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)

Request for Meeting with:

Judge Ada Brown

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 20, 2023

Greetings Judge Ada Brown

I apologize in advance for this meeting request, as my initial attempt to meet with the 

Magistrate Judge has been rejected months earlier and I have YET to look in the eyes of an 

actual human in these decision making positions, in over 3 years. 

I am disappointed to have received the Magistrate Judge’s decision to GRANT Motion to 

Dismiss (after 7 months of deliberation on the Magistrate’s behalf) on the Friday evening 

before Father’s Day and the Juneteenth Holiday weekend. 

I hope the fathers in your life had a great weekend.

I hope the African Americans you know were able to celebrate the weekend as well. 

Overview of Magistrate’s Decision

I find that the Magistrate Judge, Rebecca Rutherford did an exceptional job in reviewing the 

case and laying out the general theme, in as favorable a stance as the Defendant could have 

asked for. 

Case 3:22-cv-00594-E-BT Document 75 Filed 06/20/23 Page 1 of 5 PageID 322
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 wish for her to know that I appreciate her giving the summation of her understanding of 

events, her overview was well received and I have no complaints with regards to the thorough 

legal breakdown she delivered. Her recommendation, delivered on June 16th 2023, was 27 

pages. With her legal expertise it took the Magistrate over 7 months while my 24 page 

Amended Complaint was delivered with a 21 day deadline for completion. 

Nonetheless, my issues are more so with her findings, length of time taken to deliver her 

response and ignoring of critical, crucial material that has yet to be recorded on the docket. 

As it has taken our Magistrate Judge, with all her amassed knowledge and dearth of experience 

in employment law, over 7 months to formulate an appropriate response, please be mindful 

that I have only been allowed 14 days to save the Court Case of my life. Please also keep in 

mind that I am not a legal professional, as I have stated repeatedly over the course of the past 

16 months. Again, for the record, I was a healthcare professional. Was. 

After granting the Defendant’s Motion for a More Definite Statement to be delivered as an 

Amended Complaint, I was only given 21 days to comply with and articulate a legally compelling

argument. Had the Magistrate Judge afforded me the same length of time that was taken to 

deliberate on the Defendant’s Motion to Dismiss, I’m sure I would have delivered a more 

serviceable document as an Amended Complaint. 

On the 27th page of the much anticipated document that it took 7 months for our Magistrate 

Judge to deliver (“Recommendation to GRANT” Motion to Dismiss, delivered June 16th 2023), it 

mentioned that I have 14 total days to develop an appropriate response. I am thankful for 

those 14 days and wish to use them wisely. 

I request a meeting with my Judge (The Honorable Judge Ada Brown) to understand my 

options. I wish to state I do not seek legal advice of any sort. If nothing else, I would love to 

shake the hand of a *LIVE, BREATHING HUMAN BEING* before my fate is determined. 

Furthermore, I wish to stress I would like my day in court to prove my case. 

With regards to my case, over the course of One Calendar Year, I have gone from a “Default 

Judgement” to “Case Dismissal”. This has not been properly explained to me, despite my 

questions posed on the docket. 

1. Pending evidence ignored

In her recommendation to GRANT the Motion to Dismiss, Magistrate Judge Rutherford 

mentioned that I should not be allowed to amend my complaint further while IGNORING my 

documented plea on the docket to deliver further evidence in audio form, as transcribed and 

documented in depositions *UNDER OATH* to the Texas Worforce Commission. I asked in 

Case 3:22-cv-00594-E-BT Document 75 Filed 06/20/23 Page 2 of 5 PageID 323
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)

what manner would I be able to deliver such evidence to further my claims and this was never 

answered, rejected, acknowledged nor addressed. I would argue, without the ability to further 

assert my claim, the Magistrate Judge was in ERROR when speaking, factually, on the nature 

and position of my claims. 

It is true that I assert that I was fired WRONGFULLY as RETALIATION while seeking to have 

GENDER DISCRIMINATION investigated. Yet, for the Magistrate Judge to state unequivocally 

that I would have no such claims *ALL WHILE* ignoring further evidence seems, disingenuous at 

best. 

I seek to move towards trial. 

2. Please point to a Financial Document that I have Manipulated

Furthermore, the Magistrate never addressed the fact that the Defendant (Methodist) has yet 

to produce one document that supports their position that I MANIPULATED A FINANCIAL 

DOCUMENT. Not one document. This is what I was wrongfully terminated for. Regardless of 

the claims for retaliation and gender discrimination, please, can someone point to a document

that I manipulated and when I was made aware of such terminable offenses. The Magistrate 

also failed to address the fact that I was never suspended in lieu of investigation, as the 

Defendant’s Company Policy states. I claimed to have been terminated WRONGFULLY, the 

Defendant has yet to show any evidence that they were justified in such actions. 

I seek to move towards trial. 

3. 180 days from when exactly?

While the Magistrate Judge did acknowledge (and reject) my objection to the Defendant’s claim 

that I missed the 180 deadline to file by officially filing on the 181st day, she may have 

overlooked the fact that this 180 days is based off the time it would take a REASONABLE person 

to discover. 

I discovered this *180th day deadline* MONTHS after termination and not on the day I was 

terminated. I would like to note that I also cited a FRCP that states that if the Office of the Clerk 

is closed on the 180th day, the litigant would have the next available business day to file. In my 

case, the Magistrate Judge did not acknowledge that we were being governed during a 

pandemic at the time, as my objection stated. All government, state and local facilities were 

closed at the time. 

I seek to move towards trial. 

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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)

4. The Defendant had a responsibility to meet with me, record my grievance and 

inform the proper agencies. 

By this 180 day logic, what would be the Company’s (Defendant, Methodist) duty in reporting 

my adverse positions regarding Gender Discrimination, Retaliation and Wrongful Termination? 

I reported to the Company President, Vice President, CEO, CFO and others (via email) my claims 

of Gender Discrimination, Wrongful Termination and Retaliation well before the 180th day 

termination date deadline. Did any of these Administrative Professionals have any DUTY to 

report these claims? I have yet been given the opportunity to deliver my incident report to the 

Company, as I was fired before meeting with my requested parties. 

5. How did Methodist (the Defendant) find out about my Default Judgement?

Document 15 on the Docket clearly shows I received a Default Judgement and the case should 

have been over. Document 16 (the very next day) demonstrates awareness by the Defendant. 

How was this possible? Surely this can be explained to me. 

Furthermore, Methodist (the Defendant) feigned ignorance to my then 2 year old claim when 

asking for a More Definite Statement, THEN turned around and presented as their only 

contribution to the evidence in this case, my initial claim to the EEOC, to which we had recently 

concluded in the months prior. In that EEOC Claim, I asked that my claims be filed with all the 

state, federal and local agencies. 

6. The Right to Revise/Amend my Incomplete Claim

Due to the fact that I still had additional evidence to deliver which was ignored on the docket, I 

should have the right to amend my claim further, if nothing else. The Magistrate has informed 

me several times that she can not give legal advice but her recommendation for dismissal has 

aided me greatly in being able to formulate a more comprehensive claim. I thank her dearly. 

For the reasons listed, I seek to move towards trial. 

Because I have seen my case move from Default Judgement to Dismissed in the manner of a 

year. 

Because I have begged and been denied a lawyer 3 times by the Magistrate Judge.

Because I can show (via the docket) that every ACTIONABLE DECISION has benefited the 

Defendant and my last beneficial ACTION came before the Defendant decided to participate

(Default Judgement). 

Because audio evidence that is to be submitted HAS BEEN IGNORED, (which can be seen as a

means of delivery method requested on the docket).

Because the Magistrate Judge has put 14 day stipulations on my responses while giving herself 

over a half year to articulate her proper thoughts. 

Case 3:22-cv-00594-E-BT Document 75 Filed 06/20/23 Page 4 of 5 PageID 325
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 seek to move towards trial. 

Conclusion

Over the course of the 14 days (as instructed), I shall deliver my response(s) to this GRANTING 

of DISMISSAL. 

In the interim, I seek an audience with my Judge, the Honorable Ada Brown. 

Please inform me (and the Defendant, if necessary) of the appropriate date and time. 

I would like to stress, I have been patiently seeking my day in court for over 3 years. As a 

working man, I’m told that the Judicial System is where people like me are supposed to go to 

seek justice. 

I still hold faith in the judicial process and the Dallas County U.S. District Court’s ability to see

Justice administered. 

In my meeting, maybe the Honorable Judge Ada Brown can enlighten me as to how many “pro 

se” litigants make it passed dismissal when Rebecca Rutherford is deliberating. 

As I have been given 14 days (by law) to deliver a response to this recommendation to GRANT 

the Motion to Dismiss, I ask the Honorable Judge Ada Brown to please deliver me an answer on 

my requested meeting within 7 days, so that I can use my remaining 3 days afterwards to 

produce some sort of legal argument comparable and as legally sound as the arguments 

presented by our Magistrate, which took 7 months of patient anticipation. 

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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