Glover/Redding Lawsuits

Case 2:19-cv-00411 Document 1 Filed 03/11/19 Page 1 of 15
UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEVADA
JENNIFER GLOVER, §
§
Plaintiff, §
§ CIVIL ACTION NO. 2:19-cv-00411
v. §
§
CENTERRA GROUP, LLC; and § JURY TRIAL DEMANDED
JOHN DOES 1 THROUGH 5. §
§
Defendants. §
§
ORIGINAL COMPLAINT
Plaintiff JENNIFER GLOVER (“Plaintiff”), by and through her attorneys,
ELLWANGER LAW LLLP and RICHARD SEGERBLOM, LTD. brings this action for
damages and other legal and equitable relief from Defendants, CENTERRA GROUP, LLC
(“Centerra”) and John Does 1 through 5 (“John Does”) (collectively “Defendants”), for
violations of Title VII of the Civil Rights Act of 1964, as amended by the Civil Rights Act of
1991 (“Title VII”), 42 U.S.C. §§ 2000e et seq.; Nevada law on Equal Opportunity in
Employment, Nev. Rev. Stat. § 613.330 et seq. (“NRS 613”), and any other cause(s) of action
that can be inferred from the facts set forth herein.
INTRODUCTION
1. This is an action brought by Ms. Glover against Centerra for creating and
maintaining a work environment of rampant and vicious gender-based discrimination. Ms.
Glover’s co-workers and supervisors were routinely allowed to make wildly inappropriate sexual
comments, unabashedly sexually harass, and even sexually assault Ms. Glover without fear of
consequence. Further, Ms. Glover’s career was hamstrung by Centerra’s discriminatory use of a
“shoulder tap” promotion policy that disadvantaged qualified female employees like Ms. Glover.
ORIGINAL COMPLAINT
1
After Ms. Glover raised complaints about these issues, Centerra retaliated by denying requests
for her to be on different shifts than the men who sexually assaulted her and by continuing to
allow the culture of rampant harassment toward Ms. Glover. Ms. Glover seeks damages for acts
of discrimination based on her gender and for the maintenance of a hostile work environment
toward her. Ms. Glover seeks further damages for the assault, battery, intentional infliction of
emotional distress, and negligent hiring, retention, and supervision perpetrated by Centerra
and/or John Does 1-5. Centerra’s acts of discrimination are in violation of Title VII of the Civil
Rights Act of 1964 and Nevada law on Equal Opportunity in Employment NRS 613, as well as
any other cause(s) of action that can be inferred from the facts set forth herein.
2. Centerra contracted with the U.S. Department of Energy to provide a range of
Security Protective Force Systems services at the Nevada National Security Site (“NNSS”) in
southern Nevada. Centerra provided for the physical protection of national security interests and
other government property and employees.
3. Centerra employed Ms. Glover at the NNSS. Ms. Glover began her employment
with Centerra in April 2016. Throughout Ms. Glover’s employment with Centerra, she was
subjected to harassment, discrimination, and retaliation on the basis of her gender.
JURISDICTION AND VENUE
4. This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1331, which
confers original jurisdiction upon this Court for actions arising under the laws of the United
States, and pursuant to 28 U.S.C. §§ 1343(3) and 1343(4), which confer original jurisdiction
upon this Court in a civil action to recover damages or to secure equitable relief (i) under any Act
of Congress providing for the protection of civil rights; (ii) under the Declaratory Judgment
ORIGINAL COMPLAINT
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Statute, 28 U.S.C. § 2201; 42 U.S.C. §§ 2000e et seq., as amended, and (iii) 42 U.S.C. §§ 1981 et
seq., as amended.
5. The Court’s supplemental jurisdiction is invoked by 28 U.S.C. § 1367(a), which
confers supplemental jurisdiction over all non-federal claims arising from a common nucleus of
operative facts such that they form part of the same case or controversy under Article III of the
United States Constitution.
6. Venue is proper in this Court in as much as the unlawful employment practices
occurred in this judicial district. Venue is also proper in this Court pursuant to 28 U.S.C. §
1391(b)(1) and (c), in that Centerra maintains offices, conducts business and resides in this
district.
PARTIES
7. Ms. Glover is a person who has been aggrieved by Centerra’s actions. She is and
has been, at all relevant times, a citizen of the United States of America and is a resident of Clark
County, Nevada.
8. At all relevant times, Ms. Glover was Centerra’s employee and therefore covered
by Title VII and NRS 613.
9. Centerra is a subsidiary of Constellis Holdings, LLC headquartered at 7121
Fairway Drive, Suite 301, Palm Beach Gardens, Florida 33418. Constellis Holdings, LLC is a
privately held company headquartered at 12018 Sunrise Valley Drive, Suite 140, Reston,
Virginia 20191. Upon information and belief, Centerra employs over five thousand (5,000)
persons.
10. During all relevant times, Centerra has been an employer covered by Title VII and
NRS 613.
ORIGINAL COMPLAINT
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11. Centerra transacted business in Nevada by, among other things, employing
persons at facilities located within Nevada and within this judicial district.
EXHAUSTION OF FEDERAL ADMINISTRATIVE REMEDIES
12. Ms. Glover, who has herein alleged claims pursuant to Title VII, has timely filed
a complaint of discrimination with the Equal Employment Opportunity Commission (“EEOC”),
which constitutes a cross-filing with the Nevada Equal Rights Commission.
13. Ms. Glover has requested and received her Notice of Right to Sue letter from the
EEOC prior to the filing of this Complaint. On or around February 26, 2019, Ms. Glover
received her Notice of Right to Sue letter.
STATEMENT OF FACTS
14. Ms. Glover first started working for Centerra as a Security Police Officer (“SPO”)
in or around April 2016 at the NNSS. Ms. Glover worked for Centerra at the NNSS until March
1, 2018, when Centerra’s contract was terminated.
15. Throughout her employment with Centerra, Ms. Glover suffered gender-based
discrimination, sexual harassment, a hostile work environment, and retaliation in the form of
repeated inappropriate behavior and comments, discriminatory treatment from supervisors and
co-workers, and a violent sexual assault. Centerra never took any remedial actions to correct the
numerous issues.
16. For example, one of Defendant’s senior managers sent instant messages to Ms.
Glover which stated “Come over, have some wine. We can hang out. Whatever happens,
happens.” Ms. Glover rejected this sexual advance.
ORIGINAL COMPLAINT
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17. During this same timeframe, Ms. Glover applied for a promotion to Lieutenant in
or around April 2017, a position for which she was fully qualified. In spite of her exemplary
qualifications for the role, Centerra management failed to promote Ms. Glover.
18. Around the same time, Ms. Glover had completed and passed a highly difficult
exam to become a Special Reaction Team (“SRT”) member. This SRT position would have also
been a promotion for Ms. Glover. Despite being fully qualified and performing better than most
other applicants in the exam, Centerra failed to give Ms. Glover the position.
19. Sexual harassment and discrimination toward Ms. Glover was severe and
pervasive throughout her employment.
20. For example, soon after beginning work at the NNSS, many male SPOs referred
to Ms. Glover as the “hot chick” and propositioned her for sex while at work. Ms. Glover
rejected their advances. She was forced to remind several of the SPOs that they were married and
their comments were inappropriate. The SPOs responded that they were “not married when they
were on site.”
21. SPOs found pictures of Ms. Glover wearing a swimsuit on Facebook, saved the
pictures on their phones, and distributed them to other male SPOs.
22. SPOs often spread rumors about Ms. Glover and said that she would “sleep with
anyone.”
23. Any time Ms. Glover ran into a co-worker at a public location outside of work
(e.g. the gym or grocery store), Ms. Glover would hear rumors the following day that she was
sleeping with that co-worker. These rumors forced Ms. Glover to find a different gym to work
out at, as well as frequent grocery stores further from her home in an effort to stop the rumors.
ORIGINAL COMPLAINT
5
24. While in a work carpool, Cody Wells, a fellow SPO, exposed his genitals to Ms.
Glover and propositioned her for sex. Ms. Glover denied him, but no longer felt safe
participating in the carpool and elected to drive on her own from then on. This sparked backlash
from other members of the carpool group, who were unaware of what had happened.
25. Another SPO showed a picture of a faceless, topless woman to Ms. Glover’s co-
workers and falsely claimed it was Ms. Glover and that she had slept with him.
26. In or around October 2017, Ms. Glover received an award for employee of the
quarter. As she went up to receive her award, a male SPO shouted “Who’d you sleep with to get
that?” Ms. Glover’s supervisor, the coordinator, was present and heard the SPO, yet did nothing.
Ms. Glover identified the SPO who made the comment and reported his identity and the incident
to management, but management did nothing and the employee was not disciplined.
27. Ms. Glover’s photograph was removed from the employee of the quarter award
plaque on a weekly basis. Despite Ms. Glover’s complaints, management ignored this
harassment and did nothing to investigate. The only action taken was to replace the photograph
again and again.
28. The sexual harassment of Ms. Glover continued to be routine and undeterred by
management. Without any appropriate action, the harassment and discrimination only became
more intense and horrific.
29. In November 2017, Ms. Glover was the victim of a violent sexual assault while at
the workplace. During a force-on-force training, Ms. Glover was attacked by multiple SRT
members, referred to here as “John Does 1-5”. While Ms. Glover was handcuffed for her role in
the training, two of the SRT members picked up Ms. Glover’s rifle and hit her in the face,
busting her lip and causing it to bleed. They then grabbed and squeezed her buttocks and groin
ORIGINAL COMPLAINT
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and violently flipped her over. When she was on her back, handcuffed and bleeding, the SRT
members forced their hands under her vest, shirt, and bra and grabbed her breasts with such force
that her nipple piercing ripped and began bleeding. Because of the smoke machine used in the
training, Ms. Glover was not able to see the faces of the SRT members who assaulted her—but
she did identify one with a full sleeve tattoo on his arm.
30. Reflecting the culture of harassment at the workplace, male SPOs and SRT
members came up to Ms. Glover after the attack and made snide remarks. They asked her “hey,
what happened during the training?” and smirked at her. It was evident from their comments that
other SPOs and SRT members knew that Ms. Glover had been sexually assaulted, that the sexual
assault was premeditated, and that the SRT perpetrators were bragging about it to their co-
workers. One SRT member called Ms. Glover a “whore” to her face.
31. Human Resources conducted a three-week investigation of the incident. They
interrogated Ms. Glover for three hours and asked irrelevant questions about her time outside of
work and her personal life—portraying her as someone who “asked for it” because she was an
attractive single woman working in a male-dominated profession.
32. When Ms. Glover told one of the investigators about the comments one SPO had
made, he said, “Really? That’s so sad, he’s my bud.” Another manager, Mr. McCree, told Ms.
Glover, “This is what happens when you work in a man’s field.”
33. During and following the investigation, Ms. Glover was subjected to retaliatory
comments by some SPOs who called her a “snitch,” while other SPOs ostracized her.
34. For example, at a meeting while a Centerra manager was instructing the SPOs to
“treat everyone with respect,” a SPO loudly stated “snitches get stitches.” A member of
ORIGINAL COMPLAINT
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management was present and said nothing. Ms. Glover was present in the meeting, still injured
from the sexual assault.
35. One of Ms. Glover’s co-workers had witnessed the incident and initially agreed to
speak on her behalf. He later recanted after being told by the Deputy-in-Chief that he would be
fired because he had not originally reported the assault. The Deputy-in-Chief did nothing about
the assault itself.
36. At the end of the investigation there were no direct consequences. Upon
information and belief, one SRT member received one day off and another SRT team member
received three days off (neither of whom were one of the two SRT members who had a full
sleeve tattoo on their arm). Upon information and belief, these brief suspensions were for
spreading false rumors about a co-worker—not for the sexual assault. Human Resources refused
to tell Ms. Glover the names of the SRT team members who had assaulted her and continued to
assign her on shifts with SRT team members—any one of whom could have been one of the
perpetrators.
37. In one particular instance, Ms. Glover was scheduled to be posted alone in a tower
with a SRT member for 14 hours—even though it was a member of the SRT who sexually
assaulted Ms. Glover and Centerra was informed that a member of the SRT had sexually
assaulted her. When another SRT member saw the posted schedule, he turned to Ms. Glover and
said “oh, looks like we’ll see *you* tomorrow.” Ms. Glover took this as a threat and called out
to avoid working the shift alone in a tower with an SRT member.
38. Ms. Glover repeatedly raised complaints about the assault that were ignored by
management. Further, Ms. Glover asked to not be scheduled for the same shifts as the SRT
ORIGINAL COMPLAINT
8
members who assaulted her. These requests were repeatedly denied as retaliation for her
complaints about her assault and the harassment and discrimination she faced.
39. The only respite she received was when she decided to “call out” and take a
vacation day to avoid being forced to work with her attackers. Centerra never took any
significant actions to remedy the continued impact that her co-workers’ assault and continued
harassment had on her and her wellbeing.
40. After the investigation by Centerra management, Ms. Glover continued to receive
harassing comments from male SPOs and SRT team members about how “hot” she was,
comments about how multiple SPOs wanted to have sex with her, comments about her breast
size, and comments that she was a “whore.” In response to her complaints, the Lieutenant over
the SRT told Ms. Glover that “boys will be boys.” The Lieutenant did nothing to address the
harassment she faced or discipline the “boys” who sexually assaulted her.
41. Up until the point when SOC took over the contract from Centerra in March 2018,
Centerra failed to provide any remedy to the ongoing and constant discrimination, harassment,
and retaliation against Ms. Glover.
AS AND FOR A FIRST CAUSE OF ACTION FOR A VIOLATION OF

Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §§ 2000e et seq.
(Disparate Treatment Discrimination (Intentional Discrimination) on Account of Sex)
42. Ms. Glover is a member of a protected class and repeats and re-alleges the
allegations contained in the paragraphs above, as if fully set forth herein.
43. The conduct alleged herein violates Title VII of the Civil Rights Act of 1964, as
amended, 42 U.S.C. §§ 2000e et seq., as Centerra has engaged in the practice of discrimination
with respect to the terms and conditions of Ms. Glover’s employment.
ORIGINAL COMPLAINT
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44. Due to Ms. Glover’s sex, Centerra subjected Ms. Glover to discrimination and
discriminatory denial of promotional opportunities for which she was qualified.
45. Ms. Glover’s requests for relief are set forth below.
AS AND FOR A SECOND CAUSE OF ACTION FOR A VIOLATION OF

(Hostile Work Environment)
amended, 42 U.S.C. §§ 2000e et seq., as Centerra has engaged in gender harassment and has
created, maintained, and condoned a hostile work environment towards Ms. Glover.
AS AND FOR A THIRD CAUSE OF ACTION FOR A VIOLATION OF

(Retaliation)
50. Ms. Glover lodged complaints with Centerra regarding the discrimination and
hostile work environment to which she was subjected, and as such, engaged in protected activity
under Title VII.
51. Centerra retaliated against Ms. Glover by, among other things, denying her
requests for shift changes and continued harassment.
amended, 42 U.S.C. §§ 2000e et seq.
ORIGINAL COMPLAINT
10
AS AND FOR A FOURTH CAUSE OF ACTION FOR A VIOLATION OF

Nevada law on Equal Opportunity in Employment, Nev. Rev. Stat. § 613.330 et seq.
(Discrimination on Basis of Sex)
55. The conduct alleged herein violates the Nevada law on Equal Opportunity in
Employment, Nev. Rev. Stat. § 613.330 et seq., as Centerra has engaged the practice of
discrimination with respect to the terms and conditions of Ms. Glover’s employment.
AS AND FOR A FIFTH CAUSE OF ACTION FOR A VIOLATION OF

(Hostile Work Environment)
Employment, Nev. Rev. Stat. § 613.330 et seq., as Centerra has engaged in gender harassment
and has created, maintained and condoned a hostile work environment towards Ms. Glover.
AS AND FOR A SIXTH CAUSE OF ACTION FOR A VIOLATION OF

(Retaliation)
Employment, Nev. Rev. Stat. § 613.340 et seq., as Centerra has engaged the practice of
ORIGINAL COMPLAINT
11
retaliation against Ms. Glover by, among other things, requests for shift changes and continued
harassment in response to her complaints of discrimination and harassment.
AS AND FOR A SEVENTH CAUSE OF ACTION

Battery
63. Ms. Glover repeats and re-alleges the allegations contained in the paragraphs
above, as if fully set forth herein.
64. The conduct alleged herein involved an intentional and offensive touching of Ms.
Glover who did not consent to the touching by John Does 1-5.
65. In addition to individual liability against John Does 1-5, Centerra may be held
liable for the battery of Ms. Glover by a theory of respondeat superior.
AS AND FOR AN EIGHTH CAUSE OF ACTION

Assault
68. The conduct alleged herein involved an intentional harmful or offensive touching
of Ms. Glover who was put in apprehension of such contact by John Does 1-5.
69. In addition to individual liability against John Does 1-5, Centerra may be held
liable for the assault of Ms. Glover by a theory of respondeat superior.
AS AND FOR A NINTH CAUSE OF ACTION

Intentional Infliction of Emotional Distress
ORIGINAL COMPLAINT
12
72. The conduct alleged herein involved intentional or reckless conduct by Centerra
and John Does that was extreme and outrageous. The conduct of Centerra and John Does 1-5
caused Ms. Glover severe emotional distress.
73. In addition to individual liability against John Does 1-5 and Centerra, Centerra
may be held liable for the intentional infliction of emotional distress against Ms. Glover by a
theory of respondeat superior.
AS AND FOR A TENTH CAUSE OF ACTION

Negligent Hiring, Retention, and Supervision
76. Centerra had a duty to protect Ms. Glover from harm resulting from its
employment of supervisors and co-workers that committed assault, battery, and intentional
infliction of emotional distress torts, among others, against Ms. Glover. Centerra breached that
duty by hiring, retaining, failing to train, supervise, or discipline the tortfesors. The conduct of
Centerra proximately caused Ms. Glover significant damages.
PRAYER FOR RELIEF
WHEREFORE, Ms. Glover respectfully requests judgment against Centerra as follows:

A. A judgment declaring that the practices complained of herein are unlawful and in
violation of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §§
2000e et seq.; and the Nevada law on Equal Opportunity in Employment, Nev. Rev.
Stat. § 613.330 et seq.;
ORIGINAL COMPLAINT
13
B. All damages which Ms. Glover has sustained as a result of Centerra’s conduct,
including back pay, front pay, benefits, general and specific damages for lost
compensation, and job benefits she would have received but for Centerra’s
discriminatory practices, and for emotional distress, humiliation, embarrassment, and
anguish;
C. Exemplary and punitive damages in an amount commensurate with Centerra’s
ability and so as to deter future malicious, reckless, and/or intentional conduct;
D. Awarding Ms. Glover the costs and disbursements incurred in connection with this
action, including reasonable attorneys’ fees, expert witness fees and other costs;
E. Pre-judgment and post-judgment interest, as provided by law;
F. That the Court retain jurisdiction over Centerra until such time as it is satisfied that
they have remedied the practices complained of and are determined to be in full
compliance with the law; and
G. Granting Ms. Glover other and further relief as this Court finds necessary and
proper.
Ms. Glover also seeks injunctive relief, including, but not limited to:
H. Training on the subject of employment discrimination for all of Centerra’s
employees;
I. Diversity training for all managers conducted by reputable outside vendors;
J. Supervisory discipline up to and including termination for any supervisor who
engages in unlawful discrimination;
K. Active monitoring of the work areas to ensure compliance with discrimination
policies;
ORIGINAL COMPLAINT
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L. Monitoring by the Court or a federal agency to ensure that Centerra complies with
all injunctive relief; and
Ms. Glover further demands that she be awarded such other and further legal and
equitable relief as may be found appropriate and as the Court may deem just or equitable.
Dated: March 11, 2019 Respectfully submitted,
/s/ Richard S. Segerblom

Richard S. “Tick” Segerblom
Nevada State Bar No. 1010
rsegerblom@lvcoxmail.com
RICHARD SEGERBLOM, LTD.
702 East Bridger Ave.
Suite 520
Las Vegas, Nevada 89101
Telephone: (702) 388-9600
Facsimile: (702) 385-2909
Jay D. Ellwanger (pro hac vice to be filed)

Texas State Bar No. 24036522
jellwanger@equalrights.law
Esha Rajendran (pro hac vice to be filed)
erajendran@equalrights.law
ELLWANGER LAW LLLP
8310-1 N. Capital of Texas Hwy.
Suite 190
Austin, Texas 78731
Telephone: (737) 808-2260
Facsimile: (737) 808-2262
ORIGINAL COMPLAINT
15
UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEVADA
§
§
GUS REDDING, §
§ CIVIL ACTION NO. 2:19-cv-00412
Plaintiff, §
v. §
§ JURY TRIAL DEMANDED
SOC, LLC §
§
Defendant. §
§
ORIGINAL COMPLAINT
Plaintiff GUS REDDING (“Plaintiff” or “Redding”), by and through his attorneys,
ELLWANGER LAW LLLP and RICHARD SEGERBLOM, LTD., brings this action for
damages and other legal and equitable relief from Defendant, SOC, LLC (“Defendant” or
“SOC”), for violations of Title VII of the Civil Rights Act of 1964, Civil Rights Act of 1991
(“Title VII”), 42 U.S.C. §§ 2000e et seq.; Nevada law on Equal Opportunity in Employment,
Nev. Rev. Stat. § 613.330 et seq. (“NRS 613”), and any other cause(s) of action that can be
inferred from the facts set forth herein.
INTRODUCTION
1. This is an action brought by Redding against SOC for retaliating against him for
his participation in an investigation into the sexual assault and harassment of a co-worker.
Redding responded honestly to questions asked of him as part of his employer’s investigation
and submitted his account of events to SOC. In response, Redding faced repeated harassment
from supervisors and co-workers, was placed on administrative leave without good cause, had
his hours reduced, and was prevented from medically retiring despite receiving multiple
independent medical opinions. SOC’s acts of retaliation are in violation of Title VII of the Civil
ORIGINAL COMPLAINT
1
Rights Act of 1964, related state statutes, and any other cause(s) of action that can be inferred
from the facts set forth herein.
2. SOC employs Redding at the Nevada National Security Site (“NNSS”) in
southern Nevada. Redding began his employment at the NNSS on or around July 6, 1998.
Redding continued his employment at the NNSS with SOC after SOC began its management of
the facility on or about March 1, 2018. Redding has been subjected to harassment and retaliation
since SOC has taken over management of the facility.
JURISDICTION AND VENUE
3. This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1331, which
confers original jurisdiction upon this Court for actions arising under the laws of the United
States, and pursuant to 28 U.S.C. §§ 1343(3) and 1343(4), which confer original jurisdiction
upon this Court in a civil action to recover damages or to secure equitable relief (i) under any Act
of Congress providing for the protection of civil rights; (ii) under the Declaratory Judgment
Statute, 28 U.S.C. § 2201; 42 U.S.C. §§ 2000e et seq., as amended, and (iii) 42 U.S.C. §§ 1981 et
seq., as amended.
4. The Court’s supplemental jurisdiction is invoked by 28 U.S.C. § 1367(a), which
confers supplemental jurisdiction over all non-federal claims arising from a common nucleus of
operative facts such that they form part of the same case or controversy under Article III of the
United States Constitution.
5. Venue is proper in this Court in as much as the unlawful employment practices
occurred in this judicial district. Venue is also proper in this Court pursuant to 28 U.S.C. §
1391(b)(1) and (c), in that SOC maintains offices, conducts business and resides in this district.
ORIGINAL COMPLAINT
2
PARTIES
6. Redding is a person who has been aggrieved by SOC’s actions. He is and has
been, at all relevant times, a citizen of the United States of America and is a resident of Clark
County, Nevada.
7. At all relevant times, Redding was SOC’s employee and therefore covered by
Title VII and equivalent state statutes.
8. SOC is a privately owned company headquartered at 1500 Spring Garden Street,
Philadelphia, Pennsylvania 19130. Upon information and belief, SOC employs over five-
thousand (5,000) persons.
9. During all relevant times, SOC has been covered by Title VII and equivalent state
statutes.
10. SOC transacted and continues to transact business in Nevada by, among other
things, employing persons at facilities located within Nevada and within this judicial district.
EXHAUSTION OF FEDERAL ADMINISTRATIVE REMEDIES
11. Redding, who has herein alleged claims pursuant to Title VII and equivalent state
statutes, has timely filed a complaint of discrimination with the Equal Employment Opportunity
Commission (“EEOC”), which constitutes a cross-filing with the Nevada Equal Rights
Commission.
12. On or around February 26, 2019, Redding requested and received his Notice of
Right to Sue letter from the EEOC.
STATEMENT OF FACTS
13. Redding first started working as a Security Police Officer (“SPO” or “Pro Force”)
on or around July 6, 1998 at NNSS. Redding continued working at the NNSS when SOC began
ORIGINAL COMPLAINT
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its management contract of the facility on March 1, 2018.
14. Ms. Jennifer Glover (“Ms. Glover”) was also a SPO who was employed by SOC
at the NNSS. Throughout Ms. Glover’s employment at the NNSS, she was subjected to gender-
based discrimination, sexual harassment, and a hostile work environment in the form of repeated
inappropriate behavior and comments, discriminatory treatment from supervisors and co-
workers, as well as a violent sexual assault. Ms. Glover has her own complaint of discrimination
against SOC pending with the EEOC.
15. Since Redding’s participation in SOC’s investigation into Ms. Glover’s
harassment, discrimination, and retaliation, Redding has suffered routine harassment and
retaliation from supervisors and co-workers, culminating in being put on administrative leave for
approximately six weeks and having his medical retirement denied despite receiving multiple
independent medical opinions supporting his request for a medical retirement.
16. In late 2017, Redding was interviewed by the previous contractor that managed
the NNSS, Centerra Group, LLC (“Centerra”), about a violent sexual assault perpetrated by
Special Reaction Team (“SRT”) members against Ms. Glover. During this interview, Redding
gave an honest and forthright account that supported Ms. Glover’s complaint.
17. Ms. Glover continued to experience harassment, discriminatory treatment, and
retaliation after SOC took over the contract from Centerra in March 2018.
18. For example, on or around June 28, 2018, Ms. Glover and Redding drove a truck
to an outside cooler to grab bags of ice for the day. As Ms. Glover finished loading ice into the
truck, a group of SRT members drove up in a van and blocked Redding’s truck from leaving the
area in an attempt to humiliate and intimidate Ms. Glover and Redding, despite there being
several open parking spaces. Ms. Glover and Redding were forced to sit and wait for the SRT’s
ORIGINAL COMPLAINT
4
to move for approximately 10 minutes while SRT members watched Ms. Glover and laughed at
her.
19. On or around July 16, 2018, Redding submitted a written statement to SOC’s
Human Resources department detailing the events that occurred on June 28, 2018. On or around
August 1, 2018, the Pro Force manager told Redding that no one had received his statement.
20. That same day, Redding went to the Pro Force manager’s office and handed him a
hard copy of the statement. Redding also told the Pro Force manager that “this kind of stuff”
needs to stop, referring to the harassment and intimidation Ms. Glover was experiencing. The
Pro Force manager responded by saying, “You need to be careful what you’re asking for or you
could be opening yourself up to something you don’t want.”
21. On or around August 3, 2018, Redding was working with Ms. Glover at the main
gate. The area lieutenant approached Redding and Ms. Glover and said that he had both of them
“on a matrix.” Upon information and belief, a “matrix” is a random check that requires a SPO to
make an inventory of their gear. Upon information and belief, a “matrix” is randomly assigned
and it is very unlikely that two employees on the same shift would both be put “on a matrix.”
22. This area lieutenant had made previous sexual advances towards Ms. Glover and
the area lieutenant’s brother is also one of Ms. Glover’s harassers.
23. Redding and Ms. Glover took everything out of their bags to comply with the
“matrix,” which was done in front of other personnel in an effort to humiliate Redding and Ms.
Glover.
24. Later that day, the area lieutenant approached Redding with a disciplinary write-
up for not having his gear on at the station. Redding refused to sign the write-up, stating that
many SPO’s do not have their gear on at the station and he had never heard of someone being
ORIGINAL COMPLAINT
5
written up for that. Redding asked the area lieutenant who had issued the write-up. The area
lieutenant responded saying that the Pro Force manager had issued the write-up
25. At approximately 4:00 p.m. the same day, Redding ran into the area lieutenant
again. He told the area lieutenant that he knew what he was trying to do and said, “you’re trying
to retaliate against me because I’m with [Ms. Glover]” and “you’re trying to get me in trouble.”
Redding also said that the area lieutenant needed to “knock this stuff off,” again referring to the
harassment, intimidation, and retaliation Ms. Glover was experiencing.
26. The area lieutenant then changed his story about the “matrix” earlier that day. He
told Redding that the “matrix” was just for Redding and not Ms. Glover. The area lieutenant
denied telling Redding and Ms. Glover that the “matrix” was for both of them, though Redding
clearly heard him say that both of them were on a “matrix.”
27. Around 5:00 p.m. that day, Redding received a call from his union representative
saying that the Pro Force manager was on his way to the test site and they were going to relieve
Redding of his duty because of alleged “threats” he had made to the area lieutenant. Redding was
placed on indefinite administrative leave pending an investigation. Redding did not make any
threats to the area lieutenant.
28. During his six weeks of administrative leave, Redding’s hours were dramatically
reduced, his ability to earn overtime completely cut, and as a result his pay dramatically
decreased. Further, his Human Reliability Program (“HRP”) certification was revoked. Redding
had his photograph circulated throughout SOC’s facilities with a “Stop Order,” warning all
personnel to deny access to Redding and to immediately alert SOC if he was spotted.
29. Other comparator SPOs did not receive this level of discipline. By comparison, on
or about August 9, 2018, a Lieutenant was not performing satisfactorily in training and was sent
ORIGINAL COMPLAINT
6
to headquarters to meet with management. Upon information and belief, during this meeting the
Lieutenant began acting in an erratic enough manner that all the SPOs on site were put on
standby for a possible active shooter situation. On information and belief, the only disciplinary
action taken was to give the Lieutenant the rest of the week off, allowing him to return to his job
on Monday. His gun was not taken away, nor was his security clearance. He was not placed on
administrative leave as Redding was. He did not have his photograph circulated throughout the
facility to warn against his presence at the NNSS.
30. As further evidence of retaliation, in or around January 2019, Redding was seen
by two Physician Assistants and a Physician—who served as the Medical Director at the NNSS
for decades—for chronic neck pain that he had experienced due to the bullet proof vest he was
required to wear for 20+ years as part of his SPO uniform. All three of these medical
professionals recommended that Redding be taken off of SPO duty due to his neck pain, as
required under the Federal medical and physical readiness standards for Protective Force
Personnel under 10 C.F.R. § 1046. SOC not only denied Redding’s medical retirement, but also
terminated the contract of the medical professional who recommended Redding’s medical
retirement.
AS AND FOR A FIRST CAUSE OF ACTION FOR A VIOLATION OF

(Retaliation)
31. Redding is a member of a protected class and repeats and re-alleges the
32. Redding participated in an investigation of the sexual assault of a co-worker and
submitted a statement opposing the continued harassment of a co-worker, and as such, engaged
in protected activity under Title VII.
ORIGINAL COMPLAINT
7
33. SOC retaliated against Redding by, among other things, harassing him, putting
him on administrative leave, and refusing to grant his medical retirement.
amended, 42 U.S.C. §§ 2000e et seq.
35. Redding’s requests for relief are set forth below.
AS AND FOR A SECOND CAUSE OF ACTION FOR A VIOLATION OF

(Retaliation)
36. Redding is a member of a protected class and repeats and re-alleges the
37. Redding participated in an investigation of the sexual assault of a co-worker and
submitted a statement opposing the continued harassment of a co-worker, and as such, engaged
in protected activity under the Nevada law on Equal Opportunity in Employment, Nev. Rev. Stat.
§ 613.340 et seq.
38. SOC retaliated against Redding by, among other things, harassing him, putting
him on administrative leave, and refusing to grant his medical retirement.
Employment, Nev. Rev. Stat. § 613.340 et seq.
40. Redding’s requests for relief are set forth below.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests judgment against Defendant as follows:

A. A judgment declaring that the practices complained of herein are unlawful and in
violation of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §§
2000e et seq.
ORIGINAL COMPLAINT
8
B. All damages which Plaintiff has sustained as a result of Defendant’s conduct,
including back pay, front pay, benefits, general and specific damages for lost
compensation, and job benefits he would have received but for Defendant’s
retaliation, and for emotional distress, humiliation, embarrassment, and anguish;
C. Exemplary and punitive damages in an amount commensurate with Defendant’s
ability and so as to deter future malicious, reckless, and/or intentional conduct;
D. Awarding Plaintiff the costs and disbursements incurred in connection with this
action, including reasonable attorneys’ fees, expert witness fees and other costs;
E. Pre-judgment and post-judgment interest, as provided by law;
F. That the Court retain jurisdiction over Defendant until such time as it is satisfied that
it has remedied the practices complained of and are determined to be in full
compliance with the law; and
G. Granting Redding other and further relief as this Court finds necessary and proper.
Plaintiff also seeks injunctive relief, including, but not limited to:
H. Training on the subject of employment discrimination and retaliation for all of
Defendant’s employees;
I. Supervisory discipline up to and including termination for any supervisor who
engages in unlawful discrimination or retaliation;
J. Active monitoring of the work areas to ensure compliance with discrimination and
retaliation policies;
K. Monitoring by the Court or a federal agency to ensure that Defendant complies with
all injunctive relief; and
ORIGINAL COMPLAINT
9
Plaintiff further demands that he be awarded such other and further legal and equitable
relief as may be found appropriate and as the Court may deem just or equitable.
Dated: March 11, 2019 Respectfully submitted,
/s/ Richard S. Segerblom

Richard S. “Tick” Segerblom
Nevada State Bar No. 1010
rsegerblom@lvcoxmail.com
RICHARD SEGERBLOM, LTD.
702 East Bridger Ave.
Suite 520
Las Vegas, Nevada 89101
Telephone: (702) 388-9600
Facsimile: (702) 385-2909
Jay D. Ellwanger (pro hac vice to be filed)

jellwanger@equalrights.law
Esha Rajendran (pro hac vice to be filed)
erajendran@equalrights.law
ELLWANGER LAW LLLP
8310-1 N. Capital of Texas Hwy.
Suite 190
Austin, Texas 78731
Telephone: (737) 808-2260
Facsimile: (737) 808-2262
ORIGINAL COMPLAINT
10

Glover/Redding Lawsuits

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Glover/Redding Lawsuits

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Case 2:19-cv-00411 Document 1 Filed 03/11/19 Page 1 of 15

UNITED STATES DISTRICT COURT

Plaintiff JENNIFER GLOVER (“Plaintiff”), by and through her attorneys,

that can be inferred from the facts set forth herein.

maintaining a work environment of rampant and vicious gender-based discrimination. Ms.

2. Centerra contracted with the U.S. Department of Energy to provide a range of

other government property and employees.

subjected to harassment, discrimination, and retaliation on the basis of her gender.

JURISDICTION AND VENUE

5. The Court’s supplemental jurisdiction is invoked by 28 U.S.C. § 1367(a), which

United States Constitution.

6. Venue is proper in this Court in as much as the unlawful employment practices

by Title VII and NRS 613.

9. Centerra is a subsidiary of Constellis Holdings, LLC headquartered at 7121

EXHAUSTION OF FEDERAL ADMINISTRATIVE REMEDIES

a complaint of discrimination with the Equal Employment Opportunity Commission (“EEOC”),

which constitutes a cross-filing with the Nevada Equal Rights Commission.

received her Notice of Right to Sue letter.

1, 2018, when Centerra’s contract was terminated.

happens.” Ms. Glover rejected this sexual advance.

pervasive throughout her employment.

pictures on their phones, and distributed them to other male SPOs.

again and again.

more intense and horrific.

31. Human Resources conducted a three-week investigation of the incident. They

attractive single woman working in a male-dominated profession.

Glover, “This is what happens when you work in a man’s field.”

from the sexual assault.

the assault itself.

to avoid working the shift alone in a tower with an SRT member.

harassment had on her and her wellbeing.

and retaliation against Ms. Glover.

AS AND FOR A FIRST CAUSE OF ACTION FOR A VIOLATION OF

allegations contained in the paragraphs above, as if fully set forth herein.

with respect to the terms and conditions of Ms. Glover’s employment.

discriminatory denial of promotional opportunities for which she was qualified.

AS AND FOR A SECOND CAUSE OF ACTION FOR A VIOLATION OF

allegations contained in the paragraphs above, as if fully set forth herein.

AS AND FOR A THIRD CAUSE OF ACTION FOR A VIOLATION OF

allegations contained in the paragraphs above, as if fully set forth herein.

under Title VII.

requests for shift changes and continued harassment.

amended, 42 U.S.C. §§ 2000e et seq.

AS AND FOR A FOURTH CAUSE OF ACTION FOR A VIOLATION OF

allegations contained in the paragraphs above, as if fully set forth herein.

AS AND FOR A FIFTH CAUSE OF ACTION FOR A VIOLATION OF

allegations contained in the paragraphs above, as if fully set forth herein.

AS AND FOR A SIXTH CAUSE OF ACTION FOR A VIOLATION OF

allegations contained in the paragraphs above, as if fully set forth herein.

harassment in response to her complaints of discrimination and harassment.

AS AND FOR A SEVENTH CAUSE OF ACTION

above, as if fully set forth herein.

liable for the battery of Ms. Glover by a theory of respondeat superior.

AS AND FOR AN EIGHTH CAUSE OF ACTION

above, as if fully set forth herein.

liable for the assault of Ms. Glover by a theory of respondeat superior.

AS AND FOR A NINTH CAUSE OF ACTION

above, as if fully set forth herein.

caused Ms. Glover severe emotional distress.

theory of respondeat superior.

AS AND FOR A TENTH CAUSE OF ACTION

above, as if fully set forth herein.

Centerra proximately caused Ms. Glover significant damages.

PRAYER FOR RELIEF

WHEREFORE, Ms. Glover respectfully requests judgment against Centerra as follows:

Stat. § 613.330 et seq.;

discriminatory practices, and for emotional distress, humiliation, embarrassment, and