Willie Lee HavMmeri vs Methodist Hospital of Dallas (MHS) Case No. 3:22-cv-00594-E-BT

Wrongful Termination due to Retaliation and Discrimination

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

Claims Requiring Relief before the U.S. 

DISCTRICT COURT

U.S. District Court 

Northern District of Texas (Dallas) 

Willie Lee HavMmeri,

Plaintiff

vs.

Methodist Health Systems,

Defendant

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

Assigned Judge: Ada Brown

Magistrate Judge: Rebecca Rutherford

Defendant’s Legal Team: Ogletree Law (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: 05/05/2023

Overview

Below, I, Willie Lee HavMmeri (PLAINTIFF), shall present my FOUR (4) claims to which relief may be 

granted in my case against the Defendant in Court. This Document is an addition to the Amended 

Complaint (Doc. 24). These claims are accompanied by the relief sought for each. The claims are in 

green font. 

Should the Court require any further details for these CLAIMS TO WHICH RELIEF CAN BE GRANTED, I 

implore the Court to give me FURTHER INSTRUCTIONS. Disclaimer, this is NOT a request for legal advice. 

This is a sincere request for instruction, if further detail is needed. 

My Four Claims are as follows:

Case 3:22-cv-00594-E-BT Document 65 Filed 05/05/23 Page 1 of 3 PageID 259
Willie Lee HavMmeri vs Methodist Hospital of Dallas (MHS) Case No. 3:22-cv-00594-E-BT

Wrongful Termination due to Retaliation and Discrimination

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

Four Claims requiring Relief:

1. Claim One: I, Willie Lee HavMmeri (PLAINTIFF), CLAIM to have been WRONGFULLY TERMINATED

via the NARRATIVE that I MANIPULATED FINANCIAL DOCUMENTS. The Defendant did not 

“Suspend, Pending Investigation & Review” (“Company Policy” cited). The Defendant did not 

inform me I was being investigated for stealing time prior to termination. The Defendant 

ignored evidence to the contrary presented during termination. Damages sought from this 

WRONGFUL TERMINATION are not to exceed $3,000,000.00 (Three Million Dollars)

2. Claim Two: I, Willie Lee HavMmeri (PLAINTIFF), CLAIM to have been subject to RETALIATION 

carried out by, and with the documented backing of the Company (DEFENDANT). I FORMALLY 

COMPLAINED to the company March 17th 2020. An investigation that led to my termination 

started March 29th 2020. Presently (May 5th 2023), the Defendant STILL DENIES this 

RETALIATION TOOK PLACE (despite this FACT), on numerous records. This demonstrates

complicity. Damages sought from this RETALIATION are not to exceed $1,000,000.00 (One

Million Dollars)

3. Claim Three: I, Willie Lee HavMmeri (PLAINTIFF), CLAIM to have been the VICTIM of GENDER 

DISCRIMINATION in the forms of: HOURLY ALLOTMENT (31.5 hours), GENDER BIAS (preferential 

treatment based exclusively on GENDER) & HOW CONSEQUENCES WERE METED OUT (based 

exclusively on GENDER). MY TERMINATION AND FULL-TIME HOURS SERVE AS SUFFICIENT 

PROOF of this CLAIM, with further evidence to be provided, if necessary. Damages sought from

this DISCRIMINATION are not to exceed $1,000,000.00 (One Million Dollars)

4. Claim Four: I, Willie Lee HavMmeri (PLAINTIFF), CLAIM to have suffered greatly due to my loss of 

income, and inability to be employed in my work field. Damages sought for LOSS of 

WAGES/HEALTHBENEFITS/PANDEMIC RELIEF/401K to be deemed sufficient when calculated and 

audited. 

I, Willie Lee HavMmeri, state that I AM ABLE TO PROVE all four CLAIMS requiring relief before the Court.

The Defendant must prepare to PROVE, before the Court, their innocence to ANY OR ALL FOUR CLAIMS 

LISTED ABOVE. 

I, Willie Lee HavMmeri, am willing to concede ANY AND ALL MISCELLANEOUS RELIEF shall be deducted 

from total damages AWARDED VIA VERDICT. This is acknowledging that any MISCELLANEOUS RELIEF 

shall be deducted from TOTAL DAMAGES AWARDED via the Defendant being found GUILTY (on ANY or 

ALL CLAIMS) in this U.S. DISTRICT COURT case. 

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Willie Lee HavMmeri vs Methodist Hospital of Dallas (MHS) Case No. 3:22-cv-00594-E-BT

Wrongful Termination due to Retaliation and Discrimination

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

Conclusion 

My termination was WRONGFUL. It was RETALIATION for questioning an unfair bias, due to GENDER.

I am more than a name in the PLAINTIFF section of documents. 

Apologies for my style and manner of writing.

Respectfully submitted, 

May 5th, 2023

By: _____/s/ Willie HavMmeri_________

Willie Lee HavMmeri, self-represented “Pro se”

godcolored@gmail.com

(214) 600-6207

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