Claim -Suit, Hessel, Tina Marie
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Name: Tina Marie Hessel
Address: 2393 Kaufmann Ave. Dubuque, Iowa 52001
Telephone: (563) 495-3090
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IN THE IOWA DISTRICT COURT FOR DUBUQUE COUNTY
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TINA MARIE HESSEL,
Plaintiff,
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) Civil No. 01311 CVCV054433
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CITY OF DUBUQUE,
RANDY PECK, MICHAEL
V AN MILLIGAN, RICH
RUSSELL,
Defendants,
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NATURE OF CASE
On January 17, 2005, Tina Hessel's company Maid For You was hired to provide
cleaning services for the city of Dubuque. Ms. Hessel had four employees, two were
Caucasian and two were African American. Rich Russell, the Building Services
Manager hired Maid For You. On January 21, 2005, Shawn Baldwin, an employee
of Maid For You who is African American was seen with Ms Hessel cleaning by Ken
TeKippe. Mr. TeKippe is the Director of Finances for the city of Dubuque. He asked
who Mr. Baldwin was. A few days later, it was requested that all employees of Maid
For You have background checks done by the personnel department of City Hall.
On February 4, 2005, the two Caucasian employees of Maid For You had their
background checks done. On February 8, the two African American employees
came to city hall to have their background checks done. The city refused to do the
background checks on the African American employees. Also, the city refused to
allow Ms. Hessel's Caucasian employees to work due to their background checks.
Ms. Hessel filed a complaint with the Dubuque Human Rights Department. The city
then said her African American employees could work even though one of the
employees did jail time for stealing an automobile. Her Caucasian employees stilI
were not allowed to work despite the fact that neither person had ever done jail time
or served any probation time. In retaliation for reporting the city of Dubuque to the
Dubuque Human Rights Department, the city terminated Maid For You as the
cleaning service for the city.
CAUSE OF ACTION
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1. I allege that my constitutional rights, privileges or immunities have been
violated.
a. (1) Count I : Violation of Civil Rights Title 2 Section 202: Deprivation
of Righ ts
b. (1) Count II: Violation of Civil Rights Title 2 Section 203
Also, the city of Dubuque and its' employees committed the following:
c. Count III: Breach of Contract
d. Count IV: Fraud
e. Count V: Intentional Infliction of Emotional Distress
f. Retaliation Discrimination
REQUEST FOR RELIEF
The plaintiff is seeking relief for loss of contract, civil rigbts violations,
emotional distress aud punitive damages as well as damages against the
plaintiffs employees. (Specific amounts of monetary damages will be
obtained through discovery)
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DECLARATION UNDER PENALTY OF PERJURY
The undersigned declares under penalty ofperjmy that he/she is the plaintiff in the above action, that
he/she has read the above complaint, and that the information contained therein is true and correct.
28 D.S.C. :1746; 18 D.S.C.: 1621
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Signature