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

Wrongful Termination due to Retaliation and Discrimination

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

Motion of Summary Judgment

Support Document

Willie Lee HavMmeri,

Plaintiff

vs.

Methodist Health Systems,

Defendant

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

The Motion for Summary Judgement is FAIR, LEGALLY SOUND & JUST. (Document 35)

Statement 1:

I maintain that my employment was terminated using false claims of time theft. 

(I have provided the evidence that the claims of time theft were worth further investigating, at the 

minimum.)

Statement 2:

I maintain, and will prepare to prove in a court of law, that this termination of employment using false 

claims occurred to cover up a Formal Complaint made by myself as the Plaintiff, the terminated 

employee. 

This statement is the Summary of my Amended Complaint (Doc. 24). 

Summary Judgment establishes a foundational level of Fact for this case.

Statement 1 is the subject of the Motion for Summary Judgement and must be refuted by MHS in order 

for this Order to be DENIED. 

Statement 2 is what we are set to argue in court under the Amended Complaint charging MHS with 

Wrongful Termination, due to Discrimination & Retaliation. 

Rule 56. Motion for Summary Judgement or Partial Summary Judgement

- Rule 56(b) – Time to File a Motion. Unless a different time is set by local rule or the court 

orders otherwise, a party may file a motion for summary judgement at any time until 30 days 

after the close of all discovery. 

- Rule 56(e) – Failing to Properly Support or Address a Fact. If a party fails to properly support an 

assertion of fact as required by Rule 56(c), the court may: 

(3) grant summary judgment if the motion and supporting materials – including the facts 

considered undisputed – show that the movant is entitled to it; 

Conclusion

According to Rule 56 of the Federal Rules of Civil Procedure, I am well within my rights to request an 

Order of Summary Judgment *at any time* until 30 days after discovery. This Rule also states that 

Case 3:22-cv-00594-E-BT Document 42 Filed 11/22/22 Page 1 of 2 PageID 152
Willie Lee HavMmeri vs Methodist Hospital of Dallas Case No. 3:22-cv-00594-E-BT

Wrongful Termination due to Retaliation and Discrimination

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

failure to address a Fact can lead to the granting of summary judgement. MHS has yet to provide any 

position on whether they refute the evidence I have provided in The Motion For Summary Judgment 

(Doc. 35, Exhibit 1). 

If the MHS position regarding my proposed orders is “We haven’t reached Discovery yet!”, then I would 

like to state that I welcome the beginning of Discovery. MHS can feel free to provide a position on 

anything that I have stated so far during this case for Discrimination & Retaliation. 

By this Rule 56 of the Federal Rules of Civil Procedure, regardless of the timing that MHS prefers to give 

a position, if they can not refute the Facts that this Motion asserts then a Summary Judgment should be 

GRANTED. 

5 Proposed Orders should be considered and granted in damages sought. 

I thank the Courts for their consideration on these matters and I’m looking forward to Justice being 

administered. 

Respectfully submitted, November 22th 2022

By: _____/s/ Willie HavMmeri_________

Willie Lee HavMmeri, self-represented “Pro se”

godcolored@gmail.com

(214) 600-6207

Case 3:22-cv-00594-E-BT Document 42 Filed 11/22/22 Page 2 of 2 PageID 153