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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
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
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
;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
7. He sent her inappropriate texts messages, called her at all hours and invited her
9. Plaintiff took these complaints and evidence to the personnel department. Hall
employment.
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
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
secure an endorsement for the director from Plaintiffs father in order that the director could
18. Shortly after the endorsement, Plaintiff was reassigned to another department
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
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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
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
29. During her employment at the CHA, Plaintiff accused a close friend of the
30. The perpetrator promised that he would leverage his relationship with Alvarez to
31 . The promise coincided with Lopez' complaint and preceded her termination.
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32. In the scope of his employment, Juan Lopez wrongfully accused Plaintiff of acts
33. Defendant CHA ignored its responsibility to investigate these claims and
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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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
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
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-
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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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~ 45. Despite this knowledge, Defendant recklessly and with willful and wanton
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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
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
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
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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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Respectfully Submitted,
sf ~ ?it. Stad
Martin M. Stack
sl(M,.4~
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