Preview
2/27/2019 9:30 PM
Marilyn Burgess - District Clerk Harris County
Envelope No. 31554174
By: Kenya Kossie
Filed: 2/27/2019 9:30 PM
CAUSE NO. 2018-47782
LINDA SALINAS RONEY § IN THE DISTRICT COURT OF
Plaintiff, §
§
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§
ler
v.
§
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§ 295TH JUDICIAL DISTRICT
SOUTHWEST KEY §
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PROGRAMS, INC., §
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§
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Defendant, §
HARRIS COUNTY, TEXAS
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FIRST AMENDED PETITION AND REQUEST FOR DISCLOSURE
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TO THE HONORABLE JUDGE DONNA ROTH:
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COMES NOW, Plaintiff Linda Salinas Roney and files this her First Amended
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Petition and Request for Disclosure against Defendant, Southwest Key Programs,
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Inc1., (hereinafter referred to as “Southwest Key”) and will show the Court as
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of
follows:
Un
I.
JURISDICTION AND VENUE
1
Correctly named Southwest Key Programs, Inc. and not Southwest Key.
This court has subject matter and personal jurisdiction of this action which
arises under the Texas Family Code Section 261.110, Texas Labor Code, the
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Texas Commission on Human Rights Act. Southwest Key Programs, Inc., has
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continuous contact with the State of Texas in that an assertion of jurisdiction would
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not offend traditional notions of fair play and substantial justice. The cause of
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action arose in Harris County, Texas in that Mrs. Salinas Roney was employed by
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Southwest Key Program, Inc., in this county and Southwest Key conducts
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business.
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Child Abuse: An employee may not be retaliated against (or discriminated
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against) for reporting suspected child abuse. Tex. Fam. Code Section 261.110.
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Discrimination: An employee may not be retaliated against (or discriminated
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against) for opposing a discriminatory practice, making a discrimination charge
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filing a discrimination complaint, or testifying, assisting, or participating in an
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investigation, proceeding or hearing of discrimination. Texas law prohibits
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discrimination on the basis of race, color, disability, and retaliation, Tex. Lab.
of
Un
Code Ann Section 21.005.
II.
PARTIES AND SERVICE
Defendant, Southwest Key Program, Inc., is a private corporation that house
illegal unaccompanied minors children in detention center and has appeared and
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ler
answered on January 1, 2019. This facility is a General Residential Care facilitiy
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which is being funded by The Office of Refugee and Resettlement (ORR).
ist
Plaintiff, Linda Salinas Roney (“Roney”) is an individual who resides in Ft.
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Bend County, Texas. Her last four digits of her social security number is 7836. Her
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last three digits of her driver’s license is 466. n
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ily
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III.
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DISCOVERY CONTROL PLAN
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Plaintiff intend that this suit be governed by Discovery Control Level Three in
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this complex Child Abuse Whistleblower case under the Tex. Fam. Code Section
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2
261.110 and employment discrimination case based on her disabilities .
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IV.
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EXHAUSTION OF ADMINISTRATIVE REMEDIES
2
She suffers from PTSD’s, anxiety disorder, Sjogren's syndrome, depression and other conditions.
Plaintiff, Linda Salinas Roney has exhausted her administrative remedies
by dual filing charges with the United States Equal Employment Commission and
the Texas Commission on Human Rights and seeking a Notice of Right to File
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Civil Action. Her claims filed with the EEOC/ Texas Workforce Commission are
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a continuing violation of the original charge of discrimination and the amended
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charge.
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V.
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NATURE OF THE CASE:
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This is a child abuse and neglect,
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whistleblower retaliation and disability
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discrimination case based on a migrant children detention center, Southwest Key
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Program, Inc.’s, retaliation and constructive discharge of its case manager, Mrs.
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Linda Salinas Roney for her good faith reporting of drug sales and suspected drug
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usage at a Houston, Texas facility. A facility that houses minor children from
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ages 11 to 1 year olds.
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VI.
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BACKGROUND FACTS
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Plaintiff, Mrs. Linda Salinas Roney was hired by Southwest Key on or about
March 18, 2016 as a case manager in a professional capacity. She worked
diligently for a year and five months with Southwest Key, Montezuma program
without incident, discipline, attendance or tardiness issues. Linda Roney saw her
co-worker, Roquliea Nash engage in child abuse and neglect when she attempted
to sale Vicodin and Oxycodin in a drug transaction at the Southwest Key facility to
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a male friend that contacted her over the phone while she overheard the transaction
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take place when the drugs were to be picked up, which was at her home after she
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completed her lab classes on the evening of August 11, 2016. The male and Mrs.
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Salinas Roney did not purchase the drugs. After Ms. Nash was not successful,
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persistent she asked Mrs. Salinas Roney if she knew someone who would purchase
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the pills as she was needing the money.
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ily
Ms. Nash approached Mrs. Roney on August 25, 2016, again requesting to
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look for eating utensils and to ask Mrs. Roney if she knew anyone who may be
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e
interested in purchasing the illegal drugs. On or about August 11, 2016, concerned
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for the health, safety and well-being of children, Linda Salinas Roney reported in
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op
good faith the child abuse and neglect to Southwest Key managers, Andera
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Rodquirez, Lizette Grimaldo and Santiago Inchaurregui an attempt by her
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fic
co-worker Roquliea Nash to sale drugs, specifically Vicodin and Oxycontin at the
of
Un
Southwest Key facility which housed minor children from the ages of 11 to 1 years
old immigrants.
This issue was not properly reported by Southwest Key’s management to the
Texas Health and Human Services as as required by law. After reporting both
incidents of child abuse and or neglect, Mr. Santiago Inchaurregui requested Mrs.
k
Roney to come to his office and conduct a conference call with Connie Hernandez
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tC
from Human Resources in Austin, Texas, It was However, Susanne Arrando from
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the Texas Health and Human Services who conducted a four hour interview with
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sD
Linda Salinas Roney. During the interview, Mrs. Roney advised Mrs. Arrando of
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the illegal drug attempted transaction and ongoing drug sales efforts that were
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being conducted by Roquliea Nash at the Southwest Key’s facility.
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Ms. Nash explained to Mrs. Roney in detail how she obtained the Vicodin and
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Oxycontin and how she sold the drugs. This information was communicated to the
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Texas Health and Human Services investigating officer, Ms. Arrando by Mrs.
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Roney. However, the complaint History Report prepared by Ms. Arrando and
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Southwest Key dated November 30, 2016 does not indicated this information was
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ever logged into the Texas Health and Human Compliance History Report or ever
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fic
investigated. Southwest Key interfered with the investigation and with the safety
of
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and welfare of the innocent minor children on the property. As a result, on or about
November 30, 2016, the State with the interference from Southwest Key failed to
conduct a neutral, thorough and complete investigation into the confirmed drug
sales and suspected drug use at the Southwest Key facility housing minor children;
exposing minor children to illicit drug sales and suspected drug usage at the
facility.
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Instead of investigating the issues lodged by Ms. Roney, days later, on or about
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December 1, 2016, ironically, Southwest Key’s retaliated against Mrs. Roney and
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ordered her to undergo a “random drug test”. A test she no doubt passed. Mrs.
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Roney was upset as she knew the drug test was not a random urinalysis. This was
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more than harassment and retaliation towards the fact that Mrs. Roney had filed a
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Bu
drug grievance against Ms. Nash and that licensing was now involved.
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ily
Instead of investigating the issues lodged by Mrs. Roney’s, supervisor Sandy
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M
Perez sent an email regarding a missed/telephonic appointment with a case
of
e
manager on a home study. Mrs. Roney made the appointment the day before
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August 29, 2016, however, when Mrs. Rone went to get the minor he was not
yO
op
allowed to leave the classroom as the clinicians were with all the minor in group.
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Mrs. Roney went back to advise the home study case manager, who had notified
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fic
Mrs. Roney supervisor of the missed call.
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Instead of investigating the issues lodged by Mrs. Roney, was required to meet
with supervisors and management, Lizzette and Sandy Perez regarding her job
performance. On September 28, 2016 Mrs. Roney met with Santiago regarding
Roquliea Nash drug grievance that Mrs. Roney filed. On October 28, 2016 Mrs.
Roney received from her supervisor Sandy a 2.43 job performance evaluation.
November 23, 2016 Mrs. Roney had a conversation with Paula regarding two
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sisters whose cases were not completed due to minors mother failing to turn in
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paperwork and ID’s of other household members.
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On or about November 30, 2017 Mrs. Roney met with licensing Susie
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sD
from Austin for purposes of explaining the grievance involving child abuse and
es
neglect. Mrs. Roney the employee who filed a complaint about suspected child
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abuse: drugs on the premises was asked, if
Bushe had drugs on the premises. Mrs.
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ily
Roney advised she did not have illegal drugs only her prescribed drug. She
ar
M
requested where the bottle was located?. Mrs. Roney advised her that the
of
e
medication bottle was in a book bag that she carried daily and was zipped and
ffic
under her desk. Rather, than investigate the drug sale, Mrs. Roney was asked what
yO
op
type of medication she was taking and if she failed to explained what the
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medication was for that it would cause possible issues and CPS Policy and possibly
ial
fic
SWK policy required disclosures. Personal medication was not allowed on the
of
Un
premises. Mrs. Roney advised that other employees have medication and they
were not to disclose their medications. That she suffers from Sjogren’s syndrome
an autoimmune disease which is a cousin of Lupus and regularly take pills. Susie
told Mrs. Roney to contact her during lunch and she was told she would not be
terminated for having her medication at work and to return to meeting with the
investigator, Susie.
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Mrs. Roney immediately reported in good faith the drug sale child
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abuse/neglect misconduct to Southwest Key’s upper-management. Rather than
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management notifying Ms. Nash of the allegations and interviewing her, contacting
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Houston Police, reporting the allegation of drug sales and/ suspected drug usage to
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the Texas Department of Human Services and addressing the issues directly with
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Mrs. Nash; instead, Southwest Key
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conducted a purported investigation and
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vaguely concluded: “the concern was investigated and the investigator found
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information that will be addressed by program management” within the memo
of
e
dated September 28, 2016, was served as a conclusion and an official response to
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Mrs. Roney’s grievance.
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On or about January 11, 2017 Salinas was suspended from employment
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without pay.
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fic
To date, nothing was done at Southwest Key to stop the drug sale and
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suspected drug use by Ms. Nash from the date that Mrs. Roney reported the
conduct to Mrs. Roney’s forced and constructive discharge and otherwise
discriminated against in violation of the prohibition against employer retaliatory
discharge, suspension or otherwise discriminated against. Safety and soon from
work asked about his suspension.
Mrs. Roney in good faith concerned for the well-being of the children in the
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facility, the child abuse and neglect, initiated and reported to the government: law
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tC
enforcement, the Harris County District Attorney the drug sale and suspected drug
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usage at Southwest Key to remedy the impact of the drug sales and distribution by
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the Southwest Key employee, Ms. Nash. Particularly since Ms. Roney understood
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the mission of the program was to keep kids out of institutions and home with their
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families, in their communities. Through its
Buthree areas of programming: youth
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ily
justice alternatives, immigrant children’s shelters and education. Southwest Key
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purports to seek to create opportunities for families to become self-sufficient by
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offering programming in adult education, community building and workforce
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development. The inspiring kids and families Southwest Key work with are
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op
seeking the American dream--equality, education, and a healthier quality of life. At
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Southwest Key they claim to simply open the doors to opportunity so they can
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fic
achieve these dreams.
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Linda Roney’s efforts to adhere to the mission statement of Southwest Key
caused her to be: harassed, retaliated against and subjected to different terms and
conditions of her employment: including, but not limited to being subjected to
random drug test for reporting illegal activity-drug sales, disciplined, written up
routinely followed, denied reasonable accommodation due to her disability (denied
an office with a telephone).
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On or about August 8, 2017 Linda Salinas submitted a resignation letter to
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Southwest Key as she could no longer take the harassment, stressors and
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differences in treatment anymore.
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Linda Roney asserts her claim also as a Whistleblower under Texas Family
es
Code Section 261.110 employer retaliation asserts that these are false claims and
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an effort by Southwest Key to defraud
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the State of Texas and the Federal
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Government.
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VII.
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WHISTLEBLOWER, RETALIATION AND VIOLATIONS UNDER TEXAS
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FAMILY CODE SECTION 261.110--PUBLIC POLICY.
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Plaintiff incorporates the facts as stated above in paragraph VI.
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Plaintiff, Mr. Roney was a professional who in good faith reported child abuse
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fic
or neglect to her supervisor, lead case manager and assistant program director
of
Un
(Sandy Perez, Santiago Inchaurregui and Lizzette Grimaldo), a state regulatory
agency (Texas Health and Human Services) and law enforcement agency (Harris
County District Attorney). Plaintiff initiated or cooperated with an investigation or
proceeding by a governmental entity ( Harris County District Attorney and Texas
Health and Human Services) in relation to an allegation of child abuse or neglect.
Southwest Key responded by writing her up, suspending and constructively
k
discharging, harassing etc. Mrs. Roney’s employment as a case manager and
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otherwise discriminated against her.
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VIII.
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sD
DISABILITY DISCRIMINATION UNDER TEX. LAB. CODE
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SECTION 21.055 AND HARASSMENT/HOSTILE WORKING
ENVIRONMENT
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Plaintiff incorporates the facts as stated above in paragraph VI.
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Southwest Key Programs, Inc., violated Texas Labor Code and the Texas
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Commission on Human Rights Act when it refused to because of her disabilities,
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e
post-traumatic disorder.
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Southwest Key Programs, Inc., is engaged in an industry affecting
yO
op
commerce and has 15 or more employees during the relevant time periods. Mrs.
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Salinas Roney is disabled in that she suffers from Post traumatic Stress Disorder
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fic
(“PTSD”), anxiety, severe depression and associate disorder. After the harassment
of
Un
and stress caused by working at Southwest Key Mrs. Roney’s medications
milligrams were increased (Effexor, Xanax, Prazodone and Strattera), Mrs. Salinas
Roney suffered injuries and damages within the jurisdictional limits of this Court.
Mrs. Salinas requested a reasonable accommodation for her disabilities
which included being allowed to work in a quiet area. Dr. Neda Gandhi requested
that Mrs. Salinas be allowed to work in a quiet area because of disabilities,
k
including but not limited to PTSD etc.
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tC
On or about January 11, 2017 Salinas was suspended from employment
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without pay.
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IX.
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REQUEST FOR DISCLOSURE
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Southwest Key Program, Inc., is requested to disclose, within 50 days of
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service of this request, the information and material described in Rule 194.2.
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Preview
2/27/2019 9:30 PM Marilyn Burgess - District Clerk Harris County Envelope No. 31554174 By: Kenya Kossie Filed: 2/27/2019 9:30 PM CAUSE NO. 2018-47782 LINDA SALINAS RONEY § IN THE DISTRICT COURT OF Plaintiff, § § k § ler v. § tC § 295TH JUDICIAL DISTRICT SOUTHWEST KEY § ric PROGRAMS, INC., § ist § sD Defendant, § HARRIS COUNTY, TEXAS es rg Bu n ily ar M FIRST AMENDED PETITION AND REQUEST FOR DISCLOSURE of e TO THE HONORABLE JUDGE DONNA ROTH: ffic O COMES NOW, Plaintiff Linda Salinas Roney and files this her First Amended y op Petition and Request for Disclosure against Defendant, Southwest Key Programs, C ial Inc1., (hereinafter referred to as “Southwest Key”) and will show the Court as fic of follows: Un I. JURISDICTION AND VENUE 1 Correctly named Southwest Key Programs, Inc. and not Southwest Key. This court has subject matter and personal jurisdiction of this action which arises under the Texas Family Code Section 261.110, Texas Labor Code, the k Texas Commission on Human Rights Act. Southwest Key Programs, Inc., has ler tC continuous contact with the State of Texas in that an assertion of jurisdiction would ric not offend traditional notions of fair play and substantial justice. The cause of ist sD action arose in Harris County, Texas in that Mrs. Salinas Roney was employed by es Southwest Key Program, Inc., in this county and Southwest Key conducts rg business. Bu n ily Child Abuse: An employee may not be retaliated against (or discriminated ar M against) for reporting suspected child abuse. Tex. Fam. Code Section 261.110. of e Discrimination: An employee may not be retaliated against (or discriminated ffic against) for opposing a discriminatory practice, making a discrimination charge yO op filing a discrimination complaint, or testifying, assisting, or participating in an C investigation, proceeding or hearing of discrimination. Texas law prohibits ial fic discrimination on the basis of race, color, disability, and retaliation, Tex. Lab. of Un Code Ann Section 21.005. II. PARTIES AND SERVICE Defendant, Southwest Key Program, Inc., is a private corporation that house illegal unaccompanied minors children in detention center and has appeared and k ler answered on January 1, 2019. This facility is a General Residential Care facilitiy tC ric which is being funded by The Office of Refugee and Resettlement (ORR). ist Plaintiff, Linda Salinas Roney (“Roney”) is an individual who resides in Ft. sD es Bend County, Texas. Her last four digits of her social security number is 7836. Her rg last three digits of her driver’s license is 466. n Bu ily ar III. M DISCOVERY CONTROL PLAN of e Plaintiff intend that this suit be governed by Discovery Control Level Three in ffic O this complex Child Abuse Whistleblower case under the Tex. Fam. Code Section y op 2 261.110 and employment discrimination case based on her disabilities . C ial fic IV. of Un EXHAUSTION OF ADMINISTRATIVE REMEDIES 2 She suffers from PTSD’s, anxiety disorder, Sjogren's syndrome, depression and other conditions. Plaintiff, Linda Salinas Roney has exhausted her administrative remedies by dual filing charges with the United States Equal Employment Commission and the Texas Commission on Human Rights and seeking a Notice of Right to File k Civil Action. Her claims filed with the EEOC/ Texas Workforce Commission are ler tC a continuing violation of the original charge of discrimination and the amended ric charge. ist sD V. es NATURE OF THE CASE: rg This is a child abuse and neglect, Bu whistleblower retaliation and disability n ily discrimination case based on a migrant children detention center, Southwest Key ar M Program, Inc.’s, retaliation and constructive discharge of its case manager, Mrs. of e Linda Salinas Roney for her good faith reporting of drug sales and suspected drug ffic usage at a Houston, Texas facility. A facility that houses minor children from yO op ages 11 to 1 year olds. C VI. ial fic BACKGROUND FACTS of Un Plaintiff, Mrs. Linda Salinas Roney was hired by Southwest Key on or about March 18, 2016 as a case manager in a professional capacity. She worked diligently for a year and five months with Southwest Key, Montezuma program without incident, discipline, attendance or tardiness issues. Linda Roney saw her co-worker, Roquliea Nash engage in child abuse and neglect when she attempted to sale Vicodin and Oxycodin in a drug transaction at the Southwest Key facility to k a male friend that contacted her over the phone while she overheard the transaction ler tC take place when the drugs were to be picked up, which was at her home after she ric completed her lab classes on the evening of August 11, 2016. The male and Mrs. ist sD Salinas Roney did not purchase the drugs. After Ms. Nash was not successful, es persistent she asked Mrs. Salinas Roney if she knew someone who would purchase rg the pills as she was needing the money. Bu n ily Ms. Nash approached Mrs. Roney on August 25, 2016, again requesting to ar M look for eating utensils and to ask Mrs. Roney if she knew anyone who may be of e interested in purchasing the illegal drugs. On or about August 11, 2016, concerned ffic for the health, safety and well-being of children, Linda Salinas Roney reported in yO op good faith the child abuse and neglect to Southwest Key managers, Andera C Rodquirez, Lizette Grimaldo and Santiago Inchaurregui an attempt by her ial fic co-worker Roquliea Nash to sale drugs, specifically Vicodin and Oxycontin at the of Un Southwest Key facility which housed minor children from the ages of 11 to 1 years old immigrants. This issue was not properly reported by Southwest Key’s management to the Texas Health and Human Services as as required by law. After reporting both incidents of child abuse and or neglect, Mr. Santiago Inchaurregui requested Mrs. k Roney to come to his office and conduct a conference call with Connie Hernandez ler tC from Human Resources in Austin, Texas, It was However, Susanne Arrando from ric the Texas Health and Human Services who conducted a four hour interview with ist sD Linda Salinas Roney. During the interview, Mrs. Roney advised Mrs. Arrando of es the illegal drug attempted transaction and ongoing drug sales efforts that were rg Bu being conducted by Roquliea Nash at the Southwest Key’s facility. n ily Ms. Nash explained to Mrs. Roney in detail how she obtained the Vicodin and ar M Oxycontin and how she sold the drugs. This information was communicated to the of e Texas Health and Human Services investigating officer, Ms. Arrando by Mrs. ffic Roney. However, the complaint History Report prepared by Ms. Arrando and yO op Southwest Key dated November 30, 2016 does not indicated this information was C ever logged into the Texas Health and Human Compliance History Report or ever ial fic investigated. Southwest Key interfered with the investigation and with the safety of Un and welfare of the innocent minor children on the property. As a result, on or about November 30, 2016, the State with the interference from Southwest Key failed to conduct a neutral, thorough and complete investigation into the confirmed drug sales and suspected drug use at the Southwest Key facility housing minor children; exposing minor children to illicit drug sales and suspected drug usage at the facility. k Instead of investigating the issues lodged by Ms. Roney, days later, on or about ler tC December 1, 2016, ironically, Southwest Key’s retaliated against Mrs. Roney and ric ordered her to undergo a “random drug test”. A test she no doubt passed. Mrs. ist sD Roney was upset as she knew the drug test was not a random urinalysis. This was es more than harassment and retaliation towards the fact that Mrs. Roney had filed a rg Bu drug grievance against Ms. Nash and that licensing was now involved. n ily Instead of investigating the issues lodged by Mrs. Roney’s, supervisor Sandy ar M Perez sent an email regarding a missed/telephonic appointment with a case of e manager on a home study. Mrs. Roney made the appointment the day before ffic August 29, 2016, however, when Mrs. Rone went to get the minor he was not yO op allowed to leave the classroom as the clinicians were with all the minor in group. C Mrs. Roney went back to advise the home study case manager, who had notified ial fic Mrs. Roney supervisor of the missed call. of Un Instead of investigating the issues lodged by Mrs. Roney, was required to meet with supervisors and management, Lizzette and Sandy Perez regarding her job performance. On September 28, 2016 Mrs. Roney met with Santiago regarding Roquliea Nash drug grievance that Mrs. Roney filed. On October 28, 2016 Mrs. Roney received from her supervisor Sandy a 2.43 job performance evaluation. November 23, 2016 Mrs. Roney had a conversation with Paula regarding two k sisters whose cases were not completed due to minors mother failing to turn in ler tC paperwork and ID’s of other household members. ric On or about November 30, 2017 Mrs. Roney met with licensing Susie ist sD from Austin for purposes of explaining the grievance involving child abuse and es neglect. Mrs. Roney the employee who filed a complaint about suspected child rg abuse: drugs on the premises was asked, if Bushe had drugs on the premises. Mrs. n ily Roney advised she did not have illegal drugs only her prescribed drug. She ar M requested where the bottle was located?. Mrs. Roney advised her that the of e medication bottle was in a book bag that she carried daily and was zipped and ffic under her desk. Rather, than investigate the drug sale, Mrs. Roney was asked what yO op type of medication she was taking and if she failed to explained what the C medication was for that it would cause possible issues and CPS Policy and possibly ial fic SWK policy required disclosures. Personal medication was not allowed on the of Un premises. Mrs. Roney advised that other employees have medication and they were not to disclose their medications. That she suffers from Sjogren’s syndrome an autoimmune disease which is a cousin of Lupus and regularly take pills. Susie told Mrs. Roney to contact her during lunch and she was told she would not be terminated for having her medication at work and to return to meeting with the investigator, Susie. k Mrs. Roney immediately reported in good faith the drug sale child ler tC abuse/neglect misconduct to Southwest Key’s upper-management. Rather than ric management notifying Ms. Nash of the allegations and interviewing her, contacting ist sD Houston Police, reporting the allegation of drug sales and/ suspected drug usage to es the Texas Department of Human Services and addressing the issues directly with rg Mrs. Nash; instead, Southwest Key Bu conducted a purported investigation and n ily vaguely concluded: “the concern was investigated and the investigator found ar M information that will be addressed by program management” within the memo of e dated September 28, 2016, was served as a conclusion and an official response to ffic Mrs. Roney’s grievance. yO op On or about January 11, 2017 Salinas was suspended from employment C without pay. ial fic To date, nothing was done at Southwest Key to stop the drug sale and of Un suspected drug use by Ms. Nash from the date that Mrs. Roney reported the conduct to Mrs. Roney’s forced and constructive discharge and otherwise discriminated against in violation of the prohibition against employer retaliatory discharge, suspension or otherwise discriminated against. Safety and soon from work asked about his suspension. Mrs. Roney in good faith concerned for the well-being of the children in the k facility, the child abuse and neglect, initiated and reported to the government: law ler tC enforcement, the Harris County District Attorney the drug sale and suspected drug ric usage at Southwest Key to remedy the impact of the drug sales and distribution by ist sD the Southwest Key employee, Ms. Nash. Particularly since Ms. Roney understood es the mission of the program was to keep kids out of institutions and home with their rg families, in their communities. Through its Buthree areas of programming: youth n ily justice alternatives, immigrant children’s shelters and education. Southwest Key ar M purports to seek to create opportunities for families to become self-sufficient by of e offering programming in adult education, community building and workforce ffic development. The inspiring kids and families Southwest Key work with are yO op seeking the American dream--equality, education, and a healthier quality of life. At C Southwest Key they claim to simply open the doors to opportunity so they can ial fic achieve these dreams. of Un Linda Roney’s efforts to adhere to the mission statement of Southwest Key caused her to be: harassed, retaliated against and subjected to different terms and conditions of her employment: including, but not limited to being subjected to random drug test for reporting illegal activity-drug sales, disciplined, written up routinely followed, denied reasonable accommodation due to her disability (denied an office with a telephone). k On or about August 8, 2017 Linda Salinas submitted a resignation letter to ler tC Southwest Key as she could no longer take the harassment, stressors and ric differences in treatment anymore. ist sD Linda Roney asserts her claim also as a Whistleblower under Texas Family es Code Section 261.110 employer retaliation asserts that these are false claims and rg an effort by Southwest Key to defraud Bu the State of Texas and the Federal n ily Government. ar M VII. of e WHISTLEBLOWER, RETALIATION AND VIOLATIONS UNDER TEXAS ffic FAMILY CODE SECTION 261.110--PUBLIC POLICY. yO op Plaintiff incorporates the facts as stated above in paragraph VI. C Plaintiff, Mr. Roney was a professional who in good faith reported child abuse ial fic or neglect to her supervisor, lead case manager and assistant program director of Un (Sandy Perez, Santiago Inchaurregui and Lizzette Grimaldo), a state regulatory agency (Texas Health and Human Services) and law enforcement agency (Harris County District Attorney). Plaintiff initiated or cooperated with an investigation or proceeding by a governmental entity ( Harris County District Attorney and Texas Health and Human Services) in relation to an allegation of child abuse or neglect. Southwest Key responded by writing her up, suspending and constructively k discharging, harassing etc. Mrs. Roney’s employment as a case manager and ler tC otherwise discriminated against her. ric VIII. ist sD DISABILITY DISCRIMINATION UNDER TEX. LAB. CODE es SECTION 21.055 AND HARASSMENT/HOSTILE WORKING ENVIRONMENT rg Bu Plaintiff incorporates the facts as stated above in paragraph VI. n ily Southwest Key Programs, Inc., violated Texas Labor Code and the Texas ar M Commission on Human Rights Act when it refused to because of her disabilities, of e post-traumatic disorder. ffic Southwest Key Programs, Inc., is engaged in an industry affecting yO op commerce and has 15 or more employees during the relevant time periods. Mrs. C Salinas Roney is disabled in that she suffers from Post traumatic Stress Disorder ial fic (“PTSD”), anxiety, severe depression and associate disorder. After the harassment of Un and stress caused by working at Southwest Key Mrs. Roney’s medications milligrams were increased (Effexor, Xanax, Prazodone and Strattera), Mrs. Salinas Roney suffered injuries and damages within the jurisdictional limits of this Court. Mrs. Salinas requested a reasonable accommodation for her disabilities which included being allowed to work in a quiet area. Dr. Neda Gandhi requested that Mrs. Salinas be allowed to work in a quiet area because of disabilities, k including but not limited to PTSD etc. ler tC On or about January 11, 2017 Salinas was suspended from employment ric without pay. ist sD es IX. rg REQUEST FOR DISCLOSURE Bu n ily Southwest Key Program, Inc., is requested to disclose, within 50 days of ar M service of this request, the information and material described in Rule 194.2. of e ffic