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UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

SAN ANTONIO DIVISION

Rena Michelle Eravi § Civil Action No.:

Plaintiff, §

§

vs. § 5:20-cv-257

§

Gonzales County, Texas §

Defendant. § A Jury Is Demanded

PLAINTIFF’S ORIGINAL COMPLAINT

COMES NOW, Rena Michelle Eravi, Plaintiff, herein, complaining of Gonzales 

County, Texas, Defendant herein, and for cause of action would show the following:

JURISDICTION AND VENUE

1. This case is brought pursuant to Title VII, Civil Rights Act of 1964, as amended, 

42 U.S.C. §2000e et seq. This Court has jurisdiction of this case pursuant to 28 U.S.C. 

§1331.

2. Venue is invoked pursuant to 28 U.S.C. 1391.

PARTIES

3. The Plaintiff, Rena Michelle Eravi, is a female adult resident of the United States 

of America.

4. The Defendant, Gonzales County, Texas, is a state governmental agency located 

in Gonzales, Gonzales County, Texas. Defendant may be served with process upon its 

chief executive officer, Patrick C. Davis, 414 St. Joseph St., Ste. 200, Gonzales, Texas 

78629

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STATEMENT OF FACTS

5. The Defendant is a person who is an employer engaged in an industry affecting 

commerce and who had 500 or more employees for each working day in each of twenty 

or more calendar weeks in the current or preceding calendar year. (42 U.S.C. 2000e(a); 

42 U.S.C. 2003(b)). 

6. The Plaintiff was first employed by the Defendant on or about December 20, 2013

as a detention officer in the Gonzales County Jail at an hourly wage rate of $15.26.

7. Plaintiff was terminated effective September 7, 2018.

8. Plaintiff’s hourly wage rate on the date she was terminated was $20.34.

9. Cynthia Perez and Gracie Crumley were co-workers of Plaintiff.

10. Prior to, but shortly before September 4, 2018 Cynthia Perez advised Gracie 

Crumley of complaints she had about Caesar Martinez’ conduct toward her.

11. Cynthia Perez’ complaints about Caesar Martinez’ conduct consisted, in part, of 

sexual remarks he would make.

12. The Gonzales County Sheriff’s Office’s General Operations Manual directs an 

employee “. . . who believes they have been subjected to sexual harassment files(sic) 

complaints using the appropriate process. Typically, the first complaint is directed to the 

first line supervisor.”

13 Attached hereto as Exhibit “A” is a true and correct page from the Gonzales County 

Sheriff’s Office’ General Operations Manual.

14. The Gonzales County Sheriff’s Office’ General Operations Manual further directs 

“. . . any (emphasis added) supervisor who may receive a complaint of sexual harassment 

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to investigate and resolve such complaint. Failure to do so may result in disciplinary 

action up to the including termination.” 

15. On or about September 4, 2018, Gracie Crumley approached the Plaintiff and

asked for her assistance in proofreading an email she intended to send to her supervisors 

regarding Cynthia Martinez’ complaints about Caesar Martinez’s conduct.

16. Plaintiff agreed to assist Gracie Crumley in proofreading the email she intended to 

send to her supervisors.

17. At 8:23 p.m. on September 5, 2018 Gracie Crumley sent an email to her 

supervisors regarding Cynthia Perez’ complaints about Caesar Martinez’ conduct.

18. Attached hereto as Exhibit “B” is a true and correct copy of the September 5, 2018 

email Gracie Crumley sent to her supervisors.

19. The email Gracie Crumley emailed to her supervisors on September 5, 2018 did 

not state when Cynthia Perez alleged Caesar Martinez made the alleged sexual remarks.

20. At 4:34 a.m. on September 7, 2018, Plaintiff sent an email to James McWhorter, 

her supervisor, regarding the conversation she had with Gracie Crumley on or about 

September 4, 2018.

21. Attached hereto as Exhibit “C” is a true and correct copy of the email Plaintiff sent 

to James McWhorter at 4:34 a.m. on September 7, 2018.

22. Plaintiff’s email to James McWhorter dated September 7, 2018 references a 

second sexual harassment complaint by Cynthia Perez regarding Caesar Martinez’ 

conduct.

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23. Plaintiff’s conduct in emailing James McWhorter regarding Cynthia Perez’ 

complaint about Caesar Martinez’ conduct was in accordance with the policy set forth by 

the Gonzales County Sheriff as set forth in Exhibit “A.”

24. At approximately 6:30 p.m., less than 14 hours after Plaintiff emailed Exhibit “C” to 

her supervisor. she was called in to Lynn Wilburn’s, chief of the jail, office and was 

terminated because she was creating a “ruckus.”

25. In response to Plaintiff’s claim for unemployment insurance benefits the Defendant 

replied that she was terminated for harassing other employees.

26. As a result of Defendant’s response to Plaintiff’s claim for unemployment insurance 

benefits, Plaintiff was denied any benefits.

EXHAUSTION OF ADMINISTRATIVE REMEDIES

27. The Plaintiff timely filed a charge of retaliation she suffered at the hands of the 

Defendant. The EEOC issued a right to sue letter on February 18, 2020, authorizing this 

civil action. Plaintiff received a notice of the right to sue from the EEOC within 90 days of 

the filing of this Complaint. All administrative prerequisites and conditions precedent have 

occurred or been performed.

DISCRIMINATION BY RETALIATION

28. Plaintiff incorporates herein by reference paragraphs 5-30.

29. The Defendant at all times pertinent hereto acted by and through its authorized 

agents, employees and/or representatives.

30. The Defendant’s acts and/or omissions as outlined above discriminated against 

Plaintiff on account that she opposed acts made an unlawful employment practice by 42 

U.S.C. 2000e et seq. Defendant’s retaliation included but was not limited to firing Plaintiff.

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DAMAGES

31. The damages suffered by Plaintiff include lost wages and benefits, as well as 

compensatory damages for the injuries suffered at the hands of the Defendant, including 

but not limited to, mental anguish.

ATTORNEYS’ FEES

32. Plaintiff is entitled to an award of attorneys’ fees, expert fees and allowable costs

under Title VII, 42 U.S.C. §2000e-5(k).

JURY DEMAND

33. The Plaintiff requests a jury trial on all questions of fact raised by Plaintiff’s 

complaint.

RELIEF REQUESTED

The Plaintiff asks this court to enter a judgment:

1. Declaring that the acts and practices complained of in this Complaint are in 

violation of Title VII of the Civil Rights Act of 1964, as amended (42 U.S.C. 2000e et seq.), 

and 29 U.S.C. §2601 et seq.

2. Enjoining and permanently restraining the violations of law;

3. Directing the Defendant to pay the plaintiff actual and compensatory damages that 

she suffered, past and future;

4. Awarding Plaintiff pre-judgment interest on the amounts owed at the maximum rate 

allowed by law;

5. Awarding Plaintiff the costs of this action, together with reasonable attorney’s fees 

and expert witness fees;

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6. Awarding Plaintiff post-judgment interest on the amount of the judgment until paid 

at the maximum rate allowed by law; and

7. Awarding Plaintiff such other relief, legal or equitable, as may be warranted.

Respectfully submitted,

/s/ Oscar H. Villarreal

OSCAR H. VILLARREAL

Texas Bar No.: 20583900

10 Canterview

San Antonio, Texas 78254

(210) 887-5181 Telephone

(210) 698-5364 Telecopier

ohvillarreal@ohvlaw.com

Lead Counsel 

/s/ Ali Hakeem

ALI HAKEEM

Texas Bar No.: 24065354

21022 Gathering Oak

San Antonio, Texas 78260

(210) 899-3631 Telephone

(210) 899-3632 Telecopier

ali@hakeemlaw.com

ATTORNEYS FOR PLAINTIFF

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