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HJring Date: No hearing scheduled

C~rtroom Number: No hearing scheduled


FILED
11/29/2018 4:34 PM
DOROTHY BROWN
CIRCUIT CLERK

ico IN THE CIRCUIT COURT OF COOK COUNTY ILLINOIS COOK COUNTY, IL


2018L012864
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COUNTY DEPARTMENT-LAW DIVISION
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N RHONDA BARRETT, )
Plaintiff, )
) 2018L012864
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Chicago Housing Authority, )
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COMPLAINT AT LAW

NOW COMES THE PLAINTIFF, Rhonda Barrett, through undersigned counsel, in this

action for damages stemming from intentional torts inflicted by agents and employees of the

Chicago Housing Authority. She states as follows:

JURISDICTION AND VENUE

I. This Court has jurisdiction and venue over the action pursuant to 735 ILCS 5/2-

10 I all of the events or omissions giving rise to the claims occurred in Cook County and the

corporate or public body defendant is located or does business in the County of Cook as well.

PARTIES

2. Rhonda Barrett is a United States citizen of majority age residing in Chicago,

Cook County, Illinois.

3. Chicago Housing Authority is a municipal corporation and constitutes a body

both corporate and politic, exercising public and essential governmental functions, and having all

the powers necessary or convenient to carry out and effectuate the purposes and provisions of the

Illinois Housing Authorities Act.


FACTUAL BASIS

;2; 4. Plaintiff began her employment with the Chicago Housing Authority as a Front
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Desk Monitor on September 21 , 2015 .
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5. Plaintiffs brother Torrey Barrett secured her employment with CHA through his

friend and Chief Operating Officer Jose Alvarez. Shortly thereafter, her supervisor, the Manager

of Safety and Security, Jon Hall, began to proposition her for sexual favors.
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6. Hall' s behavior included showing up to Plaintiffs house after work and in pre-
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work hours, inviting her to fake training sessions, exposing his genitals and placed them in her

face while she was seated at a desk .

7. He sent her inappropriate texts messages, called her at all hours and invited her

out for pleasure visits.

8. At one point during his supervision of the Plaintiff, he misdirected a suggestive

and private text meant for her to an entire broadcast group.

9. Plaintiff took these complaints and evidence to the personnel department. Hall

resigned prior to completion of the Agency's investigation of the misconduct.

10. Anthony Powell - a close friend of Hall - assumed supervision of Plaintiffs

employment.

11. In Hall ' s absence, Powell commenced a retaliatory campaign.

12. Powell belittlied Plaintiff in front of others and condemned her professional and

charitable work.

13. He threatened her with allegations that anonymous employees complained about

her work ethic. And that the unnamed confederates could trigger her summary termination.

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14. At her annual rcview Powell presented Plaintiff with above average reviews on

ig the "Pcrfom1ance Evaluation Fon11."


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CX) 15. This, too. was part and parcel of the hostile campaign because, as Plaintiff later
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discovered, Powell submitted a separate fom1 to her personnel file that she did not endorse

showing her perfonnancc as deficient.

16. Plaintiff attempted to address these issues with Cl IA management.


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work environment but demandcd a favor from Plaintiff in return. She demanded that Plaintiff

secure an endorsement for the director from Plaintiffs father in order that the director could

secure a promotion at CHA.

18. Shortly after the endorsement, Plaintiff was reassigned to another department

where her counterpart was Juan Lopez - recent CHA recruit.

19. Lopez and Plaintiff initially established a good rapport.

20. Without provocation, he turned volatile and leveled agitation towards Plaintiff.

21 . Lopez, too, began belittling Plaintiff in front of coworkers and demeaning her

charitable endeavors.

22. Lopez physically imposed himself on Plaintiff with invasions of her personal

space.

23. Lopez bragged to Plaintiff that he would not face employment consequences for

his conduct because of powerful political alliances at CHA and within the City of Chicago.

24. Lopez accused Plaintiff of sexually harassing him and, on his word alone, CHA

terminated her employment.

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25 . Prior to his employment at CHA, Juan Lopez was a cadet in the Chicago Fire

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Academy where he was tem1inated for sexually harassing and bullying female employees.
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co 26. Prior to his employment at CHA, Juan Lopez, was tenninated from a security job
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at DePaul University. Thereafter, he was discharged from the Chicago Fire Department before

graduating from the Fire Academy.

27. During his employment at CHA, Juan Lopez murdered three people, including a
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~ Chicago Police Officer, a Licensed Physician and a Pharmacist at Mercy Hospital in Chicago.
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u:: 28. Juan Lopez murdered these people because of a grievance against the physician

who was his fiance.

29. During her employment at the CHA, Plaintiff accused a close friend of the

CHA 's Chief Operating Officer of criminal sexual assault in Indiana.

30. The perpetrator promised that he would leverage his relationship with Alvarez to

adversely affect her employment with CHA.

31 . The promise coincided with Lopez' complaint and preceded her termination.

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The Hiring and Retention of Juan Lopez

32. In the scope of his employment, Juan Lopez wrongfully accused Plaintiff of acts

that resulted in her termination from the CHA.

33. Defendant CHA ignored its responsibility to investigate these claims and

summarily terminated her solely on the basis of Juan Lopez's statement.

34. CHA endorsed Lopez statements as a pretext to terminate Plaintiff for reporting

the sexuals misconduct of Hall and the assault by the COO's confederate reported to authorities

in Indiana.

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35 . CHA wilfully and wantonly ignored Lopez' unfitness for employment.

$ 36. CHA willfully and wantonly ignored Lopez· employment history rife with verbal
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co and physical hostility towards women in the workplace at a sister agency's training program
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from which he was di scharged prior to completing.

37. Defendants maintain a duty to hire competent and trustworthy employees to

conduct business and provide a safe working environment for its employees,including Plaintiff ,
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as well as the public.
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38. Defendant CHA has a duty to examine the background and experience of the

individuals it hires, including Juan Lopez, to provide a safe and secure working environment.

39. While at the Fire Academy Juan Lopez threatened co-workers with false

accusations of misconduct and on several occasions behaved in a manner as to cause his entire

class of fellow cadets to be disciplined.

40. Despite the ready availability of this information from a sister agency, the CHA

hired and retained Juan Lopez who falsely accused Plaintiff of conduct that resulted in her

termination.

41 . At all times after his hire, Lopez was under the direction, supervision and control

of the CHA and their agents and Juan Lopez was placed in proximity to the Plaintiff and had to

interact with the Plaintiff on a daily basis

42. The actions of the CHA in the hiring of Juan Lopez was intentional, and willful

and wanton. The CHA hired Juan Lopez despite dismissal from the Fire Academy and its well-

documented investigation of his ctroubling conduct and misogyny.

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43. His tennination from the Fire Academy on May 22, 2014 foretold his public

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employment conduct at the CHA and Defendant recklessly and intentionally leveraged this
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CX) unstable employee to execute a senior executive's grievance against Plaintiff.
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44. Lopez conduct at the CHA was foreseeable and the injuries the was capable of

inflicting on employees, including Plaintiff, and the public was apparent to only the willfully

negligent.
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abandon failed to properly supervise the hiring and thereafter the behavior of Juan Lopez.

46. As a direct result of Defendant CHA willful and wanton conduct with regard to

the hiring and retention of Juan Lopez, Plaintiff Rhonda Barrett has suffered the injuries alleged

herein.

47. The Defendant through its agents terminated the Plaintiff Rhonda Barrett in

September of 2018 based on information it obtained from Juan Lopez in June of 2018.

48. According to the words and the statements made by Juan Lopez to the Plaintiff

prior to her termination from CHA, the Defendant Lopez told Plaintiff had conducted a sham

investigation against the Plaintiff that would result in her termination.

49. Despite Plaintiffs complaints about Lopez hostility towards her , including

swearing at her in front of employees and the public, bullying her physically, touching her

shoulders and pushing on her body, using his legs to reach out and touch the Plaintiff, the

Defendant CHA failed to investigate her complaints.

50. The conduct of the CHA in regards to wrongfully tenninating the Plaintiff was

intentional or willful and wanton in that it never conducted any inquiry into the veracity of Juan

Lopez 's character or his capacity for honesty.

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WHEREFORE, Rhonda Barrett prays that judgment be entered in his favor and against
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a, the Defendant and that Ms. Barrett be granted:
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A. an Order requiring that Defendants immediately remove or otherwise purge from

its files documents regarding her termination from CHA;

B. all compensatory damages including front pay, pension benefits healthcare


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C. compensation for her pain and suffering and punitive damages;

D. reasonable attorneys ' fees and court costs;

E. such other relief as the Court deems just and proper

Respectfully Submitted,

sf ~ ?it. Stad
Martin M. Stack

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John Lanahan
Attorneys for Rhonda Barrett

Martin M. Stack
Attorney No. 2730 I
John Lanahan
Attorney No. 58525
19 E I st Street
Hinsdale, Illinois 60521
312-550-6271