NO.

JEFFERSON CIRCUIT COURT

CIVIL DIVISION
JUDGE

LISA CLINTON-GARCES
546 Birchwood Circle
Shelbyville, KY 40065

PLAINTIFF

VS.

COMPLAINT

SHEREE THOMPSON
JEFFERSON COUNTY PUBLIC SCHOOLS
3332 NEWBURG ROAD
LOUISVILLE, KY 40219
JENNIFER CAVE, PRINCIPAL
NOE MIDDLE SCHOOL
121 WEST LEE STREET
LOUISVILLE, KY 40208
AMY DENNES
REGIONAL ADMINISTRATOR
3332 NEWBURG ROAD
LOUISVILLE, KY 40219

DEFENDANTS

*****************************

Comes the Plaintiff, LISA CLINTON-GARCES, and for her cause of action
states as follows:
1. That the Plaintiff, LISA CLINTON-GARCES was a substitute teacher for the
Jefferson County Public Schools while awaiting placement as a teacher in the Jefferson
County Public Schools

2. That Plaintiff had enjoyed her time as a substitute teacher until October 16, 2015
when as a substitute teacher at Noe Middle School, she was placed in the transition class.
A verbal altercation erupted between an a permanent employee at Noe Middle and a
student in the class causing a security officer to be called. The security officer began to
physically assault the student and against the applicable rules and regulations. The
security officer told Lisa to leave the room. Fearing harm would befall the student,
Plaintiff began filming the incident including numerous screams of pain and anguish
from the student.
3. That the student was thereafter physically removed from the class.
4. That upon realizing that Plaintiff had videoed the entire incident, Defendant, Cave
summoned plaintiff to her office; and an assistant principal was present. Defendant,
Cave called Amy Dennes, regional administrator, on her cell phone who threatened
plaintiff that she would never work another day for the Jefferson County Schools unless
she deleted the video. Plaintiff deleted the video in their presence. Or al least thought she
had. Plaintiff had a new phone and instead of immediately deleting the video, the video
was moved to a separate delete file; and is still in existence.
5. That after leaving Noe Middle, Plaintiff became concerned as to the welfare of the
student and as required by law, called child protective services to report the incident
6. That allowing a few days to pass, Plaintiff called Child Protective Services back to
find out what had happened. CPS advised her that they had called Noe Middle and were
advised by the principal that there was nothing had been reported.
7. That soon thereafter, ending on October 27, 2015, plaintiff was called to the office of
defendant, Sheree Thompson, Director of substitute teachers; and without due process

was advised that they had now received three reports as to her being an ineffective
substitute teacher and she was summarily dismissed from ever being a substitute teacher
again for the Jefferson County Public Schools.
8. That the actions of the Defendants violated KRS 61.102, 61.103, et.al. when learning
of plaintiff having reported the assault to an appropriate Agency, retaliated against the
Plaintiff by wrongfully discharging the Plaintiff; and/or retaliated against the Plaintiff by
wrongfully terminating the Plaintiff all in violation of KRS 61.102, 61.103, et.al.. That
plaintiff is blackballed from ever substituting in the Jefferson County School system
which would cause her to never be hired as a teacher by the Jefferson County Public
School; and said information in her personnel file would prevent her from being hired
anywhere as a teacher.
9. That the wrongful actions of the Defendants have prevented her from being employed
as a teacher to date, which may cause the default provisions of her student loans to
accelerate costing the Plaintiff fifteen thousand dollars in damages.
10. That the actions of the Defendant, Cave and Amy Dennes in demanding plaintiff
destroy evidence of wrong doing in order to maintain her employment is a violation of
public policy and caused the wrongful termination of the Plaintiff.
10. That the damages complained of herein exceed the jurisdictional limit of the
Jefferson Circuit Court.
11. That KRS 61.102 and 61.103 et.al. cause punitive damages to be allowed.
Wherefore the Plaintiff, LISA CLINTON-GARCES, demand judgment against
the Defendants, AMY DENNES, REGIONAL ADMINISTRATER, Dr. JENNIFER
CAVE, and SHEREE THOMPSON, jointly and severally liable, as follows:

1. Actual damages that exceed the jurisdictional limit of the Jefferson Circuit
Court,
2. Punitive damages where allowed by law
3. Reinstatement with back pay to be allowed to substitute again and removal
from the blackballed list to be eligible to be a teacher in the Jefferson County
Public Schools and elsewhere
4. Removal of all negative information from her personnel file,
5. Damages for wrongful termination violating public policy,
6. Attorneys fees where allowed by law.
7.

Her court costs herein expended.

8. A trail by jury herein,

9. Any and all other relief to which the Plaintiff, LISA CLINTON-GARCES,
may appear entitled.

______________________________
TEDDY B. GORDON
Attorney for Plaintiff
807 W. Market Street
Louisville, KY 40202
(502) 585-3534

Plaintiff, LISA CLINTON-GARCES states that she has read the allegations of the
foregoing Complaint, and the statements contained herein are true and correct as she
verily believes.

_______________________________
LISA CLINTON-GARCES

SUBSCRIBED AND SWORN to before me by LISA CLINTON-GARCES on

this _____ day of January, 2016
My commission expires:__________________________.

_________________________________
NOTARY PUBLIC, State at Large, KY