Second Amended Complaint

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND
NICOLE ANDREA SMITH

ADDRESS
REDACTED
And
JACQUELINE KIANA MORANT
ADDRESS
REDACTED
Case #GLR-15-2921
JURY TRIAL DEMANDED
And
AMY TOWSON
ADDRESS
REDACTED
And
SARA GARRET
ADDRESS
REDACTED
And
ONNADAY MCINTOSH-GRIGGS
ADDRESS
REDACTED
And
STEPHANIE HARRIS
ADDRESS
REDACTED
And
SHANAE BARNES
ADDRESS
REDACTED
And
CELESTE ENGLISH
ADDRESS
REDACTED
And
TAKIRA CARTER
ADDRESS
REDACTED
And
LYNETTE COOPER
ADDRESS
REDACTED
And
DETRIA ADAMS
ADDRESS
REDACTED
And
SHANAE BOLES
ADDRESS
REDACTED
And
LASONIA GILBERT
ADDRESS
REDACTED
And
MYRTLE GILBERT
ADDRESS
REDACTED
And
TRACEY HOLDEN
ADDRESS
REDACTED
And
KHRYSTYNA KELLEY
ADDRESS
REDACTED
And
TOWANDA PARKER
ADDRESS
REDACTED
And
SIERRIA WARREN
ADDRESS
REDACTED
And
ROSENA PRINCE
ADDRESS
REDACTED
All of the above Individually
Named Plaintiffs On Behalf of Themselves
and all Others Similarly Situated
Plaintiffs
v.
THE CITY OF BALTIMORE
100 Holliday St #250
Baltimore, MD 21202
And
MAYOR AND CITY COUNSEL OF
BALTIMORE
Baltimore, MD 21202
And
HOUSING AUTHORITY OF BALTIMORE

CITY
417 E. Fayette Street, Suite 1339
Baltimore, MD 21202
And
PAUL T. GRAZIANO,
BALTIMORE CITY HOUSING
COMMISSIONER AND EXECUTIVE
DIRECTOR OF THE HOUSING
AUTHORITY OF BALTIMORE CITY
Baltimore, MD 21202
and
417 E Fayette St, Suite 1339
Baltimore, MD 21202
And
CHARLES COLEMAN, aka
CLINTON COLEMAN
1640 Balmor Court
Baltimore, MD 21217
And
MICHAEL ROBINSON
1640 Balmor Court
Baltimore, MD 21217
And
DOUG HUSSEY
5220 York Road
Baltimore, MD 21212
Defendants
SECOND AMENDED COMPLAINT, CLASS ACTION CLAIMS AND JURY DEMAND
Comes now the above-named plaintiffs, by and through counsel, Cary J. Hansel of
Hansel Law, PC, and Annie B. Hirsch of Hirsch and Cosca, PC and sue the above-named
defendants, stating as follows:
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INTRODUCTION
1)
This lawsuit is being filed to stop the widespread sexual abuse and harassment
perpetrated by maintenance men against vulnerable women living in Baltimore City public
housing. The Housing Authority of Baltimore City has known for years, as the result of
numerous complaints, that Maintenance Supervisor Charles, aka Clinton, Coleman, Michael
Robinson, Doug Hussy and other maintenance men demand sex before repairing deplorable
conditions in Baltimores public housing.
2)
These Housing Authority employees routinely harass and abuse the vulnerable
women in public housing. By refusing to perform repairs without sexual quid pro quo, these
defendants are subjecting the tenants to life-threatening living conditions including, but not
limited to: mold, lack of heat, rodent and insect infestations and risk of electrocution. These
victims are too poor to move out and relocate their families. Consequently, they are left with the
impossible choice of either succumbing to unwanted sexual demands in order to save themselves
and their children from life-threatening conditions in their homes, or, living in squalor.
3)
The individual defendants and other Housing Authority employees prey on
females from under-aged girls to women in their 50s and from the able-bodied to the
handicapped. In addition to their refusal to repair life-threatening conditions if their demands for
sexual quid pro quo are not met, at least one defendant has also threatened physical violence
against one of the young female plaintiffs if she did not succumb to his sexual demands, while
another defendant has offered cash for sex when withholding repairs was insufficient.
4)
These affronts are about power and control over the most vulnerable members of
society, including the poor, the young, and the disabled. In addition to satisfying their prurient
sexual desires, the maintenance staff also intimidates and deters women from requesting
maintenance repairs by sexually harassing them. This allows the individual defendants to shirk
their duties.
5)
This abuse has run rampant throughout Gilmor Homes, the housing project where
Freddie Gray lived before his murder. Sadly, these abuses are not contained there as Defendants
Coleman and Robinson are sometimes assigned to other projects, where they continue their
pattern of preying on women, including defenseless single mothers. In addition, Defendant
Hussy preys on women in Govans Manor, another HABC property.
6)
The practice of demanding sex for repairs is so widespread that it is a pattern and
practice by the Housing Authority of Baltimore City, whose housing officials have repeatedly
turned their backs on the most vulnerable city residents. For years, the Housing Authority of
Baltimore City (the Housing Authority) has ignored numerous complaints and repeatedly
allowed abusers to maintain their positions of power.
7)
Internal e-mail communications show that the sexual harassment complaint of one
of the plaintiffs made it to the desk of the Inspector General of the Housing Authority as early as
December 31, 2013 at 10:11 a.m. The e-mail chain shows that the Community Liaison, the
Senior Director of Asset Management, the Inspector General and other top HABC officials were
informed of many of the exact same facts later raised in this complaint, but they ignored this
information for two years until a lawsuit had to be filed. During that time, an untold number of
women continued to be needlessly subjected to sexual assaults and harassment across Baltimore.
8)
In addition, the attached sworn affidavit testimony demonstrates that:
A) An HABC employee complained to the Gilmor property manager that both the employee
and tenants were harassed by maintenance men in 2006;
B) A plaintiff complained to the Gilmor property manager in 2012 about being sexually
assaulted by a maintenance man;
C) A second plaintiff complained to the Gilmor property manager in 2012 about being
sexually assaulted by a maintenance man;
D) In sworn testimony, the Union President said that the Union investigation found that
residents complained to the Gilmor property manager in 2012 and 2013 and that these
complaints were forwarded to two different HABC Senior Assets Managers, but nothing was
done to stop the harassment, and, instead, an HABC Senior Assets Managerintervened
aggressively to save [the abusers] job;
E) A plaintiff complained in 2013 to the Gilmor rental office about maintenance men
refusing to address a flood in her unit unless she performed oral sex;
F) A plaintiff told the rental office in Gilmor Homes about the severe sexual harassment she
experienced in 2013 and then called the Housing Authoritys main office, following up
repeatedly, but nothing was done;
G) A third plaintiff complained to the Gilmor property manager in 2013 about being
sexually harassed by a maintenance man;
H) Another plaintiff complained to the HABC maintenance supervisor and two other people
in that office over a period of weeks in 2013 about being sexually harassed by a
maintenance man;
I) A plaintiff complained to the Gilmor property manager in early 2014 about being forced
to have sex with a maintenance man to get life threatening conditions corrected and nothing
was done;
J) A plaintiff called the Housing Authoritys main office in 2015 to complaint about
maintenance men soliciting underage girls, but nothing was done;
K) A plaintiff who worked in HABC headquarters told the Deputy Executive Director of the
Housing Authority in 2015 of the sexual harassment she suffered and nothing was done; and
L) The Union revealed the results of its investigation and called for the termination of guilty
maintenance men in 2015.
9)
The plaintiffs and their witnesses filed more than 10 complaints, mostly in the last
three years, of sexual misconduct so severe that any one instance should have been aggressively
pursued by the authorities. Yet, they were all ignored which resulted in the continued
subjugation of these women to the sexual demands of the Housing Authority maintenance staff.
10)
These abusers hold tremendous power over the women bringing this lawsuit.
Defendants Coleman and Robinson: possess keys to all of their victims homes which they
utilize to come and go as they please, have the ability to have residents evicted, and the ability to
ignore badly-needed repairs. Despite all of this, seven brave women have chosen to come
forward. Their stories are in the Facts section below and in the sworn affidavits attached as
Exhibit 1, which are incorporated herein by reference.
JURISDICTION
11)
Jurisdiction is proper in this Honorable Court under 28 U.S. Code 1331 because
this is a civil action arising under the Constitution, laws, or treaties of the United States.
VENUE
12)
Venue is proper in this Honorable Court under 28 U.S.C. 1391 because the
parties are domiciled in Maryland, or organized under Maryland law, and the events at issue took
place in Baltimore, Maryland.
PARTIES
13)
Nicole Andrea Smith is an adult citizen of Baltimore, Maryland.
14)
Jacqueline Kiana Morant is an adult citizen of Baltimore, Maryland.
15)
Amy Towson is an adult citizen of Baltimore, Maryland.
16)
Sara Garret is an adult citizen of Baltimore, Maryland.
17)
Onnaday McIntosh-Griggs is an adult citizen of Baltimore, Maryland.
18)
Stephanie V. Harris is an adult citizen of Baltimore, Maryland.
19)
Shanae Barnes is an adult citizen of Baltimore, Maryland.
20)
Celeste English is an adult citizen of Baltimore, Maryland.
21)
Takira Carter is an adult citizen of Baltimore, Maryland.
22)
Lynette Cooper is an adult citizen of Baltimore, Maryland
23)
Detria Adams is an adult citizen of Baltimore, Maryland.
24)
Shanae Boles is an adult citizen of Baltimore, Maryland.
25)
Lasonia Gilbert is an adult citizen of Baltimore, Maryland.
26)
Myrtle Gilbert is an adult citizen of Baltimore, Maryland.
27)
Tracey Holden is an adult citizen of Columbia, Maryland.
28)
Khrystyna Kelley is an adult citizen of Baltimore, Maryland.
29)
Towanda Parker is an adult citizen of Baltimore, Maryland.
30)
Sierria Warren is an adult citizen of Baltimore, Maryland.
31)
Rosena Prince is an adult citizen of Baltimore, Maryland.
32)
The Housing Authority of Baltimore City is a public body corporate and politic
created under the laws of the State of Maryland.

33)
The Housing Authority of Baltimore City is sui juris.
34)
Paul T. Graziano is the Baltimore Housing Commissioner and Executive Director
of the Housing Authority directly responsible for the pattern and practice of misconduct
discussed herein and being sued in his individual and official capacities.
35)
Charles, aka Clinton, Coleman is an adult citizen of Baltimore, Maryland and, at
all times relevant hereto, was an employee of the Housing Authority of Baltimore City.
36)
Michael Robinson is an adult citizen of Baltimore, Maryland and, at all times
relevant hereto, was an employee of the Housing Authority of Baltimore City.

37)
Doug Hussy is an adult citizen of Baltimore, Maryland and, at all times relevant
hereto, was an employee of the Housing Authority of Baltimore City.
FACTS COMMON TO ALL COUNTS

38)
Charles, aka Clinton, Coleman, was an employee of HABC at all times relevant
hereto. Coleman performed maintenance duties at various HABC Public Housing properties,
including, but not limited to, Gilmor Homes at all times relevant herein.
39)
During the course of Colemans employment with HABC, he became a
maintenance supervisor.
40)
At all times relevant herein, agents, staff and/or employees, including Coleman,
were acting in the course and scope of their authority, agency, service and/or employment for
these Defendants.
41)
While employed by HABC, Coleman made numerous unwanted sexual advances
towards countless women who resided in the HABCs public housing units, including but not
limited to Gilmor Homes.
42)
Furthermore, while employed by HABC, Coleman informed countless women
that resided in public housing that their outstanding work orders would not be fulfilled by
maintenance unless they provided various sexual favors which included, but were not limited to:
providing sexually graphic pictures of themselves, performing oral sex, performing sexual
intercourse, and performing various other sexual acts.
43)
In addition to repeatedly making these demands of the female residents in public
housing, Coleman would repeatedly make sexual comments to the female residents about their
appearance and what he would like to do to them and/or have them do to him, as well as touch
them inappropriately and touch himself inappropriately in front of them.
44)
This sexual harassment and/or sexual assault was perpetrated by Robinson against
these female residents for many years, during which time he purposefully failed to make repairs
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in these womens homes, repairs that were required of him within the scope of his job. Coleman
repeatedly informed the female residents in public housing that these repairs could get done, if
they would acquiesce to his demands.
45)
Michael Robinson, was an employee of HABC. Robinson performed
maintenance duties at various HABC Public Housing properties, including, but not limited to,
Gilmor Homes.
46)
At all times relevant hereto, agents, staff and/or employees, including Robinson,
these Defendants.
47)
While employed by HABC, Robinson made numerous sexual advances towards
countless women who resided in the HABCs public housing units, including but not limited to
Gilmor Homes.
48)
Furthermore, while employed by HABC, Robinson informed countless women
that resided in public housing that their outstanding work orders would not be fulfilled by
intercourse, performing various other sexual acts.
49)
housing, Robinson would repeatedly make sexual comments to the female residents about their
appearance and what he would like to do to them or with them, as well as touch them
inappropriately and touch himself inappropriately in front of them.
50)
these female residents for many years, during which time he purposefully failed to make the
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mandatory repairs that were required of him in the scope of his job. He repeatedly informed the
female residents that these repairs could get done, if they would acquiesce to his demands.
51)
Doug Hussy, was an employee of the Housing authority of Baltimore City. Hussy
performed maintenance duties at various HABC Public Housing properties, including, but not
limited to, Govans Manor.
52)
At all times relevant hereto, agents, staff and/or employees, including Hussy,
these Defendants.
53)
While employed by HABC, Hussy made numerous sexual advances towards
countless women who resided in the HABCs public housing units, including but not limited to
Govans Manor.
54)
Furthermore, while employed by HABC, Hussy informed countless women that
resided in public housing that their outstanding work orders would not be fulfilled by
intercourse, performing various other sexual acts.
55)
housing, Hussy would repeatedly make sexual comments to the female residents about their
appearance and what he would like to do to them or with them, as well as touch them
inappropriately and touch himself inappropriately in front of them.
56)
these female residents for many years, during which time he purposefully failed to make the
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mandatory repairs that were required of him in the scope of his job. He repeatedly informed the
female residents that these repairs could get done, if they would acquiesce to his demands.
57)
Defendants Robinson, Coleman and Hussy are employees of the Housing
Authority of Baltimore City, acting under color of State and local law.
58)
Defendants Robinson, Coleman and Hussy knew or should have known that their
sexual advances were unwelcome.

59)
Defendants Robinson, Coleman and Hussy have a special relationship with the
residents of public housing in Baltimore in that they are in positions of trust, holding keys and
with access to the homes of the hundreds of residents whose units they are charged with
repairing. Defendants Robinson, Coleman and Hussy abused their positions of power and trust.
60)
At all times relevant hereto, the Housing Authority of Baltimore City and
defendant Graziano knew or should have known of the abuses taking place in Baltimore public
housing. Ample notice was provided through repeated complaints stretching back for years.
Complaints started at the rental office level, went up to the Housing Authority office and even
included detailed reports to one of Grazianos top lieutenants.
61)
The abuses outlined herein are not limited to the women who have chosen to
come forward. In fact, they represent only a small fraction of the women subjected to this
behavior by maintenance workers employed by HABC and/or The City of Baltimore.
62)
Lucky Crosby, Sr., the Safety Officer for AFSCME Local 647, the union which
protects the rights of Maintenance workers employed by the Housing Authority of Baltimore
City was directed by his union president to investigate any related health and safety issues in
Gilmor Homes.
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63)
Mr. Crosby went door-to-door in the community and uncovered numerous women
who substantiated the allegations in the lawsuit. He was repeatedly told that HABC employees
Coleman and Robinson were demanding sex for repairs.
64)
One woman reported to Mr. Crosby that when she went to the maintenance office
to seek help during work hours, HABC employee Michael Robinson heard her enter and came
rushing downstairs with no shirt on dripping with sweat. A short time later, a young female
resident was seen leaving his office.
65)
In the 1400 block of Delano Court, a woman named Karen reported to Mr. Crosby
that she had recently moved in and that she was groped by the Maintenance Supervisor when
she asked for repairs. The maintenance supervisor is Charles, aka, Clinton, Coleman.
66)
In the 1500 block of Mountmor Court, a woman reported to Mr. Crosby that the
maintenance staff do not do any work and instead, they just try to have sex with the women. She
later said she was referring to Coleman.
67)
In the 1600 block of Mountmor Court, a woman self-identified as a lesbian, but
said that Coleman had attempted to sleep with her anyway when she needed repairs.
68)
In the 1600 block of Mountmor Court, another woman reported to Mr. Crosby
that the bathtub was stopped up and that Coleman had demanded naked pictures of her before he
would fix it. After she provided the pictures, she reported that Coleman fixed her tub.
69)
In the 1600 block of Mountmor Court, a petite African American woman reported
to Mr. Crosby that a maintenance man had said so many inappropriate things to her that she
was afraid to call to have her broken sink fixed. In the same area, 3 or 4 women on a stoop
reported that Coleman attempts to have sex with them all the time, and that they are afraid to
14
even go to the maintenance office to report concerns. One of these women showed Mr. Crosby
the holes in her ceiling, a broken radiator and mildew which might have been mold.
70)
In the 1500 block of Mountmor behind Sperry Court, 2 young girls reported to
Mr. Crosby that Coleman had gotten a Gilmor Court resident nick-named, Juicy, pregnant.
One of the girls showed him mildew which might have been mold and broken cabinets that
Coleman refused to fix in her unit after she turned down his propositions.
71)
In the 1600 block of Vincent Court, Mr. Crosby spoke to a young woman named
Crystal who had three young children. Her front door was broken and could not be latched
closed or locked. She was so afraid of Coleman after he propositioned her when she requested
repairs that she had a male relative come over and build a wood door bar out of 2x4 boards so
that she could keep Coleman out at night. She reported to Mr. Crosby being afraid that Coleman
would rape her.
72)
Mr. Crosby observed one workman pull by a young female resident in his car and
ask her, When are you going to let me come over and hit that? He said this right in front of the
young womans 3 or 4 year-old daughter.
73)
HABC repeatedly told Mr. Crosby and the Union not to investigate and not to put
anything in writing.
74)
After the investigation by Mr. Crosby, Union President Anthony Coates
recommended that Coleman and Robinson be immediately removed from their positions of trust
and that all available resources be used to repair the work orders at Gilmor Homes. We made
these requests in a meeting that included HABC Chief of Human Resources Carla Walton,
HABC Chief of Staff Kimberley Washington, HABC Deputy Associate Director Shawn
Buchannan, and HABC Special Assistant for Housing Operations Nicolaus Calase.
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75)
HABC responded by telling the union to stop investigating even though the union
contract gives the union every right to investigate. HABC also specifically instructed the union
not to put anything that had been learned in writing. The union was told by HABC Chief of
Human Resources Carla Walton to call HABC Special Investigator Lamont Bivens. When the
union called Mr. Bivens to report its findings, Bivens told the union to call Ms. Walton.
Ultimately, HABC acted to avoid the unions input and refused to implement any of the unions
suggestions to immediately address the problem.
76)
The union investigation also revealed that residents at Gilmor Homes had
complained to the property manager there, Ms. Emma Scott, as early as 2012 and 2013 about
sexual harassment by Coleman and HABC employee Michael Robinson.
77)
The union investigation further revealed that when Ms. Scott attempted to
discipline Coleman, HABC Senior Assets Manager Susan B. Pierce intervened aggressively to
save Colemans job. Her intervention led to Ms. Scotts retirement.
78)
The plaintiffs have suffered physical violations of their persons in the form of
unwanted physical and sexual contact.

79)
The plaintiffs have suffered actual economic losses in the form of time away from
work, efforts to make repairs themselves, property stolen as a result of the failure of the
defendants to secure the plaintiffs homes and property destroyed by mold, as well as rodent and
insect infestations.
80)
The plaintiffs and their children have suffered severe physical harm as a result of
the refusal of Baltimore employees to repair their homes, including exposure to disease, mold,
rodent feces, roaches, and a wide variety of other dangerous conditions.
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81)
The plaintiffs and their children have suffered severe mental pain, suffering and
anguish as a result of all of these abuses. This mental pain and suffering manifests itself
physically through vomiting, heightened blood pressure, heightened heart rate, sweating,
sleeplessness, flushing, tremors, headache, loss of sleep, loss of appetite, nervousness and panic.
82)
The violations at issue are continuing in nature. Defendants Coleman, Robinson
and Hussy have deliberately withheld and delayed repairs as a result of not receiving sexual
favors up to and including the present. Defendant Housing Authority and Graziano have failed
to intervene or take any steps to address the problem. The plaintiffs are currently subject to the
unlawful policy that if they want repairs, they must acquiesce to the sexual demands of
defendants Coleman, Robinson and Hussy. Moreover, in addition to the fact that the quid pro
quo aspects of the harassment at Gilmor and other public housing facilities is continuing, so is
the hostile environment created by the defendants. The plaintiffs are subject to a hostile
environment every day through lewd and lascivious requests and comments from maintenance
men, cat calls, horn honking, and physical sexual assaults or the threat thereof.
83)
Recently, an investigation by a local grassroots organization, Communities
United, brought these concerns to light. Thereafter, Coleman was transferred out of Gilmor.
Only then, with Coleman gone, did the seven plaintiffs feel safe enough to come forward and
retain counsel. Thus, the fear and intimidation sown by defendant Coleman kept these women
from coming forward sooner. That fear is reasonable given the physical assaults and threats of
the same with which Coleman controlled his victims. Unfortunately, since counsel has been
retained and despite many of the concerns raised herein having become public, the defendants
returned Coleman to Gilmor, where he is once again preying on the plaintiffs and others. Upon
information and belief, this was done intentionally by HABC and defendant Graziano in
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retaliation for the complaints and in a futile effort to intimidate the plaintiffs from moving
forward with the filing of this Complaint and others efforts to address the ongoing harassment.
84)
As of this filing Defendants Coleman, Robinson and Hussy have been terminated
from their positions with HABC. Their terminations came only belatedly after the filing of this
lawsuit.
85)
Defendants have subjected, and continue to subject, female residents and
participants in the Section 8 program to discrimination on the basis of sex, including severe,
pervasive, and unwelcome sexual harassment, on multiple occasions. Such conduct has included,
but is not limited to: a. Making unwelcome sexual comments and unwelcome sexual advances to
female residents and participants in the Section 8 program, including subjecting them to
unwanted sexual touching; b. HABC employees touching themselves in a sexual manner and
exposing their genitals in the presence of female applicants and participants in the Section 8
program; c. Conditioning or offering tangible housing benefits such as repairs in exchange
for sexual acts; and d. Taking adverse housing actions, or threatening to take such actions,
against female applicants and participants in the Section 8 program who have not granted or
would not continue to grant sexual favors.
86)
The discriminatory incidents described herein occurred while defendants were
exercising their authority as employees of HABC.

87)
Defendant HABC is liable for the actions of the individual defendants. HABC
hired the individual defendants, knew or should have known of their discriminatory conduct, had
the authority to take preventive and corrective action, and failed to take reasonable preventive or
corrective measures.
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88)
By the actions and statements described above, defendants have: a. discriminated
in the terms, conditions, or privileges of the rental of dwellings, or in the provision of services or
facilities in connection therewith, because of sex, in violation of 42 U.S.C. 3604(b); b. made
statements with respect to the rental of dwellings that indicate a preference, a limitation, or
discrimination based on sex, in violation 42 U.S.C. 3604(c); and c. coerced, intimidated,
threatened, or interfered with persons in the exercise or enjoyment of, or on account of their
having exercised or enjoyed, their rights granted or protected by Section 804 of the Fair Housing
Act, in violation of 42 U.S.C. 3617.
89)
Defendants conduct described above constitutes: a. A pattern or practice of
resistance to the full enjoyment of the rights granted by the Fair Housing Act, 42 U.S.C. 3601,
et seq., or b. A denial to a group of persons of rights granted by the Fair Housing Act, 42 U.S.C.
3601, et seq., which denial raises an issue of general public importance.
90)
Female residents and participants in the Section 8 program and persons associated
with them have been injured by defendants discriminatory conduct. Such persons are aggrieved
persons as defined in 42 U.S.C. 3602(i), and have suffered damages as a result of Defendants
conduct.
91)
Defendants conduct was intentional, willful, and taken in reckless disregard of
the rights of others.

NAMED INDIVIDUAL PLAINTIFF FACTS
Nicole Andrea Smiths Story
92)
Nicole Andrea Smith is a 33 year-old female resident of Gilmor Homes, a public
housing project in Baltimore, Maryland. Gilmor Homes is owned and operated by the Housing
Authority of Baltimore City.
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93)
Ms. Smith is a gainfully-employed single mother. She has one daughter that lives
with her who is currently 8 years old.

94)
In 2008, Ms. Smith, a single woman in her 20s, came to Gilmore Homes with her
then one-year old daughter. She was fleeing an abusive relationship which had culminated in her
childs father breaking into her previous home and attempting to kill her. Prior to that, she had
never lived in public housing.
95)
Despite working full time, Ms. Smith was unable to afford to leave Gilmor
Homes because her finances were left in shambles as a result of the abusive relationship she had
just escaped.
96)
Shortly after Ms. Smith first arrived, the head of maintenance (a man named
Clinton Coleman) came to her home to do an inspection. Coleman was an employee of the
Housing Authority of Baltimore City.
97)
After the "inspection, Coleman told Ms. Smith that she could get extra stuff if
she needed it.

98)
Ms. Smith asked Coleman what he meant by this. Coleman responded that he
would fix any problems in the apartment if she came to see him in his office where the two of
them could talk about it. He looked at her suggestively when he said this, but she did not fully
understand what he meant at the time.
99)
The next day, Ms. Smith went to Colemans office expecting to discuss the
procedures for having repairs made in her home.

100)
Coleman asked Ms. Smith to come in and close the door. It was just the two of
them in the office. Ms. Smith inquired, what do I have to do to get things fixed? She expected
him to explain the work order procedure to her. Instead, Coleman, who was seated at the time,
20
pushed himself back from his desk, unzipped his fly, exposed his penis to her and asked her,
what can you do with this?
101)
Ms. Smith was shocked. She was young, scared, had just fled from an abusive
relationship, and was worried about the health and safety of her daughter. She felt she had no
choice but to give in to Colemans demands. So she did as he had asked and performed oral sex
on him. Afterward, Ms. Smith left his office. Ms. Smith was scared and ashamed. She
desperately tried to forget about the incident and made every effort to avoid Coleman.
102)
As additional problems arose with her unit, Ms. Smith followed procedure and
made official requests for repairs (also known as work orders) with the housing office.
Initially, all of her work orders were timely addressed. She noticed, however, that other women
were not getting the same level of service she received.
103)
As time went by, Coleman began to ignore Ms. Smiths requests for repairs.
Although she tried to avoid him, when Ms. Smith did see Coleman, he frequently demanded
intercourse or oral sex from her. These sexual demands have continued throughout her time at
Gilmor and persist to the present.
104)
Badly needed repairs in Ms. Smiths unit were ignored and remained unaddressed
for long periods of time.

105)
Ms. Smith became more and more afraid of Coleman during this period. Coleman
controls a large group of male maintenance workers, some of whom also engage in this abusive
behavior.
106)
Frequently, maintenance workers would make sexual remarks to Ms. Smith about
her body, including, but not limited to, comments about her buttocks. Maintenance workers have
21
continued to make unwanted and aggressive remarks toward Ms. Smith throughout her time at
Gilmor, to the present.
107)
There came a time when Ms. Smith discovered a gas leak behind her stove. She
could smell the gas and was in fear for her life and the life of her daughter. She could no longer
avoid Coleman.
108)
Ms. Smith went to Colemans office to request that the gas leak be fixed. He said
that he could not smell the leak from his office across the street, but that he would come by her
home after hours.
109)
Coleman came to Ms. Smiths house that evening around 10:00 p.m. Ms. Smith
opened the door. Coleman entered immediately and, without saying anything, put his hands on
her and proceeded to have sex with her in the front room.
110)
Ms. Smith did not physically or verbally encourage Coleman. She was disgusted
and wanted it to end as quickly as possible. To get through the ordeal, Ms. Smith focused on her
safety and the safety of her daughter.
111)
When Coleman was finished, he left.
112)
The next day, workmen directed by Coleman arrived at Ms. Smiths home and
fixed the gas leak.

113)
After that, Coleman began to ignore Ms. Smiths work orders again.
114)
Among other problems that had accrued, an earthquake caused a portion of one of
Ms. Smiths walls to begin to cave in.

115)
At one point, Ms. Smiths front door was broken and did not close properly. She
was afraid for her safety because the door would not latch properly and someone could have
easily broken in.
22
116)
Gilmor Homes is located in an extremely high crime area. Ms. Smith was so
scared that she would pile heavy objects against the door at night. However, this also made her
worry that in the event of a fire, she and her daughter would be trapped inside.
117)
Ms. Smith also suffered, at times, with insufficient heat in the house.
118)
Ms. Smith put in work orders whenever problems arose, but they were ignored.
119)
Ms. Smiths next door neighbor warned her that if she did not continue to give in
to Colemans sexual demands, in addition to allowing her unit to go unrepaired, Coleman would
send other women to physically assault Ms. Smith. Upon information and belief, the reason why
these women would follow Colemans directions in this regards would be so that they could
avoid having to perform sexual favors for Coleman in exchange for repairs being done to their
homes. Ms. Smith believed that Coleman told the neighbor to pass this threat along to her.
120)
After she received Colemans threat through her neighbor, Ms. Smith was
petrified.
121)
Coleman maintains significant power over the Gilmor community, which he
exhibits in a most reprehensible manner. In addition to withholding repairs and making physical
threats, he and his maintenance crew have the ability to make complaints that may result in
residents losing their homes.
122)
Ms. Smith and her daughter have no place else to go. Consequently, they would
be homeless if this happened.

123)
For all of these reasons, but primarily out of fear and in an effort to protect her
daughter, Ms. Smith gave in to Colemans demands for sexual intercourse a total of four times
and oral sex once. These encounters occurred in his office and in her home. At least three of
these events occurred within the last three years.
23
124)
After each respective time that Ms. Smith gave in to Colemans demands,
Coleman would have his maintenance crew complete the long-overdue work in her unit.
125)
In approximately late 2013/early 2014, Coleman referenced Defendant Michael
Robinson in a conversation with Ms. Smith. Coleman told Ms. Smith, if you help Mike get
some, well do your work orders. Mike was another maintenance technician employed by
the Housing Authority of Baltimore City. Mike is supervised by Coleman.
126)
By this time, the stress of living with what she was being forced to do was
overwhelming. Ms. Smith was doing everything possible to avoid Coleman. She even arranged
her work schedule so that she could leave her home before he arrived and return after he had left
for the day.
127)
Colemans office is directly across from Ms. Smiths house and he can watch her
come and go, so there is ultimately no escaping him. When she sees him, he makes suggestive
comments and faces which make her feel ill.
128)
Ms. Smith could not stand the thought of this happening with another man. So,
she refused to help Mike get some. As a result, Coleman has prevented any further
significant work from being done to her house.
129)
In early 2014, Ms. Smith went to Colemans boss, Ms. Emma Scott, the property
manager. Ms. Scott is an employee of the Housing Authority of Baltimore City. Ms. Smith
explained to Ms. Scott everything that is included in this Complaint in even greater detail. Ms.
Scott listened to everything Ms. Smith had to say and offered no response at all. She just sat
there. After a long pause, Ms. Smith said thank you for listening to me and left. Shortly
thereafter, Ms. Scott retired. Ms. Smith never heard back from anyone regarding the discussion.
24
130)
Currently, there are numerous unaddressed health and safety issues in Ms.
Smiths home, including: a radiator which leaks and will not provide heat for the coming winter,
a bathroom heater that does not work, clogged drains, broken doors, broken windows and broken
cabinets. All of these items are reflected in work orders that have been pending for months or
longer.
Jacqueline Kiana Morants Story
131)
Jacqueline Kiana Morant, is a 29 year-old female resident of Westport, a public
housing project in Baltimore, Maryland. Westport is owned and operated by the Housing
Authority of Baltimore City. Ms. Morant moved to Westport in October of 2010.
132)
In late 2013, Defendant Coleman came to her home to replace her blinds.
133)
Ms. Morant had heard stories of widespread sexual harassment by maintenance
workers in Baltimore City public housing. Therefore, she used her mobile phone to videotape
Coleman while he was in her home.
134)
Shortly after Coleman arrived, a male cousin of Ms. Morants arrived. He also
witnessed some of the events which transpired.

135)
After removing the upstairs blinds, Coleman came downstairs where Ms. Morant
was visiting with her cousin.

136)
Without provocation, Coleman looked at Ms. Morant and said, I want you. I just
want you. Coleman then went on to tell Ms. Morant disgusting stories of him looking up
womens nightgowns when he is doing repairs, and women having sex with the maintenance
men.
137)
Ms. Morant was shocked and appalled. She had done nothing to encourage this
behavior.
25
138)
After Coleman left, Ms. Morant contacted the rental office to complain about this
behavior. Ms. Morant spoke to Colemans supervisor. When that complaint went nowhere, Ms.
Morant called the Housing Authority of Baltimore City and spoke to Lamont Bivens. Ms.
Morant repeatedly followed up with Mr. Bivens. She even sent him a copy of the video tape.
Mr. Bivens eventually responded by telling Ms. Morant that she was not the first person to
complain about Coleman.
139)
Coleman left the community for a short period and then came back. When he
came back, every time he saw Ms. Morant, he would give her dirty looks and give her the
finger.
140)
Ms. Morant never heard back from Mr. Bivens with a solution.
141)
Ms. Morant has observed Coleman harassing other women and young girls. In
the summer of 2015, Ms. Morant observed Coleman soliciting underage girls in the community.
Ms. Morant contacted Lamont Bivens again. Mr. Bivens took her complaint. Once again,
nothing was done.
142)
Coleman looks at Ms. Morant in a threatening manner whenever she sees him.
Coleman has keys to her house. Other women have told Ms. Morant that Coleman enters their
homes uninvited, without knocking, when they are awake and while they are sleeping.
Understandably, Ms. Morant is extremely afraid of Coleman.
Amy Towsons Story
143)
Amy Towson is a 38 year-old female resident of Gilmor Homes, a public housing
project in Baltimore, Maryland. She moved in to Gilmor Homes in 2011.
26
144)
In the spring of 2012, Ms. Towsons unit needed repairs so she contacted the
maintenance crew. Defendant Michael Robinson came to her home. He asked if he could come
back in an hour and a half and she agreed.
145)
When Robinson came back, he said he would pay Ms. Towson for a date if she
let him come over and that he pays the girls in Gilmor well. He then grabbed her breast.
146)
Ms. Towson was shocked and appalled. She had done nothing to encourage this
behavior. She told him to stop and asked him to leave.

147)
Ms. Towson immediately contacted Ms. Emma Scott, the property manager and
Defendant Robinsons boss, to voice her complaints. Ms. Towson told Ms. Scott everything that
happened. Ms. Scott told her that when she calls for maintenance, she should just request that
Robinson not come to her house. Ms. Scott took no further action as far as Ms. Towson is
aware. After the meeting, Ms. Towson never heard from anyone again in connection with her
complaint.
148)
In retaliation for voicing her concerns and complaints to Ms. Scott, the
maintenance crew, including Defendants Coleman and Robinson, refused to perform repairs in a
timely manner in Ms. Towsons home.
149)
Furthermore, instead of doing the necessary repairs, Robinson waits outside Ms.
Towsons home for long periods of time and stares at her house. Ms. Towson believes Robinson
does this to show her that he has time to do the repairs and he could do the repairs if he wanted
to, but he chooses not to.
150)
Even now, four years later, there are major problems with Ms. Towsons unit
which maintenance continues to refuse to address.
27
151)
Among other issues, Ms. Towsons unit has unrepaired leaking pipes. When she
runs the shower, a puddle forms on the floor from water seeping through the walls. Ms. Towson
followed proper procedure and filed a work order five months ago to have this repaired. She
was ignored.
152)
The leak has led to mold in all four rooms. The mold is so bad that Ms. Towson
has had to throw away furniture. Furthermore, her health and the health of her children has been
endangered by the mold. She has coughed up blood and she fears for the health of her two-year
old daughter and her five-year-old son who takes asthma medicine and who now gets frequent
nose bleeds. Ms. Towson has continued to follow the proper procedures and has filed a work
order to have this repaired. She was ignored.
153)
In addition to the leaky pipes and mold, Ms. Towsons windows do not properly
lock. As such, her home remains unsecured in this high crime area. She followed proper
procedure and filed a work order to have this repaired. She was ignored.
Sara Garrets Story
154)
Sara Garret is a 31-year-old resident of Gilmor Homes. She currently resides
there with her four children who range in age from four to twelve-years old.
155)
Ms. Garret has lived in Gilmor for four years. Three years ago, Defendants
Robinson and Coleman began harassing her.

156)
There came a time when Ms. Garret needed repairs in her home. She properly put
in work orders with the office, however, the repair requests remained unaddressed.
Subsequently, Ms. Garret went to Colemans office to follow up on the overdue work orders. He
told her that she looked good for having four children. He leered at her and continued to make
28
unwanted advances. Ms. Garret told Coleman that she did not come to his office to be treated
like that and she wanted to know about her repairs.
157)
In addition to the unaddressed repairs and the unwanted advances of Coleman,
Defendant Robinson has entered Ms. Garrets house unannounced on multiple occasions. In one
instance, Ms. Garret was in the shower when Robinson entered without invitation or permission.
When Ms. Garret discovered him in the house, he quickly left without doing any repairs.
158)
Every time Ms. Garret has called maintenance, she has been sexually harassed
and each time she has made it clear to these men that these sexual advances are unwelcomed.
159)
In addition to problems with Defendants Robinson and Coleman, other
maintenance men at Gilmor Homes engage in cat calling and honking their horns at the women
residents. This behavior is not only permitted, but is often encouraged by their supervisor,
Coleman.
160)
Because she has repeatedly rejected their advances, Defendants Robinson and
Coleman have refused to perform the much needed repairs in Ms. Garrets home.
161)
Ms. Garrets home currently has numerous defects, many of which are life-
threatening to her and her four young children. These defects include: electrical sockets hanging
out of the wall by exposed wires, a broken stove, mold, chipped paint, rodent and roach
infestations, holes in the walls, broken baseboards and windows that do not function properly.
The mold is so rampant that Ms. Garret has had to throw out otherwise perfect furniture. Given
the hostile environment and the dilapidated living conditions, Ms. Garret continues to fear for the
health and safety of her family while residing at Gilmor Homes.
29
Onnaday McIntosh-Griggs Story

162)
Onnaday McIntosh-Griggs is an adult female resident of Gilmor Homes. She is
employed full-time as a Certified Nursing Assistant, providing one-on-one care for the elderly.
163)
In 2014, Ms. McIntosh-Griggs spoke to Coleman, asking him when he was going
to perform repairs in her home. Coleman responded, when are you going to let me come see
you at your house? Ms. McIntosh-Griggs refused his advances and the repairs were never done.
164)
On another occasion, Ms. McIntosh-Griggs lost electrical power in her home.
She placed a call for service and Coleman responded. Coleman looked at her suggestively and
said, it looks nice in here; it looks good in here; you want to go upstairs? Again, Ms.
McIntosh-Griggs refused his advances.
165)
On another occasion, Ms. McIntosh-Griggs went to the rental office to ask about
necessary repairs to her floors. Coleman responded, I can wax your floors, Ill give you some
wax alright. Again, Ms. McIntosh-Griggs refused his advances.
166)
On yet another occasion when Ms. McIntosh-Griggs was in the rental office,
Coleman came up behind her and rubbed his erect penis on her buttocks. Again, she made it
abundantly clear that this was unwelcome.
167)
As a result of Ms. McIntosh-Griggs rejection of these advances, Coleman has
refused to properly follow up on her requests for services, allowing dangerous conditions to
fester in her home, unabated.
168)
The deplorable conditions in Ms. McIntosh-Griggs home include: peeling paint,
a rat infestation, a hole in the kitchen ceiling with water leaking from the upstairs toilet (this
prevents her from cooking in the kitchen), tiles falling off of the shower walls, a toilet which is
not secured to the floor, a heater leaking water in the kitchen (which maintenance just turned off
30
instead of fixing, so she now has no heat in the kitchen with the winter coming), no heat in two
of her five rooms, windows that do not open, gaps around the windows allowing cold air to come
in, and a broken refrigerator.
Stephanie V. Harris Story
169)
Stephanie V. Harris, a female resident of Gilmor Homes, moved in to the
community on February 10, 2014,

170)
In the spring of 2014, Ms. Harriss unit needed repairs. When propositioned, she
refused to provide sexual favors for Coleman in exchange for said repairs.
171)
In response to her refusal, Defendant Coleman replied you dont want to get with
me? You think you are having problems now, just wait.
This response was an unequivocal
threat to Ms. Harris that if she did not acquiesce to Colemans sexual demands, then her unit
would not be repaired.
172)
Coleman made good on his threat after Ms. Harris refused to sleep with him.
Repairs to Ms. Harris home were not timely performed by Coleman, or his maintenance crew.
173)
Currently, the following issues are unabated in Ms. Harris unit: the bathtub knob
is broken and Ms. Harris must operate her bathtub with plyers, there is a roach infestation, there
are rodents and rodent feces in her cabinets, there are sockets dangling from the walls by their
wires, her windows are not the correct size for their frames leaving air gaps and her windows do
not lock (an obvious security danger that has resulted in Ms. Harris having three microwaves and
a video camera stolen from her home).
31
Shanae Barnes Story

174)
Shanae Barnes is a 24 year-old female resident of Gilmor Homes, a public
housing project in Baltimore, Maryland. Ms. Barnes moved in to Gilmor in 2012. Ms. Barnes
has a 5 year-old daughter.
175)
When she first moved in, there was an insect infestation in Ms. Barnes unit. As a
result, she met with a maintenance supervisor employed by the Baltimore City Housing
Authority she came to know as Coleman. Coleman is Defendant Coleman here.
176)
When she asked Coleman what the Housing Authority was going to do about the
insects, he asked, what are you going to do for me? At first, Ms. Barnes thought this was a
joke, but she was wrong.
177)
Throughout her time at Gilmor, up to and including this year, Defendant Coleman
and Defendant Michael Robinson routinely asked Ms. Barnes for sex and sexual favors,
including a blow job.
178)
When Ms. Barnes asked Defendant Robinson to stop, he did, but Defendant
Coleman continued even after she repeatedly asked him to stop and told him that his advances
were unwelcome.
179)
In 2013, Ms. Barnes heat pipes burst, flooding the upstairs of her unit and
making her heat inoperable.

180)
Ms. Barnes had no choice but to go to Coleman as the maintenance supervisor.
181)
Coleman came to her unit to look at the damage. There was standing water all
over the upstairs floor.
32
182)
Ms. Barnes asked Coleman how he was going to get the water cleaned up and
Coleman said, If you let me taste you, it will be fixed right away. Ms. Barnes refused and
Coleman said, Then how are you going to get the water cleaned up?
183)
Coleman left without doing any repairs or cleanup after Ms. Barnes rejected his
advances. As a result, Ms. Barnes had to soak up the water with comforters and blankets and she
has not had any heat for the last two years.
184)
Ms. Barnes complained to the rental office in 2013 about Colemans behavior, but
nothing was ever done. Ms. Barnes never even heard back from the rental office regarding her
complaint.
185)
As a result of the water leak, Ms. Barnes now has mold in her unit, both upstairs
and downstairs.
186)
Ms. Barnes suffers from asthma and her daughter has had bronchitis, all of which
is caused by and made worse by the mold.

187)
In 2014, Ms. Barnes daughter walked away from her and went into the
maintenance office to look at a fish tank there. Ms. Barnes caught up with her and told her she
should not run off like that. Coleman came over and physically rubbed up against Ms. Barnes
and grabbed her thigh. He lectured Ms. Barnes for scolding her daughter and when she pulled
away from him, Coleman said, Stuff like that that will keep you from getting your repairs
done.
188)
At times, Ms. Barnes and her daughter have had to sleep on the kitchen floor with
the oven open and on to stay warm in the winter.

189)
In January of 2015, the cold and lack of heat became unbearable so Ms. Barnes
went to maintenance again. They did not fix the heat, but they brought a portable heater which
33
only heats one room at a time. Ms. Barnes asked Coleman what the next step was and he said,
you know what the next step is, in reference to his previous request to perform oral sex on her.
The heat has still not been repaired.
190)
Ms. Barnes went to Coleman a second time after that and he explicitly told her
that he would repair the heat if she gave him a blow job. She refused and the heat has not been
repaired for two years.
191)
When Ms. Barnes refused his multiple advances, Coleman offered that, in
addition to doing her repairs, he would pay her for sex. She repeatedly refused.
192)
In March of 2015, Ms. Barnes was dressed up for her birthday and when Coleman
saw her in the community, he said, I would like to bang you over and suck the soul out of you.
193)
Ms. Barnes found work at the Housing Authority for Baltimore City and became
the office assistant to the Deputy Executive Director, Anthony Scott.

194)
Ms. Barnes fear of Coleman kept her from saying anything to Mr. Scott until Mr.
Scott asked her about conditions at Gilmor in May of 2015. In response to his questions, Ms.
Barnes told Deputy Executive Director Anthony Scott about Colemans repeated sexual
harassment of her and about the fact that she did not have any heat as a result.
195)
Shortly after she complained to Mr. Scott in May, Ms. Barnes was contacted by
an Audit Investigator named Mr. Scriber and she told him everything that had happened.
196)
In June of 2015, Mr. Scriber told Ms. Barnes that he could not guarantee her
safety if she continued with her complaint. This was an obvious threat designed to silence Ms.
Barnes.
197)
On September 29, 2015, after the lawsuit became public, Ms. Barnes spoke with
Mr. Scott about coming forward and he told her to call Mr. Scriber. Ms. Barnes left a message
34
for Mr. Scriber and he called her back and asked what was wrong with her apartment. Ms.
Barnes had previously told him about the lack of heat, but she told him again. Mr. Scriber told
Ms. Barnes that someone would call on September 30 to repair her heat. She waited all morning
and no one called.
198)
Ms. Barnes still has no heat and, to date, no action has been taken on any of her
complaints.
199)
Ms. Barnes remains gravely afraid, for herself and her daughter, of Coleman.
Lynnette Coopers Story

200)
Lynnette Cooper, is an adult female resident of Govans Manor, which is a part of
Baltimore City Public Housing.

201)
In approximately October of 2015, Ms. Cooper placed a work order which
required Mr. Doug Hussy to begin performing repairs in her home. After this encounter, Hussy
began making more and more sexually explicit comments to her when he would do repairs in her
home and when she would see him around the property.
202)
On several occasions, Hussy asked Ms. Cooper to walk away so I can see your
fat ass. Another time, while performing work in her home, Hussy commented that Ms.
Coopers bed looked big and comfortable and that we could both lay down in it. Ms. Cooper
asked him to leave and refused his advances.
203)
On another occasion, Hussy asked Ms. Cooper, whats your bra size, whats your
waist size and what are the color of your panties? When doing this he rubbed up against Ms.
Coopers buttocks.
204)
Again, she rejected his advances.
On another occasion, Hussy asked Ms. Cooper if he could see her feet and said
he would like to suck her toes. He also asked if Ms. Cooper shaved her pussy hairs? Each
35
time Ms. Cooper would see him, his comments became more and more explicit. On one
occasion Defendant Hussy said to Ms. Cooper, damn, I will tear your ass up. Again, she
rejected his advances.
205)
On another occasion, Hussy told Ms. Cooper that he liked having his dick, balls
and ass licked and then Ill bust off in your mouth. He told Ms. Cooper that his wife would
suck his dick, but she didnt enjoy it like she should. Although she do not have a boyfriend, he
would ask Ms. Cooper where her boyfriend was and Hussy said he would be happy to watch Ms.
Cooper and her boyfriend fuck. Again, she rejected his advances.
206)
On another occasion, Hussy told Ms. Cooper that she did not have to live here
anymore and that he would kick his wife out so that Ms. Cooper could live with him. He told
Ms. Copper he was buying a new house. He opened his cell phone to show Ms. Cooper pictures
of the new house. Instead of bringing up pictures of a house, he pulled up a pornographic
website. Again, Ms. Cooper rejected his advances.
207)
On another occasion, Ms. Hussy informed Ms. Cooper that he would do a Bill
Cosby on her. Ms. Cooper came to understand that this meant he was threatening to drug me
and rape her.
208)
At this time, Ms. Cooper told Ms. Hussy again to stop speaking to her in this way
and to stop disrespecting her. Hussy informed Ms. Cooper that he would not be helping her in
any way until she helped him and gave him what he wanted. At this time, he stopped
making repairs and stopped responding to her work order requests.
209)
There came a time when there was a leak in the apartment two floors above Ms.
Cooper and it went down through her apartment and into the apartment below. Hussy repaired
36
the apartments above and below. He refused to repair the water damage to Ms. Coopers
apartment until she gave him what he wanted.
210)
On September 25, 2015, Hussy arrived at Ms. Coopers home to do repairs,
including to fix some peeling paint. While he was there, Ms. Cooper mentioned that she needed
to clean her home and that she kept a very clean and organized home with everything to be in its
place.
211)
Hussy did most of the repairs and left Ms. Coopers home. Shortly after Hussy
left, Ms. Cooper left to do some errands. While leaving her home, Ms. Cooper saw Hussy sitting
on a bench outside of her apartment. He told Ms. Cooper not to worry, the remainder of the
repairs would be done at 12. Ms. Cooper was scared. Ms. Cooper did not know if he meant
midnight or some other time. Hussy knew he was not allowed in Ms. Coopers home unless she
was present. At that time, Ms. Cooper left her apartment for approximately 4-5 hours.
212)
When Ms. Cooper returned from doing her errands, she unlocked her door and
found her house had been gone through. All of her doors and cabinets were open, numerous
possessions had been stolen including her money, a doc martin shoe kit and a gold necklace. She
also noticed that all of the food cabinets were open with the food having been turned in various
directions, as well as her medicine bottles having been turned with the labels facing different
ways. Her clothing drawers were open and her undergarment drawer had also been gone
through. Items in the kitchen drawers had been neatly moved around.
213)
The individual who came into her house had opened the door with a key,
rummaged through it, stole the items and locked up when he was done. Ms. Cooper reported it
to the police and they came out and did a report. Upon information and belief, Hussy was the
perpetrator who robbed Ms. Cooper.
37
214)
Hussys repeated and unwanted advances made Ms. Cooper frightened to leave
her home. She changed her schedule and changed what she wore to avoid comments from him.
Ms. Cooper began wearing large sweatpants and large t-shirts during the summer to make sure
she was completely covered up. Ms. Cooper was worried that he would come after her because
of these comments and because he had keys to her apartment.
215)
On another occasion, Hussy told Ms. Cooper that he used to work at Cherry Hill
Housing, but HABC transferred him to Govans Manor due to him having had inappropriate
sexual relations with the tenants of Cherry Hill. HABC was aware that Hussy had a history of
sexual misconduct before he was transferred to his position at Govans Manor.
Celeste Englishs Story
216)
Celeste English is an adult female resident of Gilmor Homes, a public housing
project in Baltimore, Maryland. She moved in to Gilmor in 2013.

217)
On June 4, 2013, when Ms. English first encountered the maintenance supervisor
she knew as Coleman, she was walking by and he said, you walk like your pussys good.
218)
Coleman and Ms. English did not previously know each other and had never
spoken. These were the first words Coleman ever said to Ms. English.
219)
Coleman repeats these words, or makes a similar comment, almost every time he
sees Ms. English, including up to the present. She tries to ignore him.
220)
Once, when it was hot out, Coleman saw Ms. English in the community and said,
why dont you go upstairs and draw us some bath water? Ms. English told him that she would
not be another notch in his belt.
38
221)
Coleman ignored Ms. Englishs work orders when she would not give into his
sexual desires. He told Ms. English, you get what you ask for, you get what you pay for,
and you get what you put out.
222)
Ms. English refused and problems in her home like broken doors, a missing
doorknob, a banister which is unattached to the wall and mold went unaddressed.
223)
Coleman obtained Ms. Englishs phone number from her maintenance records
and texted her asking for pictures of her pedicured toes and pictures of her undressed.
224)
At times, out of fear and in order to get her repairs made, Ms. English would say
that she would send him pictures, but she did not have the actual intent to do so and she never
did. Coleman did not do the work.
225)
In summer of 2015, Coleman pressed his body up against Ms. English and rubbed
his penis on her buttocks. Ms. English was horrified and got away from him.
226)
To date, Ms. English still has mold in her bathtub.
227)
Ms. English lives over the maintenance office and has seen and heard Coleman
make unwanted sexual advances towards other women and girls in the community on a weekly
basis.
Takira Carters Story
228)
Takira Carter is a 26 year-old female resident of Gilmor Homes, a public housing
project in Baltimore, Maryland. Ms. Carter moved in to Gilmor in November of 2013 with her
daughter, who is now 4 years-old. When she first moved in, the finish in her bathtub was peeling
off and her daughter developed health problems which she believe were a result of the finish
peeling off and getting into the water.
39
229)
Ms. Carter asked maintenance to fix the problem and the maintenance supervisor,
who she knows as Coleman, asked for her telephone number. She gave it to him expecting that
he needed it to communicate with her in order to fix the bathtub.
230)
Instead, Coleman texted her repeatedly making sexual advances, saying things
like, you look sexy.

231)
Coleman also Ms. Carter a video of him in the shower naked.
232)
By text and in person, Coleman asked Ms. Carter questions like, how much
would it cost for us to have sex, and can we have sex?

233)
Before he would fix anything in Ms. Carters unit, Coleman demanded that she
send him pictures of her in her underwear.

234)
Ms. Carter was afraid of Coleman and worried for her daughter, so she sent him
the photographs he requested. After that, Coleman did some repairs.

235)
Once, when he was in Ms. Carters house fixing a broken switch, Coleman came
into her bedroom and asked if he could go down on her. She told him no and after that he
refused to repair a broken sink in her bathroom which was falling off of the wall and needed a
cabinet under it.
236)
Coleman stares at Ms. Carter in a menacing manner whenever she sees him in the
community.
237)
Recently, after these issues appeared in the media, the Housing Authority
responded by sending other workmen out to begin doing work and they did some of the work
Coleman refused to do after Ms. Carter rejected his sexual advances. For instance, after the
media began to report on these issues, Ms. Carters bathroom sink was fixed.
40
Detria Adams Story

238)
Detria Adams is a 31 year-old female resident of Gilmor Homes, a public housing
project in Baltimore, Maryland. She moved into Gilmor Homes in 2009. While residing there,
she gave birth to her now four year old son and her now two month old son. Both of whom
reside with her in Gilmor homes.
239)
Shortly after moving in, while she was sleeping, Ms. Adams heard a knock at the
door. Maintenance came in before she had the opportunity to get out of bed. By the time she got
to the bedroom door, they were in her home. At that time she had no outstanding work orders
and so she did not understand why they were in her home. As soon as they saw her, the
maintenance men left abruptly.
240)
of her pussy.
In 2013, Mr. Mike Robinson approached Ms. Adams and asked her for pictures
His request made her feel degraded. Ms. Adams was scared and worried as to
what would happen if she didnt comply with his request, especially since maintenance had
previously entered her apartment unannounced and invited and without any work orders.
241)
Because she was scared and worried for her safety, and the safety of her child,
Ms. Adams sent Robinson graphic pictures that she downloaded off of the internet and attempted
to pass them off as pictures of herself. Robinson quickly responded that he knew the pictures
were not of her. He became angry and upset with Ms. Adams.
242)
Robinson made numerous additional advances towards Ms. Adams, including
asking her to go to the beach with him. She consistently rejected his advances.
243)
Subsequent to these multiple rejections, Ms. Robinson and the maintenance crew
refused to properly follow up on Ms. Adams numerous requests for repairs, allowing dangerous
conditions to fester in her home unabated. The deplorable conditions included: mold, water
41
damage from flooding, electrical problems, a broken refrigerator, heating problems, missing legs
on the bathroom sink, rat infestation and bed bugs. These conditions persist to this day.
244)
In addition to the unlivable conditions, as the result of the maintenance crews
failure to respond to Ms. Adams numerous work order requests, she has lost several
refrigerators worth of food for herself and her child. On several occasions, she has had to resort
to putting her food outside in the winter-time to keep it cold enough to consume. However, this
was a short-term fix since the rats would then begin to chew through her screen to access our
food.
Shanae Boles Story
245)
Shanae Boles is a 28 year-old female resident of Gilmor Homes, a public housing
project in Baltimore, Maryland. She moved in to Gilmor Homes in 2011 with her son, who is
now 9 years old.
246)
Prior to moving in, Ms. Boles has heard about the maintenance men from other
residents and to watch out for them.

247)
When Ms. Boles moved into the property she did not have a refrigerator. She
waited two days until finally Coleman came to her home with a refrigerator. When he came
inside he said I see you live here by yourself, let me show you what this tongue can do. Ms.
Boles rejected Colemans advances.
248)
Each time Ms. Boles saw Coleman, he made a sexually explicit comments to her
such as: when are you going to give me a chance to taste it, when are you going to give me a
chance to show you what I can do and when are you going to let me come lay with you?
Each time she rejected his advances.
42
249)
In addition to suffering from Colemans harassment, Ms. Boles also witnessed
Coleman making similar comments to other female residents. Ms. Boles also witnessed
Coleman slap the behind of another female resident.
250)
As a child, Ms. Boles was the victim of sexual abuse. Colemans comments took
her back to that place. He made her feel uncomfortable and scared. She feared for her safety
and the safety of her son.
251)
Ms. Boles had numerous life-threatening conditions for which she has made
numerous repair requests but which have remained unabated. These include: a lack of heat
throughout the unit, roach infestations and mold.
Lasonia Gilberts Story
252)
Lasonia Gilbert is a 30 year-old female resident of Gilmor Homes, a public
housing project in Baltimore, Maryland. She moved into Gilmor Homes in 2007 with her
daughter, who is now ten. She also resides there with her now two year old daughter. She is
currently employed full-time as a medical assistant.
253)
Ms. Gilbert first met Coleman in 2011. Shortly after she met him, he began
making unwanted sexual advances towards her. He repeatedly asked her out, asked her for her
phone number and would say things like you are so sexy and your butt is so big.
254)
Whenever Ms. Gilbert would see Coleman on the street, or in the office, he would
hug her. When he hugged her, Ms. Coleman would press his body against her, grab her buttocks
and rub his arms and hands around her back in an extremely inappropriate manner.
255)
Over the years, Coleman made numerous sexually explicit comments towards Ms.
Gilbert, including: can I come down to your house so we can fuck, can we get it in, and
your man cant take care of you like I can, I want to go down on you and You would fall in
43
love with me if you tasted me.
On most occasions, Coleman would follow up these comments
with the statement that I can make sure all of your house issues get handled if you let me come
down and fuck you. Ms. Gilbert refused Colemans advances. These comments continued
throughout her time at Gilmore homes, up until 2015.
256)
In one instance in 2014, Ms. Gilbert ran into Coleman when she was out with
friends. Ms. Gilbert was about to go into a club when Coleman, who was parked in front of the
club, saw her. He got out of his car and approached Ms. Gilbert. Coleman asked Ms. Gilbert
how things were going. Ms. Gilbert informed him that she still had all of the maintenance
problems she had previously lodged work orders for. She asked him when workers would come
to her home to fix things. Coleman responded by asking if Ms. Gilbert would come to a room
with him. Coleman stated that he would go down on her, make her feel good and make her
fall in love with him. Coleman then offered Ms. Gilbert money if she would go to a room with
him. Coleman informed Ms. Gilbert that if she came with him, he would definitely have
workmen come down and work on her property. He then told Ms. Gilbert to go ahead and
finish having a good time and he would be waiting for her outside of the club.
257)
When Ms. Gilbert came out of the club, approximately one and a half hours later,
Coleman was still there. Ms. Gilbert walked passed him and did her best to avoid him. She was
extremely frightened. She worried that anywhere she went, she might see him and have to
interact with him.
258)
Coleman continued to make graphic comments and repeated advances towards
Ms. Gilbert throughout her time living at Gilmor Homes. Each time she did her best to ignore
him and refuse his advances.
44
259)
Throughout her time at Gilmor Homes, Ms. Gilbert has lived with dangerous
conditions which have remained unaddressed per Colemans threats towards her. These
conditions include: roach infestations, mice infestations, holes in the ceiling from the mice,
peeling paint, mold, broken windows that wont open, as well as living for years without heat
throughout the unit.
260)
In addition to the life threatening conditions, Ms. Gilbert was, and continues to
be, extremely scared. She has felt violated and frightened for her safety and for the safety of her
children. She has been suffering from anxiety, panic attacks, lack of sleep and depression.
Myrtle Gilberts Story
261)
Myrtle Gilbert is a 50 year-old female resident of Gilmor Homes, a public
housing project in Baltimore, Maryland. She moved into Gilmor Homes in 2006
262)
Over the years, Ms. Gilbert filed numerous work orders and complaints about her
broken refrigerator.
263)
In 2008, Robinson informed Ms. Gilbert that if she wanted a new refrigerator, she
needed to have sex with him. After years of asking for the repairs and never having them made,
Ms. Gilbert was desperate. She was on disability and had limited means. She was consistently
losing food and was not able to afford new food. She felt that she had no choice and she gave
into his demands. Ms. Gilbert had sex with Robinson on two occasions. She felt degraded and
wronged.
264)
Over the course of the next two years, Ms. Gilbert received two refurbished
refrigerators, both of which eventually stopped working.
45
265)
In 2012, Ms. Gilbert followed up again with Robinson and asked him when she
was going to get a new refrigerator like he promised her. Robinson told Ms. Gilbert that if she
wanted a new refrigerator she would have to have sex with him again. She refused his advances.
266)
From 2012 through 2015, Robinson continuously harassed Ms. Gilbert for sex.
Ms. Gilbert continuously refused his advances.

267)
In 2013, Ms. Gilbert complained to the rental office about Robinson and his
sexual demands, as well as the unaddressed conditions in her home. The woman in the rental
office told Ms. Gilbert that she needed to speak with maintenance directly. Ms. Gilbert was
directed to go back to the maintenance office.
268)
Ms. Gilbert did as the woman in the rental office instructed her to and told the
maintenance supervisor, Coleman, about what had happened with Robinson. Coleman laughed
at Ms. Gilbert. Humiliated, Ms. Gilbert cried. Coleman continued to laugh at Ms. Gilbert.
269)
Ms. Gilbert felt humiliated and depressed.
She felt like no one cared.
270)
When Ms. Gilbert gave in to Robinsons demands, he gave her two refurbished
refrigerators. When Ms. Gilbert stopped giving in, Robinson stopped helping her. Robinson
continued to demand that Ms. Gilbert do more for him, but she refused.
271)
The conditions in Ms. Gilberts home that were unaddressed for years included: a
broken refrigerator, a broken stove, rodent infestations, bed bug infestations and electricity
problems.
Tracey Holdens Story
272)
Tracey Holden is a 33 year-old female and was a resident of Gilmor Homes, a
public housing project in Baltimore, Maryland. She moved into Gilmor Homes in 2005 with her
46
two young daughters, now fourteen and fifteen years old. While living there, she had another
daughter, now seven years old, and a son, now three years old.
273)
Over the years there were numerous problems with the unit. Ms. Holden would
go down to the maintenance office to follow up on her work orders. Whenever she would go
down there, Robinson would make comments to her such as I can fix it for you, but you need to
do something for me. She rejected his advances.
274)
There came a time when Coleman came to work at the maintenance office as the
maintenance supervisor. When Ms. Holden would go down to the maintenance office to ask him
about her outstanding repairs, he made comments to her like you have to do some strange for
some change. She rejected his advances.
275)
On numerous occasions, when Ms. Holden went down to the maintenance office,
Robinson would physically brush up against her. She rejected his advances.
276)
On several occasions, when Ms. Holden was down in the maintenance office
following up on outstanding work orders, Robinson made sexually explicit comments to her like
would you mind if I touched your titties and if you give me some head and Ill fix it up for
you myself and you wont have to wait for maintenance. He also tried to grab her buttocks.
She hit his hand away and continued to reject his advances.
277)
Over the years, Coleman repeatedly made inappropriate sexual comments to Ms.
Holden such as you should bend over, it wont hurt you to give oral sometime and you know
what happened to those single girls His comments became increasingly explicit and
aggressive and Ms. Holden became increasingly concerned for her safety and the safety of her
children.
47
278)
These sexual comments and advances by Coleman and Robinson continued
throughout Ms. Holdens time at Gilmor Homes up until 2014.

279)
In 2012, Ms. Holden complained to Ms. Turner at the rental office about the
sexual advances by Robinson. Ms. Turner responded that she would discuss the issue with the
maintenance supervisor, Coleman. Nothing ever happened in response to Ms. Holdens
complaint to the rental office.
280)
Because the maintenance men refused to do the necessary repairs, the rodent
infestation got so bad in Ms. Holdens unit that she had to buy a cat. One of her daughters was
even bitten by a rodent. Ms. Holdens family broke out from the bug bites from the insect
infestations that went unabated.
281)
Coleman and Mr. Robinson made Ms. Holden feel scared and panicked. She
went into therapy while living there because of what they put her through. Their comments
made her feel broken and the lack of response from the rental office made her feel hopeless.
282)
Ms. Holden continued to reject Colemans and Robinsons advances and
consequently, Ms. Holdens life threatening living conditions went unrepaired. These included:
no heat throughout the house, unstable bathroom sink, a hole in the tub that would flood her
bathroom and downstairs, broken pipes that caused flooding throughout her house, shot out
windows, mold and mildew, mice infestations and roach infestations.
Khrystyna Kelleys Story
283)
Khrystyna Kelley is a 30 year-old female and is a resident of Gilmor Homes. She
moved in to Gilmor Homes in 2012 with her three children and while pregnant with her fourth
child.
48
284)
Within the first couple of weeks of moving into Gilmor Homes, Ms. Kelley
needed repairs completed. She went down to the maintenance office and spoke with Coleman.
Coleman told Ms. Kelley that there was no telling how long it would take to get someone in to
fix things. He then informed Ms. Kelley that if she slept with him, it would get things done
faster. Coleman also told Ms. Kelley that if she gave him her number it would be a lot easier for
repairs to get done. Coleman told Ms. Kelley that he could come over and do them himself and
spend the night. Ms. Kelley refused his advances. The repairs were not done.
285)
Shortly after moving in, the heater in the main room stopped working. Ms.
Kelley put in a work order. No one ever came to fix it. As a result, Ms. Kelley (who was
pregnant at the time) and her three children, all slept together, in her bed, with their winter coats
on.
286)
While living in Gilmor Homes, from 20122013, Ms. Kelley observed sparks
shooting out of the sockets. She placed numerous work orders to have this repaired. It was not
until Ms. Kelleys daughters leg was burned in 2013 that this dangerous condition was repaired.
287)
In 2014, the heater in Ms. Kelleys bedroom exploded. Her house was covered in
steam and water from the steam pouring out of the valve. Ms. Kelley ran to the maintenance
office and asked for help. Coleman was there and he accompanied Ms. Kelley back to her home.
288)
While Ms. Kelley was showing Coleman the radiator, he walked behind her and
pressed his body up against hers. He then pressed his penis into her back. Again, Ms. Kelley
refused his advances. Coleman left and returned with another maintenance man. They turned
off the valve. They told Ms. Kelley any further work was an outside contractor issue. Ms.
Kelley and her children lived without heat for a year.
49
289)
Approximately one year later, someone from an outside service came and fixed
the heater in Ms. Kelleys bedroom. As of the present day, Ms. Kelley still does not have heat in
her main room.
290)
In addition to heating problems, Ms. Kelley put in work orders because rats had
chewed holes through her front door. No one ever came to look at the problem or fix it.
Subsequently, there was a significant rodent infestation in Ms. Kelleys home. Ms. Kelleys cat
killed many of the rodents, leaving many dead rodents throughout her home. But this did not
stop them from chewing through her front door.
291)
Ms. Kelley eventually confronted Coleman and Robinson and told them since
they wouldnt fix the holes and the rodent issue, she would be calling Fox 45 news. She called
the news and a news crew came on site and interviewed her and several neighbors about the
rodents. The maintenance crew came and fixed the holes after the news crew left.
292)
On numerous occasions Ms. Kelley would encounter Robinson outside her home
on the grounds. He would repeatedly ask for her phone number. Because she refused his
advances, Robinson picked on her and harassed her. This included Robinson cutting Ms.
Kelleys Satellite Dish wires on three separate occasions.
293)
Despite numerous requests, dangerous conditions in Ms. Kelleys home continued
to fester. These include: black mold, water damage, a peeling tub, peeling paint, broken
radiators, lack of heat, a broken refrigerator and loose step runners.
Towanda Parkers Story
294)
Towanda Parker is a 50 year-old female and a resident of Gilmor Homes, a public
housing project in Baltimore, Maryland. Ms. Parker moved in to Gilmor Homes in

approximately 2010, with her young daughter who is now 10 years old.
50
295)
Prior to meeting Coleman, Ms. Parker had heard from some of the other female
residents at Gilmor Homes that he would get fresh with her.

296)
In approximately 2012 Ms. Parker had her first interaction with Coleman. She
had been waiting on several work orders that had not been fulfilled so she went down to the
maintenance office to see what was going on. When Ms. Parker asked Coleman about the work
orders, he told her I will try to push it as fast as I can but if you give me a smile, maybe they
will come tomorrow. Ms. Parker rejected his advances.
297)
On several other occasions, when Ms. Parker saw Coleman in the maintenance
office, he would push himself up against her. Other times he would grab her behind. Each time
Ms. Parker would move away and reject his advances.
298)
On one occasion, when Ms. Parker walked into the maintenance office, Coleman
grabbed his crotch and stared at her. It appeared that he was masturbating in front of her. On
another occasion, Ms. Parker went down to the maintenance office to get supplies. However, it
was not supply day. Coleman told Ms. Parker if you work with me, I will work with you. She
rejected his advances.
299)
Whenever Ms. Parker would see Coleman, he would make sexually explicit
comments to her. This included him saying things to her such as: your ass is so fat, I would
love to fuck you, I would love to do a Bill Cosby on you, and if you want your work done,
you have to put in your time.
300)
These advances by Coleman continued throughout Ms. Parkers time at Gilmor
homes and have occurred most recently at the end of July 2015, beginning of August, 2015.
301)
In accordance with his threats, dangerous conditions in Ms. Parkers home went
unabated. These included: mold, rodent infestations, roach and ant infestations, holes in the
51
living room wall, holes in the kitchen walls and holes in the bedroom walls, insecure legs on the
bathroom sink, lack of heat in the bathroom, lack of heat in the living room and lack of heat in
the kitchen.
302)
Ms. Parker lives with her young daughter. Colemans comments and behavior
made her fear for her safety and the safety of her daughter. On occasion, Coleman would show
up at Ms. Parkers apartment. She was afraid to open the door for him since she did not know
what he would try to do to her, or her daughter.
303)
Colemans words and behavior made Ms. Parker feel degraded. She has
described it as feeling as if she had been raped inside, like she was nothing.
Sierria Warrens Story
304)
Sierria Warren is a 29 year-old female and resident of Gilmor Homes, a public
housing project in Baltimore, Maryland. Ms. Warren moved in to Gilmor Homes in 2008 with
her daughter, who is now 13 years old.
305)
After moving in, it was apparent to Ms. Warren that the unit needed numerous
306)
Ms. Warren had been warned by other female residents that if she wanted any
repairs.
repairs done, the maintenance men would likely ask for sex in exchange for making the
necessary repairs.
307)
Over the years that she lived there, Ms. Warren put in work orders for the repair
issues that arose. However, nothing was done in response to the work orders.
308)
In 2012, she began going to the maintenance office in person to request that her
repairs be done. Instead of addressing the repairs, Coleman made comments to her about Ms.
Warren getting fat and made unwanted sexual advances, including asking Ms. Warren out.
52
Ms. Warren was upset about the comments and left the maintenance office. She rejected his
advances.
309)
In 2013, Ms. Warren went to the maintenance office and asked Coleman about
repairing a hole in the kitchen ceiling. The hole was caused by a previously reported, ongoing
and unaddressed leak from the upstairs toilet that subsequently caused water damage to the
kitchen ceiling.
310)
When Ms. Warren asked about the repairs, Coleman responded by commenting
that her butt had gotten very fat. Coleman then physically turned Ms. Warren around to look
at her body. He then asked who was around my house and made other sexual inferences.
Colemans actions and comments made Ms. Warren feel uncomfortable and violated.
311)
Ms. Warren has a history of sexual abuse as a child and his comments brought her
back to that place. She has avoided him since then.

312)
Ms. Warren fears for her safety, and the safety of her child. Ms. Warrens home
has had significant problems including one occasion where the electrical wires in her daughters
room caught on fire and burnt the outlet strip along the wall. The damaged wires remain to this
day.
313)
The deplorable conditions that remain unaddressed after Ms. Warren refused to
give in to the sexual demands include: mold, mildew, roaches, bed bugs, a loose toilet, lack of
electricity, and lack of refrigeration due to a lack of electricity.
314)
In addition, as a result of the unabated and dangerous living conditions, Ms.
Warrens daughters health has suffered. She has exhibited an increase in headaches and
vomiting, along with a noticeable increase in difficulties in her schooling. All of which occurred
as the physical conditions in the home worsened.
53
Rosena Princes Story

315)
Rosena Prince is an adult female resident of Baltimore public housing. She lives
in a scattered sites home on Teresa Court in Baltimore, Maryland.

316)
On February 15, 2013, a maintenance man named Carey, whose last name Ms.
Prince does not know, was called to her home to fix her front door. Rats had gnawed a hole
through the bottom of the door frame and she had seen at least one squirming into her house.
317)
When the maintenance man arrived, Ms. Prince happened to be on the telephone
with her niece, Nicole Johnson, who has provided an affidavit attached hereto and incorporated
herein by reference. Ms. Johnsons affidavit corroborates the facts reported by Ms. Prince.
318)
Ms. Prince showed the maintenance man the hole and explained that rats were
coming into her home. The maintenance man replied with words to the effect of, I know why
the rats want in here; I want to get with you also; Id want to take a bite out of you too. He
went on for some time with comments like this and stood uncomfortably close to Ms. Prince.
319)
Ms. Prince asked him why he thought he could speak to her like that and he
became even ruder.

320)
Ms. Prince hung up with her niece and immediately called the maintenance
supervisor, Ms. Owings, to complain. Ms. Prince told Ms. Owings what happened and she told
the maintenance man to pack up and leave immediately.
321)
The maintenance man falsely told Ms. Owings Ms. Prince did not need a new
door despite the obvious hole and the rat problem. This was in direct retaliation for the
complaint Ms. Prince filed.
322)
The maintenance man left without fixing or replacing the rat-damaged door.
54
323)
Ms. Prince received a call back regarding her complaint from a gentleman with
the Housing Authority who did not leave his name. Ms. Prince reiterated her complaint and her
concerns about the maintenance man and the door. Ms. Prince never heard anything else after
this call except when she initiated further contact as described below.
324)
Ms. Prince knew that no significant action was taken because three days later, she
saw the same maintenance man working on an HABC house down the street.
325)
When her door had still not been replaced, Ms. Prince complained again
approximately a week after the incident, to Brandy Marcus (maiden name, George). Ms. Marcus
put a Ms. Hopkins on the telephone. After Ms. Prince told them both about the harassment and
retaliation, Ms. Hopkins said she would speak to the maintenance staff. Ms. Prince never heard
anything back about it.
326)
Only after Ms. Prince spoke to Ms. Hopkins was the door finally replaced.
327)
Ever since she complained, Ms. Prince has been mistreated by the Housing
Authority maintenance staff. Her concerns have been ignored, she has been treated rudely and
referred to by staff as the one who complained, a problem, and a nuisance. Ms. Prince was
never treated this way before she brought up the harassment.
328)
When tile in her upstairs bathroom needed to be fixed, a maintenance man did the
job, but tracked glue all over the new tile and across Ms. Princes carpet. The tracks were so
obvious and involved so much glue that this act had to have been intentional.
329)
When she needed closet doors replaced upstairs, the maintenance man left with
the keys and never returned them.

330)
Sewage periodically leaks into the drinking and bathing water in Ms. Princes
home and the water is dark or black in color and reeks when coming from the sink or bathtub.
55
Ms. Prince has repeatedly complained about this, but other than giving her bleach, nothing has
been done.
331)
Ms. Prince is seeking medical attention for the resulting health problems and she
has to burn candles in her home to help mask the smell. The refusal to do anything about the
sewage in Ms. Princes water is a direct result of the fact that she complained. Before she
complained, she was not mistreated in this way.
332)
All of these actions, and the rude treatment she has endured, are retaliation for the
complaint Ms. Prince filed.

CLASS ALLEGATIONS
333)
This Class Action is being filed by the plaintiffs, pursuant to Federal Rule of Civil
Procedure 23, on behalf of themselves and others similarly situated.

334)
Plaintiffs seek to certify the following classes, defined as:

CLASS A: All women who were/are residents of HABC public housing, were
sexually harassed, verbally and/or physically assaulted by maintenance employee(s) of HABC,

were at least initially refused repairs to their homes, and who acquiesced to the sexual demands
of the maintenance employee(s), including, but not limited to: performing sexual acts and/or
providing pictures of themselves for the sexual gratification of the maintenance employee(s).
CLASS B: All women who were/are residents of HABC public housing, and
who were sexually harassed and physically assaulted by maintenance employee(s) of HABC.
CLASS C: All women who were/are residents of HABC public housing, were
sexually harassed through words and/or deeds, but not physically assaulted by maintenance
employee(s) of HABC, and who were refused repairs to their homes, but did not acquiesce to any
sexual demands.
56
CLASS D: All women who were/are residents of HABC public housing, were
sexually harassed through words and/or deeds, but not physically assaulted by maintenance
employee(s) of HABC, and who did not acquiesce to any sexual demands.
335)
To the extent revealed by discovery and investigation, there may be additional
appropriate classes and/or subclasses from the above class definitions which are broader and/or
narrower in time or scope of exposure.
336)
Excluded from the classes are Defendants officers, directors, agents or
employees and members of their immediate families; and the judicial officers to whom this case
is assigned, their staff and the members of their immediate families.
337)
Excluded from the classes are any local, state, or federal government entities.
338)
This Court may maintain these claims as a Class Action pursuant to Fed. R. Civ.
339)
Numerosity Fed. R. Civ. P. 23(a)(1): The members of each class are so
P. 23.
numerous that joinder of all members is impractical.

340)
The members of the Plaintiffs class is currently at 19. There are additional
women who have not yet come forward out of fear and/or embarrassment, but whom may still
come forward in time with claims that are identical to those Plaintiffs who have already been
named.
341)
Furthermore, there are women who would come forward if applying to an
established class fund who would not come forward as part of a lawsuit given the relative
anonymity available to applicants to a class fund as opposed to the public scrutiny which has
attached to the women bringing this claims.
57
342)
Additional women have contacted the office of the undersigned without leaving
their contact information to say that the same thing happened to them, but that they will not come
forward as part of a public lawsuit because the victims cannot bear to have family members,
including significant others, parents and young children learn what the victims suffered.
343)
The investigation of the Union reflected in the affidavit of Lucy Crosby, which is
attached hereto as an exhibit, reflects the investigation Mr. Crosby conducted into the sexual
extortion at Gilmor Homes. A careful review of his findings combined with a familiarity of the
streets he covered suggests that approximately 45-50% of the sample of women he contacted
complained of sexual harassment by the maintenance men. There are over 520 units in Gilmor
Homes alone. A reasonable extrapolation would suggest that a conservative estimate of the
number of victims of sexual harassment by maintenance men just in this one complex could
easily stretch to one hundred or more.
344)
HABC claims on its website to have 20,000 residents in approximately 11,000
units. For socio-economic and regulatory reasons, the vast majority of adult residents are
women. Nevertheless, assuming a lower female occupancy rate of just 50%, and assuming
further that only 50% of those are adults, there are, very conservatively, at least 5,000 adult
women in public housing. Assuming a rate of abuse much lower than the Union found of just
15% suggests the very real potential for as many as 750 victims city-wide. As such, a class is the
only way to ensure these unnamed womens interests are served.
345)
Commonality Fed. R. Civ. P. 23(a)(2): There are common questions of law and
fact that affect the rights of every member of each respective class, and the types of relief sought
are common to every member of each respective class. The same conduct by each Defendants
have injured every member of each respective class. A Class Action is superior to other
58
available methods for the fair and efficient adjudication of the controversy, in satisfaction of Fed.
R. Civ. P. 23(a)(2). Common questions of law and/or fact common to each respective class
include, but are not limited to:
(a)
Whether Charles Coleman was an actual and/or apparent agent, servant
and/or employee of the Defendants at all relevant times herein;

(b)
Whether Charles Coleman subjected the female residents of Baltimore city
public housing to unwanted sexual advances;

(c)
Whether Charles Coleman refused to make requisite repairs on Baltimore
City Public Housing unless the female residents acquiesced to his sexual quid pro quo;
(d)
Whether Charles Coleman made requisite repairs when the female
residents in Baltimore city Public Housing acquiesced to his sexual quid pro quo;
(e)
Whether Michael Robinson was an actual and/or apparent agent,
servant and/or employee of the Defendants at all relevant times herein;

(f)
Whether Michael Robinson subjected the female residents of
Baltimore city public housing to unwanted sexual advances;

(g)
Whether Michael Robinson refused to make requisite repairs on
Baltimore City Public Housing unless the female residents acquiesced to his sexual quid pro quo;
(h)
Whether Michael Robinson made requisite repairs when the female
(i)
Whether Doug Hussy was an actual and/or apparent agent, servant
and/or employee of the Defendants at all relevant times herein;

(j)
Whether Doug Hussy subjected the female residents of Baltimore
city public housing to unwanted sexual advances;
59
(k)
Whether Doug Hussy refused to make requisite repairs on Baltimore City
Public Housing unless the female residents acquiesced to his sexual quid pro quo;
(l)
Whether Doug Hussy made requisite repairs when the female
(m)
Whether unnamed maintenance man was an actual and/or apparent agent,
servant and/or employee of the Defendants at all relevant times herein;

(n)
Whether unnamed maintenance man subjected the female residents of
Baltimore city public housing to unwanted sexual advances;

(o)
Whether unnamed maintenance man refused to make requisite repairs on
Baltimore City Public Housing unless the female residents acquiesced to his sexual quid pro quo;
(p)
Whether unnamed maintenance man made requisite repairs when the
female residents in Baltimore city Public Housing acquiesced to his sexual quid pro quo;
(q)
Whether and when the Housing Authority of Baltimore City had notice of
the misconduct and the ability to stop it;

(r)
Whether and when the Housing Authority of Baltimore City took any
action to adopt policies and procedures to discourage this misconduct;

(s)
Whether and when the Housing Authority of Baltimore City took specific
action in response to complaints it received;

(t)
Whether the Housing Authority of Baltimore Citys actions and/or alleged
failures to act, including their alleged failure to properly investigate, monitor and supervise
Charles Coleman, Michel Robinson, Doug Hussy and/or any unnamed individual maintenance
men employed by HABC, directly and proximately resulted in foreseeable injuries or damages to
class members.
60
346)
These questions of law and/or fact are common to each class and predominate
over any questions affecting only individual class members.

347)
Typicality Fed. R. Civ. P. 23(a)(3): The claims of Plaintiffs: Nicole Andrea
Smith, Takira Carter and Myrtle Gilbert are typical of the claims of the members of the Class A
(Class A Plaintiffs), as required by Fed. R. Civ. P. 23(a)(3),in that all claims are based upon
the same factual and legal theories. The claims of Plaintiffs: Celeste English, Amy Towson,
Onnaday McIntosh-Griggs, Towanda Parker, Tracey Holden, Lynette Cooper, Khrystyna Kelley,
Lasonia Gilbert and Sierria Warren are typical of claims of members of Class B (Class B
Plaintiffs), as required by Fed. R. Civ. P. 23(a)(3), in that all claims are based upon the same
factual and legal theories. The claims of Plaintiffs: Stephanie Harris, Shanae Barnes, Sara
Garrett, Detria Adams, and Rosena Prince are typical of the claim of members of Class C (Class
C Plaintiffs), as required y Fed. R. Civ. P. 23(a)(3), in that all claims are based upon the same
factual and legal theories. The claims of Plaintiffs Jacqueline Kiana Morant and Shanae Boles
are typical of the claim of members of Class D (Class D Plaintiffs), as required y Fed. R. Civ.
P. 23(a)(3), in that all claims are based upon the same factual and legal theories. It is the same
conduct by each Defendant that has injured every member of each class. The principal issue in
this matter involves Defendants conduct in wrongfully making sexual advances towards female
resident in Baltimore city public housing and withholding requisite repairs if said female
residents failed to acquiesce to the Defendants sexual demands, while Defendant employers of
the individual Defendants failed to properly oversee and/or respond to complaints of this
wrongful conduct.
348)
Adequacy Fed. R. Civ. P. (23)(a)(4): Plaintiffs Nicole Andrea Smith, Takira
Carter and Myrtle Gilbert will fairly and adequately represent the interests of Class A, as
61
required by Fed. R. Civ. P. 23(a)(4). Plaintiffs Celeste English, Amy Towson, Onnaday
McIntosh-Griggs, Towanda Parker, Tracey Holden, Lynette Cooper, Khrystyna Kelley, Lasonia
Gilbert and Sierria Warren will fairly and adequately represent the interests of Class B, as
required by Fed. R. Civ. P. 23(a)(4). Plaintiffs Stephanie Harris, Shanae Barnes, Sara Garrett,
Detria Adams and Rosena Prince will fairly and adequately represent the interests of Class C, as
required by Fed. R. Civ. P. 23(a)(4). Plaintiffs Jacqueline Kiana Morant and Shanae Boles will
fairly and adequately represent the interests of Class D, as required by Fed. R. Civ. P. 23(a)(4).
Plaintiffs have retained counsel with substantial experience in the prosecution of complex civil
rights matters in the State of Maryland and in Federal Court in Maryland. Furthermore, Plaintiffs
have retained counsel with substantial experience in litigating complex matters throughout the
state of Maryland and Federal Court in Maryland. Plaintiffs and their counsel are committed to
vigorously prosecuting this action on behalf of the classes, and they have the financial resources
to do so. Neither these plaintiffs nor counsel has any interest adverse to those of the class.
349)
Class certification is appropriate pursuant to Fed. R. Civ. P. 23(b)(1) because the
prosecution of separate actions by individual members of the classes would create a risk of
inconsistent or varying adjudications that would establish incompatible standards of conduct for
Defendants and/or because adjudications respecting individual members of the classes would, as
a practical matter, be dispositive of the interests of the other members or would risk substantially
impairing or impending their ability to prosecute their interests.
350)
Class certification is appropriate pursuant to Fed. R. Civ. P. 23(b)(2) because
Defendants have acted or refused to act on grounds generally applicable to all members of each
Class.
62
351)
Plaintiffs have suffered, and will continue to suffer, harm and damages as a result
of Defendants unlawful and wrongful conduct.

352)
A class action is superior to other available methods for the fair and efficient
adjudication of the controversy under Fed. R. Civ. P. 23(b)(3). Absent a class action, most
members of the classes likely would find the cost of litigating their claims to be prohibitive, and
will have no effective remedy at law. The class treatment of common question of law and fact is
also superior to multiple individual actions or piecemeal litigation in that it conserves the
resources of the courts and the litigants and promotes consistency and efficiency of adjudication.
353)
Class certification is also appropriate because this Court can designate particular
claims or issues for class-wide treatment and may designate one or more subclasses pursuant to
Fed. R. Civ. P. 23(c)(4).
354)
Maintenance of this action as a class action is a fair and efficient method for
adjudication of this controversy. It would be impracticable and undesirable for each member of
the classes who has suffered harm to bring a separate action. In addition, the maintenance of
separate actions would place a substantial and unnecessary burden on the courts and could result
in inconsistent adjudications, while a single class action can determine, with judicial economy,
the rights of all members of the classes.
355)
Furthermore, in the name of judicial economy, many, if not all, of these Plaintiffs
would have to be called as witnesses in each individually litigated case as their testimony will
provide evidence of notice, pattern and practice. As such, each Plaintiff would be required to
testify at least nineteen times, as would the Defendants and independent witnesses (referenced in
the above facts common to all counts), in each respective case. Litigating these cases
individually would be a significant waste of resources for this Court, these plaintiffs and the
63
Defendants. Furthermore, litigating these claims individually would neglect those women who
have not yet come forward, but who likely will as these cases progress if litigated individually.
356)
No unusual difficulties are likely to be encountered in the management of this
action as a class action.

357)
Class certification is also appropriate because Defendants have acted on grounds
generally applicable to Plaintiffs of each class, making relief appropriate with respect to
Plaintiffs. Specifically, Plaintiffs seek compensation for their severe mental anguish and
physical suffering, repairs to their properties, relocation where appropriate and all other relief
deemed just and proper.
358)
Plaintiffs were not in any way responsible for the unwanted sexual conduct of
these Defendants, the Defendants failure to make the requisite repairs and the Defendant
employers failure to properly oversee and/or respond to complaints of this behavior.
CLAIMS FOR RELIEF
COUNT I FAIR HOUSING ACT
QUID PRO QUO SEXUAL HARRASSMENT
(All Plaintiffs Versus All Defendants)
359)
All paragraphs of this complaint, whether found above or below, not falling under
this count, are incorporated herein by reference as if fully stated under this count.
360)
The plaintiffs are all women and, thus, members of a protected class.
361)
The Housing Authority of Baltimore City receives federal funding to operate the
housing projects where the plaintiffs reside and suffered discrimination.

362)
The plaintiffs suffered discrimination on the basis of sex at the hands of the
defendants in the sale or rental of housing.
64
363)
Sex or sexual favors were demanded of and/or forced from the female plaintiffs
by those in control of their housing in return for livable housing and housing benefits. These
demands were unwelcome. Similar demands were not made of male residents.
364)
The plaintiffs who refused the defendants demands suffered adverse housing
actions as a direct and proximate result of their refusal. They were denied housing or substantial
benefits of housing. In particular, repairs were intentionally left undone to the point that their
homes are no longer safely habitable.
365)
The Housing Authority of Baltimore City, Paul T. Graziano, Executive Director
of HABC and Baltimore City Housing Commissioner knew, or should have known, of the
harassment given the many complaints made stretching back over the years. These defendants
failed to timely and properly investigate, stop the harassment and otherwise remedy the situation.
WHEREFORE, the plaintiffs each demand TEN MILLION DOLLARS ($10,000,000.00)
in compensatory damages, punitive damages in an amount to be determined by a jury, costs and
attorneys fees, injunctive relief in the form of an order that all health or safety concerns in their
homes be immediately abated, and such other relief as this Honorable Court deems appropriate.
COUNT II FAIR HOUSING ACT
HOSTILE ENVIRONMENT SEXUAL HARRASSMENT
366)
367)
The plaintiffs routinely suffer unwelcome behavior of a sexual nature that creates
an intimidating, hostile or abusive housing environment and has the effect of unreasonably
interfering with a tenant's housing.
65
368)
Maintenance men, including, but not limited to defendants Coleman, Robinson
and Hussy, have made repeated unwanted sexual advances, sexual threats and have touched the
female plaintiff tenants in a sexual way when these women do not want him to.
369)
The plaintiffs are subjected to unwelcome and extensive sexual harassment in the
form of sexual advances, requests for sexual favors, and other verbal or physical conduct of a
sexual nature, which has not been solicited or desired and which is undesirable or offensive.
370)
The harassment was based on sex. But for the plaintiffs gender, the harassment
would not have taken place.

371)
The harassment makes continued tenancy burdensome and significantly less
desirable than if the harassment were not occurring.

372)
The harassment occurs with a high frequency, including virtually every time the
plaintiffs are forced to have contact with defendants Coleman and Robinson and other members
of the maintenance crew.
373)
The harassment often rises to the level of being physically threatening or
humiliating.
374)
The defendants conduct has resulted in severe psychological harm evidenced by
physical reactions in some of the plaintiffs, including the loss of sleep, becoming physically ill to
the point of vomiting, as well as sweating, flushing, shaking, increased heart rate and panic
reactions associated with extreme anxiety and fear.
375)
As demonstrated above, there have been a series of harassing incidents occurring
unabated over the course of years.
66
376)
The plaintiffs have suffered sexual batteries in their own homes or in their
communities by defendants Coleman and Robinson, whose very role was to provide a safe
environment.
377)
The sexual harassment suffered by the plaintiffs is severe and pervasive.
378)
The plaintiffs who refused the defendants demands suffered adverse housing
actions as a direct and proximate result of their refusal. They were denied housing or substantial
benefits of housing.
379)
The Housing Authority of Baltimore City and Paul T. Graziano, Executive
Director of HABC and Baltimore Housing Commissioner knew or should have known of the
harassment given the many complaints made stretching back years. These defendants failed to
timely and properly investigate, stop the harassment and otherwise remedy the situation. These
defendants have not properly informed their agents or employees that they cannot engage in
sexual harassment, have no or insufficient procedures for bringing complaints of sexual
harassment to their attention and having them remedied, and repeatedly ignore complaints of
sexual harassment.
COUNT III CIVIL RIGHTS
ACT DUE PROCESS CLAIM
380)
67
381)
The defendants were, at all relevant times, acting under color of law, pursuant
to Baltimore Citys charter, codes, ordinances and regulations.

382)
The plaintiffs were deprived of their constitutional rights as well as their rights as
described above under the Fair Housing Act, a federal statute.

383)
With respect to the United States Constitution, the plaintiffs were denied the right
to due process of law insofar as their complaints went unaddressed despite controlling law
requiring remedy and they were summarily punished by agents of the government.
384)
The plaintiffs have a liberty interest in the right to be secure in their person, both
at home and in their community. This interest was violated when the defendants touched the
plaintiffs in unwanted ways, threatened their physical safety and security, and created a hostile
environment through continued and excessive sexual harassment.
385)
There are no adequate procedural safeguards in place to prevent this abuse, or
adequately address it after it has occurred. Moreover, what procedures do exist have not been
followed by the defendants, which allows the abuse to continue unabated.
386)
In addition to their procedural due process claims, the plaintiffs assert substantive
due process claims because they were physically assaulted as described elsewhere herein,
without due process of law.
387)
To whatever extent it is determined that the plaintiffs were seized for purposes
of the Fourth Amendment to the United States Constitution, the plaintiffs hereby assert a Fourth
Amendment claim for excessive force.
68
COUNT IV CIVIL RIGHTS
ACT EQUAL PROTECTION CLAIM
388)
389)
The female plaintiffs are treated differently than their similarly-situated male
counterparts, based solely on their sex.

390)
The plaintiffs are singled out for harassment by the defendants. Similarly situated
males suffer no harassment.

391)
There is not a rational basis, legitimate state purpose, or compelling governmental
interest in the harassment and discrimination at issue.

392)
The plaintiffs are being intentionally singled out because of their sex. As such,
they are members of a suspect classification and the harassment must be viewed with strict
scrutiny.
393)
The harassment at issue interferes with the plaintiffs fundamental rights to
physical security, to be secure in their homes and to privacy.

69
COUNT V MARYLAND CONSTITUTION

ARTICLES 24 & 26 DUE PROCESS CLAIM
394)
COUNT VI MARYLAND CONSTITUTION
ARTICLES 24 & 26 EQUAL PROTECTION CLAIM
395)
COUNT VII ASSAULT
(All Plaintiffs Versus Defendants Coleman, Robinson and Hussy)
396)
397)
Defendants Coleman and Robinson intentionally threatened the plaintiffs, without
legal cause or excuse, while possessing the actual and apparent present ability to carry out the
threats.
70
398)
The actions of defendants Coleman and Robinson raised in the plaintiffs minds a
reasonable apprehension of imminent bodily harm.

399)
As a result of the defendants actions, the plaintiffs suffered and continue to suffer
severe mental anguish as well as physical pain and suffering.

COUNT VIII BATTERY
(Plaintiffs Smith, McIntosh-Griggs, Towson, Gilbert, Gilbert, English, Kelley, Parker and
Warren Versus Defendants Coleman and Robinson)
400)
401)
Defendants Coleman and Robinson intentionally touched certain plaintiffs as
described above.
402)
The touching was deliberate, undertaken with actual malice, and was offensive
and non-consensual.
403)

71
COUNT IX INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

404)
405)
The defendants conduct, as described elsewhere herein, was intentional, reckless,
and in deliberate disregard of a high degree of probability that emotional distress would result to
the plaintiffs.
406)
The defendants conduct, as described elsewhere herein, was extreme, outrageous
and beyond the bounds of decency in society.

407)
The defendants conduct, as described elsewhere herein, was malicious, willful
and intentional.
408)
severe and extreme emotional distress as evidenced by physical symptoms such as vomiting, loss
of sleep, elevated heart rate, excessive sweating, flushing, nervousness and panic attacks.
COUNT X NEGLIGENT HIRING,
TRAINING, RETENTION & SUPERVISION
(All Plaintiffs Versus the Housing Authority of Baltimore City and Paul T. Graziano)
409)
72
410)
Defendants Housing Authority of Baltimore City and Paul T. Graziano, Baltimore
City Housing Commissioner and Executive Director of HABC bear direct responsibility for the
hiring, retention and supervision of defendants Coleman and Richardson.
411) Defendants Housing Authority of Baltimore City and Paul T. Graziano, Baltimore
City Housing Commissioner and Executive Director of HABC, knew or should have known,
prior to hiring defendants Coleman and Richardson, that they were unfit for the duties of their
job and dangerous to the women in question. A review of the Maryland Case Search website
reveals numerous criminal convictions under the name, Michael Robinson in Baltimore and
numerous civil judgments against an individual named Clinton Coleman in Baltimore.
412)
This publicly-available information is sufficient to place the other defendants on
notice that defendants Coleman and Richardson are unfit for duties which include being
entrusted with such power of the residents of Baltimores public housing and the keys to their
apartments.
413)
City Housing Commissioner and Executive Director of HABC, failed to exercise their duty to
provide any training sufficient to prevent the sexual harassment and other misconduct outlined
herein.
414)
City Housing Commissioner and Executive Director of HABC, failed to exercise their duty to
properly supervise defendants Coleman and Richardson so as to prevent the sexual harassment
and other misconduct outlined herein.
415)
City Housing Commissioner and Executive Director of HABC, knew or should have known of
73
the numerous complaints against defendants Coleman and Richardson. These complaints clearly
illustrated defendants Coleman and Richardsons unfitness for the duties of their job and their
dangerousness to the women in question. Yet, defendants Housing Authority of Baltimore City
and Paul T. Graziano, Baltimore City Housing Commissioner and Executive Director of HABC,
violated their duty to terminate the employment of defendants Coleman and Richardson.
416) As a result of the defendants actions, the plaintiffs suffered and continue to suffer
COUNT XI NEGLIGENT ENTRUSTMENT
417)
418)
City Housing Commissioner and Executive Director of HABC, bear direct responsibility for
entrusting employees with keys to the plaintiffs units and the power of the plaintiffs which
defendants Coleman and Robinson wielded.
419)
City Housing Commissioner and Executive Director of HABC, knew or should have known,
prior to entrusting defendants Coleman and Robinson that they could not be trusted with such
access or authority.
74
420)
City Housing Commissioner and Executive Director of HABC, breached their duty to permit
only qualified individuals to have keys and access to the plaintiffs units as well as the other
power over the plaintiffs with which defendants Coleman and Robinson were entrusted.
421)

COUNT XII FEDERAL UNCONSTITUTIONAL PATTERN AND PRACTICE
(All Plaintiffs Versus the City of Baltimore, the Mayor and
City Counsel of Baltimore, HABC and Paul T. Graziano)
422)
423)
The violations of the United States Constitution detailed above are so ubiquitous
as to constitute a pattern and practice by the Housing Authority of Baltimore City.

424)
In addition to the seven plaintiffs named in this case, there are dozens more who
have been subjected to the same unlawful patterns and practices.

425)
This pattern and practice rises to the level of the official policy of Baltimore.
426)
the policy of sexual harassment ruthlessly enforced against defenseless single women in
Baltimore public housing.
75
427)

COUNT XIII MARYLAND LONGTIN CLAIM FOR
UNCONSTITUTIONAL PATTERN AND PRACTICE
428)
429)
The violations of the Maryland Constitution detailed above are so ubiquitous as to
constitute a pattern and practice by the City of Baltimore.

430)
In addition to the seven plaintiffs named in this case, there are dozens more who
have been subjected to the same unlawful patterns and practices.

431)
This pattern and practice rises to the level of the official policy of the Housing
Authority of Baltimore City.

432)
the policy of sexual harassment ruthlessly enforced against defenseless single women in
Baltimore public housing.
433)
76

COUNT XIV DECLARATORY JUDGMENT
434)
435)
There is an actual controversy between the parties and within the jurisdiction of
this Honorable Court. The controversy is whether the plaintiffs are immediately entitled to have
deficiencies affecting their safety and lives abated immediately without offering sexual favors in
return.
436)
The plaintiffs respectfully request that this Honorable Court declare the rights and
other legal relations of the parties and order that the necessary repairs be made at once.
77
JURY TRIAL DEMAND

The plaintiffs demand trial by jury.
Respectfully submitted,
HANSEL LAW, PC
HIRSCH & COSCA, PC
_______/s/_____________
Cary J. Hansel, No. 14722
2514 N. Charles Street
Baltimore, MD 21218
Phone: 301-461-1040
Facsimile: 443-451-8606
cary@hansellaw.com
________/s/____________
Annie B. Hirsch, No. 16681
2514 N. Charles Street
Baltimore, MD 21218
Phone: 410-864-8491
Facsimile: 410-982-6597
abh@hirschandcosca.com
78

Second Amended Complaint

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Second Amended Complaint

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

NICOLE ANDREA SMITH

HOUSING AUTHORITY OF BALTIMORE

The individual defendants and other Housing Authority employees prey on

In addition, the attached sworn affidavit testimony demonstrates that:

Nicole Andrea Smith is an adult citizen of Baltimore, Maryland.

Jacqueline Kiana Morant is an adult citizen of Baltimore, Maryland.

Amy Towson is an adult citizen of Baltimore, Maryland.

Sara Garret is an adult citizen of Baltimore, Maryland.

Onnaday McIntosh-Griggs is an adult citizen of Baltimore, Maryland.

Stephanie V. Harris is an adult citizen of Baltimore, Maryland.

Shanae Barnes is an adult citizen of Baltimore, Maryland.

Celeste English is an adult citizen of Baltimore, Maryland.

Takira Carter is an adult citizen of Baltimore, Maryland.

Lynette Cooper is an adult citizen of Baltimore, Maryland

Detria Adams is an adult citizen of Baltimore, Maryland.

Shanae Boles is an adult citizen of Baltimore, Maryland.

Lasonia Gilbert is an adult citizen of Baltimore, Maryland.

Myrtle Gilbert is an adult citizen of Baltimore, Maryland.

Tracey Holden is an adult citizen of Columbia, Maryland.

Khrystyna Kelley is an adult citizen of Baltimore, Maryland.

Towanda Parker is an adult citizen of Baltimore, Maryland.

Sierria Warren is an adult citizen of Baltimore, Maryland.

Rosena Prince is an adult citizen of Baltimore, Maryland.

created under the laws of the State of Maryland.

The Housing Authority of Baltimore City is sui juris.

Paul T. Graziano is the Baltimore Housing Commissioner and Executive Director

Charles, aka Clinton, Coleman is an adult citizen of Baltimore, Maryland and, at

Michael Robinson is an adult citizen of Baltimore, Maryland and, at all times

relevant hereto, was an employee of the Housing Authority of Baltimore City.

hereto, was an employee of the Housing Authority of Baltimore City.

FACTS COMMON TO ALL COUNTS

During the course of Colemans employment with HABC, he became a

While employed by HABC, Coleman made numerous unwanted sexual advances

Furthermore, while employed by HABC, Coleman informed countless women

In addition to repeatedly making these demands of the female residents in public

Michael Robinson, was an employee of HABC. Robinson performed

While employed by HABC, Robinson made numerous sexual advances towards

Furthermore, while employed by HABC, Robinson informed countless women

In addition to repeatedly making these demands of the female residents in public

While employed by HABC, Hussy made numerous sexual advances towards

Furthermore, while employed by HABC, Hussy informed countless women that

In addition to repeatedly making these demands of the female residents in public

Defendants Robinson, Coleman and Hussy are employees of the Housing

sexual advances were unwelcome.

In the 1600 block of Mountmor Court, a woman self-identified as a lesbian, but

After the investigation by Mr. Crosby, Union President Anthony Coates

unwanted physical and sexual contact.

The violations at issue are continuing in nature. Defendants Coleman, Robinson

Recently, an investigation by a local grassroots organization, Communities

Defendants have subjected, and continue to subject, female residents and

The discriminatory incidents described herein occurred while defendants were

exercising their authority as employees of HABC.

By the actions and statements described above, defendants have: a. discriminated

Defendants conduct described above constitutes: a. A pattern or practice of

Defendants conduct was intentional, willful, and taken in reckless disregard of

the rights of others.

Nicole Andrea Smith is a 33 year-old female resident of Gilmor Homes, a public

with her who is currently 8 years old.

she needed it.

procedures for having repairs made in her home.

for long periods of time.

When Coleman was finished, he left.

fixed the gas leak.