IN THE UNITED STATES DISTRICT 

COURT FOR THE NORTHERN

DISTRICT OF FLORIDA

GAINSVILLE DIVISION

PLAINTIFF’S INITIAL DISCLOSURES

(1) State precisely the classification of the cause of action being filed, a brief 

factual outline of the case including plaintiff’s contention as to what defendant did or 

failed to do, and a succinct statement of the legal issues in the case.

Response to Disclosure 1:

As set forth more fully in the Complaint, this is a Title VII action wherein 

Plaintiff, Human Resource Assistant, GS-0203-07, HRMS, at the Gainesville VA 

Medical Center in Gainesville Florida, alleges that he was subjected to discrimination 

based on sex, age, and reprisal when from November 12, 2019, and continuing, it 

required him to perform duties not at his grade. Plaintiff seeks to be placed into a 

TIMOTHY BAILEY,

Plaintiff,

v.

DENIS MCDONOUGH, 

SECRETARY, DEPARTMENT OF 

VETERANS AFFAIRS

Defendant.

Civil Action No. 

1:21-cv-1-MWGRJ

Case 1:21-cv-00001-MW-ZCB Document 29 Filed 12/22/21 Page 1 of 11
position that he would have been but for the Defendant’s alleged discrimination, 

compensatory damages, equitable relief, declaratory, injunctive relief, and any other 

remedies available by law. Specifically, the law requires the federal government to 

make personnel actions, and Plaintiff argues by turn, the workplace, “free from” 

discrimination, which is failed to do, entitling her to relief.

Legal issues:

(1) Whether Department of Veterans Affairs (VA) through Responsible 

Management Officials of (VA) violated Title VII.

(2) Whether VA retaliated in violation of 42 U.S.C. § 2000e-3(a).

(3) Whether Plaintiff is entitled to the relief he seeks and/ or any other relief 

the Court deems appropriate. 

Response to Disclosure 2:

Title VII of the Civil Rights Act of 1964, as amended.

Babb v. Wilkie, 140 S. Ct. 1168, 1171, 206 L. Ed. 2d 432 (2020).

The Plaintiff reserves the right to make use of additional authorities, statutes, 

case law, and judicial decisions, as this case progresses. The above list is not intended 

to be exhaustive.

Case 1:21-cv-00001-MW-ZCB Document 29 Filed 12/22/21 Page 2 of 11
(1) Provide the name and, if known, the address and telephone number of each 

individual likely to have discoverable information that you may use to support your 

claims or defense, unless solely for impeachment, identifying the subjects of the 

information. (Attach witness list to Initial Disclosures as Attachment A.)

Response to Disclosure 3:

See Attachment A. 

(2) Provide a copy of, or a description by category and location of, all 

documents, data compilations, and tangible things in your possession, custody or 

control that you may use to support your claims or defenses unless solely for 

impeachment, identifying the subjects of the information. (Attach document list and 

descriptions to Initial Disclosures as Attachment B.) 

Response to Disclosure 4: 

See Attachment B.

(3) In the space provided below, provide a computation of any category of 

damages claimed by you. In addition, include a copy of, or describe by category and 

location of, the documents or other evidentiary material, not privileged or protected 

from disclosure, on which such computation is based, including materials bearing on 

Case 1:21-cv-00001-MW-ZCB Document 29 Filed 12/22/21 Page 3 of 11
the nature and extent of injuries suffered, making such documents or evidentiary 

material available for inspection, and copying as under Fed.R.Civ.P. 34. (Attach any 

copies and descriptions to Initial Disclosures as Attachment C.) 

Response to Disclosure 5: 

See Attachment C.

(4) Attach for inspection and copying as Fed.R.Civ.P. 34 any insurance 

agreement under which any person carrying on an insurance business may be liable to 

satisfy part or all of a judgment which may be entered in this action or to indemnify 

or reimburse for payments made to satisfy the judgment. (Attach copy of insurance 

agreement to Initial Disclosures as Attachment D.) 

Response to Disclosure 6:

Any such insurance agreements which may exist are in the possession, custody, 

or control of the Defendants.

Case 1:21-cv-00001-MW-ZCB Document 29 Filed 12/22/21 Page 4 of 11
ATTACHMENT A

The following individuals should have knowledge of the facts and 

circumstances surrounding the Plaintiff's allegations in his Complaint and 

Defendants’ Answers and Defenses thereto. The plaintiff reserves the right to 

supplement this list as discovery is completed. 

1. Timothy Bailey (Plaintiff), c/o Plaintiff’s Counsel; Georgia Lawrence of 

Southworth, P.C. 1100 Peachtree Street, NE, Suite 200, Atlanta, GA 30309, 

404-585-8095

2. Elizabeth Shotwell, Section Chief Labor/Employee Relations, GS-13, 

Human Resources Services Management.

3. Sandra Emery, Human Resource Officer, GS-14, North Florida/South 

Georgia Veteran Healthcare System.

4. Patrick Ward, Assistant Human Resources, Officer, GS-13, North 

Florida/South Georgia Veteran Healthcare System.

5. Trina Lyons, VISN 8 Chief of Staffing, GS-14, VHA VISN 8 Network 

Office.

6. Rhonda Kridner, Human Resource Specialist, GS-12, VISN 6 Strategic 

Business Unit.

Case 1:21-cv-00001-MW-ZCB Document 29 Filed 12/22/21 Page 5 of 11
7. Linda Brown, Supervisory Human Resource Specialist, GS-13, Human 

Resources Management Services.

8. Ursula Barlow, Human Resource Specialist, GS-12, Human Resources 

Management Services.

Case 1:21-cv-00001-MW-ZCB Document 29 Filed 12/22/21 Page 6 of 11
ATTACHMENT B

1. Plaintiff’s EEOC Formal Complaint;

2. Documents in the Administrative Record in this Case;

3. Documents concerning damages;

4. Defendant’s correspondence to Plaintiff, and vice versa.

Plaintiff notes that many other documents are relevant to and/or discoverable in 

this case. Plaintiff expects these to come to light during the discovery period of this 

case. Plaintiff reserves the right to alter, add to, or amend this list of documents as 

discovery in this matter progresses, either by amendment to these Initial Disclosures 

or through the identification of the documents in depositions or responses to written 

discovery requests.

Case 1:21-cv-00001-MW-ZCB Document 29 Filed 12/22/21 Page 7 of 11
ATTACHMENT C

Plaintiff has not yet determined the amount of his damages, but makes claims 

for the following categories of damages for which an amount may be calculated:

Lost earning and benefits: Plaintiff seeks back pay and lost benefits in an 

amount equal to what he would have received but for Defendant’s unlawful actions, 

less any interim earnings and benefits. Exact compilation of this amount is subject to 

review of documentary evidence in Defendant’s possession and control.

Compensatory damages: Plaintiff seeks compensation for non-monetary losses, 

including emotional distress. Plaintiff will ask the jury to award an amount of money 

for emotional pain and suffering that will fairly compensate him for the mental pain 

and suffering endured as a result of the unlawful acts of the Defendant. Plaintiff is 

seeking the maximum amount of compensatory damages permitted under the law.

Attorneys’ fees and costs: Should Plaintiff prevail on his claims against the

Defendant, he seeks to recover reasonable attorneys’ fees and reasonable expert 

witness fees together with any and all other costs associated with this action as 

provided by law.

At a mutually convenient time and place, Plaintiff will produce for inspection 

all non-privileged documents in his possession, custody, and control that he contends 

may support his claims for damages. Plaintiff also seeks additional relief as requested 

Case 1:21-cv-00001-MW-ZCB Document 29 Filed 12/22/21 Page 8 of 11
in his Complaint.

Respectfully submitted today,

SOUTHWORTH, P.C.

____________________ 

Georgia Lawrence, Esq.

Georgia Bar No. 270123

Southworth P.C. 

1100 Peachtree Street NE, Suite 

200 

Atlanta, GA 30309 

Phone: (404) 585-8095 

Fax: (404) 393-4129 

georgia@southworthpc.com

Case 1:21-cv-00001-MW-ZCB Document 29 Filed 12/22/21 Page 9 of 11
IN THE UNITED STATES DISTRICT 

COURT FOR THE NORTHERN

DISTRICT OF FLORIDA

GAINESVILLE DIVISION

CERTIFICATE OF SERVICE

I certify that on December 22, 2021, I electronically filed Plaintiff’s Initial 

Disclosures with the Clerk of Court using the CM/ECF system, which will send 

notification of the filing to the following counsel of record:

JASON COODY

ACTING UNITED STATES ATTORNEY

/s/ Herbert S. Lindsey

HERBERT S. LINDSEY

Assistant United States Attorney

Texas Bar No. 00784476

111 North Adams Street

Tallahassee, FL 32301

Tel. 850-942-8430

TIMOTHY BAILEY,

Plaintiff,

v.

DENIS MCDONOUGH,

SECRETARY, DEPARTMENT OF 

VETERANS AFFAIRS

Defendant.

Civil Action No. 

1:21-cv-1-MWGRJ

Case 1:21-cv-00001-MW-ZCB Document 29 Filed 12/22/21 Page 10 of 11
Fax. 850-942-8466

herbert.lindsey@usdoj.gov

Respectfully submitted today,

SOUTHWORTH, P.C.

____________________ 

Georgia Lawrence, Esq.

Georgia Bar No. 270123

Southworth P.C. 

1100 Peachtree Street NE, Suite 

200 

Atlanta, GA 30309 

Phone: (404) 585-8095 

Fax: (404) 393-4129 

georgia@southworthpc.com

Case 1:21-cv-00001-MW-ZCB Document 29 Filed 12/22/21 Page 11 of 11