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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF GEORGIA

ATLANTA DIVISION

DONOVAN CHRISTIE,

 Plaintiff,

v.

ADTALEN GLOBAL EDUCATION, 

INC., WELLSTAR HEALTH 

SYSTEM, INC. 

 Defendants.

Civil Action No.:

AMENDED COMPLAINT FOR DAMAGES

COMES NOW, Plaintiff Donovan Christie (“Plaintiff”), by and through his

undersigned counsel, and files this Complaint for Damages, and shows the Court as 

follows:

I. NATURE OF COMPLAINT

1.

Plaintiff brings this action for damages and reasonable attorney fees for 

Defendant’s violation of his rights under Title VII of the Civil Rights Act of 1964, 

as amended, 42 U.S.C. § 2000e (“Title VII”), and the Civil Rights Act of 1991, 42 

U.S.C. § 1981, et. seq. (“Section 1981”). 

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II. ADMINISTRATIVE PROCEDURES

2.

Plaintiff has fulfilled all conditions necessary to proceed with this cause of 

action under Title VII. Plaintiff filed his charge of discrimination against 

Defendants WELLSTAR HEALTH SYSTEM and ADTALEN GLOBAL 

EDUCATION, INC. (“Defendants”) with the EEOC, and the EEOC issued its 

Notice of Right to Sue on May 8, 2022.

3.

Plaintiff timely filed this action within ninety (90) days of receipt of the Notice 

of Right to Sue from the EEOC.

III. JURISDICTION AND VENUE

4.

Plaintiff invokes the jurisdiction of this court pursuant to 28 U.S.C. §§ 1331 

and 1343, 42 U.S.C. § 1981, and 29 U.S.C. § 261(b)

5.

Defendant Wellstar Health System’s headquarters is located within this 

district, and Adtalen Global Education, Inc. does business within this district. In 

accordance with 28 U.S.C. § 1391 and 42 U.S.C. §1981, venue is appropriate in this 

Court.

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IV. PARTIES

6.

Plaintiff is an African American male citizen of the United States of America, 

and is subject to the jurisdiction of this Court.

7.

At all times relevant Defendants were qualified and licensed to do business in 

Georgia, and at all times material hereto has conducted business within this District. 

8.

Defendants now and at all times relevant hereto, have been a domestic forprofit corporation engaged in an industry affecting commerce. During all times 

relevant hereto, Defendants have employed fifteen (15) or more employees for the 

requisite duration under Title VII. Defendant is therefore covered under Title VII in 

accordance with 42 U.S.C. § 2000e(b).

9.

Defendant Adtalen Global Education, Inc. may be served with process 

through its registered agent at the following address: Triumph Research Specialists 

Agents, Inc., 279 W. Crogan Street, Lawrenceville, GA, 30046, USA.

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10.

Defendant Wellstar Health System, Inc. may be served with process through 

its registered agent at the following address: Leo E. Reichert, 793 Sawyer Road, 

Marietta, GA, 30062, USA.

V. FACTUAL ALLEGATIONS

Plaintiff is an African American (Jamaican Descent) previous employee who, 

during the relevant time period, worked at Defendants as a Preceptor and as

Clerkship Director and Director of Medical Education (DME) for Defendant Adtalen 

Global Education, Inc d/b/a Ross School of Medicine Medical Students at Defendant 

Wellstar site for Clinical Clerkship and Electives as part of a joint employer 

relationship between the two entities.

11.

During Plaintiff’s employment at Defendants, he applied for numerous 

positions in which he was qualified for but was not selected for none of these 

positions. 

12.

For one particular position, Defendants left the position open for several 

months after his application had been submitted, only to fill the position with a 

Caucasian employee who had substantially less experience than Plaintiff. 

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13.

Defendants did not even afford Plaintiff with an opportunity to interview for 

this position or any other position he had applied for. 

14.

In January 2021, Defendants informed Plaintiff that it wanted to change his

reporting relationship so that he reported directly to Defendant Adtalen, in an 

attempt to remove his affiliation with Defendant Wellstar. Plaintiff was assured that 

his salary would remain the same. 

15.

In April 2021, Plaintiff received the updated terms of this contract which 

included a deduction in his pay by $5,000, with no consideration to make the contract 

effective. 

16.

In March 2021, Plaintiff received a notice from Defendant Adtalen that he had 

received a poor review from a student. 

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17.

It was common for preceptors to receive isolated poor reviews from students. 

Chief of Surgery (Caucasian), Chief of Orthopedics (Caucasian), Chief of Family 

Medicine (Caucasian), and Assistant Chief (Caucasian) had all received a poor 

performance review from a student in the past, but none of these professors who 

were similarly situated to him had been terminated. 

18.

On September 9, 2021, Plaintiff submitted a complaint to Defendant Adtalen

Human Resources in which he claimed he was being discriminated against on the 

basis of his race. On September 21, 2021, Plaintiff received a Notice of Termination 

from RUSM “without cause.”

19.

On October 20, 2021, Plaintiff’s termination became effective. Plaintiff was 

never provided with a reason for his termination when asked, and the Employers 

failed to provide any substantive feedback to him. 

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20.

Defendants clearly treated Plaintiff less favorably than it did his comparators 

outside of his protected group. Any reasons for its actions against Plaintiff will be 

seen as pretext. 

VI. CLAIMS FOR RELIEF 

COUNT ONE: RACE DISCRIMINATION IN VIOLATION OF TITLE VII 

21.

Plaintiff re-alleges the preceding paragraphs as if set forth fully herein.

22.

Defendants’ actions in subjecting Plaintiff to ongoing race discrimination 

constitute unlawful discrimination on basis of 

Plaintiff’s race in violation of Title VII.

23.

Defendant willfully and wantonly disregarded Plaintiff’s rights, and its 

discrimination against Plaintiff was undertaken in bad faith.

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24.

The effect of the conduct complained of herein has been to deprive Plaintiff

of equal employment opportunity, and to otherwise adversely affect his status as an 

employee because of his race.

25.

As a direct and proximate result of Defendants’ violation of Title VII, Plaintiff

has been made the victim of acts that have adversely affected his psychological and 

physical well-being. 

26.

Accordingly, Defendant is liable for the damages Plaintiff has sustained as a 

result of Defendant’s unlawful discrimination.

COUNT TWO: VIOLATION OF 42 U.S.C. § 1981

(RACE DISCRIMINATION AND RETALIATION)

27.

Plaintiff re-alleges the preceding paragraphs as if set forth fully herein.

28.

Defendants subjected Plaintiff to discrimination and harassment on the basis 

of his race.

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29.

Defendants’ actions in subjecting Plaintiff to different terms and conditions 

of employment constitutes unlawful discrimination on the basis of race in violation 

of 42 U.S.C. section 1981.

30.

The effect of the conduct was to deprive Plaintiff of economic opportunites, 

and otherwise adversely effect Plaintiff’s status as an employee, because of his race.

31.

As a direct and proximate result of these actions, Plaintiff has been made a 

victim of acts that adversely affected his psychological and physical well being.

32.

As a direct and proximate result of Defendants’ unlawful employment 

practices, Plaintiff has been embarrassed, humiliated and has suffered damage to his

emotional health, and has lost back pay and front pay.

33.

Defendants have willfully and wantonly disregarded Plaintiff’s rights, and 

Defendant’s discrimination against Plaintiff was undertaken in bad faith.

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34.

Defendants chose not to take appropriate remedial steps to prevent or correct 

the harassment.

WHEREFORE, Plaintiff judgment as follows:

(a) General damages for mental and emotional suffering caused by 

Defendants’ misconduct;

(b) Punitive damages based on Defendants’ willful, malicious, 

intentional, and deliberate acts, including ratification, 

condemnation and approval of said acts;

(c) Special damages and/or liquidated damages for lost wages and 

benefits and prejudgment interest thereon;

(d) Reasonable attorney’s fees and expenses of litigation;

(e) Trial by jury as to all issues;

(f) Prejudgment interest at the rate allowed by law;

(g) Declaratory relief to the effect that Defendants have violated 

Plaintiff’s statutory rights;

(h) Injunctive relief of reinstatement, or front pay in lieu thereof, and 

prohibiting Defendantsfrom further unlawful conduct of the type 

described herein; and

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(i) All other relief to which he may be entitled.

Respectfully submitted the 5

th day of August, 2022.

/s/ Jeremy Stephens

Jeremy Stephens, Esq.

Ga. Bar No.: 702063

MORGAN & MORGAN, P.A.

191 Peachtree Street, N.E., Suite 4200

Post Office Box 57007

Atlanta, Georgia 30343-1007

Tel: (404) 965-1682

Email: jstephens@forthepeople.com

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