1.
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIK'LED IN CLERK'S OFF/CE
ATLANTA DIVISION U.S.D.C. -Atlanta
AIESHA B. CALLAHAN,
]
[
[
]
[
[
NOV f 7 2022
Plaintiff,
KEVIN p WEIMER Ci
By. ~u,J.,,/,. , erk
=~~ Cler;.
v.
EMORY HEALTHCARE, INC., Case 1:21-CV-01367-WMR-JSA
Defendant.
PLAINTIFF'S OBJECTIONS TO JUDGE ANAND'S UNETIDCAL
REPORT AND RECOMMENDATION
Under FRCP 72 and LR 72, Plaintiffobjects to Judge Anand's Unethical
Report, Recommendation ("R&R"), and Final Order. (Doc.105);(106).
DE NOVO REVIEW STANDARD
While reviewing Plaintiff's objections to the R&R, the Court "shall make a
de novo determination of those portions ofthe report or specify those findings or
recommendations to which the objection is made." 28 U.S.C. § 636(b)(1 ).
A District Judge gives "fresh" consideration to those issues to which a party
has made a specific objection. Jeffrey S. v. State Bd. ofEduc., 896, F. 2d 507, 512
(11th Cir. 1990) (quoting H. R. 1609, 94th Cong.§ 2 (1976)).
After conducting a careful review, the Court may accept, reject, or modify
Judge Anand's R&R. See 28 U.S.C. § 636(b)(l); Williams v. Wainright, 681 F.2d
732 (11th Cir. 1982)
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*LIST OF SPECIFIC OBJECTIONS*
1. Judge Anand suppressed relevant facts and arguments from Plaintiff's
Response and Sur-Reply to force a win for Defendant. Although
Defendant abandoned all claims, Judge Anand hid Defendant's loss.
{!!1 Defendant's Motion For Summary Judgment abandoned all ofPlaintiffs
claims by seeking dismissal ofthis case based on "Two Pre-Termination claims"
backed by "inoperable EEOC right-to-sue-notices." Plus, Defendant conceded that
there were "No Genuine Issues of Material Facts." (Doc.88); (Doc. 88-1).
@ Plaintiffopposed based on all "Three claims" supported by the operative
EEOC right-to-sue notice dated March 31, 2021. (Doc.96 p. 1-4); (Doc. 4).
{£1. Defendant again abandoned all claims in its Reply Brief by failing to
oppose all Three claims supported by the operative EEOC right-to-sue notice dated
March 31, 2021. Instead, Defendant maintained there were "No Genuine Issues of
Material Facts" and sandbagged Plaintiffwith new arguments urging Judge Anand
to admit its facts and consider Plaintiffs claims abandoned. (Doc. 101 p.1-4).
{!!l Opposing new arguments, Plaintifffiled a Motion To File a Sur-Reply
(Doc.103) and a Proposed Sur-Reply (Doc.104), yet for the third time, Defendant
abandoned all claims by never opposing the Sur-Reply's arguments.
{!)_ To cover up Defendant's loss, Judge Anand Granted Defendant's Motion
for Summary Judgment; and only Granted Plaintiff's Motion to File the Sur-Reply
(Doc.103) while burying all arguments from the Sur-Reply (Doc.104).
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{11. To strangle Plaintiffwith confusion, Judge Anand's R&R violated the
Summary Judgment Standard by ignoring undisputed facts in the "non-movant's
favor" about Plaintifrs September 10, 2019, Termination, October 10, 2019,
EEOC charge, and the operative EEOC right-to-sue notice dated March 31, 2021.
Plaintiffobjects, noting that the operative charge in this case was filed on
October 10, 2019. PRDF ,r 118. As explained in the analysis below, the
Court finds that assertion to be incorrect. This objection is repeated a
number oftimes; the Court will not repeat its analysis for each objection.
(Doc.I05 p. 12).
{gl To suffocate Plaintiffand kill her case, the R&R contradicts its opinion
that facts were incorrect about Plaintifrs September 10, 2019, Termination,
October 10, 2019, EEOC charge, and the operative EEOC right-to-sue notice dated
March 31, 2021. The R&R threw out the Two Pre-Termination Claims, backed by
inoperable right-to-sue notices, Defendant relied on for Summary Judgment and
based its analysis on the third EEOC charge dated March 31, 2021, which supports
Plaintiff's Pre-Termination and Termination claims, which Defendant abandoned.
Accordingly, Plaintiff's claims based on...Written Warnings are time-
barred, and the remainder of the undersigned's analysis is devoted to
Plaintiff's termination-based claims only. Any "absurdity" in this
outcome is the result ofPlaintiff's decision to file Three overlapping EEOC
charges in rapid succession. (Doc. 105 p. 25).
2. The R&R incorrectly decided that Plaintiff failed to exhaust
administrative remedies with the EEOC regarding her Two Pre-
Termination claims; atl Three claims in her Complaint are timely.
Accordingly, Plaintiff's claims based on...Written Warnings are time-barred,
and the remainder oftheundersigned's analysis is devoted to Plaintiff"s
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Termination-based claims only. Any "absurdity" in this outcome is the result of
Plaintiffs decision to file Three overlapping EEOC charges in rapid succession.
(Doc. 105 p. 25).
Countering the fabricated R&R the case law and facts argued in Plaintiffs
response prove she did not fail to exhaust administrative remedies for any claim
(Doc. 96 p. 2-3). Plaintiff filed an EEOC charge after Defendant reprimanded her
on August 7, 2019. (Plaintiffs Deposition Testimony ("Pl. Dep." Ex. 1-2)).
She filed a second charge after Defendant reprimanded her on September 4,
2019. Id. Ex. 3-4.
Then, after Defendant fired her on September 10, 2019, she filed a third
charge on October 10, 2019. Id. Ex. 5; 23. On the Termination notice, Defendant
lists the August 7 and September 4, 2019, reprimands as justification for firing
Plaintiff, alleging repeated insubordination. Id. For that reason, when Plaintifffiled
the third EEOC charge, she listed Three counts ofdiscrimination and retaliation
regarding the "Two Pre-Termination reprimands" and "Termination" claims Id.
Ex. 5.
The EEOC issued Plaintiff the operative right-to-sue notice dated March 31,
2021 , regarding her "Two Pre-Termination" and "Termination" claims. Pl. Dep.
Ex. 5; (Doc.4); (Doc. 41p.3111). One week later, Plaintifffiled her Complaint
on April 6, 2021, meeting the 90-day deadline. (Doc.I). See 42 U.S.C. § 2000e-
5(f)(l). Therefore, all ofPlaintiffs claims are timely. Because when Defendant
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listed the Two Pre-Termination reprimands dated August 7 and September 4, 2019,
on Plaintiff's September 10, 2019 Termination notice, that restarted the clock for
Plaintiff to file a third EEOC charge on October 10, 2019, about all Three acts.
"A discrete act ofalleged discrimination" triggers its deadline for filing an
EEOC charge. See Abram v. Fulton Cnty. Gov't, 598 F. App 'x 672, 676 (11th Cir.
2015). "A Plaintiffis free to allege in court "not only the specific complaints made
in her EEOC charge" but "any discrimination related to the charge's allegations."
Chanda v. Engelhard/ICC, 234 F.3d 1219, 1225 (11th Cir. 2000)). "The proper
inquiry is whether the complaint is like or related to, or grew out ofthe allegations
contained in the relevant charge..." Kelly v. Dun & Bradstreet, Inc. , 557 F. App'x
896, 899 (11th Cir. 2014) (internal citation omitted).
3. Judge Anand's Order Granting Defendant's Motion and Granting
Plaintiffs Sur-Reply is contradictory to the law. (Doc. 105 p. 19).
Based on Judge Anand's precedence, Defendant is not entitled to Summary
Judgment. Because Defendant failed to file an opposition to Plaintiff's Sur-Reply,
(Doc. 104); therefore, it conceded to all arguments regarding all Three claims
argued in the Sur-Reply. "Failure to respond to the opposing party's Summary
Judgment arguments regarding a claim constitutes an abandonment ofthat claim
and warrants the entry of Summary Judgment for the opposing party." Burnette v.
Northside Hosp., 342 F. Supp. 2d 1128, 1140 (N.D. Ga. 2004). See also Callahan
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v. Emory Healthcare., 1:18-CV-4856-WMR-JSA, Doc. 94 p. 2-35; 28-85 (Doc. 94
p. 61) (N.D.Ga.2018). Judge Anand should have Granted Judgment to Plaintiff.
4. Judge Anand abused bis discretion by Granting Defendant's Motion
without deciding whether Plaintiff adequately pleaded Three enjoined
discrimination and retaliation claims. The order is unclear whether the
R&R dismissed this case with or without prejudice.
Plaintiffs Complaint uses the terms "interference" and "retaliation"
interchangeably because she understands them to be the same. See (42 U.S.C §
12203 - Prohibition against retaliation and coercion). Plaintiffmaintains that her
Complaint contains Three enjoined claims ofdiscrimination and retaliation.
In contrast, Defendant argues that Plaintiff's Complaint only references
retaliation/interference claims; Judge Anand's order does not resolve this dispute.
...the Court assumes (without deciding) that Plaintiffhas asserted claims
under all Three theories, and thus the undersigned RECOMMENDS that
Defendant's Motion for Summary Judgment [88] be GRANTED. (Doc. 105
p. 19)
Judge Anand's decision not to decide the claims ofthis case while still Granting
Summary Judgment to Defendant on undecided claims is highly abusive.
Before Defendant moved for Judgment, Plaintiff showed the Court that
Defendant knew her claims were about discrimination and retaliation. At her
deposition, Defendant's counsel asked Plaintiffto clarify whether her claims were
about discrimination or retaliation; Plaintiffexplained that all Three claims were
about both. Pl. Dep. 108:4-25; 109:1-25; 110:1-25. To reclarify, she filed a Motion
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to amend her Complaint; Judge Anand denied it and her Motion for
reconsideration (Doc. 84). IfDefendant moved for Summary Judgment, the Court
urged Defendant to address the facts and theories ofthe Complaint. Id. But when
Defendant filed its Motion for Summary Judgment, it still argued that Plaintiffs
claims were only about retaliation.
Like the norms ofthis Court, Judge Anand should have allowed Plaintiff at
least one chance to amend her Complaint. Because as argued in her Response to
Defendant's Motion (Doc. 96 p. 2-3), "prose pleadings are held to a less stringent
standard than pleadings drafted by attorneys and will, therefore, be liberally
construed." Tannenbaum v. United States, 148 F.3d 1262, 1263 (11th Cir. 1998).
In review, "a [pro se] must be given at least one chance to amend the
complaint before the district court dismisses the action with prejudice..." Silberman
v. Miami Dade Transit, 927 F.3d 1123, 1132 (11th Cir. 2019) (internal citations
omitted). The Court "must look beyond the labels offilings by pro se plaintiffs to
interpret them under whatever statute would provide relief." Wilkerson v. Georgia,
618 F. App'x 610, 611 (11th Cir. 2015) (alterations omitted).
5. In contrast to the R&R, Plaintiff established a pretext for
discrimination and retaliation by showing that Defendant had no valid
reason for targeting her, assigning her a new job, or reprimanding her
twice to justify firing her.
Judge Anand buried more facts by determining that Plaintiffcannot establish
a pretext for discrimination or retaliation:
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Plaintiffhas failed to establish that Defendant's purported reason for
terminating her- insubordination-was pretextual. Thus, even ifthe Court
were to assume that Plaintiffhad established a prima facie case of
discrimination, her claim would fail like her retaliation claim at the pretext
stage. (Doc. 105 p. 32-33).
Contrary to the R&R while opposing Defendant's Motion, Plaintiff
established that Defendant's insubordination defense is pretextual. (Doc. 96 p. 17-
21 ). To prove pretext, Plaintiffwent deeper than Defendant's superficial proffered
reason-insubordination-because, logically, this case would not exist- ifnot for
Defendant disrupting Plaintiffs accommodations by ''targeting" her and assigning
her a new job. Responding to an interrogatory, Defendant says it handpicked
Plaintiff to work in the utilization review department since it did not need her job
after she stopped volunteering as a Wellness Champion. Pl. Dep. 113:16-22.
Defendant says it reprimanded her twice and fired her in one month for
repeated insubordination since she refused to accept or train for the replacement
job. Id. Ex. 15; 20; 23. Similarly, the R&R concluded--but ignored undisputed
facts favoring Plaintiff--that being a Wellness Champion was not Plaintiff's job; it
was "voluntary," and Defendant alleges it assigned her the new position to replace
voluntary work.
De Gennaro, stated: Since the Wellness program is a voluntary program and
because the Wellness Champion must participate in the program, Ed
[Lawrence] has accepted your request to no longer perform in this capacity.
However, as you will now have additional capacity within your workday and
because the business needs ofthe facility have grown, Ed has assigned you
additional duties, listed below, to assist in UR. (Doc.105 p.7).
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Simply put, Defendant asserts that ifnot for Plaintiffending her voluntary work as
a Wellness Champion, it would not have assigned her the new job. Id. So,
Defendant concedes that it did not have a legitimate reason to target Plaintiff
because her volunteer work was irrelevant to her essential job functions with
Defendant. She volunteered as a Wellness Champion for Emory University, a
separate company from Defendant. (Plaintiffs Affidavit("AC. Aff."i! 8)).
Wellness Champions pledge to serve for one year; they can quit anytime
without consequence. Id. It is certain, Defendant's insubordination defense is
pretextual. It is--impossible that Plaintiff was insubordinate since Defendant had
no legitimate reason to target her in the first place, which is "sufficient evidence to
create a Genuine issue ofmaterial fact as to whether each ofthe defendant's
proffered reasons is pretextual." Wascura v. City ofSouth Miami, 257 F.3d. 1243
(11th Cir. 2001).
A jury would conclude that Defendant's Wellness Champion and
insubordination defenses--demonstrate "weaknesses, implausibilities,
inconsistencies, incoherencies, or contradictions in [Defendants'] proffered
legitimate reasons for its action that a reasonable factfinder could find them
unworthy of credence."' Jackson v. Ala. State Tenure Comm 'n, 405 F.3d 1273,
1289 (11th Cir. 2005)). Having again proved that Defendant's insubordination and
Wellness Champion defenses are pretextual, the R&R is wrong; it is undisputed
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that Defendant has no valid defenses, which creates a triable issue regarding
Defendant's intent."The Plaintiff will always survive Summary judgment ifhe [or
she] presents circumstantial evidence that creates a triable issue concerning the
employer's discriminatory intent." Smith v. Lockheed-Martin Corp., 644 F.3d 1328
(11th Cir. 2011).
6. The R&R incorrectly determined that Plaintiff showed no direct
evidence to support her claims. (Doc. 105 p. 27).
Plaintiffshowed direct evidence ofdiscrimination and retaliation based on
facts regarding the decision-maker, Melanie De Gennaro, who co-managed
Plaintiff and coordinated all accommodations. ("AC. Aff." ,r 1-3; Ex. A-C).
De Gennaro assigned Plaintiffthe new job in the utilization review
department. Pl. Dep. Ex.15. She regarded Plaintiff as disabled by deciding the new
job she appointed maintained Plaintiff's accommodations. (Melanie De Gennaro's
Declaration ("De Gennaro Dec.") ,r 18; 32). After targeting Plaintiff, De Gennaro
was aware that Plaintiffescalated complaints ofdiscrimination and retaliation to
De Gennaro's superior. (AC. Aff. Ex. 23).
While reprimanding Plaintifftwice and firing her, De Gennaro listed the
event ofPlaintiff escalating complaints to her superior in the timeline on Plaintiffs
September 10, 2019, Termination notice. (AC. Aff. Ex. 23). Nearly one year after
firing Plaintiff, De Gennaro declared she never believed Plaintiffneeded
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accommodations and had poor interpersonal skills instead of mental or physical
impairments. (Id., 4; Ex. D., 37).
These undisputed facts are direct evidence of discrimination because a jury
would conclude that De Gennaro's opinions that Plaintiffhad interpersonal issues
instead of-a mental or physical impairment were not work-related. A Jury would
say De Gennaro regarded Plaintiffas disabled since De Gennaro determined that
the new job would meet Plaintiff's accommodations needs. Likewise, a Jury would
agree that De Gennaro regarded Plaintiff as having a disability when she
reprimanded her twice before firing her, alleging she repeatedly refused to accept
the new job. Because "the employer regarded her as having an impairment...at the
time ofthe alleged discriminatory action...." Adair v. City ofMuskogee, 823 F.3d
1297, 1306 (10th Cir. 2016) (internal citations omitted).
De Gennaro's opinions that she never believed Plaintiffneeded
accommodations, that assigning her the new job was accommodating, and that her
decision to reprimand Plaintifftwice to justify firing her is direct evidence of
discrimination. "Direct evidence of employment discrimination shows, without
inference, that a decision-maker was motivated by illegal reasons, like racial
animus, in doling out an adverse employment decision." Quigg v. Thomas County
School Dist., 814 F.3d 1227, 1236 n.5 (11th Cir. 2016). " "When a plaintiff proves
a case of discrimination by direct evidence, the application of McDonnell Douglas
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is inappropriate," Evans v. McClain ofGa., Inc., 131 F.3d 957, 961--62 (11th Cir.
1997), and the district court may not Grant Summary Judgment "where the non-
movant presents direct evidence that, ifbelieved by the jury, would be sufficient to
win at trial ... even where the movant presents conflicting evidence," Merritt v.
Dillard Paper Co., 120 F.3d 1181, 1189 (11th Cir. 1997).
7. Judge Anand's R&R suppressed all arguments in Plaintiff's Sur-Reply;
the R&R misapplied the law to lie, alleging, Plaintiff could not raise new
arguments in a Reply Brief, but it was Defendant who raised new
arguments in its Reply Brief.
Judge Anand Granted Plaintiffs Motion to File a Sur-Reply as unopposed.
(Doc. 105 p. 19). But the R&R blatantly suppressed every argument in Plaintiffs
Sur-Reply to favor a win for Defendant. Aside from the order Granting the Sur-
Reply, the only other time the R&R mentions it was in passing, in a divisive
footnote on the last page, where the R&R attacks Plaintiff with a flat-out lie.
Plaintiffsuggests in her sur-reply brief that the Court should grant summary
judgment in her favor. Pl. Sur-Reply [104-1] at 8. This is an improper
method of seeking summary judgment. See Henderson v. City ofGrantville,
Ga., 37 F. Supp. 3d 1278, 1285 (N.D. Ga. 2014) ("the Court does not
consider arguments raised for the first time ... in a reply brief'). Moreover,
because Defendant is entitled to summary judgment in its favor, Plaintiff is
obviously not entitled to summary judgment in her favor. (Doc. 105 p. 36.)
Judge Anand's rationale is undoubtedly wrong; it is a flagrant lie. Plaintiffis the
non-movant, so she filed a Sur-Reply opposing the new arguments in Defendant's
Reply Brief. As argued in the Sur-Reply, suppressed by the R&R, Defendant's
Reply Brief contains new arguments urging the Court to admit its facts and
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consider Plaintiff's claims abandoned based on lies alleging she did not oppose its
Motion (Doc.IOI p. 6); (Doc. 103); (Doc. 104 p.1-3).
But Plaintiffopposed the Motion head-on regarding the operative EEOC
right-to-sue notice dated March 31, 2021, supporting Three enjoined
discrimination and retaliation claims in her Complaint (Doc.4; 41 ; 96; 97; 98).
The burden shifted to Defendant; it could not adequately oppose since it
abandoned her claims by filing a Motion seeking Judgment on Two "Pre-
Termination claims" for retaliation backed by inoperable EEOC right-to-sue
notices (Doc. 101 p. 4). The law is clear--"Grounds alleged in the complaint but
not relied upon in Summary Judgment are deemed abandoned." See Resolution
Trust Corp. v. Dunmar Corp., 43 F.3d 587, 599 (11th Cir. 1995) (internal citation
omitted).
Defendant repeatedly abandoned all claims because, like its Motion, its
Reply withheld the relevance ofthe operative EEOC right-to-sue notice dated
March 31, 2021, supporting all Three ofPlaintiff's claims. Instead, the Reply
repeated ideas from its Motion while sandbagging Plaintiffwith new arguments.
After Plaintiff filed a Sur-Reply to Defendant's new arguments, Defendant
abandoned all claims a third time when it did not file opposition arguments to the
Sur-Reply. The law is clear--"Failure to respond to the opposing party's Summary
Judgment arguments regarding a claim constitutes an abandonment ofthat claim
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and warrants the entry of Summary Judgment for the opposing party." Burnette v.
Northside Hosp., 342 F. Supp. 2d 1128, 1140 (N.D. Ga. 2004).
Regarding facts, as argued in the Sur-Reply, suppressed by the R&R, when
Defendant responded to Plaintiff's facts, Defendant conceded many facts by saying
the Court may consider them "when ruling on Defendant's Motion for Summary
Judgment." (Doc.102. ,r 2; 6-8;14-23; 26-27; 32-34;37; 49-51 ; 53-55; 58; 63-64;
66; 80-82; 86-87; 93-95; 101; 103-104; 118-119; 153). Most ofDefendant's
responses are lengthy, argumentative, or irresponsive to the subject of the fact. (Id.
.r 3-5· 28· 31 · 36· 38-40· 42· 47-48· 51 · 56-59· 63· 67-68· 71 · 78-79· 81 · 92-
11 , , , , , , , , , , , , , ,
94;102; 104-105; 119; 127; 139; 149; 151; 152; 153). Several ofDefendant's
responses are so argumentative that it cites case law (Id. ,i 144;165-166).
Some responses refute by using citations from Plaintiff's previous case (Id.,i
72-75), which are not supportive. Because, in Plaintiff's previous case, Judge
Anand decided she failed to oppose Defendant's arguments, admitted Defendant's
facts, and considered her claims abandoned, which are technicalities. See Callahan
v. Emory Healthcare., 1:18-CV-4856-WMR-JSA, (Doc. 94 p. 61) (N.D.Ga.2018),
(Doc. 94 p. 2-35; 28-85); (Doc. 94 p. 49; 54-57). Either way, Plaintiffcan use
relevant facts from her last case for new claims. Thus, since Defendant did not
comply with LR. 56.l(B)(3), when responding to Plaintiff's facts or filing an
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opposition to the Sur-Reply, it conceded to all facts; consequently, rather than
hiding the truth, the R&R should have deemed Plaintiffs facts admitted.
In sum--Defendant was done with this case- it strategically moved on from
all claims. Because Defendant's Motion; Reply Brief, and lack of opposition to the
Sur-Reply, concedes that Plaintiffcould defeat its Motion by proving any Genuine
problem exists because it repeatedly proclaims that there are "No Genuine Issues
of Material Facts." (Doc.101 p.l). So there is no way Defendant should have won
because the law is clear-"The court shall grant summary judgment if the movant
shows that there is no genuine dispute as to any material fact and the movant is
entitled to judgment as a matter of law." See FRCP 56 (a).
The lengths Judge Anand went through to sabotage this case prove that he
knew there were no grounds to grant Judgement to Defendant. Plaintiffwon
Judgment for all her claims. As ofnow, the R&R sets the precedence that, like
Defendant, anyone can abandon claims, concede, not once, but Three times and
still win.
As argued, Plaintiffobjects to Judge Anand's unethical R&R.
Respectfully submitted this 17th
day ofNovember 2022.
15
~
Aiesha Callahan, M.A.
Plaintiff, Pro Se
Po Box 54903
Atlanta, Georgia 30308
aiesha.callahan@gmail.com
Case 1:21-cv-01367-WMR Document 107 Filed 11/17/22 Page 15 of 16

16.
CERTIFICATE OF COMPLIANCE
Undersigned below, I certify that the preceding document complies with the
type and margin requirements set forth under LR 5.1, using a font type in Times
New Roman and a point size of 14 counts.
CERTIFICATE OF SERVICE
Undersigned below, I certify that on this 17th
day ofNovember 2022, I filed
the preceding PLAINTIFF'S OBJECTIONS TO JUDGE ANAND'S UNETHICAL
REPORT AND RECOMMENDATION with the clerk and served a copy of the
same via email to Defendant's attorneys as follows:
Lewis Brisbois Bisgaard & Smith LLP.,
John S. Snelling
Email: jsnelling@lbbslaw.com
Toni J. Read
Email: tread@lbbslaw.com
Respectfully submitted this 1~ day ofNovember 2022.
16
Aiesha Callahan, M.A.
Plaintiff, Pro Se
Po Box 54903
Atlanta, Georgia 30308
aiesha.callahan@gmail.com
Case 1:21-cv-01367-WMR Document 107 Filed 11/17/22 Page 16 of 16