Willie Lee HavMmeri, Plaintiff

vs.

Methodist Health Systems, Defendant

Case No. 3:22-cv-00594-E-BT

U.S. District Court Northern District of Texas (Dallas)

Pandemic PRO SE 

Willie Lee HavMmeri, Plaintiff

vs.

Methodist Health Systems, Defendant

Case No. 3:22-cv-00594-E-BT

U.S. District Court Northern District of Texas (Dallas)

Assigned Judge: Ada Brown

Magistrate Judge: Rebecca Rutherford

Defendant’s Legal Team: Ogletree Deakins Nash Smoak & Stewart PC 

(Employment Law Firm – Dallas, Texas) 

Cause: 42:1983 Civil Rights (Employment Discrimination) 

Nature of Suit: 442 Civil Rights: Employment 

Date Filed: 03/14/2022

Today’s Date: June 30, 2023

Greetings Judge Ada Brown

I’ve already drafted my Objections to Recommendation to Dismiss and will submit it sooner 

rather than later. I am currently so far behind on child support and traffic violations that I fear 

going to jail before I get the chance to submit. However, I thank you for the July 7th Deadline. 

I’ve known that the Magistrate Judge would recommend Dismissal since January of this year 

when my Motion for Summary Judgement was dismissed as “Premature” and my Motion to 

Continue was denied with the Magistrate’s only legal advice being summarized as:

If you do in fact, go to jail for your failure to pay child support and traffic violations, please 

submit a change of address with the clerk’s office.” 

Needless to say, the recommendation was not surprising. I just wish it came sooner than 

Father’s Day weekend, as I have been respectfully requesting a decision for 6 months now. 

With that said, I find myself a bit fortunate (or lucky) that the Magistrate Judge failed to actually 

address my termination letter and my claims that the termination in itself was WRONGFUL. 

There has been ZERO PROOF provided by the Defendant that I actually manipulated a financial 

document. I never stole time as alleged on the termination letter and the defense has never 

proven it. 

Case 3:22-cv-00594-E-BT Document 79 Filed 06/30/23 Page 1 of 5 PageID 331
Willie Lee HavMmeri, Plaintiff

vs.

Methodist Health Systems, Defendant

Case No. 3:22-cv-00594-E-BT

U.S. District Court Northern District of Texas (Dallas)

April 0f 2020 – October of 2020 A reminder of a National Disaster 

The world was shaken to a standstill. Nothing would be as it was in 2019 and before. The 

public was placed on stay at home orders. We were given documents stating we were 

“essential workers”, should we be accosted by the police on our drives to work. Hospitals 

implemented “no visitor rules”. Many of the elderly and infirmed died alone in hospitals with 

loved ones unable to even see their final moments. Hospitals would only allow one visitor for 

the birth of children, with new, expecting mothers having to choose between their mothers or 

their children’s father as they delivered a baby. 

The summer of 2020 brought continued “STAY AT HOME/STOP THE SPREAD” orders from the 

government to the public. Zoom calls allowed professionals to work from home. Face to face 

interactions were not only frowned upon but discouraged entirely. 

Public lawlessness grew with the frustrated populace. A man named George Floyd was 

murdered in broad daylight and riots ensued. A major American city, Portland Oregon, was 

taken over for months. Mass death, destruction and inflation ravaged the nation. An 

experimental vaccine was mass produced and pushed on society. 

The great President Trump did all he could to hold the country together. It was an election 

year. His opponent (Biden) campaigned from his basement and would go on to win a 

presidential election that was pivotal in the direction of the country. 

It was during this time of public unrest, government instability and future uncertainty that I was 

unexpectedly fired for stealing time and forced into the position of suing my previous employer 

to clear my good name and receive justice. 3 years later and this attempt at justice has now in 

jeopardy due to deadlines that everyone knows was extremely difficult to keep regarding filing 

paperwork. 

To dismiss this case is to dismiss the notion that Covid-19 and the Pandemic played a significant 

role in how the legal systems were designed to work for a plaintiff like myself. I realize this case 

means more to me than everybody else reading these words but I’m an actual human being 

who has suffered tremendously, thanks to the actions of the Defendant. 

If Covid-19 was the fire that consumed the world for years, then my termination the gasoline 

that ignited and engulfed my life. It could not have come at a worse time. I may never fully 

recover from the magnitude of the careless and heartless actions of the Defendant, Methodist.

Today, as Methodist willfully and intentionally withholds crucial internal emails that vindicate 

my wrongful termination, I now face dismissal for failure to state claims to which relief can be 

granted. 

Case 3:22-cv-00594-E-BT Document 79 Filed 06/30/23 Page 2 of 5 PageID 332
Willie Lee HavMmeri, Plaintiff

vs.

Methodist Health Systems, Defendant

Case No. 3:22-cv-00594-E-BT

U.S. District Court Northern District of Texas (Dallas)

Pandemic Pro Se Litigant 

1.This is the case of my life. This has been the most traumatic experience I’ve ever faced in my 

43 years. I stand before the Court a man who was unexpectedly fired for stealing time right as 

some new virus swept across the nation called Covid-19. 

2.The streets were shut down to non-essential workers. The government facilities were closed 

indefinitely. There were no going into law offices, sitting across from lawyers to look in the 

eyes and plead why you needed their services. Zoom meetings became a thing. Electronic 

Filings started gaining traction. 

3.The world changed around me. The world changed around the Courts. My deadlines 

remained concrete. 

4.To voice the frustrations of seeking legal assistance during such a world altering circumstance 

is an understatement. I cashed out my 401k and paid my mortgage while searching for a lawyer 

via zoom calls. I was denied unemployment by the Defendant (later overturned). I had no 

EEOC nor any other local, federal or state agencies to file claims. There were no one to answer 

phone calls. There was no one to process mail while they worked from home. 

As a litigant who represented himself, pro se, I was told to be patient with the process. This 

could take years, I was told (it has now been over 3 years seeking justice). It took 18 months 

after filing with the EEOC for my case to go from Dallas to Louisiana to San Antonio to finally 

receive a “Right to Sue” to present to the U.S. District Courts. 

5.During the 18 months of “processing” I kept being told that “due to covid...” and “because of 

the shutdowns...” “please be patient as the entire country is dealing with this issue sir.” And 

sure. I was patient. I understood what the country was enduring. 

6.But what about what I’ve had to endure?

7.I clearly engaged in a protected activity and was fired 24 days later. The Defendant has 

provided no evidence that the termination for manipulating financial documents was valid. 

8.I was respectful of the agents that terminated me. I was understanding of the lack of lawyers 

taking clients in person during that tumultuous time in the country. I was understanding that 

the EEOC had not yet processed my mailed in claim by the 180th day. I patiently waited on a 

phone for 6 straight hours to speak with a national operator for the EEOC. I truly understood 

their rebuttals. 

9.Now, as of today, the Magistrate Judge has heard my arguments and the Defendant’s only 

contribution to this case, which was my own submission and decided to grant the Motion to 

Case 3:22-cv-00594-E-BT Document 79 Filed 06/30/23 Page 3 of 5 PageID 333
Willie Lee HavMmeri, Plaintiff

vs.

Methodist Health Systems, Defendant

Case No. 3:22-cv-00594-E-BT

U.S. District Court Northern District of Texas (Dallas)

Dismiss stating that I submitted my initial claim on the 181st day, missing the strict deadline by 

one day. Imagine my frustration. 

10.I’ve already cited the Federal Rules of Civil Procedure’s Rule 6 to which the Inaccessibility of 

the Clerk’s Office must be factored in. The Magistrate did everything possible to excuse away 

this crucial rule but even the Magistrate Judge had to admit: “Even if Rule 6 Applies...” {end 

quote} 

Because, despite efforts stating the opposite, there is no way around the fact that I tried 

everything humanly possible (on my own accord) to state timely claims DURING A HISTORICAL 

NATIONAL CALAMITY (Covid Shutdowns). 

11.It was difficult to find locations to fax documents. It was difficult to pay for printing 

documents with no income source. It’s been difficult to argue a case by QWERTY Keyboard and 

without seeing a real, flesh and blood human being the entire 3 years of trials and proceedings. 

12.I humbly ask the Courts to please consider the impact Covid had on my ability to file timely 

documents, interact with legal professionals and present a well-articulated case before the 

Court. 

Case 3:22-cv-00594-E-BT Document 79 Filed 06/30/23 Page 4 of 5 PageID 334
Willie Lee HavMmeri, Plaintiff

vs.

Methodist Health Systems, Defendant

Case No. 3:22-cv-00594-E-BT

U.S. District Court Northern District of Texas (Dallas)

I move to have my case continue toward trial. I will never let this case go until justice is served. 

Dismissing this case without the Defendant pleading nor providing any evidence to refute my 

claims is not justice. It’s taking advantage of a pro se litigant. 

I assumed that the TWC Mediator, the EEOC Investigator, the Magistrate Judge and now the 

Honorable Judge Ada Brown were the “adults in the room” for these matters of seeking legal 

remedies. I truly thought that if I could just tell the grown ups, the authority figures exactly 

what happened to me and don’t lie or embellish the truth, they (YOU) would be able to sort 

these matters out and “Judge” what is fair. 

As with the previous series of legal proceedings, I keep having to remind everyone that I’m the 

“PLAINTIFF” in this case. I’m the one who has been wronged here. I’m a man that is truly 

standing on the TRUTH and hoping somebody will hear me. 

I look forward to hearing from you and pray that justice prevails. 

Thank you for your patience with me in regards to my limited legal knowledge and 

experience with addressing the Court. 

Respectfully submitted, 

By: _____/s/ Willie HavMmeri_________ 

Willie Lee HavMmeri, self-represented “Pro se” 

godcolored@gmail.com

(214) 600-6207

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