FILED 371872018 11-18 AM CLERK OF SUPERIOR COURT DEKALB COUNTY GEORGIA STATE OF GEORGIA SUPERIOR COURT OF DEKALB COUNTY TERESA SLAYTON, Plaintiff, : CIVIL ACTION FILENO. 18CV3085 JURY TRIAL DEMANDED DEKALB COUNTY, GA Defendants. COMPLAIN. Plaintiff Teresa Slayton (“Plaintiff” or “Ms. Slayton”) files this Complaint egainst DeKalb County, GA (“Defendant”), showing the Court as follows: AURISDICTION AND VENUE L This is a lawsuit for equitable relief and monetary damages based on the retaliatory demotion and termination of Teresa Slayton by DeKalb County in violation of the Georgia Whistleblower Act, 0.C.G.A. § 45-1-4 er seg. ("GWA") and, thus, subject matter jurisdiction is proper in this Court, 2 ‘Ms. Slayton is a resident of Rockdale County, Georgia and submits herself to the jurisdiction of this Court. 3. Venue is proper in this Court because the actions alleged in this lawsuit occurred in DeKalb County. ‘THE PARTIES 4 ‘Ms. Slayton was employed by DeKalb County, Georgia as a Senior Procurement Agent in the Procurement and Contracting Department from August 2016 through her retaliatory termination on August 9, 2017,5. At all times relevant, Ms, Slayton was a “public employee” as defined by the Georgia Whistleblower Act, O.C.G.A, § 45-1-4(a)@). 6. Defendant DeKalb County, Georgia is a “public employer” as defined by 0.C.G.A. § 45-1-4(@)(4). 7. Defendant may be served with process via personal service upon the DeKalb County Chief Executive Officer, Michael L, Thurmond, at the office of the DeKalb County CEO, Manuel J. Maloof Center, 1300 Commerce Drive, 6th Floor, Decatur, Georgia 30030. EACTUAL ALLEGATIONS 8 Ms, Slayton began employment with DeKalb County as a Senior Procurement Agent in August 2016 then appointed CIP team lead. 9. At that time, Ms. Slayton’s duties included supervisory and team lead responsibilities. 10. When Ms. Slayton began employment, she was supervised by CIP Manager Warrick Sams. 11, Throughout Ms. Slayton’s employment, Talisa Clark was the Interim Chief Procurement Officer then the permanent Chief Procurement Officer for the Procurement and ‘Contracting Department. 12, OnNovember 2016, Ms. Slayton engaged in whistleblowing activity protected by the GWA when she shared with Mr, Sam's that the Department of Watershed Management had a conflict of interest with @ contractor, John Jones, and also raised concerns that a DeKalb County contractor, Tetra Tech, was overbilling the County on change orders. 13, Mz, Sams shared Ms, Slayton’s disclosures with Ms. Clark14, In January 2017, Ms, Slayton again engaged in protected activity under the GWA when she shared with Mr. Sams and Ms. Clark, in writing, that employees in the Department of Watershed Management were providing inside information to Wolpert, a bidder on a capital improvement project for an estimated $7.7 million dollars contract, in an attempt to rig the bid for a project. 15, In February 2017, Ms. Slayton again engaged in protected activity under the GWA in a face-to-face meeting with Mr. Sams when Ms, Slayton disclosed to Mr. Sams text messages and Ms, Clark contacted her and asked Ms. Slayton to engage in unethical and untruthful conduct. 16. On March 6, 2017, Ms. Clark terminated Mr. Sams. 17. On March 17, 2017, Ms, Clark and Deputy Director Cathryn Homer demoted Ms. Slayton by stripping Ms. Slayton of her supervisory and team lead responsibilities in retaliation for her engaging in protected conduct under the GWA. 18. On March 20, 2017, Ms. Slayton suffered a second adverse employment action for her protected activity when Ms. Clark and Ms. Homer failed and refused to promote her to the Interim CIP Manager position vacated by Mr, Sams despite Ms. Slayton’s exceptional credentials 19, In late March 2017, Ms. Slayton was subject to coercion by Deputy Director ‘Cathryn Homer, during 2 closed, door meeting, to engage fictitious acts and untruthful conduct, about Mr, Sams character and work product on a projects, 20. In late March 2017, Ms. Slayton met with an FBI Agent and Mr. Sams to notify them illegal activity in DeKalb County and workplace coercion. 21. Between April 6, 2017 and August 9, 2017, Ms. Slayton met with the FBI and provided the FBI information relating to the following illegal practices by the DeKalb County Departments of Watershed Management and Procurement and Contracting: collusion, bid rigging,