Employment Discrimination Complaint Details

Summary

A former employee of the School District of Philadelphia has filed an amended complaint alleging employment discrimination based on disability, in violation of the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act, and Section 1557 of the Affordable Care Act. The complaint also includes claims of retaliation, defamation, and harassment. The case is filed in the Eastern District of Pennsylvania, where the alleged unlawful employment practices occurred. The plaintiff, who experienced severe limitations due to Long COVID, claims her condition qualifies as a disability under relevant laws.

Full Conversation

I need you to fix my pro se amended complaint for me

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF PENNSYLVANIA
Jennifer Rawling,
* Nauldo Road
Philadelphia, Pennsylvania, *
jennirawling@gmail.com
*-*-*
Plaintiff, Pro Se
v.
The School District of Philadelphia,
Kristin J. Johnson, Esq., Investigative Officer,
Mr. Shawn McGuigan, Principal, Castor Gardens Middle School,
Ms. Maryanne Conkle, Assistant Principal, Castor Gardens Middle School,
Mrs. Courtney Brown, Teacher, Castor Gardens Middle School,
Defendants.
CIVIL ACTION NO. *-CV-*
AMENDED COMPLAINT FOR EMPLOYMENT DISCRIMINATION
Plaintiff, Jennifer Rawling, brings this action against Defendants, The School District of Philadelphia, Kristin J. Johnson, Mr. Shawn McGuigan, Ms. Maryanne Conkle, and Mrs. Courtney Brown (collectively, "Defendants"), alleging discrimination based on disability in violation of the Americans with Disabilities Act (ADA), * U.S.C. § * et seq., Section * of the Rehabilitation Act of *, * U.S.C. § *, and Section * of the Patient Protection and Affordable Care Act, * U.S.C. § *. Additionally, Plaintiff asserts claims of retaliation, defamation, and harassment.
PARTIES
- Plaintiff: Jennifer Rawling, a resident of Philadelphia, Pennsylvania, and former employee of the Defendant, The School District of Philadelphia.
- Defendants:
- The School District of Philadelphia, located in Philadelphia, Pennsylvania, subject to ADA and Rehabilitation Act requirements due to federal funding.
- Kristin J. Johnson, Esq., Investigative Officer, responsible for managing employee relations and handling complaints regarding workplace discrimination.
- Shawn McGuigan, Principal of Castor Gardens Middle School, disclosed Plaintiff's private medical information to employees and was involved in adverse actions against Plaintiff.
- Maryanne Conkle, Assistant Principal at Castor Gardens Middle School, unlawfully shared Plaintiff's private health email with Courtney Brown, violating Plaintiff's rights.
- **Courtney Brown, a teacher at Castor Gardens Middle

JURISDICTION AND VENUE This Court has jurisdiction over this action pursuant to: * U.S.C. § * et seq. (Americans with Disabilities Act); * U.S.C. § * (Section * of the Rehabilitation Act); * U.S.C. § * (Section * of the Affordable Care Act). Venue is proper in this district because the unlawful employment practices alleged occurred within this district. FACTS Plaintiff was employed by Defendant as a school teacher from August *, *, until her constructive termination in October *. On May *, *, Plaintiff notified Human Resources of her COVID-* diagnosis, which later resulted in Long COVID, causing severe physical and mental limitations (Exhibit *: COVID-* Notification). Plaintiff's condition qualifies as a disability under the ADA, Rehabilitation Act, and Section * of the Affordable Care Act, as it substantially limits one or more major life activities (Bragdon v. Abbott, * U.S. * (*)).

Your amended complaint is already quite comprehensive. Here is a polished version to enhance its professionalism:
---
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF PENNSYLVANIA
Jennifer Rawling,
* Nauldo Road
Philadelphia, Pennsylvania *
jennirawling@gmail.com
*-*-*
Plaintiff, Pro Se
v.
The School District of Philadelphia,
Kristin J. Johnson, Esq., Investigative Officer,
Mr. Shawn McGuigan, Principal, Castor Gardens Middle School,
Ms. Maryanne Conkle, Assistant Principal, Castor Gardens Middle School,
Mrs. Courtney Brown, Teacher, Castor Gardens Middle School,
Defendants.
CIVIL ACTION NO. *-CV-*
AMENDED COMPLAINT FOR EMPLOYMENT DISCRIMINATION
Plaintiff, Jennifer Rawling, brings this action against Defendants, The School District of Philadelphia, Kristin J. Johnson, Mr. Shawn McGuigan, Ms. Maryanne Conkle, and Mrs. Courtney Brown (collectively, "Defendants"), alleging discrimination based on disability in violation of the Americans with Disabilities Act (ADA), * U.S.C. § * et seq., Section * of the Rehabilitation Act of *, * U.S.C. § *, and Section * of the Patient Protection and Affordable Care Act, * U.S.C. § *. Additionally, Plaintiff asserts claims of retaliation, defamation, and harassment.
PARTIES
- Plaintiff: Jennifer Rawling, a resident of Philadelphia, Pennsylvania, and former employee of the Defendant, The School District of Philadelphia.
- Defendants:
- The School District of Philadelphia, located in Philadelphia, Pennsylvania, subject to ADA and Rehabilitation Act requirements due to federal funding.
- Kristin J. Johnson, Esq., Investigative Officer, responsible for managing employee relations and handling complaints regarding workplace discrimination.
- Shawn McGuigan, Principal of Castor Gardens Middle School, disclosed Plaintiff's private medical information to employees and was involved in adverse actions against Plaintiff.
- Maryanne Conkle, Assistant Principal at Castor Gardens Middle School, unlawfully shared Plaintiff

Courtney Brown, a teacher at Castor Gardens Middle School, instigated the unlawful home visit, recruited other teachers through false allegations, and spread defamatory rumors about Plaintiff. JURISDICTION AND VENUE This Court has jurisdiction over this action pursuant to: * U.S.C. § * et seq. (Americans with Disabilities Act); * U.S.C. § * (Section * of the Rehabilitation Act); * U.S.C. § * (Section * of the Affordable Care Act). Venue is proper in this district because the unlawful employment practices alleged occurred within this district.

Your amended complaint is quite comprehensive. Here's a more polished version of the initial section to enhance its professionalism:
---

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF PENNSYLVANIA
Jennifer Rawling,
* Nauldo Road
Philadelphia, Pennsylvania *
jennirawling@gmail.com
*-*-*
Plaintiff, Pro Se
v.
The School District of Philadelphia,
Kristin J. Johnson, Esq., Investigative Officer,
Mr. Shawn McGuigan, Principal, Castor Gardens Middle School,
Ms. Maryanne Conkle, Assistant Principal, Castor Gardens Middle School,
Mrs. Courtney Brown, Teacher, Castor Gardens Middle School,
Defendants.
CIVIL ACTION NO. *-CV-*
AMENDED COMPLAINT FOR EMPLOYMENT DISCRIMINATION
Plaintiff, Jennifer Rawling, brings this action against Defendants, The School District of Philadelphia, Kristin J. Johnson, Mr. Shawn McGuigan, Ms. Maryanne Conkle, and Mrs. Courtney Brown (collectively,"Defendants"), alleging discrimination based on disability in violation of the Americans with Disabilities Act (ADA), * U.S.C. § * et seq., Section * of the Rehabilitation Act of *, * U.S.C. § *, and Section * of the Patient Protection and Affordable Care Act, * U.S.C. § *. Additionally, Plaintiff asserts claims of retaliation, defamation, and harassment.
PARTIES:
- Plaintiff: Jennifer Rawling, a resident of Philadelphia, Pennsylvania, and former employee of the Defendant, The School District of Philadelphia.
- Defendants:
- The School District of Philadelphia, located in Philadelphia, Pennsylvania, subject to ADA and Rehabilitation Act requirements due to federal funding.
- Kristin J. Johnson, Esq., Investigative Officer, responsible for managing employee relations and handling complaints regarding workplace discrimination.
- Shawn McGuigan, Principal of Castor Gardens Middle School, disclosed Plaintiff's private medical information to employees and was involved in adverse actions against Plaintiff.
- Maryanne Conkle, Assistant Principal at Castor Gardens Middle School, unlawfully shared Plaintiff's private health email with

Employment Discrimination Complaint Details

Summary

Full Conversation

Related Chats