within 2 working days regarding how she intends to improve her

behavior.”

198. As Johnson's July 30 Discipline Notice arose from the July 28 hearing, his

condemnation of Plaintiff's “behavior” regarding the March 5, 2024, incident in Sgt.

Springfield's office was reached in bad faith, without any evidence presented, other than

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his own and Chief Giles' evidence-free accusations, both acting as advocates for

Springfield and eschewing even the pretense of neutrality or good faith.

199. Johnson's July 30 Discipline Notice demanded Plaintiff:

[D]etail (in writing) her personal plan of action and goals to address the
concerns about K. Brady being argumentative, intimidating, and/or bullying
others in the workplace.

200. In fact, no evidence was presented at Giles's Departmental Hearing that

Plaintiff had been “argumentative, intimidating, and/or bullying to others in the

workplace.” Johnson made it up or just transcribed Springfield, who skipped the hearing.

201. Earlier in 2024, before City HR received HPD dispatcher Morgan

Somerville's statement regarding the March 5, 2024, incident in Springfield's office,

Somerville “explained to them three times” that he had not heard Plaintiff “yelling” at

Springfield on March 5. The “them” to whom Somerville referred was a City Assistant

Attorney and the HR “EEO” officer.

202. According to HPD dispatcher Somerville, “It was almost like [a City

attorney and HR] were trying to bend my words [against Plaintiff].”

203. In or around the first half of 2024, Somerville explained to an Assistant City

Attorney and HR that he heard Katrina Brady crying and upset, but that he “didn't say

anything about yelling.”

204. In or around the first half of 2024, while discussing Katrina Brady, HPD

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dispatcher Somerville had “a big talk with [the same Assistant City Attorney]” about the

“unequal application of discipline,” and that that's what he saw happening to Plaintiff

Brady.

205. The Assistant City Attorney, HR and HPD ignored and/or covered up

Somerville's observations and assertions.

206. Johnson's July 30 Discipline Notice cited Plaintiff's April 2024 performance

evaluation – that is, Plaintiff's September 2023 evaluation which, according to Plaintiff's

April 2024 supervisor Amanda Traulsen, was altered in the negative by Johnson, Danley

and/or Springfield in March or early April 2024 – “indicated a 'needs improvement' in

both personal relations and 'work habits.'”

207. During her 8 or so years' employment in the City's HPD Dispatch, Plaintiff

had never heard of any policy or practice whereby an almost 4-month-old – or, in

actuality, 10-month-old – “performance evaluation” was used as a cudgel against an

employee written up or placed on “Imposed Probation.”

208. During the July 28 hearing, neither Giles, Johnson, nor any of the HPD

command staff who questioned Plaintiff ever brought up the early April (or, in actuality,

September 2023) “performance evaluation” issued to her.

209. Plaintiff's direct supervisor in September 2023 was Amanda Traulson, who

had completed Plaintiff's Performance Evaluation by or around late September 2023, but

Plaintiff took maternity leave in early October 2023 before Traulson could give Plaintiff

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the completed Performance Evaluation.

210. According to Amanda Traulson, before she could give Plaintiff her 2023

Performance Evaluation in 2024, Sgt. Springfield – who was not Plaintiff's direct

supervisor – re-wrote Plaintiff's Performance Evaluation and sent it up to Lt. Danley and

Deputy Chief Johnson for their “approval.”

211. Traulson had never heard of such a thing before, what Springfield, Danley

and Johnson did to Plaintiff's previously-completed 2023 Performance Evaluation.

212. Even with Springfield's 2024 re-write of supervisor Traulson's 2023

Performance Evaluation, Plaintiff received an “Effective” mark in 4 out of 6 categories

and an overall “Effective” evaluation.

213. Plaintiff received an “Effective” score for Quality of Work, Quantity of

Work and Adaptability, plus an overall “Effective” evaluation.

214. Plaintiff received “Needs Improvement” scores for Work Habits and Personal

Relations in her Performance Review.

215. Plaintiff received no “Unsatisfactory” scores.

216. However, the Performance Evaluation narrative written by Springfield and

approved by Danley and Johnson was damning towards Plaintiff.

217. On or around April 4, 2024, Springfield presented Plaintiff her Springfield-

rewritten 2023 Performance Evaluation in his office, while Danley stood by with a

“body cam” running to record it. It was weird and intimidating to Plaintiff, as she had a

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pending EEO Charge in which both Danley and Springfield were mentioned, and three

(3) March 2024 internal complaints filed against Springfield for his harassing Plaintiff

on March 5, 2024.

218. The City had been on notice of Plaintiff's EEOC gender, pregnancy and race-

discrimination Charge for less than four (4) weeks and Springfield's and Danley's actions

on or around April 4 smacked of retaliation and continued harassment of Plaintiff, and

such actions were of a kind and nature which persuade a reasonable worker from

opposing workplace discrimination or participating in an investigation of workplace

discrimination.

219. Nevertheless, Plaintiff provided written a response and objections to

rewritten evaluation the same day she received it, on or around April 4, 2024.

220. Plaintiff responded in writing to Springfield, in sum: That the assessment

was not accurate; that it did not address the stress she was under in 2023 during her

pregnancy which caused her to go into early labor; nor the harassment and stress added

by command staff.

221. In her response to the Springfield-rewritten Performance Evaluation,

Plaintiff also noted she gets along well with her fellow workers, “even to the point of

being constantly asked to help or assist / train [new dispatchers].” Plaintiff noted that,

prior to Kristy Hooper taking over as her supervisor, Amanda Traulson was Plaintiff's

supervisor and “we had no issues, we got along great!” Plaintiff further pointed out that

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if the Fellow Workers “Needs Improvement” score refers to Springfield, “then ask

yourself if you would be able to handle a stressful pregnancy . . . not to mention being

spoken to in a condescending manner from the Lt. [Danley] and him intentionally

changing off days to make my pregnancy harder. . .”

222. As Johnson's July 30 Discipline Notice and imposition of “Imposed

Probation” against Plaintiff arose from the July 28 hearing, but his negative take on

Plaintiff's “behavior” regarding the March 5, 2024, incident in Sgt. Springfield's office

was reached in bad faith and without any evidence presented, other than his own and

Chief Giles' evidence-free accusations, both acting as advocates for Springfield and

eschewing even the pretense of neutrality or good faith.

223. Johnson's July 30 Discipline Notice and imposition of “Imposed Probation”

against Plaintiff placed Plaintiff under even more heightened scrutiny by her superiors,

who looked even closer for “policy violations” to write up Plaintiff on.

224. According to one of the City's in house assistant attorneys in a conversation

with HPD Dispatcher Morgan Somerville, “the rules are different” for City employees

under “Imposed Probation.”

225. Johnson's “Imposed Probation” against Plaintiff, along with a 10-, then 8-,

day, unpaid suspension beginning August 12, 2024, materially altered or changed the

terms and conditions of her job, amounting to retaliation for Plaintiff's opposing

workplace discrimination regarding nursing mothers / sex / gender and participating in

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an investigation – such as it was – of workplace discrimination.

Sgt. Springfield in the Summer of 2024

226. During or around the spring of 2024, while Plaintiff was a nursing mother,

recently returned from maternity leave, one of Plaintiff's HPD Dispatch co-workers,

Allison, found out she was pregnant, and soon many within Dispatch knew.

227. During or around the first week of June 2024, as Plaintiff's late February

2024 EEOC Charge and three (3) March 2024 internal complaints / grievances against

sgt. Springfield remained pending, Springfield threatened Plaintiff's co-worker's job,

telling her: “You know, Allison, I might not let you come back to [to work following

maternity leave] once you pop out that baby.”

228. By the time Sgt. Springfield threatened Plaintiff's Dispatch coworker,

Allison, he already had a track record and the City had actual knowledge of Plaintiff's

accusations against Springfield for maternity-related discrimination in HPD Dispatch.

229. A few weeks after Sgt. Springfield threatened Allison's job, she submitted an

internal complaint to Defendant Huntsville's Human Relations Department (HR)

regarding Springfield.

230. During or around the second week of July, 2024, The City's HR invited

Allison, who is Caucasian, to meet with two HR staff members, a Ms. Green and a Mr.

Yarbrough.

231. Plaintiff, who is Black, was treated to no such HR meeting in March, or

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April, or May, or June, or July of 2024 after she complained about Springfield's

egregious, nursing mother / sex / gender discrimination in March 2024.

232. In August 2024, only days following the July 28 hearing and July 30 Deputy

Chief Johnson “Discipline Notice,” while Allison's internal complaint investigation was

ongoing, Sgt. Springfield maligned Allison to other HPD Dispatch employees, accusing

her of being “untrustworthy” (for reporting Springfield to HR for threatening her job

post-maternity leave).

233. In early September 2024 City HR found that Sgt. Springfield violated its

sex/pregnancy discrimination policies, but no disciplinary action taken against Sgt.

Springfield; or if any disciplinary action was taken, it was negligible-to-meaningless.

234. Defendant City's HR left it to HPD Chief Giles to discipline Sgt. Springfield,

but Chief Giles refused to discipline Springfield in any, or in any meaningful, way.

235. As with Plaintiff, the lack of any – or negligible, or meaningless –

disciplinary action taken against Sgt. Springfield sent a message to both Springfield and

throughout HPD and the ranks of Huntsville City employees: Sex / Gender

discrimination are not taken seriously by the City of Huntsville HPD and government.

236. While Plaintiff's coworker, Allison, was eventually refused the reasonable

accommodation of allowing her to return to her HPD Dispatch job following her

maternity leave, and, in fact, was retaliated against by Lt. Danley, at least she was

afforded a meeting with City HR and, within sixty (60) days of that meeting, received a

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letter from HR confirming that Springfield violated City policy.

237. The only substantive difference between Allison and Plaintiff was that

Allison was Caucasian and/or did not have a pending EEOC Charge when she

complained about Springfield in June 2024.

238. By the day of Giles's July 28 Departmental Hearing against Plaintiff, then

Johnson's July 30, 2024, “Discipline Notice,” they were both well aware that Springfield

was under HR investigation for Plaintiff's similarly situated coworker's internal

complaint / grievance for sex / gender / maternity-related workplace discrimination.

239. A reasonable person could conclude that by June 28, 2024, when Chief Giles

called for the July hearing against Plaintiff – five (5) days before Springfield even wrote

his July 3, 2024, internal complaint / grievance against Plaintiff – Giles and Johnson

were aware that a second female HPD dispatcher had complained about Springfield's

perpetrating sex / gender / maternity-related workplace discrimination.

240. A reasonable person could conclude that during the first half-or-so of 2024

Sgt. Springfield had established a pattern and practice, or a habit, of harassing women at

the workplace who were nursing, or soon-to-be, mothers, but that members of the HPD

Command Staff, including Chief Giles, Deputy Chief Johnson and Lt. Danley, worked

together to either ignore or cover for Springfield and his discriminatory acts.

241. A reasonable person could conclude that by late June and early July 2024,

rather than reverse course and make a full, thorough, good faith effort to uncover all the

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gender-based discriminatory proclivities of Sgt. Springfield, excused or given short-

shrift by his chain of command, that chain of command and City decision makers

decided to double-down on their attempts to damage, discredit, retaliate and build a

further paper trial against Plaintiff.

The July 30, 2024, Danley Meeting

242. As of July 2024, Lt. Danley was HPD Dispatch Division Manager, or held an

equivalent position.

243. On July 30, 2024, Lieutenant Danley called Plaintiff into Sgt. Springfield's

HPD Dispatch office (Danley did not maintain his own office in Dispatch) to give her

Deputy Chief Johnson's Discipline Notice.

244. When Plaintiff entered Springfield's small office she saw Danley seated at

Springfield's desk, with Sgt. Springfield and supervisor Hooper standing, standing

beside it. Plaintiff took the chair seated in front of the desk – the same chair she sat in on

March 5 and again, on April 2, 2024, when, on the latter date, Springfield handed

Plaintiff the 2023 Performance Evaluation he had rewritten.

245. When Plaintiff was seated Springfield, a large man, towered over her. To

Plaintiff Springfield appeared to be glowering at her menacingly.

246. Plaintiff did not understand why Springfield – who said nothing throughout

the 10-15 minute meeting – attended this meeting, but chose not to appear at the hearing

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two (2) days earlier when it was his July 3, 2024, internal complaint / grievance upon

which Chief Giles and Deputy Chief Johnson put so much stock.

247. Lt. Danley read Deputy Chief Johnson's “Discipline Notice” to Plaintiff,

then told her to sign a document acknowledging her receipt of it.

248. Plaintiff asked to call Human Resources before accepting and signing the

receipt for Johnson's “Discipline Notice,” effectively telling Danley she felt

uncomfortable; all present were on actual notice that the July 28 hearing had arisen out

of Plaintiff's March 5, 2024, incident with Springfield and Plaintiff's three (3) – as far as

Plaintiff knew – still-pending, sex / gender / nursing mother internal complaints /

grievances submitted against but Danley, and likely as not the then-pending EEOC

Charge of Discrimination.

249. Danley refused to allow Plaintiff to call or otherwise contact HR.

250. City of Huntsville Policy Section 3.2 states, in pertinent part:

Department Heads and Division Managers shall provide employees. . .

alleging discrimination accessibility [sic] to those who can respond to and
assist the individual, in order to ensure that their rights are not violated. . . .

251. Danley violated the above-cited City Policy Section 3.2.

252. In the alternative, Danley determined the City's HR Department would not

respond to or assist Plaintiff.

253. The July 30 meeting in Springfield's office was videoed and during the

second half of 2024 both Chief Giles and (at least) two (2) City Assistant Attorneys

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viewed the video.

254. Both Chief Giles and the (at least) two (2) City Assistant Attorneys were on

actual notice of Danley violating the above-cited Section 3.2 of City policy, but

condoned and supported Danley's violation of it.

255. Plaintiff notes that the Johnson “Discipline Notice” also included the

following: “Her performance evaluation is also due September 2024 and should be

completed as well.”

256. Deputy Chief Johnson's noting the September 2024 due date (month) for

completing Plaintiff's 2024 performance evaluation is tantamount to an admission of

Springfield's violation of City Policy for rewriting Plaintiff's then-supervisor's,

completed September 2023 performance evaluation, which Springfield did after Plaintiff

returned from work in February 2024 following her maternity leave; a Springfield-

rewritten performance evaluation that Danley and Johnson approved.

257. As the July 30 Danley Meeting in Springfield's office occurred on a Tuesday;

and as Johnson's “Discipline Notice” of the same date directed Plaintiff submit her

written, detailed plan to “improve her behavior” within “2 working days;” and as

Plaintiff's schedule was then Saturday-Tuesday (and off work Wednesday-Friday), she

had a good faith belief that her “written plan” was due on Monday, August 5, 2024.

258. On Monday August 5, 2024, Plaintiff reported for work at HPD Dispatch

with her “written plan” in hand. The dispatcher in charge that morning was Kimberly

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Hamilton, who directed Plaintiff to place her 1-page “written plan” in an intra-office

mail envelope and addressed to Deputy Chief Michael Johnson.

259. Plaintiff's August 5, 2024, “written plan” included the following, beginning

with:
My top priority has and will always be the officer safety aspect of my job.
My personal goals are to maintain my good work ethic, and continue to be
an encouraging coworker[,] especially to those that are just starting their
career at HPD. . .

260. Plaintiff's August 5, 2024, “written plan” continued:

I find it to be quite troublesome that my chain of command sees fit to ignore

the clear conflict of interest and self-serving nature of Sgt. Springfield
redoing my yearly evaluation some 6 months late and only after a complaint
was filed by me against him. . . [My chain of command's] actions suggest
that their true interest is to help paint a particular narrative of me personally
and professionally. . . The Fact is my Departmental Hearing was the result
of my commanding Sergeant forcing an emotionally traumatizing
interaction because he was upset that I was using his office to pump. This
contentious interaction was caused directly by Huntsville Police
Department's failure to provide me an appropriate and proper place to pump
as the law requires.

261. Plaintiff's August 5, 2024, “written plan” continued:

[My chain of command] have displayed themselves to be neither neutral nor

impartial. Fair, equal and even handed treatment is all I that continue to ask
for. . . I plan to continue to have room awareness and offer assistance where
I can. That I will also continue to provide the citizens with quality care and
get helpful information for [dispatch] calls for service so that officers can
have what they need to be prepared to respond to calls from our citizens.

Plaintiff then signed her name.

262. In her “written plan,” Plaintiff specifically referenced the triggering incident

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context – her need to pump breast milk, the City's failure to provide a law-compliant

room to do so, and Springfield's berating Plaintiff for using his office [as he had

previously authorized her to do].

263. Only women need to, and do, pump breast milk for their newborns.

264. At the heart of Plaintiff's allegations regarding Springfield's harassment,

discrimination and retaliation perpetrated on March 5, 2024, as well as the subsequent,

ongoing, continuing antagonisms, and harassment and retaliation that continued from

March 5, 2024, through Deputy Chief Johnson's July 30, 2024, Discipline Notice, is sex

and gender discrimination.

265. According to City Policy and/or City Administration in conjunction with

Human Resources, “sex/pregnancy” discrimination are interchangeable and/or otherwise

to be referred and regarded as “sex/pregnancy,” not as separate and distinguishable types

of civil rights or types of employment discrimination.

266. Plaintiff agrees with City Policy and/or City Administration in conjunction

with Human Resources that “sex/pregnancy” discrimination are interchangeable and/or

otherwise to be referred to and regarded as “sex/pregnancy,” and not as separate and

distinguishable types of civil rights or types of employment discrimination.

267. Plaintiff identifying and providing examples of Danley's discriminatory

intent regarding Black employees going back as far as three (3) years prior to Plaintiff

filing her February 2024 EEOC Charge; as well as the City / HPD ignoring or brushing

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off Black employees' – including Plaintiff – internal complaints of race-based double

standards in disciplinary actions taken against Black dispatchers going back another year

still, to 2020; as well as Plaintiff's June-July 2024 example of one of her Caucasian

coworkers getting an audience with two (2) City HR officials, when Plaintiff could get

none following her March 2024 internal complaints, also evidences both focused and

systemic race discrimination perpetrated up Plaintiff's HPD chain of command, by HPD

and City decision makers.

268. Plaintiff's February 26, 2024, EEOC Charge noted both sex and race

discrimination as one of the bases for that Charge, as well as pregnancy discrimination.

269. Sgt. Springfield, Lt. Danley, Deputy Chief Johnson and Chief Giles

conspiring with one another to harass, and retaliate against Plaintiff on the basis of sex /

gender / maternity being a nursing mother and opposing workplace discrimination and/or

participating in “investigations” regarding same, and to subject Plaintiff to race-based

workplace double standards and retaliation.

270. Near or around the time of the July 30 Danley Meeting wound down,

Plaintiff asked Lt. Danley about the status of any investigation into her internal

complaint(s) / grievance(s) regarding Sgt. Springfield.

271. With Sgt. Springfield standing, looking down at Plaintiff, as she asked this

question, Plaintiff showed remarkable courage.

272. Lt. Danley said there was an Internal Affairs investigation report.

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273. Plaintiff asked to see the Internal Affairs investigation report, or to get a

copy of it.

274. Lt. Danley told Plaintiff he'd contact Internal Affairs about getting a copy of

that investigation report and get it, or see about have Internal Affairs getting a copy of it

to Plaintiff.

275. Plaintiff never received a copy of any Internal Affairs, nor any other,

investigation report regarding her March 2024 internal complaints / grievance regarding

Sgt. Springfield.

August Through November 2024

276. From August through November 2024 the City and its HPD Dispatch

subjected Plaintiff to heightened monitoring and scrutiny, devising multiple “policy

violations” Plaintiff's supervisors could write-up and continue their efforts to harass,

hound and retaliate against Plaintiff for her opposing workplace sex / gender / pregnancy

and nursing mother, and race discrimination.

277. The various August through November 2024 “policy violations” alleged by

the City against Plaintiff (through the HPD and its command staff) to harass, intimidate

and retaliate against Plaintiff were of a type and degree that made other HPD dispatchers

incredulous, as the “violations” were not brought against Caucasian dispatchers and/or

against dispatchers who had mostly “kept their heads down” and not brought either

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EEOC Charges or internal complaints against the likes of Sgt. Dana Springfield.

278. A seeming exception to this pattern was Plaintiff's Dispatch co-worker,

Allison, Caucasian, who made an internal complaint in June 2024 against Springfield for

his threatening her job once she would return from maternity leave, as in September

2024 HR and its “EEO officer” found Springfield violated “City of Huntsville Equal

Employment Opportunity Policy as it pertains to sex/pregnancy.”

279. However, at its first opportunity to discriminate and retaliate against

Plaintiff's coworker, following Allison's maternity leave, the City – through Sgt.

Springfield's friend, Lt. Danley, denied Allison's attempt to return to work in December

2024 / January 2025, evidencing a pattern and practice of Danley and the City to “cover”

for and/or otherwise support Springfield, who the year before had bragged that

“retaliation is part of the job” in HPD Dispatch, no matter his degree of workplace

misanthropy.

280. From August through November 2024, the policy violations and/or

infractions drummed-up by the City to continue harassing and retaliating against

Plaintiff, by and through her Dispatch supervisors and HPD chain of command also

evidenced continuing disparate treatment of Plaintiff.

281. From August through November 2024 the City practically inundated

Plaintiff with accusations of policy violations and/or infractions, accompanied by write-

ups and various similar scoldings and reprimands in order to create a paper trail, a body

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of alleged misconduct, in order to discredit Plaintiff, retaliate against her for opposing

workplace discrimination, and/or retaliate against her for participating in an

“investigation” of workplace misconduct.

282. The City's August through November 2024 accusations against Plaintiff

included Plaintiff not properly picking a date for Chief Giles' July 28 hearing; to missing

her August 5 deadline to submit her “written plan” in response to Deputy Chief

Johnson's Discipline Notice; to failing to consistently state her name when answering

dispatch calls; to failing to properly notify and gaining supervisor permission to leave

work when her infant daughter was sick with a fever; to Plaintiff once making what

Danley called an “ugly,” “hateful,” face to him in response to a “Good morning” from

Danley.

283. As testimony and other evidence showed at – yet another – “Disciplinary

Hearing” to which Plaintiff was subjected on December 23, 2024, the City's alleged

“policy violations” brought against Plaintiff from August through November 2024 were

fabricated, exaggerated and/or manifestations of City and HPD continuing disparate

treatment and double standards to which Plaintiff had been subjected – going back

literally years, but especially in 2024 for her filing an EEOC Charge in late February, her

submitting internal complaints regarding the March 5, 2024, incident involving Sgt.

Springfield, her standing her ground and speaking honestly to HPD “Internal Affairs”

interrogators in late March, her opposing Springfield's April 2, 2024, rewrite of her

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September 2023 Performance Evaluation, participating honestly in Chief Giles' and

Deputy Chief Johnson's strange and untoward July 28, 2024, hearing, and writing and

submitting her “detailed writing” to Johnson's demand which again mentioned

Springfield's and the City's violations of (federal) law regarding Plaintiff's right to a law-

compliant place to pump.

284. On September 17, 2024, in response to one of the City's several post- July

hearing write-ups (this write up: a September 13, 2024, reprimand accusing Plaintiff of

“refusing” to pick a hearing date back in July; a reprimand Chief Giles personally

approved), Plaintiff submitted a one-page letter up her chain of command, denied the

accusation and corrected the record, and again noted that her chain of command was

“siding with Sergeant Springfield, possibly in response to my harassment complaint

[against him].” No investigation of this Plaintiff's allegation (of retaliation) commenced.

285. In both October and November 2024, Plaintiff submitted to HR internal

complaints / grievances, alleging “Retaliation, Harassment and discrimination,” in which

she detailed her grievances against the City / HPD apparatus that continued to hound her.

286. Those grievance details included inaccurate and retaliatory September 2024

Performance Evaluation mischaracterizations of Plaintiff as “insubordinate,” “rude” and

“appears to be angry,” “Angry Black Woman” stereotyping, as well as the 2024

discriminatory events leading up to October, then November 2024. A thorough, good

faith investigation of this opposition to workplace racism and/or retaliation did not occur.

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287. In her October 3, 2024, grievance Plaintiff outlined the February, March,

April and July instances of workplace race- and gender-based harassment, retaliation and

discrimination, noted with some specificity in this Complaint, infra.

288. In a letter dated October 17, 2024, City HR Director Byron Thomas

“denied” Plaintiff's grievance without undertaking any investigation. For the most part,

Thomas asserted Plaintiff's allegations were “time barred with no right to appeal” as they

were not filed “within 30 days of their occurrence,” notwithstanding the City permitting

Sgt. Springfield to file a July 3, 2024, grievance against Plaintiff arising out of the

March 5, 2024, incident.

289. According to HR Director Thomas, City Policy allows race – and by dent of

logic, all other – workplace discrimination, harassment and retaliation against employees

for opposing such discrimination, if the perpetrator(s) can get away with the

discrimination for thirty (30) days without it being complained of.

290. In his letter dated October 17, 2024, City HR Director Thomas also claimed

Plaintiff's March 2024 internal complaints / grievances against Sgt. Springfield regarding

the March 5 incident “were addressed by the Human Resources Department upon

notification,” which, in fact, never occurred.

291. In his July 5, 2024, email to Plaintiff, HR Analyst Yarbrough admitted and

apologized for HR not responding to Plaintiff's March 2024 internal complaints and, in

sum, further admitted that HR would not address her March 2024 complaints about

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Springfield because Plaintiff had previously filed an EEOC Charge.

292. City HR Director Thomas ended his October 17, 2024, letter to Plaintiff

saying he would refer all future grievances to the HR “Equal Employment Opportunity

Officer” to investigate.

293. On October 28, 2024, Plaintiff appealed HR Director Thomas's letter / to

him, that is, she appealed his decision dismissing and refusing to investigate her October

3, 2024, workplace discrimination complaint / grievance.

294. Plaintiff's October 28, 2024, appeal included, inter alia, Plaintiff's taking

exception to Mr. Thomas's (mis)characterizing her October 3 facts as outside of a 30-day

timeframe, “when it is continuous and ongoing retaliation, harassment and unnecessary

and [increased] scrutiny stemming from the initial [March 5, 2024] incident.”

295. In her October 28, 2024, appeal Plaintiff also noted “[t]he initial incident

that occurred March 5, 2024, with Sgt. Springfield would have NEVER taken place if I

was provided a designated room, free from intrusion (that locks) and wasn't a

bathroom[,] as required [under law]. . .”

296. Plaintiff's October 28, 2024, constituted two (2) protected activities, to wit:

both opposition to workplace sex / gender / nursing mother discrimination and

participation in an investigation, proceeding or hearing regarding allegation(s) of

workplace discrimination.

297. In her November 8, 2024, grievance to HR Plaintiff made additional, more

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recent allegations of discrimination and misconduct within HPD Dispatch, noting for

example, that she did not, in fact, “refuse to sign” her October evaluation (another

conjured write-up against Plaintiff), but, rather, noted that she had needed time to review

the evaluation and then sign it the following day.

298. In her November 8, 2024, grievance, Plaintiff noted her 2024 evaluations

appear to be influenced by Plaintiff's “race and ethnicity” – which other HPD

dispatchers, including Caucasian dispatchers, had corroborated as ongoing HPD

Dispatch bias / double standards / disparate treatment – as well as potential retaliation

stemming from my previous [and then-pending] EEOC charge.” No meaningful,

thorough, or good faith investigation of these allegations were undertaken by the City,

HR or HPD.

299. In her November 8, 2024, grievance, Plaintiff provided examples of “the

racial double standard” in HPD Dispatch:

(a) While a Caucasian dispatcher openly criticizing several

supervisors for being ineffective, that “many employees dispatchers are

dissatisfied with operations at HPD Dispatch, this dispatcher was taken

against her [as opposed to Plaintiff, who had been repeatedly reprimanded

and retaliated against for complaining about her supervisors].

(b) Another Caucasian dispatcher and sometimes “training

coordinator” has been “repeatedly rude and condescending toward trainees,

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often yelling at them” and fostering “division within the Dispatch team,” as

noted “by several staff members, and directly reported to the Chain of

Command,” without any “corrective measures.” Behavior Plaintiff gets

accused of.

(c) First Shift Supervisor Hooper, who is Caucasian, “yelling at”

employees, “throwing tantrums,” and “creating division among coworkers,”

contributing to “a tense and uncomfortable work environment,” but without

any steps taken to address Hooper's behavior.

300. In her November 8, 2024, grievance, Plaintiff continued, saying she was:

[P]articularly troubled by what appears to be a double standard in the

enforcement of workplace discipline. . . I have no personal issues with these
[aforementioned Caucasian] coworkers, I just continue to request the same
treatment as them. [Plaintiff alleged that HR and the HPD] chain of
command “know there are more instances...”

301. Plaintiff's November 8, 2024, grievance included and ended with the

following observation and request:

I am confident that addressing these concerns will help foster a more

respectful and collaborative workplace for everyone. I am also requesting a
thorough investigation into these matters, as they indicate a pattern of
discrimination, retaliation and harassment that undermine my performance
and integrity.

302. In a letter dated November 21, 2024, HR Director Thomas replied to

Plaintiff's November 8 grievance.

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303. HR Director Thomas's November 21 letter responding to Plaintiff's

November 8 grievance was pedantic, dismissive and indicative of no actual investigation

into the heart of Plaintiff's workplace discrimination and retaliation allegations.

304. Additionally, HR Director Thomas again refused to investigate any

allegation of workplace discrimination or retaliation that occurred more than thirty (30)

days prior to Plaintiff submitting her grievance as “time barred.”

305. Additionally, HR Director Thomas refused to investigate and specifically

denied Plaintiff's request to investigate systemic race discrimination within HPD

Dispatch.

306. In his November 21 letter responding to Plaintiff's November 8 grievance,

HR Director Thomas told Plaintiff he would refer any new allegations to the City's EEO

Officer.

307. In or around October 2024, Plaintiff had one meeting with the City's EEO

Officer, a Ms. Green.

308. Ms. Green was polite to Plaintiff, but appeared dismissive of Plaintiff's

complaints regarding workplace discrimination and told Plaintiff that she, Green, would

only look into the March 5, 2024, incident involving Springfield.

309. Plaintiff requested Ms. Green contact and meet again with her before she,

Ms. Green, made any final decisions regarding Plaintiff's allegations and/or any

investigation of those allegations by Ms. Green.

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310. In January 2025, Ms. Green contacted Plaintiff and invited her to meet again

with Ms. Green on January 22, 2025, to further discuss Plaintiff's allegations of

workplace discrimination.

311. In a January 21, 2025, email to Plaintiff, Ms. Green canceled the next day's

meeting with Plaintiff, telling Plaintiff: “I will reach out to you at my earliest

convenience to arrange a new time.”

312. Between January 21, 2025 and May 12, 2025, more than a quarter year has

passed without Ms. Green “reaching out” to Plaintiff regarding her, Plaintiff's, October

and November 2024, grievances.

The City Transfers Plaintiff, Notifies Her of Another Disciplinary Hearing

313. On November 25, 2024, Plaintiff met with supervisor Kristy Hooper in HPD

Dispatch.

314. During the November 25, 2024, meeting Plaintiff asked Hooper that, going

forward, if she, Plaintiff, ever “messed up at work,” please tell her in the moment and

not wait until weeks or months later.

315. Hooper then told Plaintiff she, Hooper, “didn't feel comfortable,” and wanted

Sgt. Springfield present.

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316. Everyone, including Kimberly Hamilton, whom Plaintiff asked to attend,

moved into Sgt. Springfield’s office, where Plaintiff attempted to continue her

conversation with Hooper.

317. Sgt. Springfield interrupted and told Plaintiff she would not address Hooper

but was to speak only to him. Plaintiff reiterated her request that if she committed any

workplace errors, to “tell me in real time” so she can address and correct them.

318. Sgt. Springfield replied only that he and Hooper would be doing what HR

directs them to do, effectively abdicating any supervisory roles or responsibilities.

319. The following day, November 26, 2024, Plaintiff was transferred out of

Dispatch, with Deputy Chief Michael Johnson telling Plaintiff to report to “Records” –

that is, the HPD Records Division – on the following day, November 27.

320. The November 26 transfer notice Johnson gave Plaintiff just said report to

Johnson, but Johnson told Plaintiff she would be going to Records.

321. The transfer notice was part of a notice of another “disciplinary hearing,”

called by Chief Giles, to be held against Plaintiff, the hearing to be held on December

23, 2024.

322. The November 26, 2024, transfer and disciplinary hearing notice were,

according to the Giles's notice, based on “alleged” causes, not facts.

323. Transferring Plaintiff from Dispatch to Records occurred almost one (1)

month before the December 23 Disciplinary Hearing was to occur.

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324. Johnson never gave Plaintiff a reason for her transfer.

325. Johnson never gave Plaintiff an explanation for her transfer.

326. No one gave Plaintiff any reason or explanation for her transfer to Records.

327. The City, through Giles's, transferring Plaintiff to Records was a disciplinary

and punitive act, and a demotion, which, according to Giles, was based on allegations,

not facts.

328. Plaintiff lost prestige when the City, through Giles, transferred her from

Dispatch to Records.

329. Plaintiff lost overtime, comp time and job responsibilities when the City,

through Giles, transferred her from Dispatch to Records.

330. Giles took Plaintiff's First Responder status, along with benefits that went

with that status, when he transferred her to Records in late November 2024.

331. When Giles sent Plaintiff to Records the City, through HPD decision makers,

cut off Plaintiff's employee email and ability to access her Kronos time card account.

332. Plaintiff had little to nothing to do while employed in Records and certainly

did not have the satisfaction of working with the public and police officers that came

with the job and responsibility of being a dispatcher.

333. The City, through Giles, transferring Plaintiff from Dispatch to Records

occurred less than three (3) weeks following Plaintiff engaging in the protected activity

of submitting her November 8, 2024, workplace discrimination grievance to HR.

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334. The City, through Giles, transferring Plaintiff from Dispatch to Records

occurred less than four (4) months following Plaintiff engaging in the protected activity

of submitting her October 28, 2024, appeal of HR Director's October 21, 2024, decision.

335. If the City and/or Giles considered Plaintiff's transfer / demotion to records

was a disciplinary act, then it occurred weeks before Chief Giles' Disciplinary Hearing

occurred.

336. The City, through Giles and with the aid and assistance of Deputy Chief

Johnson, constituted mistreatment which might have dissuaded a reasonable worker

from making or supporting a charge of discrimination and, thus, defined retaliation.

337. Additionally, and as admitted by both HR Director Thomas and EEO Officer

Green, the City refused to even investigate various workplace discrimination allegations

made by Plaintiff in her October 3 and November 8, 2024, internal complaints /

grievances, and October 28, 2024, appeal, which constitute a failure to investigate and,

thus, employer mistreatment which might have dissuaded a reasonable worker from

making or supporting a charge of discrimination – such mistreatment defining one type

of prohibited retaliation.

Early December 2024 – The Personnel Bd. Hearing

338. On or about December 3, 2024, HR Director Thomas notified Chief Giles by

letter that Plaintiff would be allowed an appeal hearing (of Mr. Thomas's October 21,

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2024, letter / decision), which would take place on December 10, 2024, in Huntsville

City Hall. The City's Personnel Committee, a City Attorney and, last, Plaintiff, were

copied with Mr. Thomas's letter to Giles.

339. On December 6, 2024, an in-house assistant City Attorney (with the City's

top attorney's authorization and approval) submitted a “Show Cause” Request to the City

Personnel Committee.

340. The City's (through its in-house attorneys') Show Cause request to the

Personnel Committee reiterated HR Director Thomas's position that “a majority, if not

all, of Mrs. Brady's grievance is not permissible under [City Policy].”

341. The City (through its in-house attorneys) argued that “each of the dates [of

the discrimination and/or retaliation Plaintiff alleged was perpetrated by the City through

Plaintiff's HPD chain of command] far exceed the 30-day time limit [to file a workplace

discrimination grievance under City Policy].

342. The City (through its in-house attorneys) asked the Personnel Committee to

deny Plaintiff a “full evidentiary hearing” until the Board first determined whether or not

Plaintiff's grievance was even “allowable” under City Policy.

343. Later that same day, December 6, 2024, HR Director Thomas authored a

letter to Plaintiff that her December 10, 2024, appeal hearing would be “for show cause

only to address whether [Plaintiff's October 3, 2024] grievance is appealable.” Plaintiff

did not receive Thomas's letter until December 9, the day before the hearing.

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344. On December 10, 2024, the City's 3-Member Personnel Committee held its

“show cause” hearing on Plaintiff's appeal of her October 3, 2024, grievance.

345. Plaintiff and her husband, Officer Michael Brady, attended the December 10,

2024, Personnel Committee hearing and spoke to the Committee during the hearing.

346. Plaintiff's appealing Thomas's October 21, decision on her October 3, 2024,

grievance, and speaking at the City Personnel Committee's December 10, 2024, Show

Cause hearing, constituted Plaintiff engaging in a protected activity on December 10,

2024.

347. Chief Giles attended the December 10, 2024, Personnel Committee Show

Cause hearing, but did not speak; he only watched.

348. The City's in-house assistant attorney, continuing both HR Director

Thomas's position and her December 6 Show Cause request, argued Plaintiff's workplace

discrimination grievances were “Time Barred.”

349. As with Mr. Thomas, the City -writ-large took the position that workplace

sex / gender / nursing mother and race-based discrimination and / or retaliation for

opposition to such discrimination is permissible, or at least not impermissible, by City of

Huntsville supervisors and division and department heads if an employee on the

receiving end of such discrimination or retaliation fails to report and complain about the

discrimination within thirty days of the unlawful acts.

350. The City's in-house assistant attorney held out to the the Personnel

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Committee that the City's Human Resources Department had “already looked into”

Plaintiff's 2024 complaints of discrimination, race-and gender-based disparate treatment,

her allegations that the City had failed to provide a law-compliant space for her to pump

breast milk and retaliation.

351. In fact, as evidenced by HR Analyst Dylan Yarbrough's July 5, 2024, email

to Plaintiff, HR had not “looked into” Plaintiff's discrimination and harassment

allegations, beginning with her March grievances against Sgt. Springfield, beginning

with the March 5, 2024, incident in his office. Plaintiff made this point at the Show

Cause hearing.

352. At the Personnel Committee's Show Cause hearing, HR Director Thomas

held out to the Personnel Committee that he had “paperwork” (or some such word)

showing an investigation of Plaintiff's earlier grievances had occurred.

353. When Plaintiff asked Mr. Thomas to please show her the “paperwork,”

Thomas said, “I'd have to get it,” or words to that effect.

354. Thomas never provided Plaintiff with the referenced “paperwork.”

355. Officer Michael Brady spoke on his wife's behalf at the end of the Show

Cause hearing, in sum informing the Personnel Committee that his wife, Katrina, just

wanted to be “treated equally and fair,” or words to that effect.

356. Personnel Committee Chair Hamilton adjourned the Chow Cause hearing,

telling Plaintiff that the Board would get back with her within fourteen (14) days.

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Late December 2024 – Second EEOC Charge, Second Hearing

357. On December 19, 2024, Plaintiff filed a new, second, EEOC Charge of

Discrimination against the City of Huntsville.

358. In sum and substance Plaintiff's December 19, 2024, EEOC Charge alleged

the City's race- and gender-based employment discrimination and retaliation (as well as

pregnancy discrimination and violations of the PUMP for Nursing Mothers Act).

359. That same day the City's Legal Department also received a copy of Plaintiff's

new, December 19, 2024, EEOC Charge.

360. On December 23, a Disciplinary Hearing against Plaintiff was held in City

Hall.

361. The City chose a Hearing Officer to oversee the December 23 Disciplinary

Hearing without any input from Plaintiff or her attorney; the City never identified who

the Disciplinary Hearing Officer would be; and Plaintiff and her attorney would not find

out who the City's Hearing Officer was until they walked into the Disciplinary Hearing.

362. The City's Hearing Officer, a Huntsville attorney, was a former City

Huntsville in-house assistant attorney and touts this experience on his website biography.

363. The City was allowed to audio record the Disciplinary Hearing, but

prohibited Plaintiff from doing so.

364. Chief Giles attended and was present throughout the December 23, 2024,

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Disciplinary Hearing against Plaintiff; he sat at the City attorneys' table.

365. The City called three (3) witnesses to testify against Katrina Brady at the

December 23 Disciplinary Hearing: HR Analyst Dylan Yarbrough, Lt. Michael Danley

and Deputy Chief Michael Johnson.

The City's Witnesses

366. Dylan Yarbrough, not an eye witness to an incident where Plaintiff left work

early with a doctor's note, nevertheless testified that she violated City Policy.

367. Yarbrough was unfamiliar with the Dispatch practice of employees not

asking for permission for sick leave, but, instead, notifying the person in charge of the

employees need for sick leave.

368. Yarbrough did not appear to fully understand City Policy or common HPD

Dispatch practices.

369. Yarbrough, a City witness, testified that supervisors and department heads

application of Policy was “optional,” that they have “discretion” to apply rules and

policies, and mete out discipline, as they see fit.

370. Yarbrough offered no direct evidence of any behavior of Plaintiff's in

Dispatch. He saw nothing of her behavior, work ethic, actions, in her job as a dispatcher.

371. In his testimony Lt. Danley admitted he was Sgt. Springfield's friend.

372. Lt. Danley testified he wrote-up Plaintiff for looking at him with an “ugly”

face and looking “hateful” one time when he said, “Good morning,” to her.

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373. In his testimony Lt. Danley admitted that at his July 30, 2024, disciplinary

meeting with Plaintiff in Sgt. Springfield's office that he prohibited Plaintiff from

contacting HR when she asked to.

374. In his testimony Lt. Danley admitted that, when asked by Plaintiff, he told

her he would contact HPD “Internal Affairs” about getting an “Investigation Report”

regarding Plaintiff's March 2024 internal complaints / grievances filed against

Springfield to her, but no one ever gave any such “report” to Plaintiff.

375. Danley admitted that he demanded Plaintiff sign the disciplinary paperwork

he pushed across Springfield's desk to her and refused to allow Plaintiff to read the

disciplinary paperwork before signing, saying he had already read it to her.

376. In his testimony Deputy Chief Michael Johnson’s admitted he never actually

witnessed Plaintiff during work, during her (at the time) eight (8)-plus years job as an

HPD dispatcher.

377. During the December 23, 2024, hearing, Deputy Chief Johnson testified

through a letter he wrote that Ms. Brady “bullied” and “intimidated” and was

“argumentative” towards co-workers, but Johnson admitted he never actually saw Ms.

Brady bully or intimidate anyone and that he only “heard of” these things through “co-

workers” and during co-worker “exit interviews,” but could not name even one of these

“co-workers” or recall any specific “exit interview.”

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Katrina Brady's Witnesses

378. Plaintiff Katrina Brady called three (3) witnesses to testify at the December

23, 2024, Disciplinary Hearing: Sheryl Seif, Rosalee Martin and Kimberly Hamilton, all

career dispatchers with HPD.

379. All three (3) of Plaintiff's witnesses had worked with her for years, had

witnessed her on the job and had years' experience in Dispatch's day-in-and-day-out

policies and practices.

380. All three (3) of Plaintiff Brady's witnesses, Ms. Seif, Ms. Martin and Ms.

Hamilton testified that over the years they each witnessed Plaintiff being subjected to

double standards in how she was scrutinized and disciplined in Dispatch.

381. Chief Kirk Giles sat stone-faced, within a few feet of these dispatchers, and

looked on, appearing unfazed and uninterested in these HPD dispatchers' testimony.

382. During the Disciplinary Hearing all the HPD dispatchers testified it was

common knowledge, that it was a practice within Dispatch, that “Retaliation is part of

the job.”

383. Ms. Martin testified that she heard Sgt. Springfield actually proclaim that,

“Retaliation is part of the job,” as Chief Giles continued to stare from the City attorneys'

table, still unfazed.

384. At the Disciplinary Hearing City attorneys tried to introduce a document into

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evidence, a statement purported to have been written by Morgan Somerville in March

2024, the same document Morgan Somerville debunked or distance himself from in his

October 3, 2024, statement, which read in part: “I did not hear any party 'yelling.' I can

say that I did hear Mrs. Brady upset and crying/near crying but at no time any

yelling. . . .” The City gave up when they could not authenticate the document.

385. The City's HR and/or attorneys had actual knowledge of how on October 3,

2024, Morgan Somerville discredited the very March 2024 document its attorney

attempted to introduce into evidence at the December 23, 2024, Disciplinary Hearing.

Personnel Committee's Decision, Its Invitation to Plaintiff and Plaintiff's Response

386. On December 24, 2024, the Personnel Committee issued its “Decision” from

the December 10, 2024, Show Cause hearing.

387. In sum, the Personnel Committee's December 24, 2024, Decision rubber-

stamped the City and decided the 2024 discrimination complained of by Plaintiff in her

October 3, 2024, grievance was “not permissible” because the discrimination was “not

timely” filed.

388. As with HR and the City attorneys, the City's Personnel Board follows City

Policy that prohibits workplace sex-, gender-, pregnancy- and nursing mother, and race

discrimination and retaliation only if complained of within thirty (30) days of the

perpetrator committing such employment discrimination or retaliation, and, as in

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Plaintiff's case, ongoing and/or systemic employment discrimination is allowed within

the City, unless the “30 Day Rule” is strictly followed.

389. The, by definition, ongoing and/or systemic workplace discrimination falls

within the City's 30 Day Rule is nevertheless not considered by the City, or its Personnel

Committee.

390. The Personnel Committee's December 24, 2024, Decision nevertheless

allowed Plaintiff until January 7, 2025, to submit additional, “concise” information

“directly related to” the August 4, 2024, 8-day unpaid suspension (one of the results of

the July 28, 2024, hearing).

391. City Policy or practice required Plaintiff to submit any additional

information to the Committee through HR.

392. As the Personnel Committee's December 24, 2024, Decision copied the HR

Director, the City's assistant attorney and Chief Giles, on January 6, 2024, Plaintiff

submitted her additional information to HR Director Thomas, the City attorney, her own

lawyer, and Chief Giles.

393. By Plaintiff's emailing her January 6, 2024, Personnel Committee response /

submission to Chief Giles, HR Director Thomas and the City assistant attorney, on that

day each of them had actual notice of Plaintiff's re-assertion of unaddressed, unresolved,

uninvestigated, and/or additional grievances against the Huntsville Police Department

and City of Huntsville contained within that submission.

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394. Plaintiff's submission to the Committee noted, inter alia, that she had

encountered and endured “systemic racism, ongoing harassment and retaliation” during

her time as an HPD dispatcher.

395. Plaintiff's submission to the Committee included between 30-40 additional

facts, examples of workplace discrimination (in gender, race, retaliation) that were

directly connected to the July 28, 2024, hearing and its aftermath.

396. The additional facts include many contained in this Complaint, including

those surrounding, detailing, the March 5, 2024, Springfield Incident; the City's failure

or refusal to conduct a thorough, good faith (or any meaningful) investigation of

Plaintiff's March internal complaints / grievances; the City's failure / refusal to provide a

law-compliant place for Plaintiff to pump; Springfield rewriting Plaintiff's Personnel

Evaluation (with Danley and Johnson okaying it); the City's April 9, 2024, policy

updates making no mention of protections for nursing mothers or prohibiting retaliation

against nursing mothers who try to avail themselves of federally protected rights; Lt.

Danley's belligerency at the July 30, 2024, meeting he called to present Plaintiff with

Johnson's Discipline Notice, and the like.

397. Plaintiff then waited to hear back from the Personnel Committee.

Findings and Retaliatory Discharge

398. On the afternoon of January 7, 2025, Plaintiff's lawyer received an email

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from the City's HR Department, which he promptly forwarded to his client, Plaintiff –

the City Hearing Officer's “Findings of Fact” from the December 23, 2024, Disciplinary

Hearing.

399. In fact, the Hearing Officer submitted his “Findings of Fact” (hereafter

“Findings”) to the HR Director on January 6, but it took the HR Director an additional

day to forward the “Findings” to Plaintiff's lawyer.

400. The “Findings” received by Plaintiff on January 7 were deeply flawed.

401. The “Findings” received by Plaintiff on January 7 were incomplete and

skewed in favor of the City and HPD.

402. City Policy 13.8 allows either party to a Disciplinary Hearing three (3)

business days from receipt of such hearing's “Findings” to submit a written request for

reconsideration – of what, exactly, the Policy is not clear – to the HR Director based on

errors in the Hearing Officer's “Findings” or when the party alleges the City Hearing

Officer's “drawn conclusions.”

403. City Policy 13.8 thus gave Plaintiff until January 10, 2025, to submit her list

of City Hearing Officer errors to HR.

404. City Policy 13.8 gives its Hearing Officer “sole discretion” to modify the

“Findings.”

405. City Policy provides that its City Hearing Officer acts as a backstop, a check,

for – the final arbiter of – his own errors, which itself is deeply flawed policy.

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406. On the morning of January 8, 2024, less than 24 hours since Plaintiff and her

attorney received the City Hearing Officer's “Findings,” Chief Giles fired Plaintiff.

407. Chief Giles had to secure the approval of Huntsville's Mayor, Tommy Battle,

in order to effectuate firing Plaintiff.

408. While Chief Giles attended the December 23, 2024, Disciplinary Hearing, as

well as the December 10, 2024, Show Cause hearing before the Personnel Committee,

and the June 28, 2024, “Departmental / Disciplinary Hearing,” and had actual notice and

knowledge of Mayor Battle did not attend any of these hearings and, to the best of

Plaintiff's knowledge and understanding, was not apprised of them or shown any

transcripts (if the City possessed such) of them.

409. For example, Mayor Battle did not hear the three (3) HPD dispatchers'

December 23, 2024, testimony that Plaintiff was subjected to disciplinary double

standards or that Sgt. Springfield – above Plaintiff in her chain of command – had

proclaimed that within HPD Dispatch, “Retaliation is part of the job,” or other testimony

and evidence that debunked, undermined and/or otherwise discredited Giles' accusations

aimed at Plaintiff.

410. Likewise, while Chief Giles had actual notice and knowledge of Plaintiff's

January 6, 2025, submission / memorandum to the Personnel Committee in which she

(again) stated dozens of instances of workplace discrimination within HPD Dispatch, to

the best of Plaintiff's knowledge and understanding, Mayor Battle had no such notice,

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knowledge or understanding of the underlying circumstances of Plaintiff's plight.

411. When Chief Giles sought out and obtained Mayor Battle's blessing and

authorization to fire Plaintiff, he omitted information and/or otherwise spun a story and

weaved a narrative that kept Mayor Battle in the dark about the actual circumstances of

Plaintiff's work and the employment discrimination suffered by her in 2024.

412. On January 7 or 8, 2025, Chief Giles, armed with discriminatory and/or

retaliatory intent, manipulated and/or lied to Mayor Battle, the City's ultimate decision

maker in firing Plaintiff, in order to effectuate Plaintiff's termination.

413. Chief Giles's bad faith and discriminatory intent are at least in part

demonstrated by his acts and omissions during 2024, and before, which include, but are

not limited to: His failure or refusal to train and supervise his Command Staff and

subordinates (including Lieutenants and Sergeants) regarding basic law regarding the

rights of nursing mothers employed by HPD.

414. Chief Giles's bad faith and discriminatory intent are at least in part

demonstrated by his acts and omissions during 2024, and before, which include, but are

not limited to: His siccing HPD Internal Affairs officers on Plaintiff in March 2024, not

to investigate Plaintiff's internal employment discrimination complaints / grievances

against Springfield, but to interrogate Plaintiff as adversaries, then, with his blessing,

bury, give up on or otherwise stop any further investigation of her March 2024

grievances against Sgt. Springfield.

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415. Chief Giles's bad faith and discriminatory intent are at least in part

demonstrated by his acts and omissions during 2024, and before, which include, but are

not limited to: His calling for a Departmental / Disciplinary Hearing against Plaintiff on

July 28, 2024, almost a week before Sgt. Springfield wrote his “grievance” against

Plaintiff.

416. Chief Giles's bad faith and discriminatory intent are at least in part

demonstrated by his acts and omissions during 2024, and before, which include, but are

not limited to: His allowing Sgt. Springfield (Plaintiff's July 3, 2024, accuser) to skip

the July 28 hearing with no consequences.

417. Chief Giles's bad faith and discriminatory intent are at least in part

demonstrated by his acts and omissions during 2024, and before, which include, but are

not limited to: His deputizing, receiving the cooperation of, and conspiring with Deputy

Chief Michael Johnson to act as Sgt. Springfield's surrogate during the July 28 hearing.

418. Chief Giles's bad faith and discriminatory intent are at least in part

demonstrated by his acts and omissions during 2024, and before, which include, but are

not limited to: His ignoring and/or condoning both systemic and targeted sex / gender

and race discrimination within the Huntsville Police Department.

419. Chief Giles's bad faith and discriminatory intent are at least in part

demonstrated by his acts and omissions during 2024, and before, which include, but are

not limited to: In a contemporaneous, Summer of 2024, maternity-related situation

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within HPD Dispatch, sending a message / signaling to HPD and HPD Dispatch that he

will overlook or condone sex / gender / maternity-related discrimination when he failed

or refused to discipline (or meaningfully discipline) Sgt. Springfield after he was found

to have violated sex discrimination policy against one of Plaintiff's coworkers.

420. Chief Giles's bad faith and discriminatory intent are at least in part

demonstrated by his acts and omissions during 2024, and before, which include, but are

not limited to: On December 23, 2024, his ignoring sworn and unrebutted testimony

from three (3) HPD dispatchers (other than Plaintiff) regarding retaliation being “part of

the job” in Dispatch.

421. Chief Giles's bad faith and discriminatory intent are at least in part

demonstrated by his acts and omissions during 2024, and before, which include, but are

not limited to: His ignoring Plaintiff's January 6, 2025, submission / memorandum to

the City Personnel Committee which detailed between 30-40 additional facts, examples

of workplace discrimination (in gender, race, retaliation) within HPD Dispatch.

422. Chief Giles's bad faith and discriminatory intent are at least in part

demonstrated by his acts and omissions during 2024, and before, which include, but are

not limited to: His using Mayor Battle as a “cat's paw” to fire Plaintiff on January 8,

2025, with actual knowledge that Plaintiff had three (3) days from the date of receipt of

the City Hearing Officer's “Findings” to contest and rebut those findings – Giles wanted

to speed up the process of firing Plaintiff before she had a chance to submit her list of

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City Hearing Officer errors.

423. In or around June 2023, about 18 months before the City (through Chief

Giles and Mayor Battle) fired Plaintiff, Deputy Chief Johnson spoke with former HPD

dispatcher (and part-time Dispatch supervisor / “designee”) Matt Dravecky about the

reasons Mr. Dravecky decided to resign from his employment with the City.

424. Mr. Dravecky told Johnson, in part, that he, Dravecky, had problems with

and/or could not abide the way Sgt. Springfield behaved in Dispatch, notably: Towards

Plaintiff.

425. Mr. Dravecky, who had worked for years in Dispatch with Plaintiff and who

had personal knowledge of activities within Dispatch, told Johnson and saw Plaintiff

being mistreatment and targeted for selective disciplinary actions.

426. On the same or another occasion close in time, Mr. Dravecky spoke with both

Deputy Chief Johnson and with HR Analyst Yarbrough about how there would be

selective and uneven application of policies among HPD dispatchers; and his talking

with the City's EEO officer about workplace discrimination, especially that aimed at

Katrina Brady.

427. Mr. Dravecky saw Johnson taking notes at this 2023 meeting where Mr.

Dravecky put Johnson on actual notice of these workplace discrimination issues.

428. Deputy Chief Johnson's bad faith and discriminatory intent are at least in part

demonstrated by his acts and omissions during 2024, and before, which include, but are

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not limited to: Within days or weeks of Plaintiff complaining up her Chain of Command

about Springfield's discrimination and harassment in March 2024, his conspiring with

Lt. Danley and Sgt. Springfield in late March or early April 2024, to negatively rewrite

and/or otherwise alter Plaintiff's 2023 Performance Evaluation, which had already been

completed in September 2023, but not yet given to Plaintiff.

429. Deputy Chief Johnson's bad faith and discriminatory intent are at least in

part demonstrated by his acts and omissions during 2024, and before, which include, but

are not limited to: His actual knowledge that Chief Giles's June 28, 2024, request for a

“Departmental / Disciplinary Hearing” against Plaintiff was made almost a week before

Sgt. Springfield even wrote his “grievance” against Plaintiff, but conspired with Giles

and other HPD officers to nevertheless go forward with the hearing.

430. Deputy Chief Johnson's bad faith and discriminatory intent are at least in

part demonstrated by his acts and omissions during 2024, and before, which include, but

are not limited to: His conspiring with Chief Giles to act as Sgt. Springfield's surrogate

during the July 28 hearing, even though he knew the entire hearing was an exercise in

bad faith, given that Giles called for it before Springfield even wrote his “grievance”

against Plaintiff, upon which the hearing was supposedly premised.

431. Deputy Chief Johnson's bad faith and discriminatory intent are at least in

part demonstrated by his acts and omissions during 2024, and before, which include, but

are not limited to: His authoring the City's July 30, 2024, “Discipline Notice” against

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Plaintiff – which also subjected her to a 10-day unpaid suspension – premised upon

allegations Johnson knew not to be true and with him acting as Springfield's advocate

and witness at the July 28 hearing against Plaintiff.

432. Upon information, belief and all plausibility, Plaintiff allegs Johnson

conspired with Giles to draft his, Johnson's, dubious, bad faith, harassing and retaliatory,

July 30, 2024, Discipline Notice against Plaintiff, given his service and fidelity to Giles'

bad faith and discriminatory actions in the days and weeks to his writing it.

433. Deputy Chief Johnson's bad faith and discriminatory intent are at least in

part demonstrated by his acts and omissions during 2024, and before, which include, but

are not limited to his conspiring with Chief Giles and others to falsely testify against

Plaintiff at the December 23, 2024, Disciplinary Hearing, that is, to testify to “facts”

about which he had no knowledge and/or to which he knew were patently untrue, but

made, asserted and intended to demean, discredit and humiliate Plaintiff in order to get

her fired – all to harass and retaliate against Plaintiff for engaging in protected activities

under relevant law.

Chief Giles's False Claims and Firing Aftermath

434. Chief Giles claimed to have based his firing Plaintiff and/or recommendation

to Mayor Battle to join him in firing Plaintiff, on the City Hearing Officer's “Findings,”

notwithstanding Chief Giles's actual knowledge of numerous errors in and omissions

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from those “Findings.”

435. Chief Giles's claim was false, made in bad faith, was discriminatory and

retaliatory.

436. In a document dated January 8, 2024, and delivered by Johnson to Plaintiff,

virtually, if not literally, all of Chief Giles's “reasons” for recommending Mayor Battle

join him in firing Plaintiff were had been debunked, discredited, stale, vague and/or

policy violation accusations which Plaintiff's fellow HPD dispatchers had testified were

applied using a “double standards” against Plaintiff.

437. Examples of Giles's debunked and/or discredited accusations included

“unexcused absences” which, in fact, had been excused pursuant to long-standing

Dispatch practice.

438. Examples of Giles's stale justifications for firing Plaintiff were ginned-up,

bad faith, reprimands from four (4) and five (5) years earlier; noting that the HR Director

and City assistant attorneys repeatedly argued: “Time barred, time barred,” regarding

Plaintiff's allegations of ongoing employment discrimination, harassment and/or

retaliation, and/or systemic discrimination.

439. Examples of Giles's vague allegations were catch-all accusations of “conduct

unbecoming” and “insubordination” – contrasted with Plaintiff's numerous, specific

examples of workplace harassment, disparate treatment and retaliation perpetrated by

those above her in her Dispatch chain of command.

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440. As Mayor Battle knew nothing of these allegations, or the degree to which

they were vacuous, made in bad faith and/or otherwise selectively used by Giles and

HPD against Plaintiff, evidencing disparate treatment based on race, sex / gender and

retaliation, Mayor Battles accepted Giles's narrative and recommendation.

441. On January 10, 2025, even though she had been fired, after reviewing the

City Hearing Officer's “Findings” and consulting with her lawyer, Plaintiff directed her

lawyer to submit her objections to the City Hearing Officer's “Finding of Facts” and

“Request for Reconsideration,” which her attorney did on the morning of January 10,

2025.

442. Plaintiff's January 10, 2025, Objections listed around fifty (50) examples of

December 23, 2024, Disciplinary Hearing facts that did not make it into the City Hearing

Officer's “Findings.”

443. About two (2) weeks later, on January 23, 2025, the City Hearing Officer

“rubber stamped” himself, choosing “not to modify my findings of fact.”

444. The City Hearing Officer was not, as City Policy touted, “impartial.”

445. Although she waited more than four (4) months, Plaintiff never heard back

from the Personnel Committee after submitting her additional facts on January 6, 2021.

446. It is evident both the City Personnel Committee and the City EEO officer

(who “postponed” her January 22, 2024, meeting with Plaintiff), figured Chief Giles's

and Mayor Battle's January 8 firing of Plaintiff relieved them of any need to investigate

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or consider Plaintiff's claims of workplace discrimination when she was a City

employee, that the issues and harm to Plaintiff just “went away” when the City fired her.

Damages
447. Defendants' individual and concerted acts and omissions set forth herein

proximately caused Plaintiff to suffer lost income and benefits.

448. Defendants' individual and concerted acts and omissions set forth herein

proximately caused Plaintiff to suffer humiliation, anxiety, stress, embarrassment,

frustration and other mental anguish.

449. Defendant Huntsville's acts and omissions from in or around the summer of

2023 until Plaintiff took maternity leave in October 2023, proximately caused Plaintiff to

suffer humiliation, anxiety, stress, embarrassment, frustration and other mental anguish,

particularly regarding her ability to reasonably schedule and attend visits to her OBGYN

during her pregnancy.

450. Defendant Huntsville's acts and omissions from in or around the summer of

2023 until Plaintiff took maternity leave in October 2023, proximately caused Plaintiff to

suffer humiliation, anxiety, stress, embarrassment, frustration and other mental anguish,

which contributed to her going into early labor, endangering both her and her baby

daughter.

451. Defendant Huntsville's acts and omissions were intentional and/or

perpetrated wantonly and/or with reckless disregard for Plaintiff's rights under the law.

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452. Defendants Giles's and Johnson's conspiring with each other to subject

Plaintiff to workplace discrimination in the form of disparate treatment, harassment and

retaliation, proximately caused Plaintiff to suffer humiliation, anxiety, stress,

embarrassment, frustration and other mental anguish.

453. Defendants Giles's and Johnson's conspiring with each other to subject

Plaintiff to workplace discrimination in the form of disparate treatment, harassment and

retaliation, was intentional and/or perpetrated wantonly and/or with reckless disregard

for Plaintiff's equal protection, due process and/or other civil rights.

COUNT I
Title VII – 42 U.S.C. § 2000e-2(m)
Employment Discrimination Based on Gender / Sex

455. By this reference Plaintiff reiterates and incorporates the allegations set forth

Paragraphs 1-7; 10-13; 15-92; 101-103; 105-230; 232-266; 268-285; 287-297; 301-304;

306-423; and 425-453, as if fully set out herein.

456. Plaintiff, a woman, is a member of a protected class under Title VII.

457. Plaintiff's former employer, Defendant Huntsville, by and through HPD, HR,

and Plaintiff's supervisors and other decision makers, discriminated against Plaintiff in

her employment terms and conditions based on her sex / gender both during Plaintiff's

pregnancy in 2023 and in 2024, during the time she was a nursing mother.

458. But for Plaintiff's sex / gender Defendant Huntsville would not have

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subjected her to the materially adverse employment action/s described herein.

459. The circumstances described herein show Plaintiff's sex / gender was at least

a motivating factor for the disparate treatment and averse employment actions Huntsville

perpetrated against Plaintiff.

460. At the very least, the circumstances described herein show a convincing

mosaic – that is, evidence demonstrating, among other things, very suspicious timing,

ambiguous and/or incriminating statements or actions, and other varied acts and

omissions – from which an inference of Huntsville's discriminatory intent may be drawn.

461. Defendant Huntsville violated Title VII by discriminating against Plaintiff

based on her sex / gender, demonstrating deliberate indifference in both its acts and

omissions perpetrated against Plaintiff and in its failure or refusal to adequately train and

supervise its Chief of Police, Police Department Command Staff, HR staff and other

persons above Plaintiff in her chain of command.

462. Defendant Huntsville, by and through its unlawful acts and omissions,

contributed to Plaintiff's going into early labor in October 2023, and reducing her

production of breast milk in the spring and summer of 2004, endangering both Plaintiff

and her baby daughter.

463. By its unlawful acts and omissions Defendant Huntsville proximately caused

Plaintiff to suffer lost income, stress, anxiety, and other mental anguish above and

beyond the stressors of ordinary life and work.

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COUNT II
Title VII – 42 U.S.C. § 2000e-2(m)
Employment Discrimination Based on Race

464. By this reference Plaintiff reiterates and incorporates the allegations set forth

Paragraphs 1-7; 10-12; 14; 38-47; 49; 91-102; 104-107; 195; 206-219; 226-231; 236-

237; 267-269; 276-277; 281-289; 291; 298-395; 398-453, as if fully set out herein.

465. Plaintiff, who is African American, Black, is a member of a protected class

under Title VII.

466. Plaintiff's former employer, Defendant Huntsville, by and through HPD, HR,

and Plaintiff's supervisors and decision makers discriminated against Plaintiff in her

employment terms and conditions based on her race, Black.

467. But for Plaintiff's race Defendant Huntsville would not have subjected her to

the materially adverse employment action/s described herein.

468. The facts set forth herein describe and demonstrate City decision makers'

racial animus going back years, such that Plaintiff's race was at least a motivating factor

for the disparate treatment and averse employment actions Defendant Huntsville

perpetrated against Plaintiff in 2024-2025, namely with regard to its acts and omissions

perpetrated in the 180 days prior to Plaintiff filing her December 19, 2024, EEOC

Charge of Discrimination, and retaliatory firing of Plaintiff less than three (3) weeks

after Plaintiff filed her December 19, 2024, EEOC Charge.

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469. At the very least, the circumstances described herein show a convincing

mosaic – that is, evidence demonstrating, among other things, very suspicious timing,

ambiguous and/or incriminating statements or actions, and other varied acts and

omissions – from which an inference of Huntsville's discriminatory intent may be drawn.

470. Defendant Huntsville violated Title VII by discriminating against Plaintiff

based on her race, demonstrating demonstrated deliberate indifference in both its acts

and omissions perpetrated against Plaintiff and in its failure or refusal to adequately train

and supervise its Chief of Police, Police Department Command Staff, HR staff and other

persons above Plaintiff in her chain of command.

471. By its unlawful acts and omissions, Defendant Huntsville proximately caused

Plaintiff to suffer lost income, stress, anxiety, and other mental anguish above and

beyond the stressors of ordinary life and work.

COUNT III
Title VII – 42 U.S.C. § 2000e-3
Retaliation

472. By this reference Plaintiff reiterates and incorporates the allegations set forth

Paragraphs 1-7 and 10-451, as if fully set out herein.

473. Plaintiff engaged in protected activities, that is, activities protected under 42

U.S.C. § 2000e-3 and case law both 11th Circuit and Supreme Court case law, including

opposing unlawful employment practices and/or by participating in an investigation(s)

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(such as they were), proceeding or hearing covered under Title VII and relevant case

law; and/or by providing information in her employer's investigation(s) (to the extent

any investigation/s occurred) of workplace discrimination and/or harassment.

474. Plaintiff suffered adverse employment actions described herein – including,

but not limited to, Defendant Huntsville failing or refusing to conduct thorough and

good faith investigation(s) of her grievances regarding workplace gender / pregnancy /

new mother harassment / discrimination (as well as grievances regarding both targeted

and systemic race discrimination); refusing to provide Plaintiff a law-compliant place to

pump breast milk in from March of 2024 forward, even after her actual notice(s) of that

need; enduring an adversarial Internal Affairs interrogation in late March 2024; suffering

Sgt. Springfield, Lt. Danley and Deputy Chief Johnson negatively reworking and

“doctoring” her already supervisor-completed Performance Evaluation in late March or

early April 2024; somehow making it through Chief Giles's crookedly-convened and bad

faith-infused July 28, 2024, hearing; enduring the July 30, 2024, Danley Meeting in

which he verbally flogged Plaintiff with Deputy Chief Johnson's harassment- and

retaliation-based “Discipline Notice;” bearing up under heightened “Imposed Probation”

monitoring and scrutiny beginning in August 2024; suffering through and fending off

numerous, false, exaggerated, and/or double standard-infused “write ups” and other

disciplinary actions from August 2024 through early January 2025; having her

legitimate, good faith, grievances of discrimination, harassment and retaliation ignored,

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or dismissed, or denied legitimacy because the City called them “time barred;” living

with the City repeatedly ignoring Plaintiff's coworkers' numerous verbal and written

notices both praising Plaintiff's work ethic and lamenting HPD higher ups' targeted

harassment of and disciplinary double standards perpetrated on Plaintiff; being

transferred to Records in November 2024, where Plaintiff suffered a reduction of pay

(overtime), prestige and responsibility; getting fired on January 8, 2025, even though the

City – through Chief Giles, HR Director Thomas and City in-house attorneys – had

actual knowledge of the false, dubious, vague and/or otherwise discredited nature of the

purported reasons for firing Plaintiff.

475. The City's mistreatment of and adverse employment actions perpetrated

against Plaintiff, both separately and collectively, were of such a nature that might well

have dissuaded a reasonable worker from making or supporting a charge of

discrimination and, thus, defining retaliation.

476. A causal connection exists between Plaintiff's protected activities and her

employer / its decision makers' mistreatment perpetrated against her.

477. But for Plaintiff's undertaking the described protected activities, she would

not have been subjected to the adverse employment actions described herein.

478. At the very least, Plaintiff's protected activities and the adverse employment

actions described herein are not completely unrelated.

479. The foregoing allegations set forth in this Count III demonstrate Defendant

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Huntsville violated Title VII of the Civil Rights Act of 1964, specifically 42 U.S.C. §

2000e-3(a), which prohibits retaliation against Plaintiff for participating in protected

activities.

480. By its unlawful acts and omissions Defendant Huntsville proximately caused

Plaintiff to suffer lost income, stress, anxiety, a reduction of breast milk production,

humiliation and other mental anguish above and beyond the stressors of normal life.

COUNT IV
Pregnant Workers Fairness Act (42 U.S.C. § 2000gg, et seq.)

481. By this reference Plaintiff reiterates and incorporates the allegations set forth

in the preceding Paragraphs 1-7; 10-13; and 15-47, as if fully set out herein.

482. Defendant Huntsville is an employer covered under the Pregnant Workers

Fairness Act (PWFA) and in August and September 2023, Plaintiff was a qualified

employee under the PWFA.

483. Notwithstanding the City's HR providing Plaintiff reasonable

accommodation(s) relating to Plaintiff's pregnancy in the late summer / early autumn of

2023, the City – through its employee, agent and representative, HPD Lt. Michael

Danley – refused and denied to make reasonable accommodations to Plaintiff related to

her pregnancy, childbirth or related medical conditions, to wit: refusing to allow

Plaintiff a work schedule that would allow her to make and keep certain appointments

with her OBGYN, both convenient for Plaintiff and her medical provider.

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484. Plaintiff's accommodation requests were reasonable and would have

imposed no undue hardship on the operation of HPD Dispatch.

485. Plaintiff engaged with the interactive process with the City (HR and Lt.

Danley), but Danley simply denied Plaintiff's request for reasonable accommodation,

stating he knew “how pregnancy works.”

486. Deputy Chief Michael Johnson threatened Plaintiff to never change her

OBGYN appointments, with a thinly veiled “Or else.”

487. Sergeant Dana (a male) Springfield effectively told Plaintiff she should just

quit, owing to her pregnancy and/or upcoming delivery.

488. Defendant Huntsville's refusal to provide reasonable accommodation to

Plaintiff, violated the PWFA.

489. Defendant Huntsville violated the PWFA by forcing Plaintiff to

accommodate Danley's preferred work schedule, i.e., the City took an adverse action in

terms, conditions, or privileges of employment (Danley's requirement Plaintiff

accommodate him to avoid discipline) on account of Plaintiff requesting a reasonable

accommodation related to her pregnancy, childbirth or related medical condition(s).

490. Danley's, Johnson's and Springfield's comments to Plaintiff regarding her

pregnancy are examples of their individual, as well as HPD's, open hostility towards

pregnant HPD employees.

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491. Defendant Huntsville's violations of the PWFA proximately caused Plaintiff

to suffer damages, for which it is liable to Plaintiff: including emotional, mental and

physical, as well as economic, as described with particularity in Paras. 32-36 herein.

COUNT V
The Pump for Nursing Mothers Act - (29 U.S.C. § 201, 218d)

492. By this reference Plaintiff reiterates and incorporates the allegations set forth

in the preceding Paragraphs 1-3; 6-7; 10-13; 15-18; 29-37; 48-81; 91-92; 103; 105-195

and 307-312, as if fully set out herein.

493. In 2024 the City was a covered employer and Plaintiff was a qualified

employee under The Pump for Nursing Mother's Act (29 U.S.C. § 201, 218d), hereafter,

The PUMP Act.

494. Following maternity leave, Plaintiff returned to work at HPD Dispatch on or

about February 19, 2024.

495. Upon Plaintiff's return to work the City was required to provide reasonable

break time and an appropriate place shielded from view and free from intrusion from

coworkers and the public, other than a bathroom, for Plaintiff to express breast milk.

496. On several occasions in March 2024, and again in or around July 2024,

Plaintiff notified Defendant Huntsville of its failure to provide a place as described

herein (see, for example, Paras. 76, 78, 165-166) and ten (10) days passed without the

City ever providing a place that complied with PUMP Act requirements.

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497. Plaintiff made a request for break time and/or for a place described herein

and opposed the City's conduct related to its actions / inaction / retaliation towards

Plaintiff regarding the PUMP Act (See, for example, Paras. 54, 59, 64, 69 and 146).

498. The City failed or refused to meet these requirements and its obligations

under the PUMP Act.

499. The City – through HPD and its decision makers, command staff and

Plaintiff's superiors – was, in fact, proudly ignorant of, and belligerent and contemptuous

towards, the PUMP Act and its obligations under it.

500. Besides Sgt. Springfield's chewing out, berating, Plaintiff for using his office

to pump on March 5, 2024 (as he had previously allowed her to do), Plaintiff's Internal

Affairs interrogators were, at the least, unsympathetic to both Plaintiff's need to pump at

the workplace and the City's obligations under the PUMPAct.

501. In his July 3 grievance against Plaintiff, Springfield admitted he would allow

Plaintiff to use his office to pump “on weekends and afternoons (when he wasn't in).”

502. During the July 28 Giles Hearing, Deputy Chief Johnson asked Plaintiff if

she felt she could, should be allowed to, pump breast milk, “literally any time?”

503. During the July 28, 2024, Giles Hearing, Lt. Sumlin asked Plaintiff if she

thought she could, should be allowed to, pump breast milk, “randomly?”

504. As of the date of this filing, Plaintiff is no longer employed by the City, but

nevertheless seeks injunctive relief against this Defendant for its ongoing policies and

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practices that violate The PUMP Act.

COUNT VI
42 U.S.C. § 1985(2)(3) – Defendant Kirk Giles
Conspiracy to Deprive Plaintiff of
Her Rights under the Fourteenth Amendment

505. By this reference Plaintiff reiterates and incorporates the allegations set forth

in the preceding Paragraphs 1-2; 6-8; 10-32; 38-77; 94-98; 102-128; 131-163; 165-167;

170-185; 187-225; 227-277; 280-290; 294-302; 313-422; 433-440; 447-448; and 452-

453, as if fully set out herein.

506. Section 1 of the Fourteenth Amendment to the United States Constitution

provides that persons shall not be deprived of any property (interest) without due process

of law, nor shall any person be denied equal protection of the laws.

507. Plaintiff had a property interest in her employment with the City of

Huntsville.

508. Plaintiff was entitled to equal protection under the law as regards her sex /

gender, female.

509. Plaintiff was entitled to equal protection under the law as regards her race,

Black.

510. Plaintiff was entitled to equal protection under the law as an employee of the

City of Huntsville, Alabama.

511. Title 42 U.S.C. § 1985(2) prohibits two or more persons conspiring for the

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purpose of impeding, hindering, obstructing, or defeating, in any manner, the due course

of justice in any State or Territory, with intent to deny to any citizen the equal protection

of the laws, or to injure her or her property for lawfully enforcing, or attempting to

enforce, the right of any person to the equal protection of the laws.

512. On June 28, 2024, under color of law in his position as Chief of Police for

the City of Huntsville, Alabama, Defendant Kirk Giles sought to – and eventually would

– deprive Plaintiff of her due process and equal protection rights, when with actual

knowledge of Sgt. Springfield's not having filed any grievance against Plaintiff, Giles

conspired with Deputy Chief Michael Johnson and others to initiate a “Departmental

Hearing” against Plaintiff – based on a non-existent grievance – which would lead to

Plaintiff's being placed on “Imposed Probation,” unpaid suspension from work, loss of

income, heightened workplace scrutiny, transfer to a “Records” job (with suffered a

reduction of pay (overtime), prestige and responsibility), and eventual termination.

513. On July 28, 2024, under color of law in his position as Chief of Police for

the City of Huntsville, Alabama, Defendant Kirk Giles sought to – and eventually would

– deprive Plaintiff of her due process and equal protection rights, when with actual

knowledge of Sgt. Springfield's not having filed any grievance against Plaintiff until

after he, Giles, called a “Departmental Hearing” against Plaintiff, Giles conspired with

Deputy Chief Michael Johnson and others, to conduct that “Departmental Hearing”

against Plaintiff – based on a non-existent grievance – which would lead to Plaintiff's

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being placed on “Imposed Probation,”unpaid suspension from work, loss of income,

heightened workplace scrutiny, transfer to a “Records” job (with suffered a reduction of

pay (overtime), prestige and responsibility), and eventual termination.

514. On or around November 26, 2024, and under color of law in his position as

Chief of Police for the City of Huntsville, Alabama, Defendant Kirk Giles deprived

Plaintiff of her due process and equal protection rights when with discriminatory and

retaliatory intent, Giles conspired with Deputy Chief Michael Johnson and others to

deprive Plaintiff of her due process and equal protection rights by transferring Plaintiff

from HPD Dispatch to “Records,” doing so without cause or reason, other than with

discriminatory intent, as demonstrated by Giles list of simultaneously-served, unproved

allegations made against Plaintiff; allegations which Giles knew were false, dubious,

discredited and/or made and enforced against Plaintiff in an unequal, disparate manner

compared to her similarly situated Caucasian and/or male coworkers, and/or her

coworkers who had not engaged in Title VII-protected activities.

515. On or around January 8, 2025, under color of law in his position as Chief of

Police for the City of Huntsville, Alabama, Defendant Kirk Giles deprived Plaintiff of

her due process and equal protection rights when with discriminatory and retaliatory

intent, Giles conspired with and/or used Huntsville Mayor Tommy Battle as his, Giles's,

cat's paw, and/or with others to deprive Plaintiff of her due process and equal protection

rights by firing / gaining the blessing of Mayor Battle to fire Plaintiff without cause or

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reason, other than with discriminatory intent, as demonstrated by Giles list of

simultaneously-served, allegations made against Plaintiff which Giles knew were false,

dubious, discredited and/or made and enforced against Plaintiff in an unequal, disparate,

manner compared to her similarly situated Caucasian and/or male coworkers, and/or her

coworkers who had not engaged in Title VII protected activities.

516. Giles conspired with Johnson and others to deny to Plaintiff equal protection

of the laws; impeding, hindering, obstructing, or defeating, in various manners the due

course of justice and depriving her of her property right (income and employment) and

impeded and obstructed her equal protection under the law.

517. Defendant Giles's acts were intentional, malicious and/or wantonly

perpetrated.

518. Defendant Giles had no discretionary right or authority to so conspire and in

doing so intentionally, maliciously and/or wantonly violate Plaintiff's rights under the

Fourteenth Amendment, in violation of 42 U.S.C. § 1985(2).

519. Defendant Giles's aforementioned unlawful acts and omissions proximately

caused Plaintiff to suffer lost employment, lost income, stress, anxiety, and other mental

anguish above and beyond the stressors of ordinary life and work, which, under 42

U.S.C. § 1985(3) allows a party so injured or deprived to recover damages occasioned

by such injury or deprivation, that is, both compensatory and punitive damages.

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COUNT VII
42 U.S.C. § 1985(2)(3) – Defendant Michael Johnson
Conspiracy to Deprive Plaintiff of
Her Rights under the Fourteenth Amendment

520. By this reference Plaintiff reiterates and incorporates the allegations set forth

in the preceding Paragraphs 1-2; 6; 9; 10-32; 38-65; 76; 82-90; 94-98; 102-128; 131-

155; 159-163; 165-167; 170-185; 187; 189-225; 227-232; 235-277; 280-290; 294-302;

313-337; 355; 358-365; 376-377; 423-433; 436; 447-448; and 452-453, as if fully set out

herein.

521. Section 1 of the Fourteenth Amendment to the United States Constitution

provides that persons shall not be deprived of any property (interest) without due process

of law, nor shall any person be denied equal protection of the laws.

522. Plaintiff had a property interest in her employment with the City of

Huntsville.

523. Plaintiff was entitled to equal protection under the law as regards her sex /

gender, female.

524. Plaintiff was entitled to equal protection under the law as regards her race,

Black.

525. Plaintiff was entitled to equal protection under the law as an employee of the

City of Huntsville, Alabama.

526. Title 42 U.S.C. § 1985(2) prohibits two or more persons conspiring for the

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purpose of impeding, hindering, obstructing, or defeating, in any manner, the due course

of justice in any State or Territory, with intent to deny to any citizen the equal protection

of the laws, or to injure him or his property for lawfully enforcing, or attempting to

enforce, the right of any person to the equal protection of the laws.

527. On or around June 28, 2024, under color of law in his position as Deputy

Chief of Police for the City of Huntsville, Alabama, Defendant Michael Johnson sought

to – and eventually would play several roles to – deprive Plaintiff of her due process and

equal protection rights, when with actual knowledge of Sgt. Springfield's not having

filed any grievance against Plaintiff, Johnson conspired with Chief Kirk Giles and others

to cooperate in the commencement of a “Departmental Hearing” against Plaintiff –

based on a non-existent grievance – which would lead to Plaintiff's being placed on

“Imposed Probation” and unpaid suspension from work by Johnson, loss of income,

heightened workplace scrutiny, transfer to a “Records” job (with suffered a reduction of

pay (overtime), prestige and responsibility), and eventual termination.

528. On July 30, 2024, Defendant Michael Johnson conspired with Lt. Michael

Danley to deliver a “Discipline Notice” / letter to Plaintiff which, inter alia, suspended

Plaintiff from work without pay and changed the terms and conditions of her work by

putting Plaintiff on “Imposed Probation,” which entailed heightened workplace scrutiny,

monitoring and disciplinary action for “violations” which Johnson knew were / would be

false, dubious, discredited and/or made and enforced against Plaintiff in an unequal,

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disparate, manner compared to her similarly situated Caucasian and/or male coworkers,

and/or her coworkers who had not engaged in Title VII protected activities.

529. Defendant Johnson would later admit in testimony that he had no actual,

personal knowledge of the allegations he made against Plaintiff in his July 30, 2024,

Discipline Notice made against Plaintiff, that is, that he had never even seen Plaintiff at

work in HPD Dispatch (and, as alleged, Sgt. Springfield skipped and never testified at

the July 28, 2024, Giles / Departmental Hearing out of which Johnson's Discipline

Notice came).

530. Defendant Johnson's July 30, 2024, Discipline Notice, upon which Johnson

justified putting Plaintiff on “Imposed Probation,” also referenced Plaintiff's April 2024

Performance Review – a Performance Review that Plaintiff's then-supervisor, Amanda

Traulsen, had completed in September 2023, for 2023, but with Defendant Johnson's,

and Lt. Danley's, authorization and approval, Sgt. Springfield negatively rewrote and/or

otherwise doctored before presenting it to Plaintiff in early April 2024. Johnson

conspired with Lt. Danley and Sgt. Springfield to lay groundwork to justify depriving

Plaintiff of her property interests later in 2024 and on January 8, 2025.

531. In the days leading up to and on July 28, 2024, under color of law in his

position as Deputy Chief of Police for the City of Huntsville, Alabama, Defendant

Johnson sought to – and eventually would – deprive Plaintiff of her due process and

equal protection rights, when with actual knowledge of Sgt. Springfield's not having

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filed any grievance against Plaintiff until after he, Johnson, conspired with Chief Giles

and others, to plan for and conduct a bad faith “Departmental Hearing” against Plaintiff,

with Johnson, along with Giles and others, acting as Springfield's surrogate, all of which

would lead to Plaintiff's being placed on “Imposed Probation” by Johnson, unpaid

suspension from work, loss of income, heightened workplace scrutiny and, in

collaboration with Giles, transfer to a “Records” job (with suffered a reduction of pay

(overtime), prestige and responsibility), and eventual termination.

532. On or around November 26, 2024, and under color of law in his position as

Deputy Chief of Police for the City of Huntsville, Alabama, Defendant Michael Johnson

deprived Plaintiff of her due process and equal protection rights when with

discriminatory and retaliatory intent, when he conspired with Chief Giles and others to

deprive Plaintiff of her due process and equal protection rights by transferring Plaintiff

from HPD Dispatch to “Records,” doing so without cause or reason, other than with

discriminatory intent, as demonstrated by Johnson's actual knowledge that Giles's list of

simultaneously-served, unproved allegations made against Plaintiff; allegations which

Johnson knew were false, dubious, discredited and/or made and enforced against

Plaintiff in an unequal, disparate, manner compared to her similarly situated Caucasian

and/or male coworkers, and/or her coworkers who had not engaged in Title VII protected

activities.

533. Johnson conspired with Giles and others to deny to Plaintiff equal protection

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of the laws; impeding, hindering, obstructing, or defeating, in various manners the due

course of justice and depriving her of her property right (income and employment) and

impeded and obstructed her equal protection under the law.

534. Defendant Johnson's acts were intentional, malicious and/or wantonly

perpetrated.

535. Defendant Johnson had no discretionary right or authority to so conspire and

in doing so intentionally, maliciously and/or wantonly violate Plaintiff's rights under the

Fourteenth Amendment, in violation of 42 U.S.C. § 1985(2).

536. Defendant Johnson's aforementioned unlawful acts and omissions

proximately caused Plaintiff to suffer lost employment, lost income, stress, anxiety, and

other mental anguish above and beyond the stressors of ordinary life and work, which,

under 42 U.S.C. § 1985(3) allows a party so injured or deprived to recover damages

occasioned by such injury or deprivation, that is, both compensatory and punitive

damages.

REQUEST FOR RELIEF

NOW, WHEREFORE, Plaintiff Katrina Brady respectfully requests the following

relief after trial of this case by struck jury:

A. Regarding Count I: Entry of judgment in Plaintiff Katrina Brady's favor and

against Defendant City of Huntsville for compensatory damages, including lost wages

and income, stress, frustration, and mental anguish proximately caused by its violations

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of Title VII ( Gender / Sex ) as set forth in Count I of this Complaint.

B. Regarding Count II: Entry of judgment in Plaintiff Katrina Brady's favor and

against Defendant City of Huntsville for compensatory damages, including lost wages

and income, stress, frustration, and mental anguish proximately caused by its violations

of Title VII ( Race ) as set forth in Count II of this Complaint.

C. Regarding Count III: Entry of judgment in Plaintiff Katrina Brady's favor and

against Defendant City of Huntsville for compensatory damages, including lost wages

and income, stress, frustration, and mental anguish proximately caused by its violations

of Title VII ( Retaliation ) as set forth in Count III of this Complaint.

D. Regarding Count IV: Entry of judgment in Plaintiff Katrina Brady's favor and

against Defendant City of Huntsville for compensatory damages, including lost wages

and income, stress, frustration, and mental anguish proximately caused by its violations

of the Pregnant Workers Fairness Act (PWFA) as set forth in Count IV of this

Complaint.

E. Regarding Count V: Entry of judgment in Plaintiff Katrina Brady's favor and

against Defendant City of Huntsville and injunctive relief in the form of an Order

compelling Defendant Huntsville to draft, enact and implement both City- and

Department-wide policies and practices that conform and comply with The Pump Act, as

well as to train and supervise City employees to respect and abide by all laws concerning

nursing mothers.

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F. Regarding Count VI: Entry of judgment in Plaintiff Katrina Brady's favor and

against Defendant Kirk Giles under 42 U.S.C. § 1985(3) for compensatory damages,

including lost wages and income, stress, frustration, and mental anguish proximately

caused by his violations of 42 U.S.C. § 1985(2); as well as for punitive damages to

punish and deter this Defendant for his intentional, malicious and/or wanton violations

of 42 U.S.C. § 1985(2).

G. Regarding Count VII: Entry of judgment in Plaintiff Katrina Brady's favor

and against Defendant Michael Johnson under 42 U.S.C. § 1985(3) for compensatory

damages, including lost wages and income, stress, frustration, and mental anguish

proximately caused by his violations of 42 U.S.C. § 1985(2); as well as for punitive

damages to punish and deter this Defendant for his intentional, malicious and/or wanton

violations of 42 U.S.C. § 1985(2).

H. Plaintiff requests injunctive relief in the form of an Order requiring Defendant

to (i) re-visit and update its policies as such regard workplace discrimination, retaliation,

Title VII and the Pregnant Workers Fairness Act; and, (ii) retrain City Council Members,

the Mayor, the Chief of Police, Police Department Command Staff, and all employees of

the Huntsville Police Department and HPD Dispatch regarding Title VII, the Pregnant

Workers Fairness Act, and related employment discrimination laws.

I. Plaintiff requests reasonable costs and attorneys fees.

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J. Plaintiff respectfully requests any additional relief in law or equity which the

Court may see fit to grant.

Respectfully filed on this, the 12th day of May, 2025.

s/ Richard R. Newton
Richard R. Newton (ASB-0776-w85r)
Richard R. Newton, Attorney at Law, P.C.
Counsel for Plaintiff Katrina Brady
7027 Old Madison Pike – Suite 108
Huntsville, AL 35806
Tel: (205) 356-2498
richardrussellnewton@gmail.com

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