Saint-Fleur

FACTS AND PROCEDURAL HISTORY

Plaintiff’s Employment and Events Leading to Present Lawsuit Plaintiff was employed by the County of Fresno from 1990 to 2009 in the Department of Children and Family Services. From 1991 to 2009, plaintiff’s particular employment with the County of Fresno was as a licensed mental health clinician. His job classification was “Senior Licensed Mental Health Clinician.” In 2004, plaintiff sought, and was granted, military leave in order to serve as a Chaplain for our Nation’s armed forces in a combat zone overseas in the Middle East. Upon his return in 2008, plaintiff was reinstated by the County of Fresno. However, after his reinstatement, plaintiff was allegedly targeted by his new supervisor, Deputy Director Donna Taylor (Taylor), who purportedly treated plaintiff unfairly or harassed plaintiff. The alleged harassment included allegations by Taylor that plaintiff had engaged in fraudulent billing practices. Taylor conducted an investigation into plaintiff’s billing practices, but plaintiff was not

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2. given an opportunity to respond to the…