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Suit by Vicki McCreaIN THE IOWA DISTRICT COURT IN AND FOR DUBUQUE COUNTY VICKI L. McCREA, ) £) CASE NO. LACY 058231 0'4x. --G Plaintiff, ) 0 ill n Lis -_,-s?... Ca) 111 CITY OF DUBUQUE, ) ORIGINAL NOTICE > =2 0 CD Defendant. ) TO THE ABOVE-NAMED DEFENDANT, CITY OF DUBUQUE: YOU ARE HEREBY NOTIFIED that an Amended Petition at Law has been filed on the (1 day of April, 2014, in the Office of the Clerk of this Court, naming you as the Defendant in this action. A copy of the Petition (and any documents filed with it) is attached to this Notice. The Plaintiff's attorney is Emilie J. Roth Richardson, Roth Law Office, P.C., 1400 University Ave., Suite D, Dubuque, Iowa 52001 (Phone: 563-557-1611; Fax: 563-557-9775). You must serve a Motion or Answer within twenty (20) days after service of this Original Notice upon you, and, within a reasonable time thereafter, file your motion or answer with the Clerk of Court for Dubuque County at 720 Central Avenue, Dubuque, Iowa, 52001. If you do not, judgment by default may be rendered against you for the relief demanded in the Petition. If you need assistance to participate in court due to a disability, call the disability coordinator at #319-833-3332. Persons who are hearing impaired or speech impaired may call Relay Iowa TTY #1-800-735-2942. Disability coordinators cannot provide legal advice. (SEAL) CLERK OF COURT Dubuque County Courthouse Dubuque, Iowa 52001 IMPORTANT: YOU ARE ADVISED TO SEEK LEGAL ADVICE AT ONCE TO PROTECT YOUR INTERESTS. IN THE IOWA DISTRICT COURT IN AND FOR DUBUQUE COUNTY VICKI L. McCREA, Plaintiff, v. CITY OF DUBUQUE, Defendant. CASE NO. LACV ,,71,3 ORIGINAL NOTICE TO THE ABOVE-NAMED DEFENDANT, CITY OF DUBUQUE: YOU ARE HEREBY NOTIFIED that a Petition at Law has been filed on the f a day of February, 2014, in the Office of the Clerk of this Court, naming you as the Defendant in this action. A copy of the Petition (and any documents filed with it) is attached to this Notice. The Plaintiff's attorney is Emilie J. Roth Richardson, Roth Law Office, P.C., 1400 University Ave., Suite D, Dubuque, Iowa 52001 (Phone: 563-557-1611; Fax: 563-557-9775). You must serve a Motion or Answer within twenty (20) days after service of this Original Notice upon you, and, within a reasonable time thereafter, file your motion or answer with the Clerk of Court for Dubuque County at 720 Central Avenue, Dubuque, Iowa, 52001. If you do not, judgment by default may be rendered against you for the relief demanded in the Petition. If you need assistance to participate in court due to a disability, call the disability coordinator at #319-833-3332. Persons who are hearing impaired or speech impaired may call Relay Iowa TTY #1-800-735-2942. Disability coordinators cannot provide legal advice. (SEAL) CLERK OF COURT Dubuque County Courthouse Dubuque, Iowa 52001 IMPORTANT: YOU ARE ADVISED TO SEEK LEGAL ADVICE AT ONCE TO PROTECT YOUR INTERESTS. IN THE IOWA DISTRICT COURT IN AND FOR DUBUQUE COUNTY VICKI L. McCREA, Plaintiff, v. CITY OF DUBUQUE, Defendant. CASE NO. LACV 6 / PETITION AT LAW c� mo, 002, o al COMES NOW Plaintiff Vicki L. McCrea by and through her attar-rapa Emilie J. Roth Richardson of Roth Law Office, P.C., states as follows in support of this Petition at Law: COMMON ELEMENTS 1. The jurisdiction of this Court is invoked pursuant to the Iowa Civil Rights Act, Iowa Code § 216. 2. The unlawful employment practices alleged below have been committed within Dubuque, Dubuque County, Iowa. 3. On or about September 11, 2013, Plaintiff Vicki L. McCrea, filed a complaint within 300 days from the date of the occurrence of the discriminatory act with the Iowa Civil Rights Commission on or about alleging discrimination on the basis of gender, disability and a claim for retaliation. 4. On November 20, 2013 the Iowa Civil Rights Commission issued Plaintiff Vicki McCrea a right -to -sue letter. (Exhibit A). 5. Plaintiff Vicki L. McCrea is and was at all times hereto a resident of Dubuque County Iowa. 6. Plaintiff Vicki L. McCrea is employed by the City of Dubuque, Water Department. 7. Defendant City of Dubuque is municipality located in Dubuque County, Iowa. 8. Defendant is an employer within the meaning of the Iowa Civil Rights Act, Iowa § 216.2(7). COUNT ONE- HARASSMENT 9. Plaintiff re -pleads paragraphs 1 through 8. 10. Plaintiff works as an executive assistant in the Water Department, City of Dubuque. Plaintiff has been an employee with the City of Dubuque since July 30, 1990. 11. In 2013 Plaintiff was been harassed on the basis of her gender, female, by her supervisors at the Water Department, City of Dubuque. 12. Plaintiff was disciplined and adversely affected in the workplace, subjected to negative comments about her gender in the workplace, subjected to being isolated in the workplace by her supervisors, subjected to false disciplinary memos by her supervisors all on the basis of her gender, female. 13. In 2013 Plaintiff reported the harassment and hostile work environment to her supervisors, the Personnel Department and City Manager's Department. 14. Defendant knew of the harassment based on gender, female, perpetrated upon Plaintiff by her supervisors in the Water Department for the City of Dubuque and Defendant failed to take action to stop the harassment. 15. These discriminatory actions are in violation of Iowa Code § 216. 2 16. That as a proximate cause of the discriminatory actions by Defendant the Plaintiff has suffered lost wages, emotional distress, mental anguish, humiliation, embarrassment, and loss of enjoyment of life all to her detriment. 17. The damages sustained by Plaintiff are in excess of the small claims jurisdiction amount and Defendant is liable to her for said damages. WHEREFORE Plaintiff Vicki L. McCrea respectfully prays that this Court enter judgment against the City of Dubuque and award damages, including damages for lost wages, emotional distress, mental anguish, compensatory relief, reasonable attorney fees, and court costs with interest, as provided by law and such other and further relief as the Court deems just and equitable COUNT TWO — FAILURE TO ACCOMMODATE 18. Plaintiff re -pleads paragraphs 1 through 17. 19. In January 2013 Plaintiff requested a job transfer within the City of Dubuque to accommodate her mental health condition. 20. Plaintiff requested that her employer, the Water Department of the City of Dubuque, transfer her to another department within the City. Plaintiff requested to be transferred to a similar clerical position with another department. 21. Plaintiff informed her supervisors at the Water Department that the hostile working conditions in her department caused by her supervisors was aggravating her mental health condition and as a result requested to be transferred to a different department for the City of Dubuque. 3 22. Defendant denied Plaintiff's request for an accommodation due to a mental disability. Defendant did not authorize or agree to transfer Plaintiff to a different department within the City of Dubuque. 23. Defendant had no legitimate business reason to deny Plaintiff's reasonable request to be transferred to a similar position within a different department for the City of Dubuque. 24. Defendant failed to accommodate Plaintiffs reasonable request for an accommodation on the basis of a mental health disability in violation of Iowa Code § 216. 25. That as a proximate result of the discriminatory actions by Defendant, City of Dubuque, the Plaintiff has suffered emotional distress, mental anguish, embarrassment, loss of enjoyment of life and lost wages all to her detriment. 26. The damages sustained by Plaintiff are in excess of the small claims jurisdiction amount and Defendant is liable to her for said damages. WHEREFORE Plaintiff Vicki L. McCrea respectfully prays that this Court enter judgment against the City of Dubuque and award damages, including damages for lost wages, emotional distress, mental anguish, compensatory relief, reasonable attorney fees, and court costs with interest, as provided by law and such other and further relief as the Court deems just and equitable. COUNT THREE — FAILURE TO HIRE 27. Plaintiff re -pleads paragraphs 1 through 26. 4 28. In 2013 Plaintiff applied for different clerical positions within the City of Dubuque in hopes of finding a different job to remove herself from the hostile work environment at the Water Department. 29. Plaintiff was not hired for other clerical positions she applied for in 2013. 30. Plaintiff believes that her employer, the Water Department, interfered with her applications for other clerical work within the City of Dubuque and caused her to not be hired by other City departments. 31. Defendant failed to hire Plaintiff in violation of Iowa Code § 216 in retaliation for Plaintiff requesting an accommodation due to a mental health disability and in retaliation for Plaintiff making numerous internal ,complaints about a hostile work environment and gender discrimination. 32. Defendant interfered with Plaintiff's hiring process in other City of Dubuque departments in violation Iowa Code § 216. 33. That as a proximate result of the discriminatory actions by Defendant, City of Dubuque — Water Department, Plaintiff has suffered emotional distress, mental anguish, embarrassment, loss of enjoyment of life and lost wages all to her detriment. 34. The damages sustained by Plaintiff are in excess of the small claims jurisdiction amount and Defendant is liable to her for said damages. WHEREFORE Plaintiff Vicki L. McCrea respectfully prays that this Court enter judgment against the City of Dubuque and award damages, including damages for lost wages, emotional distress, mental anguish, compensatory 5 relief, reasonable attorney fees, and court costs with interest, as provided by law and such other and further relief as the Court deems just and equitable. COUNT THREE — RETALIATION 35. Plaintiff re -pleads paragraphs 1 through 34. 36. In 2012 and 2013 Plaintiff made internal complaints to the City of Dubuque Personnel Department and City Manager's Department regarding a hostile work environment caused by her supervisors at the City of Dubuque Water Department. Plaintiff made numerous complaints to the Personnel Department and City Manager's Department that she felt she was being singled out by her supervisors due to her gender, being treated differently by her supervisors due to her gender and being harassed in the workplace by her supervisors on the basis of her gender. 37. Defendant knew of the complaints Plaintiff made to the Personnel Department and City Manager's Department. Plaintiffs supervisors were also informed that Plaintiff made these internal complaints. 38. As a result of the internal complaints, in 2013 Plaintiff's supervisors denied her request to be transferred to a different City of Dubuque department in a similar position, interfered with Plaintiff's attempts to be hired for clerical positions in other departments, encouraged Plaintiffs co-workers to make complaints about her and subjected Plaintiff to unwarranted discipline. 39. Defendant retaliated against Plaintiff violation of Iowa Code § 216. 40. That as a proximate result of the retaliatory actions by Defendant, City of Dubuque — Water Department, Plaintiff has suffered emotional distress, 6 mental anguish, embarrassment, loss of enjoyment of life and lost wages all to her detriment. 41. The damages sustained by Plaintiff are in excess of the small claims jurisdiction amount and Defendant is liable to her for said damages. WHEREFORE Plaintiff Vicki L. McCrea respectfully prays that this Court enter judgment against the City of Dubuque and award damages, including damages for lost wages, emotional distress, mental anguish, compensatory relief, reasonable attorney fees, and court costs with interest, as provided by law 8nd such other and further relief as the Court deems just and equitable. V G-K-I-M,QCREAS _P-Fatiff; 1 Er i1ie J. Roth'Richardson_T006'8•51----- Rot aw Office F.c 1400 University Ave., Suite D Dubuque, IA 52001 Tele: (563) 557-1611 Fax: (563) 557-9775 Email: eroth@rothlawdbq.com ATTORNEY FOR PLAINTIFF 7 Fields of opportunities STATE OF IOWA TERRY BRANSTAD, GOVERNOR KIM REYNOLDS, LT. GOVERNOR MS. VICKI MCCREA 8279 KALB RIDGE PEOSTA, IA 52058 Dear MS. VICKI MCCREA: IOWA CIVIL RIGHTS COMMISSION BETH TOWNSEND EXECUTIVE DIRECTOR 11/20/2013 RE: CITY OF DUBUQUE --- WATER DEPARTMENT CP# 09-13-54790 EEOC# 26A -2013-01099C Enclosed is the 'Right -to -Sue' letter as you requested. Since the Right -to -Sue letter was granted, the Iowa Civil Rights Commission (ICRC) has administratively closed the case cited above effective the date of this letter. ICRC will take no further action on this case. Once the Right -to -Sue letter is granted, both parties have the right to request a copy of the file. Please be aware there is a charge for copying. You have ninety days (90) from the date of this letter to initiate or file a lawsuit against the Respondent in District Court. If you have not retained an attorney, you may wish to contact the Iowa Bar Association's Lawyer Referral Services at www.iabar.net A copy of the Right -to -Sue letter is being sent to Respondent(s) for their information. Thank you for your cooperation. Sincerely, Iowa Civil Rights Commission Enclosure: Right -to -Sue letter CC: File EMILIE ROTH RICHARDSON, Complainant's Attorney Grimes State Office Building, 400 E. 14In Street, Des Moines, Iowa 50319-1004 515 281-4121 / 1-800-457-4416 / Fax 515-242-5840 http://www.state.ia.us/government/crc Administrative Release (Letter of Right -To -Sue) To: MS. VICKI MCCREA 8279 KALB RIDGE PEOSTA, IA 52068 ) From: ) ) Iowa Civil Rights Commission ) Grimes State Office Building ) 400 E. 14th Street Des Moines, Iowa 50319 Complaint CP# 09-13-64790 EEOC# 26A -2013-01099C This is your Administrative Release (Right -To -Sue) Letter issued pursuant to Iowa Code Section 216.16 and 161 Iowa Administrative Code Section 3.10. It is issued pursuant to the Complainant's request. The following conditions have been met: 1. The complaint was timely filed with the Iowa Civil Rights Commission (ICRC) as provided in Iowa Code Section 216.15(12); Sixty (60) days have expired since the complaint was filed with ICRC; 2. 3, None of the exceptions -set forth in Administrative Rule 161 — 3.10(4) are applicable. With this Administrative Release, the Complainant has the right to commence an action in district court, That action must be commenced within ninety (90) days of the issue date 11/20/2013. The Right -to -Sue Letter is not a finding by ICRC on the merits of the charge. ICRC will take no further actions in this matter. A copy of this Administrative Release/Letter of Right -To -Sue has been sent to the Respondent(s) and counsel(s) as shown below. The Code allows any party to obtain a complete copy of the case file after a Right -To -Sue has been issued. Requests for copies should be directed to Annette Flaherty at ICRC. The Iowa Civil Rights Commission Phone: (515) 281-4121 FAX: (515) 242-5840 cc: File EMILIE ROTH RICHARDSON, Complainant's Attorney LES REDDICK, Respondent's iii LES V. REDDICK, Respondent a ttor ney CITY OF DUBUQUE --- WATER DEPARTMENT CITY OF DUBUQUE ROBERT (BOB) GREEN, BOSS ICRC/S36 (24) IN THE IOWA DISTRICT COURT IN AND FOR DUBUQUE COUNT c,�Fr ,� (.�' VICKI L. McCREA, Plaintiff, v. CITY OF DUBUQUE, Defendant. CASE NO. 01311 LACV 058231 AMENDED PETITION AT LAW COMES NOW Plaintiff Vicki L. McCrea by and through her attorney, Emilie J. Roth Richardson of Roth Law Office, P.C., states as follows in support of this Amended Petition at Law: COMMON ELEMENTS 1. The jurisdiction of this Court is invoked pursuant to the Iowa Civil Rights Act, Iowa Code § 216. 2. The unlawful employment practices alleged below have been committed within Dubuque, Dubuque County, Iowa. 3. On or about September 11, 2013, Plaintiff Vicki L. McCrea filed a complaint within 300 days from the date of the occurrence of the discriminatory act with the Iowa Civil Rights Commission on or about alleging discrimination on the basis of gender, disability and a claim for retaliation. 4. On November 20, 2013 the Iowa Civil Rights Commission issued Plaintiff Vicki L. McCrea a right -to -sue letter. (Exhibit A). 5. On or about January 17, 2014, Plaintiff Vicki L. McCrea filed a complaint within 300 days from the date of the occurrence of the discriminatory act with the Iowa Civil Rights Commission on or about alleging retaliation due to filing a prior civil rights complaint. 6. On April 2, 2014 the Iowa Civil Rights Commission issued Plaintiff Vicki L. McCrea a right -to -sue letter. (Exhibit B). 7. Plaintiff Vicki L. McCrea is and was at all times hereto a resident of Dubuque County Iowa. 8. Plaintiff Vicki L. McCrea is employed by the City of Dubuque, Water Department. 9. Defendant City of Dubuque is municipality located in Dubuque County, Iowa. 10. Defendant is an employer within the meaning of the Iowa Civil Rights Act, Iowa § 216.2(7). COUNT ONE- HARASSMENT 11. Plaintiff re -pleads paragraphs 1 through 10. 12. Plaintiff works as an executive assistant in the Water Department, City of Dubuque. Plaintiff has been an employee with the City of Dubuque since July 30, 1990. 13. In 2013 Plaintiff was been harassed on the basis of her gender, female, by her supervisors at the Water Department, City of Dubuque. 14. Plaintiff was disciplined and adversely affected in the workplace, subjected to negative comments about her gender in the workplace, subjected to being isolated in the workplace by her supervisors, subjected to false disciplinary memos by her supervisors all on the basis of her gender, female. 2 15. In 2013 Plaintiff reported the harassment and hostile work environment to her supervisors, the Personnel Department and City Manager's Department. 16. Defendant knew of the harassment based on gender, female, perpetrated upon Plaintiff by her supervisors in the Water Department for the City of Dubuque and Defendant failed to take action to stop the harassment. 17. These discriminatory actions are in violation of Iowa Code § 216. 18. That as a proximate cause of the discriminatory actions by Defendant the Plaintiff has suffered lost wages, emotional distress, mental anguish, humiliation, embarrassment, and loss of enjoyment of life all to her detriment. 19. The damages sustained by Plaintiff are in excess of the small claims jurisdiction amount and Defendant is liable to her for said damages. WHEREFORE Plaintiff Vicki L. McCrea respectfully prays that this Court enter judgment against the City of Dubuque and award damages, including damages for lost wages, emotional distress, mental anguish, compensatory relief, reasonable attorney fees, and court costs with interest, as provided by law and such other and further relief as the Court deems just and equitable. COUNT TWO — FAILURE TO ACCOMMODATE 20. Plaintiff re -pleads paragraphs 1 through 19. 3 21. In January 2013 Plaintiff requested a job transfer within the City of Dubuque to accommodate her mental health condition. 22. Plaintiff requested that her employer, the Water Department of the City of Dubuque, transfer her to another department within the City. Plaintiff requested to be transferred to a similar clerical position with another department. 23. Plaintiff informed her supervisors at the Water Department that the hostile working conditions in her department caused by her supervisors was aggravating her mental health condition and as a result requested to be transferred to a different department for the City of Dubuque. 24. Defendant denied Plaintiff's request for an accommodation due to a mental disability. Defendant did not authorize or agree to transfer Plaintiff to a different department within the City of Dubuque. 25. Defendant had no legitimate business reason to deny Plaintiffs reasonable request to be transferred to a similar position within a different department for the City of Dubuque. 26. Defendant failed to accommodate Plaintiffs reasonable request for an accommodation on the basis of a mental health disability in violation of Iowa Code § 216. 27. That as a proximate result of the discriminatory actions by Defendant, City of Dubuque, the Plaintiff has suffered emotional distress, mental anguish, embarrassment, loss of enjoyment of life and lost wages all to her detriment. 28. The damages sustained by Plaintiff are in excess of the small claims jurisdiction amount and Defendant is liable to her for said damages. 4 WHEREFORE Plaintiff Vicki L. McCrea respectfully prays that this Court enter judgment against the City of Dubuque and award damages, including damages for lost wages, emotional distress, mental anguish, compensatory relief, reasonable attorney fees, and court costs with interest, as provided by law and such other and further relief as the Court deems just and equitable. COUNT THREE — FAILURE TO HIRE 29. Plaintiff re -pleads paragraphs 1 through 28. 30. In 2013 Plaintiff applied for different clerical positions within the City of Dubuque in hopes of finding a different job to remove herself from the hostile work environment at the Water Department. 31. Plaintiff was not hired for other clerical positions she applied for in 2013. 32. Plaintiff believes that her employer, the Water Department, interfered with her applications for other clerical work within the City of Dubuque and caused her to not be hired by other City departments. 33. Defendant failed to hire Plaintiff in violation of Iowa Code § 216 in retaliation for Plaintiff requesting an accommodation due to a mental health disability and in retaliation • for Plaintiff making numerous internal complaints about a hostile work environment and gender discrimination. 34. Defendant interfered with Plaintiffs hiring process in other City of Dubuque departments in violation Iowa Code § 216. 35. That as a proximate result of the discriminatory actions by Defendant, City of Dubuque — Water Department, Plaintiff has suffered emotional 5 distress, mental anguish, embarrassment, loss of enjoyment of life and lost wages all to her detriment. 36. The damages sustained by Plaintiff are in excess of the small claims jurisdiction amount and Defendant is liable to her for said damages. WHEREFORE Plaintiff Vicki L. McCrea respectfully prays that this Court enter judgment against the City of Dubuque and award damages, including damages for lost wages, emotional distress, mental anguish, compensatory relief, reasonable attorney fees, and court costs with interest, as provided by law and such other and further relief as the Court deems just and equitable. COUNT FOUR— RETALIATION 37. Plaintiff re -pleads paragraphs 1 through 36. 38. In 2012 and 2013 Plaintiff made internal complaints to the City of Dubuque Personnel Department and City Manager's Department regarding a hostile work environment caused by her supervisors at the City of Dubuque Water Department. Plaintiff made numerous complaints to the Personnel Department and City Manager's Department that she felt she was being singled out by her supervisors due to her gender, being treated differently by her supervisors due to her gender and being harassed in the workplace by her supervisors on the basis of her gender. 39. Defendant knew of the complaints Plaintiff made to the Personnel Department and City Manager's Department. Plaintiff's supervisors were also informed that Plaintiff made these internal complaints. 6 40. As a result of the internal complaints, in 2013 Plaintiffs supervisors denied her request to be transferred to a different City of Dubuque department in a similar position, interfered with Plaintiff's attempts to be hired for clerical positions in other departments, encouraged Plaintiff's co-workers to make complaints about her and subjected Plaintiff to unwarranted discipline. 41. Plaintiff has been formally disciplined, required to take unpaid time off work and suspended from work since she filed her initial Iowa Civil Rights Commission complaint on September 11, 2013. 42. As a result of unpaid time off work and being suspended from work, Plaintiff has suffered lost wages and incurred further adverse employment action by Defendant. 43. Plaintiff has incurred adverse employment action as a result of filing the initial Iowa Civil Rights Commission complaint on September 11, 2013 44. Defendant retaliated against Plaintiff violation of Iowa Code § 216. 45. That as a proximate result of the retaliatory actions by Defendant, City of Dubuque — Water Department, Plaintiff has suffered lost wages, emotional distress, mental anguish, embarrassment, loss of enjoyment of life and lost wages all to her detriment. 46. The damages sustained by Plaintiff are in excess of the small claims jurisdiction amount and Defendant is liable to her for said damages. WHEREFORE Plaintiff Vicki L. McCrea respectfully prays that this Court enter judgment against the City of Dubuque and award damages, including damages for lost wages, emotional distress, mental anguish, compensatory 7 relief, reasonable attorney fees, and court costs with interest, as provided by law and such other and further relief as the Court deems just and equitable. V Ct-"IC'CREA, Plaintiff; Al ilie' eth-Ricirdson_ATs0006851 Roth Law Office, P.C. 1400 University Ave., Suite D Dubuque, IA 52001 Tele: (563) 557-1611 Fax: (563) 557-9775 Email: eroth©rothlawdbq.com AI I ORNEY FOR PLAINTIFF Fields of opportunities [A Q W TERRY BRANSTAD, GOVERNOR KIM REYNOLDS, LT. GOVERNOR MS. VICKI MCCREA 8279 KALB RIDGE PEOSTA, IA 52068 IOWA CIVIL RIGHTS COMMISSION BETH TOWNSEND EXECUTIVE DIRECTOR 11/20/2013 RE: CITY OF DUBUQUE --- WATER DEPARTMENT CP# 09-13-64790 EEOC# 26A -2013-01099C Dear MS. VICKI MCCREA: Enclosed is the Right -to -Sue' letter as you requested. Since the Right -to -Sue letter was granted, the Iowa Civil Rights Commission (ICRC) has administratively closed the case cited above effective the date of this letter. ICRC will take no further action on this case. Once the Right -to -Sue letter is granted, both parties have the right to request a copy of the file. Please be aware there is a charge for copying. You have ninety days (90) from the date of this letter to initiate or file a lawsuit against the Respondent in District Court. If you have not retained an attorney, you may wish -to contact the Iowa Bar Association's Lawyer Referral Services at www.iabar.net A copy of the Right4o-Sue letter is being sent to Respondent(s) for their information. Thank you for your cooperation. Sincerely, Iowa Civil Rights Commission Enclosure: Right -to -Sue letter CC: File EMILIE ROTH RICHARDSON, Complainant's Attorney Grimes State Office Building, 400 E. 141h Street, Des Moines, Iowa 50319-1004 515 281-4121 / 1-800-457-4416 / Fax 515-242-5840 http://www.state.ia.us/governmenticrc Administrative Release (Letter of Right -To -Sue) To: MS. VICKI MCCREA 8279 KALB RIDGE PEOSTA, IA 52068 ) From: ) ) Iowa Civil Rights Commission ) Grimes State Office Building ) 400 E. 14th Street Des Moines, Iowa 50319 Complaint CP# 09-13-64790 EEOC# 26A -2013-01099C This is your Administrative Release (Right -To -Sue) Letter issued pursuant to Iowa Code Section 216.16 and 161 Iowa Administrative Code Section 3.10. It is issued pursuant to the Complainant's request. The following conditions have been met: . The complaint was timely filed with the Iowa Civil Rights Commission (ICRC) as provided in lowa Code Section 216.15(12); 2, Sixty (60) days have expired since the complaint was filed with ICRC; 3. None of the exceptions set forth in Administrative Rule 161 — 3.10(4) are applicable. With -this Administrative Release, the Complainant has the right to commence an action in district court. That action must be commenced within ninety (90) days of the issue date 11/20/2013. The Right -to -Sue Letter is not a finding by ICRC on the merits of the charge. ICRC will take no further actions in this matter. A copy of this Administrative Release/Letter of Right -To -Sue has been sent to the Respondent(s) and counsel(s) as shown below. The Code allows any party to obtain a complete copy of the case file after a Right -To -Sue has been issued. Requests for copies should be directed to Annette Flaherty at ICRC. The Iowa Civil Rights Commission Phone: (515) 281-4121 FAX: (515) 242-5840 cc: File EMILIE ROTH RICHARDSON, Complainant's Attorney LES V. REDDICK, Respondent's Attorney CITY OF DUBUQUE --- WATER DEPARTMENT CITY OF DUBUQUE ROBERT (BOB) GREEN, BOSS ICRC/S36 (24) Fields of opportunities TERRY BRANSTAD, GOVERNOR KIM REYNOLDS, LT. GOVERNOR MS. VICKI MCCREA 8279 KALB RIDGE PEOSTA, IA 52068 IOWA CIVIL RIGHTS COMMISSION BETH TOWNSEND EXECUTIVE DIRECTOR 4/2/2014 RE: CITY OF DUBUQUE --- WATER DEPARTMENT CP# 01-14-65274 EEOC# 26A -2014-00311C Dear MS. VICKI MCCREA: Enclosed is the `Right -to -Sue' letter as you requested. Since the Right -to -Sue letter was granted, the Iowa Civil Rights Commission (ICRC) has administratively closed the case cited above effective .the date of this letter. ICRC will take no further action on this case. Once the Right -to -Sue letter is granted, both parties have the right to request a copy of the file. Please be aware there is a charge for copying. You have ninety days (90) from the date of this letter to initiate or file a lawsuit against the Respondent in District Court. If you have not retained an attorney, you may wish to contact the Iowa Bar Association's Lawyer Referral Services at www.iabar.net A copy of the Right -to -Sue letter is being sent to Respondent(s) -for their information. Thank you for your cooperation. Sincerely, Iowa Civil Rights Commission Enclosure: Right -to -Sue letter CC: File :EMILIE J. ROTH RICHARD.SON,..Complainant's Attorney Grimes State Office Building, 400 E. 14`" Street, Des Moines, Iowa 50319-1004 515 281-4121 / 1-800-457-4416 / Fax 515-242-5840 http://www.state.ia.us/government/crc Administrative Release (Letter of Right -To -Sue) To: MS. VICKI MCCREA 8279 KALB RIDGE PEOSTA, IA 52068 ) From: ) ) Iowa Civil Rights Commission ) Grimes State Office Building ) 400 E. 14th Street Des Moines, Iowa 50319 Complaint CP# 01-14-65274 EEOC# 26A -2014-00311C This is your Administrative Release (Right -To -Sue) Letter issued pursuant to Iowa Code Section 216.16 and 161 Iowa Administrative Code Section 3.10. It is issued pursuant to the Complainant's request. The following conditions have been met: 1. The complaint was timely filed with the Iowa Civil Rights Commission (ICRC) as provided in Iowa Code Section 216.15(12); 2. Sixty (60) days have expired since the complaint was filed with !CRC; 3. None of the exceptions set forth in Administrative Rule 161 3.10(4) are applicable. VVith this Administrative Release, the Complainant has the right to commence an action in district court. That action must be commenced within ninety (90) days of the issue date 4/2/2014. The Right - to -Sue Letter is not a finding by ICRC on the .merits of the charge. ICRC will take no further actions in this matter. A copy of this Administrative Release/Letter of Right -To -Sue has been sent to the Respondent(s) and counsel(s) as shown below. The Code allows any party to obtain a complete copy of the case file after a Right -To -Sue has been issued. Requests for copies should be directed to Annette Flaherty at The lowa Civil Rights Commission Phone: (515) 281-4121 FAX: (515) 242-5840 cc: File EMILIE J. ROTH RICHARDSON, Complainant's Attorney LES V. REDDICK, Respondent's Attorney CITY OF DUBUQUE --- WATER DEPARTMENT CITY OF DUBUQUE ICRC/S36 (24)