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COM PLAINT FOR W OLA TION OF CW IL RIGH TS

(Non.pdsonerComplaint)

NOTICE

FederalRulesofCivilProcedure5.2addressestheprivacyandsectlrityconcernsresultingfrom publicaccessto

electroniccourtfiles.Underthisrule,papersfiledwiththecourtshouldnotcontain:anindividual'sfullsocial

securitynumberorfu11birthdate;thefulnameofaperson knowntobeaminor;oracompletefinancialaccount

number.A filingmayincludeonly:thelastfourdigitsofasocialsecuritynumber;theyearofanindividual's

birth;a'minor'sinitials;andthelastfourdigitsofafinancialaccountnum ber.

Exceptasnotedinthisform,plaintiffneednotsendexhibits,affidavits,p ievanceorwim essstatem ents, orany

othermaterialstotheClerk'sOfficewiththiscomplaint.

InorderforyourcomplainttobeGled,itm ustbeaccompnniedbythefilingfeeoran applicationtoproceedirl

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JAO Jun 23, 2020 Miami

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ProSe15(Rev.12/16)Complaintf0rViolationofCivilRights(Non-prisoner) -- . .- - .-

1. ThePartiestoThisCom plaint

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includetheperson'sjobortitle(ifknown)andcheckwhetheryouarebringingthiscomplaintagainst

them intheirindividualcapacityoroO cialcapacity,orboth.Attach additionalpagesifneeded.

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Page2of6

Case 1:20-cv-22587-RNS Document 1 Entered on FLSD Docket 06/23/2020 Page 2 of 10
ProSel5(Rev.12/16)ComplaintforViolationofCivilRight.s(Non-plisoner) . - - ---

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D. Section 1983allowsdefendantstobefoundliableonlywhentheyhaveactedï'undercolorofacy

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42U.S.C.j1983.Ifyouaresuingundersection1983,explainhow eachdefendantactedundercolor

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federallaw .Attachadditionalpagesifneeded.

lH . Statem entofClaim

Stateasbrieflyaspossiblethefactsofyourcase. Describehow eachdefendantwaspersonallyhwolvedinthe

allegedwrongf'ulaction, alongwiththedatesandlocationsofa1lrelevantevents. Youmaywishtoinclude

furtherdetailssuchasthenam esofotherpersonsinvolvedintheeventsgivingrisetoyourclaim s. D onotcite

any casesorstamtes.Ifmoret11% oneclaim ismsserted,num bereachclaim andwriteashortandplain

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Case 1:20-cv-22587-RNS Document 1 Entered on FLSD Docket 06/23/2020 Page 3 of 10
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Case 1:20-cv-22587-RNS Document 1 Entered on FLSD Docket 06/23/2020 Page 4 of 10
Pro841.5(Rev.12/.16)Com.p.laint-forViolationofCivilRfght.s(Non-prisoner) E .E2....-'E.LZ. -

V.I. Certincationand Closing

UnderFederalRuleofCivilProcedure11,bysigningbelow,lcertifytothebestofmyknowledge,infbrmation,

andbeliefthatthiscomplaint:(1)isnotbeingpresentedforanimproperpurpose,suchastoharass,cause

urmecessarydelay,orneedlesslyincreasethecostoflitigation;(2)issupportedbyexistinglaw orbya

nonfrivolousargumentforerending,modifying,orreversingexistinglaw;(3)thefactualcontentionshave

evidentiary supportor,ifspecificallyso identified,willlikelyhaveevidentiac supportaRerareasonable

opporttmityforfurtherinvestigationordiscovery;and(4)thecomplaintothenvisecomplieswiththe

requirem entsofRule11.

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Case 1:20-cv-22587-RNS Document 1 Entered on FLSD Docket 06/23/2020 Page 5 of 10
l 

Attachment for III. Statement of Claim, C. 

Honorable Judge: 

With all due respect, I would like to share with you the violation of my civil rights I have 

suffered when working at Defense Language Institute Foreign Language Center (DLIFLC) 

between the period April 2011 to May 2012. My wife and I were hired to work in the same 

program, under the supervision of the same boss, Mr. Samir Sallam. Both my wife and I 

had received very good evaluations and feedback for our performance until Mr. Sallam 

started requesting sexual favors from my wife. My wife filed an EEO case in January 2012, 

and I became a protected witness in her case. Then, given the overwhelming discrimination 

and hostile work environment I was experiencing, I also filed an EEO case in April 2012. 

In May 2012, as reprisal, DLIFLC gave me a letter, informing me that my contract was not 

going to be extended for "lack of work" although the institution was internally and 

externally advertising the need to fill various positions for which I had also applied. 

My case (EEOC No. 480-2013-00138X; Agency No. ARPOM12April01562) went to trial 

in April 2014, and a decision in favor of the defendant (DLIFLC) was given on September 

28, 2018. 

I appealed the case (Appeal No. 2019001281) and on January 14, 2020 the Office of 

Federal Operations informed me that I had the right to request and file a Civil Action. 

Below, I am provided a summary of the events. 

1. I started work on April 12, 2011. On my first day, I was greeted by another 

colleague, Ms. MacArthur who showed me around and explained a few things about the 

ProMES program and the institution. My supervisor, Mr. Samir Sallam, I met him a week 

later as he [Sallam] was on temporary duty (TDY). 

2. During that first week, I also met other coworkers from other departments. Thus, 

when Mirtha Kaufman (the coordinator of Resident program) and Tristan Cajar (team 

leader of Distance Learning) found out that I had a Ph.D. in Spanish-American Language, 

Literature and Culture, asked me to help their programs and teach some courses to their 

students. I told them that I was happy to do that, but before they had to request permission 

to my supervisor. Thus, after Sallam' s approval, I was given a schedule to teach in both 

programs, Resident and Distance Learning. 

3. At Salam's arrival to the office, it did not take long to realize that Sallam was 

favoring the two Arabic team members (Tariq Khaitous and Dr. Aloussi) whom he would 

assign as team leaders and have us watched very close. 

4. Things were going on pretty well: I was teaching in various programs, and the 

programs had expressed their content with my work both orally and in writing. 

5. My wife joined the team the first week of June 2011. Mr. Sallam started constantly 

calling my wife to his office, and I realized that my wife became very stressed. Then, my 

wife started telling me that Mr. Sallam was sexually harassing her and that she was afraid 

of him. Thus, I told my wife that if Sallam was going to call her again to see him alone in 

his office, I was going to accompany her. When Sallam realized that, he changed his 

attitude. Sallam ordered the team leader not to allow my wife and me to leave the office, 

even if it were for using the restroom, without asking and getting permission; many times I 

wanted to use the restroom, but because the team leader would disappear and Sallam would 

1 

Case 1:20-cv-22587-RNS Document 1 Entered on FLSD Docket 06/23/2020 Page 6 of 10
not answer my calls, I had to remain seated for hours and wait for permission. This is when 

I realized that Sallam started to police us, using the two Arabic coworkers and specifically 

he started bullying me constantly, not only in private but mostly in public when colleagues 

from our program and/or other programs would be present, such as when Dr. Ali Afshar, 

Dr. Ali Naqib, and Margarita from Distance Learning were present and Sallam -out of 

nowhere- would start yelling at me and scolding me for unknown reasons. If I dared asked 

what was going on, Sallam would burst at me, saying that I had no right to question his 

actions because he was my boss and he had the right to hire or fire me. 

6. Then, one day, Prof. Veronique from the Resident program told me that her 

supervisor Mirtha Kaufman had told Veronique that Sallam had me punished to remain in 

the office and that they could not invite me to teach in their program. Therefore, I would be 

seating all day long and writing the books Sallam was asking me to write: the textbook to 

teach Spanish in an intensive course, a textbook on Latin-American culture, and another 

textbook on Costa Rican culture. 

7. Then, in August 2011, I was sent on TDY with Tariq Khaitous to Ft. Dix, NJ. 

There, I had a very good mission. One day, a four-start general in company of Mr. Rob 

Miltersen came to observe my class. They were very impressed with my class. Also, at the 

end of the mission, the site coordinator, Mr. Jay Strack wrote a letter of appreciation to 

thank me for the work I have done and inform our DLI coordinator for TDYs in that area 

that he [Strack] wanted to have me back teaching at Fort Dix. Additionally, the students 

had written me letters thanking me for the great experience and knowledge they had gained. 

However, at my return to Monterey, CA, I found out that, Mr. Khaitous made up a story 

and told Sallam that my students were complaining about me. When I showed Sallam the 

thank you letters from students and site coordinator, he did not want to hear me, saying that 

he believed Khaitous. 

8. On October 15, 2011, all ProMES team went TDY to Montgomery, AL. The next 

day, Sallam humiliated me in front of the hotel manager. With the excuse to introduce me 

and my wife to the manager, Sallam said "Look at this couple. They are Uliana and Walter. 

Uliana is my best teacher. The bad part is that she got married to this guy. I don't know 

where she found him. No, problem (said Sallam looking at Uliana) I will get back with you 

later and I will fix your problem." We politely listened, smiled, greeted and follow our 

path. I said nothing for courtesy because the Manager does not know me, but I saw that Mr. 

Sall am' s behavior and comments were inappropriate because he was referring to my 

marnage. 

9. On October 17, 2011, after work, the colleagues got to the hotel restaurant for 

dinner. After dinner, the group stayed longer around a glass of wine. At a given time, Mr. 

Sallam asked Eve (a contractor teacher) for a "culin." Then, Projestus (a contractor from 

Tanzania) asked me what is the "culin". I warned Projestus that one must be careful when 

using the word "culin" (the word used by Mr. Sallam) because a "culin" can be a little bit of 

wine into the bottom of a glass or "culin" refers also to the behind/bottom of the person and 

that is why in Spanish one should be careful when using this word. When Projestus 

understood the word, he said in English: "then, give me a culon" or a big drink of wine. All 

laughed and we kept talking as among peers. Projestus said that after this party and 

drinking, Mr. Sallam and the Latina contractor teachers continued the party in a private 

where Projestus was also invited and where he witnessed Sallamar interacting in very 

unprofessional and inappropriate way with the contractor women. 

10. On Tuesday, November 1st, 2011, a few of the colleagues were having dinner. My 

wife Uliana was seating at a table talking to Olga, a Russian contractor instructor (her 

phone number is: 301-641-1357 or email: olga.kras@yahoo.com). I was at the next table 

with another group of colleagues when I saw Mr. Sallam going to the table where Uliana 

2 

Case 1:20-cv-22587-RNS Document 1 Entered on FLSD Docket 06/23/2020 Page 7 of 10
and Olga were talking. I saw that Mr. Sallam was very close to my wife Uliana. I saw that 

Mr. Sallam passed his hand caressing Uliana' s shoulders, hands and kept talking. Then, I 

saw that Sallam took Uliana' s hand in his hand and immediately Sallam gave her a kiss on 

the head. Quickly after, I saw the anxiety in Uliana's face. I do not think that this is an 

Arabic culture, as they are very jealous with their wives. 

11. On Saturday, November 16, at 3 p.m., Uliana met with Mr. Sallam in the elevator 

and seeing her, he asked, "Where is Walter?" Uliana replied, "He is in the room cooking." 

Then, Mr. Sall am said to her, "Yes, put him to work because this man doesn't do anything." 

In fact, I do not think that this had be Sallam' s concern because this is my private life and 

Sallam had no right to get into my private relationship with my wife. 

12. On Tuesday, October 25, at 9:30 a.m., Mr. Sallam invited Daniel Jimenez (who was 

coordinator of Spanish division) and me to a meeting. There, Sallam accused me that 4 

students had complained about my teaching. Sallam was yelling at me and told me that I 

had to meet with his every day to show him my lesson plans and what I was teaching. 

Again, Sallam started intimidating me and saying that we were in economic recession, that 

the economy was bad, and if I did not do what he asked me, he had the power to hire and 

fire me. The next day, I went to see Mr. Rob Miltersen to see what I could do for the 

students who had complained about me, as Sallam had said. Miltersen said that there was 

no complaint, just 4 students had to be assigned to a different level. This issue was clarified 

a couple of days later, when Colonel Palmer, the site military coordinator sent an email 

stating that there were no complains, it was just that some student had not been properly 

assigned to their level, for which those students had been reassigned and classes had been 

restructured. There, I realized that none of my students were moved, but only students from 

the contractors' courses, and that I had nothing to do with Sallam's made up complaint 

against me. That reaffirmed the idea that Mr. Sallam had me on his target and was looking 

to find any excuse to harm me. 

13. On Sunday, October 30th, I started seeing Sallam and turning into him my lesson 

plans, yet Sallam would just take them make me seat for 30 minutes in silence and then he 

would leave without giving any feedback. A few days later, Sallam said that he did not find 

it any longer necessary for me to turn into him my daily lesson plans. 

14. As my wife and I were assigned to the same car and we did not have the same 

teaching schedule, many times my wife would remain alone in the building until late at 

night waiting for me to come from another side of the base. Therefore, I asked Mr. 

Miltersen permission for my wife to join me to the class while waiting for me to finish the 

course. Mr. Miltersen accepted. Yet, some time later, Sallam order that Uliana could not 

accompany me to the other building when I was teaching and that she had to wait for me in 

the office. Given that Sallam was constantly after my wife, Uliana was extremely worried 

to stay there alone. Ashamed with such treatment, my wife and I did not tell Miltersen 

about Sallam's prohibition. 

15. On November 6, 2011, at 6 p.m., Mr. Sallam met with Uliana to tell her that he 

wanted to educate her so that she can advise me because I was going into a wrong direction 

and if so he would not renew my contract; and that she (Uliana) should "remember that the 

economy is bad and it is difficult to lose the job". Very concerned, Uliana told me what Mr. 

Sallam told her, but that she did not know what to answer. Both Uliana and I knew that this 

was Mr. Sallam's judgment to not renew our contracts. This type of labor terror did not 

surprise me because Mr. Sallam did that in other occasions too (as it happened on October 

30 in the lobby of the hotel) when he commented to me that the situation of the economy 

was difficult and if I lose the job it will be tough to find another one. After the meeting 

Sayed Pacha ( our ProMES colleague) concerned, came to ask me what I was doing all that 

time with the boss. 

3 

Case 1:20-cv-22587-RNS Document 1 Entered on FLSD Docket 06/23/2020 Page 8 of 10
16. Overwhelmed with Sallam's constant harassment (listening behind our room door) 

and discrimination, my wife and I asked to be given the opportunity to move to another 

hotel, yet on Sunday, November 6, Sallam called the team leader Nathalie MacArthur and 

told her that we were prohibited to move from the hotel, although Li Zang, another 

colleague of ours was stay at the base hotel. 

17. On Thursday, November 3, at 9:15 am, Sallam called for a meeting. In the meeting, 

Sallam prohibited the team to leave the hotel without his authorization even if it was after 

work hours. Then, Sallam directly attacked my wife and me, alleging that I had used the 

word "culin" and that my wife and I were not team players because we did not spend after 

work time with others. Uliana tried to intervene, but Sallam started yelling at her and 

mocking on her, for which Uliana started crying, and Sallam was yelling even more and 

accusing me that I made Uliana cry. Colleagues tried to intervene, but Sallam started 

yelling at them, too. That was one of the most humiliating moments. 

18. On October 28, 2011, at 6:30 pm, Said Pacha, my coworker came to tell me that 

Sallam called Pacha to tell him that he [Sallam] was not going to renew my contract, that he 

did not like Costa Rica people, that all Costa Rica people have fake degrees, and that he 

[Sallam] was looking for excuses not to renew my contract. 

19. On another occasion, before going to bed, my wife and I decide to take out trash. 

When we got downstairs, Sallam was watching some colleagues belly dancing for him. 

When Sallam saw my wife, he ordered her to dance for him. My wife started shaking, and I 

took her away to avoid any unpleasant situation. 

20. About a week later, while my wife was seating at the cafeteria table with Mina, 

Pacha's wife, Sallam called Pacha's wife and told her that my wife, Uliana was his princess 

and he [Sallam] was in love with her. 

21. We returned to Monterey in December, yet Sallam continued with his constant 

attacks. On January 3, 2012, when I arrived at work, I found a CD on my desk with a note 

"It will help you." The CD had recorded all the November meeting when Sallam yelled at 

me and my wife. A copy of the CD and a transcription can be provided upon request. 

22. Later on, that same morning, January 3rd, 2012, Sallam called me in and handed me 

a 10-day notice of termination. 

23. On January 12, 2012, I met with the Provost, Dr. Fischer who reversed the 

termination letter and initiated investigation on Mr. Sallam for sexual harassment, 

discrimination, and hostile work environment. The internal investigation was carried by Dr. 

Thomas Perry. The report of the investigation was given on May 16, 2020 (ten days after 

my final labor termination) where Sallam is found guilty and removed from the position of 

administrator and transferred to instructor. 

24. On January 12, 2012 at my and my wife's reveal of Sallam's conduct, ProMES 

program is closed and its members transferred to other DLI programs. 

25. On January 13, 2012, I am transferred to Residence Program under the supervision 

of Mirtha Kaufman. As Kaufman and I already knew each other, Kaufman asks me what 

had happened, and my wife told her about the sexual harassment, discrimination, 

retaliation, and hostile work environment we lived under Sallam. 

26. On February 18, 2012, my wife opens an official EEO case based on Sexual 

Harassment and discrimination of National Origin, and I am offered as key witness. 

27. On March 6, 2012, Ms. Kaufman makes up the excuse, alleging that my spouse is 

doing the work for him. 

28. On March 12, 2012, Ms. Sahie Kang (dean of Resident program) tells me that she 

was asked by Dr. Thomas Perry to inform me that I had to meet with Dr. Perry to make a 

declaration for my wife's spouse Sexual Harassment investigation. 

4 

Case 1:20-cv-22587-RNS Document 1 Entered on FLSD Docket 06/23/2020 Page 9 of 10
29. Soon after, as a form of retaliation, Ms. Kaufman assigns Ms. Valoree BatistaMason to observe my classes. 

30. On March 23, 2012, Ms. Kaufman gives me a letter of Mid-point Review where she 

plagiarizes Sallam's letter of Termination. 

31. On April 3rd, 2012, I answer in writing to Ms. Kaufman's Letter of Mid-point 

Review. When I take the rebuttal letter to Ms. Kaufman, she yells at me, verbally offends 

and humiliates me in front of other colleagues, intimidating me that she will call on me Ms. 

Jennifer Amorin from CPAC (human resources). 

32. On April 17, 2012, overwhelmed with the constant abuse, I open an EEO case of 

reprisal and discrimination based on National Origin (EEOC No. 480-2013-00138X; 

Agency No. ARPOM12April01562). 

33. On May I8\ Ms. Kaufman and Ms. Sahie Kang hand me a Letter of Non-Renewal, 

alleging "lack of work". I immediately go online to see if there are any job posts, and I 

apply to various internal and external advertisements within DLIFLC. Between the period 

May pt and May 9th, 2012, seeing that there were several openings and Calls for 

Candidates in various DLIFLC's programs, I met with the deans Mr. Steven Collins, Mr. 

Michael Vezilich, and Ms. Deanna Tovar trying to get a transfer and find a position within 

their Departments. Yet, all the contacted deans told me that they had no open position for 

me, although the positions were active and unfilled. It was clear that, although I have a 

Ph.D. in teaching Spanish language, literature, and culture, they did not want to give me a 

job because they had been instructed not to do so. 

34. On or around May 3th, 2012, through Associate Provost Mr. Steven Collins, I 

requested a meeting with Ms. Betty Leaver who refused to see me, alleging that the 

meeting would not be productive. 

35. Then, I reached out to the Provost, Dr. Donald Fischer requesting a meeting. Dr. 

Fischer alleges lack of time, then traveling and passes the issue to his replacement Mr. Jielu 

Zhao who informed me that the office of the Provost cannot deal with my issue. 

36. Subsequently, I requested a meeting with Commandant Colonel Pick, and the 

Commandant's administrative assistant referred me to the Assistant Commandant, Colonel 

Ryan. At the meeting, Colonel Ryan is accompanied by CPAC representative, Ms. Jennifer 

Amorin and both state "lack of work". Following the chain of command, I asked for 

permission to meet with Commandant Colonel Pick. Yet, Colonel Ryan refused to give me 

permission to meet with the Commandant Colonel Pick. 

37. On May 16, 2012, -six days after my termination- Associate Provost Mr. Jielu Zhao 

sends Mr. Samir A. Sallam a letter of Suspension from Duty where Mr. Sallam is 

suspended for 5 days no pay, and removed from any managerial duties at DLIFLC due to 

the behavior Mr. Sallam showed with Complainant and Complainant's spouse; among 

others, the report states "you [Sallam] conducted yourself unprofessionally and caused a 

demoralizing situation for at least two of your subordinates in a public setting. Making 

unwelcomed physical contact with employees and discussing individual performance 

deficiencies in a group setting are offensive acts that discredit your inability to be an 

effective manager". 

38. In April 2014, the EEOC hearing is held for two day, and the decision is given on 

September 28, 2018. 

39. I appealed the case (Appeal No. 2019001281), and on January 14, 2020 the Office 

of Federal Operations mailed a letter to inform me that I had the right to file a Civil Action. 40 ~ W1~ 1

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