PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

KIM PICKRELL; KEITH HENSLEE; §

FALLON LAFLEUR; VYKIM LE; JANE DOE 1; §

and JANE DOE 2, §

 Plaintiffs § CIVIL ACTION NO. 

 § JURY TRIAL DEMANDED

VS. §

 §

COLLIN COUNTY, TEXAS; GREG WILLIS, §

Individually; BILL WIRSKYE, Individually; §

DARRELL HALE, Individually; SUSAN §

FLETCHER, Individually; CHRIS HILL, §

Individually; CHERYL WILLIAMS, Individually; §

and DUNCAN WEBB, Individually §

 Defendants § 

PLAINTIFFS’ ORIGINAL COMPLAINT

AND JURY DEMAND

COME NOW Plaintiffs KIM PICKRELL, KEITH HENSLEE, FALLON LAFLEUR, 

VYKIM LE, JANE DOE 1, and JANE DOE 2 and file this their Original Complaint against 

Defendants COLLIN COUNTY, TEXAS, GREG WILLIS, Individually, BILL WIRSKYE, 

Individually, CHRIS HILL, Individually, DARRELL HALE, Individually, SUSAN FLETCHER, 

Individually, CHERYL WILLIAMS, Individually and DUNCAN WEBB, Individually, and in 

support of their causes of action would respectfully show the following: This is a claim for 

employment discrimination, harassment and retaliation pursuant to Title VII of the Civil Rights

Act of 1964, 42 U.S.C. §§ 2000e to 2000e-17 (“Title VII”), and the Texas Commission on Human 

Rights Act, Texas Labor Code § 21.001 et seq. (the “TCHRA”). Title VII and the TCHRA make 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 2

it unlawful to discriminate against or harass employees because of their gender as well as to 

retaliate for opposing or reporting such conduct. The plaintiffs further present this Original 

Complaint under 42 U.S.C. § 1983, 42 U.S.C. § 1985 sections 2 and 3 and 42 U.S.C. § 1986. 

The Collin County District Attorney’s Office is supposed to be a principled law 

enforcement unit that exhibits irreproachable workplace ethics and a steadfast commitment to 

equal protection under law. Instead, as set forth in the paragraphs below, District Attorney Greg 

Willis treats many female employees as objects that, without their consent, must gratify his sexual 

impulses and personal vanity, while First Assistant Bill Wirskye runs the office as a crass, 

misogynistic fraternity complete with systemic hazing of the County’s attorneys, investigators 

and staff. The Collin County Commissioners, including County Judge Chris Hill have known of 

this misconduct for years but have continued to enable it by refusing to take remedial action or 

even conduct a reasonable investigation. Only in recent weeks has the Commissioners Court 

initiated a review of these charges, but on information and belief, it did so solely for the selfinterested purpose of evaluating Collin County’s legal liabilities arising from the Commissioners 

Court’s acquiescence to the abuses that Mr. Willis and Mr. Wirskye have committed on the 

Plaintiffs in this case and to other employees in the District Attorney’s Office. Collin County, 

through its governance by the Collin County Commissioners Court, as well as through its Human 

Resources Department, aided and abetted the independently elected District Attorney, Greg 

Willis, and his First Assistant Bill Wirskye (Defendants) to deprive Plaintiffs of equal protection 

under the law, discriminated against, harassed and retaliated against them for reasons which 

included, not exhaustively, gender and opposition to their illegal conduct . In furtherance of each 

Defendant’s individual and joint unlawful acts and omissions, the Defendants coerced, censored,

and intimidated those with personal knowledge to deter them from exposing Defendants’ 
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unconscionable abuses, and did so in violation of 42 U.S.C. § 1985 and 42 U.S.C § 1986.

Defendants’ misconduct caused Plaintiffs substantial harm for which Defendants are jointly and 

severally liable. 

I. PARTIES

1. Plaintiff Kim Pickrell is a natural person and citizen of the United States, residing 

in Collin County, Texas. 

2. Plaintiff Keith Henslee is a natural person and citizen of the United States, residing 

in Grayson County. 

3. Plaintiff Jane Doe 1 is a citizen of the United States, residing in Collin County.

4. Plaintiff Fallon LaFleur is a citizen of the United States and resides in Collin

County. 

5. Plaintiff Jane Doe 2 is a citizen of the United States, residing in Collin County.

6. Plaintiff VyKim Le is a citizen of the United States, residing in Dallas County.

7. Defendant Collin County is a governmental entity and may be served with process 

at 2300 Bloomdale Road, McKinney, Texas. 

8. Defendant Greg Willis is the independently elected District Attorney of Collin 

County and may be served at 2100 Bloomdale Road, McKinney, Texas, or wherever he may be 

found.

9. Defendant Bill Wirskye is the First Assistant to the Collin County District Attorney 

and may be served at 2100 Bloomdale Road, McKinney, Texas or wherever he may be found. 

10. Defendant Chris Hill is the Collin County Judge who may be served at 2300 
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Bloomdale Road, McKinney, Texas. 

11. Defendant Darrell Hale is a Collin County Commissioner who may be served at

2300 Bloomdale Road, McKinney, Texas. 

12. Defendant Susan Fletcher is a Collin County Commissioner who may be served at

2300 Bloomdale Road, McKinney, Texas. 

13. Defendant Cheryl Williams is a Collin County Commissioner who may be served 

at 2300 Bloomdale Road, McKinney, Texas. 

14. Defendant Duncan Webb is a Collin County Commissioner who may be served at

2300 Bloomdale Road, McKinney, Texas. 

II. VENUE

15. Venue is proper in this Judicial District pursuant to 28 U.S.C. §1391(b)(2) as a 

substantial part of the events or omissions given rise to Plaintiffs’ claims as detailed above and 

further below occurred in the Northern District of Texas. Additionally, pursuant to 28 U.S.C. 

§1391(b)(1) venue is proper in this Judicial District as at least one Defendant, Bill Wirskye, 

resides in this District at the time of this filing.

III. JURISDICTION

16. This Court has Jurisdiction pursuant to 28 U.S.C. § 1331. This is a discrimination, 

harassment and retaliation case under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 

2000e, et seq. and the Texas Labor Code. Further, this suit is brought for violations of the 

constitutional rights of the Plaintiffs by state actors under 42 U.S.C. § 1983, for conspiring to

deprive Plaintiffs of the equal protection of the laws in violation of 42 U.S.C. § 1985, and for the 

conduct of the state actors who knew of § 1985 violations but neglected and refused to prevent 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 5

said violations under 42 U.S.C. § 1986. 

IV. BACKGROUND FACTS

17. As reinforced by Collin County Human Resources, the elected District Attorney is 

considered “untouchable.” This is not a secret. The power and authority wielded by the District 

Attorney is formidable. This is not just a boss who holds the prosecutors’ and investigators’ jobs 

in his hands, DA Willis has the power to destroy careers in criminal law enforcement and to inflict 

penal resprisal. He can decide who will be investigated, referred for indictment, and criminally 

prosecuted. Such power constrained his victims from exposing his misconduct, or into 

maintaining anonymity when decrying his abuses, until they could no longer suffer silently. 

18. Collin County Government employs more than one thousand employees. The 

District Attorney is required to represent the State of Texas in county and district courts on 

criminal matters as well as to work with law enforcement to investigate criminal matters, 

represent victims of violence in seeking protective orders and finally to represent the state to 

remove children from abusive households. The employees of the District Attorney are paid by 

the County whom the District Attorney represents on behalf of the State of Texas. Both the 

District Attorney, his agents, and Collin County Government are required to provide equal 

protection under the law and provide protection to employees from discrimination, harassment 

and retaliation, just as private sector employers are required to provide.

19. The Office of the District Attorney employs several categories of individuals. The 

Office employs Certified Peace Officers who work exclusively for the District Attorney; they are 

called Investigators. The Office employs licensed attorneys who represent the State of Texas on 

behalf of the elected District Attorney; they are called Assistant District Attorneys and are known 

as “prosecuting attorneys” or “prosecutors.” The Office employs support staff such as secretaries 
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and Victim’s Assistance Coordinators, as well as media specialists among others. 

20. Each Independently Elected Official appoints their own staff. For example, the Collin 

County Sheriff is Independently Elected and employs hundreds of individuals in various roles. 

The District Clerk employs a staff of their own, as do the Tax Assessor, the County Clerk and 

others. The staff are paid by the County. 

21. Chief Kim Pickrell has worked at the District Attorney’s Office since 2006 and has 

occupied the position of Chief Investigator since 2016. Chief Pickrell reported directly to DA 

Greg Willis and is still employed at the DA’s Office to this day. 

22. Deputy Chief Keith Henslee has worked at the District Attorney’s Office since 2002 

and has occupied the position of Deputy Chief Investigator since 2016. Deputy Chief Henslee 

reported directly to Chief Kim Pickrell and is still employed at the DA’s Office to this day. 

23. Jane Doe 1 began in the District Attorney’s Office in 2019 as a receptionist. She 

continued to work at the Collin County District Attorney’s Office in various positions until 

August 2022.

24. Fallon LaFleur began working as a prosecutor in the Collin County District 

Attorney’s Office in 2019. She continued to work as a prosecutor in the District Attorney’s Office 

until 2021.

25. Jane Doe 3 began working as a Community Relations Director in 2020 in the Collin 

County District Attorney’s Office. She reported directly to Greg Willis. She continued to work 

in the District Attorney’s Office until 2021.

26. VyKim Le began working for the Collin County District Attorney’s Office as a 

prosecutor in 2016. She began reporting directly to Greg Willis in 2019. Despite the abuse 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 7

detailed herein she continues to be employed as a prosecutor for the Collin County District 

Attorney’s Office to this day. 

27. In November 2010, Defendant Greg Willis was elected to the office of District 

Attorney (hereinafter referred to as “DA” or “DA Willis”). His first term began on January 3, 

2011. DA Willis is married to a sitting District Judge in Collin County.

28. Between 2011 and 2016, Defendant Willis had several First Assistants. The First 

Assistant is the highest-ranking prosecutor in the office, other than the elected DA. The First 

Assistant generally handles prosecution of capital murder cases, serious felonies, as well as 

ultimate supervision of the attorneys in the office and media inquiries. The First Assistant is 

generally considered the top rank in the attorney “Chain of Command” aside from the DA. 

29. The Office of the District Attorney is considered to be law enforcement. The 

District Attorney represents the State of Texas in criminal matters in Collin County, from the 

Justice of the Peace level to the District Court level. The prosecutors are appointed and are issued 

credentials including a card and a badge. Investigators also carry a card and badge. District 

Attorney’s Offices, like other law enforcement, utilize the “Chain of Command” for solving 

problems and escalating issues. 

30. Each state court is assigned a Prosecution Team to represent the State of Texas in 

criminal matters. Every court has an assigned Chief Prosecutor and generally a “#2 prosecutor” 

and a “#3 prosecutor.” The workload consists of Jury Trials, which are generally set for Mondays 

and Tuesdays, Bench Trials, which are generally set for Thursdays and Fridays, and docket days 

which are generally Wednesdays, Thursdays, and Fridays. In addition to the regular court teams, 

there are special courts that require prosecution staffing. Auxiliary court is one example, which

exists to exclusively deal with plea bargains, protective orders and bond hearings. 
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31. In addition to the staffing of courts with prosecution teams, each prosecution team 

is assigned an Investigator. Investigators are Certified Peace Officers, many of whom have prior 

law enforcement experience. Investigators are required to provide security for the prosecutors 

and witnesses. They carry a badge and a weapon and are required to secure the attendance of 

witnesses for Jury Trials, Bench Trials and Evidentiary hearings. Those duties involve making 

sure the police officers are subpoenaed and appear, making sure civilian witnesses (such as 

victims of domestic violence) are located, subpoenaed and appear, obtaining records of many 

types from various private and public entities, and running TLETS searches. Investigators have 

their own “Chain of Command” in the separate but parallel system to prosecutors. Both ultimately 

answer to the DA.

32. In 2016, Defendant Willis hired Defendant Bill Wirskye into the District Attorney’s 

Office as a prosecutor. He was promoted to First Assistant in January 2017. During this time as 

well as afterwards, Chief Pickrell was reporting directly to Defendant Willis, as well as managing 

the entire Investigator team, the secretarial staff, and the victim’s assistance unit, in addition to 

managing the Crime Victim’s Luncheon and the Tree of Angels events. Chief Pickrell was also 

the point person on a massive software development project called “Foray.” TCOLE training, 

firearms training budget and payroll were also part of Chief Pickrell’s assigned duties. Chief Kim 

Pickrell is responsible for physical security of the entire District Attorney’s Office. Defendant

Wirskye oversaw operations for the entire attorney staff of the District Attorney’s Office. During 

this time, the Commissioner’s Court was comprised of County Judge Chris Hill, Commissioner 

Cheryl Williams, Commissioner Duncan Webb, Commissioner Darrell Hale, and Commissioner 

Susan Fletcher. Cynthia Jacobsen was the Director of Human Resources and Erica Johnson was 

the Assistant Director. 
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33. Once Chief Pickrell began reporting to Defendant Willis, he began to treat her 

differently from male employees. He made repeated unwanted sexual advances at Chief Pickrell, 

as well as routine and unwelcome efforts to flirt with her. In one of her first roles under Defendant

Willis, she accompanied him to a Texas District and County Attorney’s Association (TDCAA) 

conference. As Chief Investigator, Kim Pickrell is Defendant Willis’ head of security. At this 

conference, he requested that Chief Pickrell escort him to a welcome reception along the seawall 

where the attendees of the conference were socializing upon arrival. Chief Pickrell believed this 

request was made to her in her law enforcement capacity and in the performance of her role as a 

security professional. Once she delivered Defendant Willis to the welcome reception, she 

requested permission to briefly leave the reception to call her husband. After Chief Pickrell asked 

for that moment to call her husband, Defendant Willis unexpectedly offered to leave the reception

and accompany her to the hotel. Chief Pickrell was confused by the DA’s offer, since he had 

been at the reception for less than 10 minutes, and she, a security professional, had no need to 

have to have the DA accompany her. Then it dawned on her. DA Willis wanted to be alone with 

her at the hotel for reasons that were not legitimately job-related. This incident was only the 

beginning. 

34. As part of Chief Pickrell’s reporting to Defendant Willis, he required exceptionally 

long meetings on a weekly basis. These meetings sometimes went on for hours and during the 

entirety of the meetings, he required his door to remain closed. During these meetings, Defendant

Willis sometimes moved from the seat behind his desk to sit next to Chief Pickrell in the seats 

facing his desk. This seating arrangement was tight and it caused their knees to touch. On one 

specific occasion, he “needed help” on an electronic document located on his computer and 

invited her over to his computer area. Once she was in place, he began to stroke her hand with 
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his hand. Quite frequently he would give her full frontal body hugs while pressing her breasts 

into his chest, rubbing her lower back with his hands and moaning. He’d often remark about the 

condition of Chief Pickrell’s body, saying he could tell that she “worked out.” Defendant Willis 

told Chief Pickrell how good her body looked, and that he just couldn’t be around her because 

she “looked so good.” On another occasion, he alluded to his own arousal and said that he couldn’t 

sit next to Chief Pickrell anymore because he couldn’t help himself getting excited because she 

looked too good. On multiple occasions, he told her she was beautiful, and that she had beautiful 

eyes. During these extended meetings, there were times Defendant Willis refused to discuss 

business and instead asked personal questions about Chief Pickrell’s family life. The harassment 

and unwanted touching at the computer was typical, but unusual only in that the pretext that there 

was a business purpose, as he told Chief Pickrell expressly that his motive for these meetings was 

“personal, not business” to him. When he saw Chief Pickrell in the hallway, he would sometimes 

ask her to join him in his office. As they walked toward his office, he would position himself to 

look over her shoulder and down at her breasts. While they walked, with his eyes fixated on 

Chief Pickrell’s breasts, he would literally moan. He would often say in these moments, “I’m 

sorry you just look too good” and keep moaning. On another occasion, Defendant Willis chose 

to pull Chief Pickrell into his office from the hall. After doing so, he pulled her body into his, 

pressing her breasts against his chest. He then leaned toward her with his face in an attempt to 

kiss her on the mouth. There was no agenda or official County business to discuss; this was 

simply his way of showing her he could control her and that he would continue to use her as an 

object for his romantic or sexual desires. Chief Pickrell understood that to keep her position as 

Chief Investigator, she would be required to tolerate Defendant Willis’ sexual advances as part 

of his quid pro quo, as well as tolerate his abuse when she did not submit to his advances.
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35. Defendant Willis’ conduct became more threatening once it was clear to him that 

Chief Pickrell was not receptive to his sexual advances or his attempts to flirt with her. He began 

berating and belittling Chief Pickrell so frequently that Chief Pickrell never knew what version 

of Defendant Willis she would get on that day-- he was just as likely to come onto her as he was 

to scream at her. Notably, Defendant Willis often refused to discuss business with her, choosing 

instead to play mind-games. Defendant Willis would make Chief Pickrell do “role play” scenarios 

where he would pretend to be her and he would require her to play the DA. Whereas role play 

can be a useful management exercise, he used it as a means to groom, flirt, make sexual advances 

and assert control. During “role play,” Defendant Willis would berate her for not being able to 

“read [his] mind.” She could read his non-verbal communication that he wanted a sexual interlude 

with her and he got angry when she never provided him with that answer. His harassment of 

Chief Pickrell fit a familiar pattern for Defendant Willis: he initiates scenarios and exchanges that 

he intends to be flirtations from which he draws gratification. He also uses his position of power 

to force unwanted touching, knowing that even when not reciprocal, the female employee is in 

no position to rebuff him outwardly. Once he comes to understand that there will be no actual 

sexual interlude, he is gratified by expressing his anger through acts of intimidation, control, 

manipulation and retaliation. Defendant Willis also consistently refused to accept personal 

responsibility for conduct he knew to be sexually harassing and unlawful. As he would tell it, it 

was never his fault that he made unwanted sexual advances at Chief Pickrell, but rather hers, 

because she “looked too good” for him to be expected to control his urges. Similarly, he wanted 

VyKim Le to believe, while he was sexually harassing her, that workplace sexual misconduct 

was a compulsion for him, rather than a personal choice, because he just “could not help 

[him]self” from doing so when near her. 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 12

36. As early as 2017, Chief Pickrell told her Deputy Chief, Keith Henslee about 

Defendant Willis’ consistent abuse of her. She disclosed that she had not reported the abuse to 

HR because she was afraid of losing her job and that she always became anxious, nervous and 

physically sick each time she would be scheduled for a one-on-one meeting with Defendant

Willis, who insisted that his opaque frosted door remain closed. 

37. Due to the anxiety, fear and physical anguish Chief Pickrell felt during these closed 

door meetings, Deputy Chief Henslee would frequently sit in Chief Pickrell’s office (which 

shared a wall with DA Willis’ office). Chief Pickrell and Deputy Chief Henslee developed a plan 

that in the event a meeting with DA Willis escalated to a level of harassment she could not 

navigate, she would knock on the wall so Henslee could intervene. These meetings happened 

regularly. There were many occasions where Chief Pickrell desperately wanted to knock on the 

wall to signal Henslee that she was in distress, but did not do so, for fear of incurring DA Willis’s 

wrath should he perceive her knock as a cry for help and a joint challenge to his authority. 

38. Defendant Willis’ abuse and harassment wasn’t limited to Chief Pickrell. Indeed, 

Deputy Chief Henslee personally witnessed other instances with a previous Administrative 

Assistant to Defendant Willis where extreme yelling matches would ensue. On at least one 

occasion, Defendant Willis threw a backpack in his office at a female staffer, a fact which is 

known by many in the office. It was common for Deputy Chief Henslee to see women leave 

Defendant Willis’ office in tears. 

39. Between 2017 and 2022, Chief Pickrell was often the confidante for others who 

were experiencing the erratic and abusive behavior from Defendant Willis. This behavior at times

was sexually charged, like she experienced, while other times were eruptions of DA Willis’ fierce 

rage similary to what she endured. It was not unusual for women to come into her office and cry-
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 13

- tears were routine in the DA’s Office. However, crying was expressly prohibited by Defendant

Wirskye, which compounded the anguish that Chief Pickrell and others experienced as a result 

of their interactions with Defendant Willis. Defendant Wirskye enforced his “no crying” policy 

in prosecutor team meetings whereby he would issue edicts such as “go home if you’re gonna 

cry,” “there’s no crying in the DA’s office,” “no snowflakes in this office,” “check your emotions 

at the door,” and “nobody gives a shit about your feelings.” Given his role and professional 

relationship with Chief Pickrell, Deputy Chief Henslee witnessed this as well. Deputy Chief 

Henslee was alarmed by the female employees who were pushed to the point of tears as this had 

not happened anywhere else during his career in law enforcement and was not objectively normal, 

professional or acceptable.

40. The abuse from Defendant Willis was not limited to Chief Pickrell. Jane Doe 1 was 

hired as a receptionist at the District Attorney’s Office in 2019. A few months into that position, 

Jane Doe 1 became Defendant Willis’ Administrative Assistant on a “trial period.” Almost 

immediately, Defendant Willis made unwanted comments about Jane Doe 1’s appearance—

comments that were inappropriate coming from the elected District Attorney in a professional 

District Attorney’s Office. In addition to these inappropriate comments and full-frontal hugs with 

moaning, Defendant Willis held the same type of closed-door meetings with Jane Doe 1 as he did 

with Chief Pickrell, with no one else present in the room. During the “trial period,” as part of her 

job, Jane Doe 1 travelled to a Texas County and District Attorney’s Office conference in 

Galveston. This is the same annual conference hosted by the Texas District and County 

Attorney’s Association (TDCAA) where he had in a prior year harassed Chief Kim Pickrell. After 

a group dinner, Jane Doe 1 was sitting in the hotel lobby with Defendant Willis while the group 

dispersed for the evening. During this time, Defendant Willis invited Jane Doe 1 up to his hotel 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 14

room, which she politely declined. He changed the subject for a bit, then asked her again if she 

would come up to his hotel room, saying “I’m not sure where it could lead, but we could explore.” 

Jane Doe 1 replied, “That is not what I am here for.” 

41. After Jane Doe 1 refused Defendant Willis’ advances at the Galveston TDCAA

conference, he treated her quite differently in the workplace. He began demeaning and berating 

her. In one closed-door meeting he told her, “You think like a child, and I will treat you like a 

child.” Defendant Willis likely appreciated the gender slurring that is implicit in a male supervisor 

telling a female employee that she "thinks(s) like a child” and shall therefore be treated as one, 

which makes his misconduct even more violative of personal and public trust. In the same vein, 

Defendant Willis told Jane Doe 1 that her opinion was “unimportant” and that she must sit in the 

back of the room during executive meetings, take notes, and say absolutely nothing. Rebuffing 

his sexual advances put Jane Doe 1 in the proverbial back of the bus. In several other closed-door 

meetings, both before and after the conference, Defendant Willis would give full body frontal 

hugs where he pressed her breasts into his body and lingered while moaning. He rubbed her lower 

back with his hands while her arms were stiffly by her side. More than once, she tried to break 

free, but he held her tighter. These physical encounters were unwanted and sexual in their nature. 

Jane Doe 1 eventually put in for a position in the Victim’s Assistance Division and got it, in 

December 2020. This role put her under the supervision of Chief Pickrell, a welcome change. 

However, the unwanted touching and full frontal hugs with moaning continued--the most recent 

of these sexualized hugs was April 2022. 

42. Similar to Jane Doe 1, Defendant Willis personally recruited Jane Doe 2 for the 

Community Engagement Director Position after searching the professional networking website

LinkedIn himself, going outside the normal hiring methodology. This job paid less than half of 
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Jane Doe 2’s usual rate, but Defendant Willis made representations that he would pay her 

significantly more. Thereafter, he assured her that he would persuade the Commissioner’s Court 

to create a hybrid position that paid her more appropriately. Jane Doe 2 had a passion for crisis 

media management and accepted the significantly lower pay to do that work and in reliance on 

the DA’s representations to her that a pay increase would soon be forthcoming. 

43. During Jane Doe 2’s tenure with the District Attorney, Defendant Willis conducted 

his frequent closed-door meetings with her, just like the others. These meetings with Jane Doe 2

occurred during the COVID pandemic when the office was far less populated. In those meetings 

and in other office settings, Defendant Willis soon began making sexually suggestive remarks to 

Jane Doe 2, including “No one rocks those jeans like you.” One day, he walked into her office 

and said, “I thought the heat (from the space heater) was from your hotness.” On another day, he 

walked into her office while she was on the phone. She remarked to the listener on the other end 

of the phone discussion that she needed to cut the call short because her boss walked in. Defendant

Willis heard the remark and then said to Jane Doe 2, “Come on, throw me a bone. Can’t you just 

say that a good-looking guy walked in?” On another specific occasion, Defendants Willis and 

Wirskye, while in the office and aware of Jane Doe 2’s presence, made a smirking remark about 

the physique of a female model in an apparel catalog. More specifically, Defendant Willis was 

unable to answer a work-related question posed to him by Jane Doe 2, to which Defendant

Wirskye commented that Willis was “distracted” by the model in the catalog. 

44. In addition to the sexually harassing remarks, Defendant Willis often berated Jane 

Doe 2 when he perceived she was not sufficiently flattering of him. He frequently solicited 

compliments from her and expressed frustration when he was not praised by Jane Doe 2 and 

others. He refused to make basic decisions or engage in discussions about actual business, 
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choosing rather to inflict emotional distress through circular browbeating sessions whereby he 

would grow angry that Jane Doe 2 could not read his mind. Defendant Willis asked about Jane 

Doe 2’s personal love life, and attempted to invite himself to her home in McKinney. Jane Doe 

2 became overwhelmed by Defendant Willis’ harassment and abuses of her, and therefore left the 

DA’s office. Defendant Willis’ created a highly toxic workplace by targeting female employees 

to try to flirt with or to direct outright sexual advances. He marginalized those who declined, 

which forced many of them to leave their positions, a pattern that substantially contributed to a 

conspicuously high turnover rate. Collin County Human Resources collects data on employee 

turnover rates. According to data collated by that department, in 2013, when Defendant Willis 

had been in office for almost two years, the projected annual turnover for felony prosecutors was 

8%. Ten years later, the same report shows the projected felony prosecutor annual turnover for 

2022 as 32%.

45. Like Chief Pickrell, and Jane Does 1 and 2, Defendant Willis sexually harassed 

VyKim Le on many occasions. Ms. Le is an attorney, and a prosecutor in the DA’s Office. She

is uniquely positioned to report directly to Defendant Willis as a feature of her role as a Pre-Trial 

Diversion Prosecutor. This is a Division of one prosecutor where she reports directly to Defendant

Willis, a point of access that he has frequently exploited to harass her. Defendant Willis 

repeatedly told her he loved her and that he “enjoys her.” Like he did with Jane Doe 2, he asked 

VyKim Le if he could come to her home. He asked Ms. Le if she “dreamed” about him “last 

night.” He questioned about her dating life, and asked her to report to him if she started dating 

someone. She declined his repeated unwanted sexual and romantic overtures. As is his pattern 

with so many female employees, Defendant Willis repeatedly rubbed Ms. Le’s back and moaned 

while pulling her breasts into his body for extended, unwanted hugs. He also held several closed-
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door one-on-one meetings with Ms. Le where he would compliment her on her beauty and 

appearance, causing her to feel violated and fearful. 

46. Other instances of harassment of Ms. Le by Defendant Willis include a time when 

Willis asked that Ms. Le get up from the seat across from his desk, and insisted that she moved 

to the tall bar-height table. Ms. Le was wearing a skirt. She complied, and sat in a chair at the tall 

bar table in his office. Defendant Willis slid his chair over to her at eye level with her skirt opening 

and stroked her leg with his hand while she was attempting to explain a report. He smiled with 

pleasure as he did this and moaned while he touched her, with his eyes closed. This went on for 

a couple minutes and she was trapped in that moment—frozen in shock and fear. Ms. Le, like the 

other Plaintiffs, felt added intimidation about exposing Defendant Willis for his abuses because 

of the enormous power he wields over the criminal justice system in Collin County. This fear 

appears founded by the experience of Fallon LaFleur, as described in subsequent sections of this 

Complaint. 

47. Another instance occurred when Ms. Le was in Willis’ office to discuss a business 

matter. He feigned that he could not find a file on his computer, and he asked that she come 

around to his side of the desk. Defendant Willis repeatedly contrived this scenario to fondle 

female employees, one he also deployed upon Chief Pickrell. He told Ms. Le to sit in his tufted 

leather chair. Once she complied, he pushed the chair in under the desk trapping her. Defendant

Willis then began to rub her shoulders in a massaging fashion – firmly – for longer than he had 

touched her leg on the previous occasion. He again moaned in a sexual manner, as he had before 

while he massaged her shoulders. Ms. Le finally accomplished the “task” and scooted her chair 

back to break the encounter at his desk. 

48. On another occasion, Defendant Willis summoned VyKim Le to his office. He 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 18

instructed her to stand at a table in the blind spot of his office against the wall to the right of his 

desk. As she stood there, Willis grabbed a mat that was big enough for only one person to stand

upon. He placed it on the floor under the pretext of helping her feet while she was wearing heels. 

He looked her up and down. Defendant Willis then stood next to Ms. Le, and began rubbing her 

forearm. While Willis rubbed Ms. Le’s arm, he moaned and sighed in a sexual manner. He then 

said to her, “Sometimes I can’t help myself.” He often told Ms. Le that he “could not help 

himself” when he was near her. 

49. While Defendant Willis was engaged in sexual harassment of the Plaintiffs, 

Defendant Wirskye had unfettered access to the misdemeanor and felony divisions, by virtue of 

his position as first assistant. Defendant Willis rarely if ever involved himself in the 

administration of the attorney divisions and Defendant Wirskye had tremendous discretion to 

treat his subordinates however he wanted. He consistently chose to torment them. This behavior 

is documented through the first of the “Anonymous Letters” which is dated October 2019 and 

was initially sent to the District Attorney. The letter is addressed to “Collin County District 

Attorney Willis” and states: 

“ADA’s have left Collin County due to the bullying, intimidation and harassment 

by your 1st Assistant, Bill Wirskye. I understand that you personally do not 

routinely conduct exit interviews and you personally do not speak with those 

leaving the office without Bill present. I will submit that no one currently in your 

office is going to communicate to you regarding Bill’s behavior, his temper, or his 

bullying of ADA’s. His conduct is intentional, intimidating and pervasive. 

Since you don’t speak directly with your Misdemeanor ADA’s or Felony ADA’s this 

letter will inform you of some of the actions that have occurred and are currently 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 19

occurring in your office. This is the tip of the iceberg and the adage “where there 

is smoke there is fire” is true in this case. Listed below are some examples: 

• A misdemeanor meeting was held, and everyone was told to put their cell 

phones in a basket and then they were “screamed and yelled at” and then told 

not to tell anyone about the meeting. Really? Adult professionals are being 

intimidated and reprimanded like this in your office? Consider that Bill is over 

6 tall and that he is physically intimidating. Intimidation of any employee is 

hostile.

• When ADAs resign as a result of targeted harassment, Bill is instructing 

them that if they say anything negative about him, he will insure they never 

work again. The bullying continues beyond the role in the office. Many of 

those who have left the office have been coerced into resigning because 

otherwise they will never work as an ADA again in the state of Texas. 

• A female ADA was told by Bill prior to leaving on maternity leave “You are 

not really going to take the full maternity leave if you want your job?” This is 

not a joking statement from a man in a position of power. 

• Tenured Prosecutors close to retirement are demoted or moved because 

they have crossed Bill. Anyone close to retirement won’t tell you what is 

happening in your organization because they need their job to protect their 

financial future. Were these tenured prosecutors not competent or did they just 

not conform to Bill’s expectations of bullying? Several of these ADA’s are 

under your leadership today but stay away from Bill.
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 20

• ADAs are told to take Personal Business Allowance time off and campaign 

for your re-election. Is this ethical? Were you aware of this? 

• Bill has been known to discuss which ADA’s who are the most “fuckable”. 

Whether said in the office or outside with other Chiefs this is disgusting and 

offensive. Is this how he decides who is a good ADA? 

• There was a male ADA off-site and not one female ADA was invited. Were 

county funds used in any way to support or fund a “boys” only outing? This 

event drives a perception of discrimination in the District Attorney’s office in 

Collin County. 

• A male ADA was re-assigned because he dated a woman that ran against 

you, DA Greg Willis, in the recent election. Questionable from an ethics 

perspective. 

• Bill has a “list” of the targeted ADA’s he wishes to have exit the office and 

his very close confidants are aware of this list. Many of your Chiefs have 

witnessed his screaming and yelling and truly think people are being unfairly 

targeted. Several of them at first try to explain or defend the ADA under fire 

but Bill will not tolerate any explanation or feedback. His goal is to target, 

intimidate and exit those ADA’s he doesn’t personally like. 

• At least five or more ADA’s who resigned did so because of the treatment 

they received from Bill; bullying, screaming, and intimidation. These people 

have suffered mental abuse by the verbal attacks made by Bill. Were you or 

are you even aware that this behavior is going on and goes on today? 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 21

• The surprise resignation of the Chief of Misdemeanor was due to bullying 

and intimidation not incompetence.

• Recent resignation of a highly respected female prosecutor due to targeted 

intimidation.

The next ADA is already being targeted, the screaming, bullying and intimidation 

is pervasive and will continue unless something is done to stop it. (Ask Bill who is 

next on the list) Like any good attorney will do all the above will be explained away 

but as you and I know there are elements of truth in every statement above. Only 

you can decide how best to find out what is going on in your office. I trust that as 

a taxpayer and voter that you will give credence to the above statements. The ADAs

are working in fear and in a hostile work environment and they are afraid to say 

anything because they are concerned for their careers. Don’t let Bill persuade you 

that this is something blown out of proportion. This has been going on in your office 

since Bill’s arrival and in fact getting worse. You are losing control and Bill is 

gaining control. Your reputation is being destroyed by the person you trust most. 

The Defense Bar and Judges are aware of the situation and questioning what is 

going on in Collin County. They are seeing competent prosecutors treated unfairly 

and questioning your involvement and awareness. Informing you is my first step 

and consideration is being given to other avenues to expose questionable bullying 

actions and/or a hostile work environment in the District Attorney’s office in Collin 

County.”

50. Despite the revelations in this letter, Defendant Willis did not ask Chief Pickrell or 

any other person to investigate allegations contained therein. Upon information and belief, the 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 22

DA did not report this letter to Human Resources nor did the DA hold any meetings to investigate 

the allegations from the October 2019 letter. Defendant Willis instead acted as through he never 

received this letter. Contrary to his feigned ignorance, Jane Doe 1 specifically recalls receiving 

the letter when she was his Administrative Assistant. She recalls Defendant Willis calling 

Defendant Wirskye into his office and asking Jane Doe 1 to leave. A few days later, Jane Doe 1 

recalls County Judge Chris Hill coming to the DA’s Office and meeting with Defendants Willis 

and Wirskye to discuss the October 2019 letter. Jane Doe 1 also recalls the next letter with 

allegations about Defendant Wirskye arriving in December 2019.

51. In December 2019, a second letter was addressed to the Collin County 

Commissioners and attached a copy of the October 2019 letter. Jane Doe 1 recalls Defendant

Hale meeting with Defendant Willis about this letter shortly after receipt. Aside from this, the 

Commissioners Court did not open an inquiry into the allegations contained in the December 

letter, nor was it recorded in any Court agendas or briefings. Upon information and belief, the 

Commissioners Court did not initiate any independent, unbiased investigations into the 

allegations. Again, like Defendant Willis the Commissioners behaved as though they never 

received this letter. 

52. Following these letters to the Defendants, in January 2020, a felony prosecutor gave 

an exit interview to Human Resources. Her description of events was extensive and detailed

discrimination committed by both Defendant Wirskye and Defendant Willis. Human Resources 

had knowledge at least as of January 2020 that the operations inside the District Attorney’s Office 

were of serious concern. Even if Defendant Willis and the Collin County Commissioners failed 

to share the October 2019 and December 2019 letters with Cynthia Jacobsen or Erica Johnson, 

the Human Resources Department would have undeniably learned of the severe and pervasive 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 23

discrimination from the January 2020 exit interview with the aforementioned prosecutor. 

53. Meanwhile, in 2019 Fallon LaFleur nee Jolly had been hired into the Misdemeanor 

Division as an entry-level prosecutor. Becoming a prosecutor had been her childhood dream. She

wanted to make a career of it, and, in fact, desired to retire from Collin County after a full tenure 

of public service. Ms. LaFleur had only been in the office for a few days when Defendant Wirskye 

began targeting her. The office encouraged new hires to frame their diplomas and to make their 

office “their own.” Many prosecutors had their own furniture in their offices, and Ms. LaFleur 

was given express permission to bring in her own chairs, which were tufted and plush. On her 

third day at work, Defendant Wirskye came into her office and yelled “I can’t sit in here. You 

look like a whore in a whorehouse.” He then went into Ms. Le’s office where she was with two 

other female prosecutors and he boasted that he had humiliated Ms. LaFleur about “her 

whorehouse furniture.” Defendant Wirskye instructed Ms. LaFleur to remove the chairs, which 

she did. 

54. Approximately a week later, Ms. LaFleur wore shoes that Defendant Wirskye didn’t 

like and he instructed her chief to tell her to go home and change them. The next day, Defendant

Wirskye came into the docket room and, in front of other prosecutors and defense attorneys,

began degrading and ostracizing her because of her shoe choice the day before. He demanded to 

inspect the shoes that Ms. was wearing at that moment, humiliating her in front of the numerous 

individuals present at docket. Defendant Wirskye did not require any male prosecutors to go 

home and change their clothes, even when they violated the dress code. 

55. It was commonplace for Defendant Wirskye to address groups of prosecutors, 

including Ms. LaFleur, as "motherfuckers" in division meetings. He referred to and addressed 

female prosecutors by the words "gossips,” “bitches,” “whores,” and “sluts.” He said that the 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 24

female misdemeanor prosecutors were causing the office to "rot from the bottom" because they 

were "bitches." At one training session on trial tactics and effective opening statements, Mr. 

Wirskye said "it's not like fucking a woman -- there's no need for foreplay." At another trial 

strategy training, he said, "the best victims are dead ones" and "it's like bad sex, they want to 

come in and blow their wad." He said that the “best victims are dead ones” because in those 

instances, the prosecutor does not have to listen to them, counsel them, or manage their

expectations. Ms. LaFleur, Keith Henslee and Ms. Le were also present in a training where 

Defendant Wirskye told the female prosecutors to "get wet and stay wet." Wirskye also expressed 

his motto for the female prosecutors to “hook up, not down” while at conferences, meaning they 

should have sexual encounters at those meetings only with individuals who can advance their 

careers.

56. In addition to the sexual harassment and verbal abuse, Ms. LaFleur experienced a 

well-known phenomenon in the DA’s Office – being “passed over.” According to the District 

Attorney Policy manual, the District Attorney’s Office is an Equal Opportunity Employer.1

57. Despite this, promotions are capriciously denied in the Collin County DA’s office 

to execute a pattern and practice of discrimination. Promotions are sometimes given to buy 

silence or complicity to supervisor misconduct while others are denied, not based on merit, but 

1 Collin County Criminal District Attorney Policy Manual
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 25

to punish or deter resistance to supervisor misconduct. “Team Players” who are loyal to 

Defendant Wirskye are rewarded and are jump-promoted from the outside. 

58. In the year 2020, during the early months of the Covid pandemic, Ms. LaFleur, in

isolation, began to obtain a master’s degree in criminal justice online after work hours. Ms. 

LaFleur read the District Attorney’s Office’s Policy Manual when she first started in 2019--this 

policy manual had been in effect since 2011. The Office encourages education that pertains to 

the performance of job duties.

59. As seen above, the policy manual is emphatic in its encouragement for prosecutors

to continue their law enforcement development; however, when Ms. LaFleur sought an online 

degree in criminal justice after-hours during the pandemic, Defendant Wirskye was furious that 

she was pursuing after-hours education and he made sure she knew it. He deemed her schoolwork

a distraction from her duties and an act of “team” disloyalty that he would punish. Wirskye told 

Ms. LaFleur that he questioned her commitment to his “team” and threatened her: “you are up 

for felony soon and I will not forget this.” Defendant Wirskye’s punitive threats against Ms. 

LaFleur were commonplace. Defendant Wirskye often threatened future retaliatory actions and 

other consequences during day-to-day work. Anything could set him off, and in turn, damage a 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 26

subordinate lawyer’s career. Wirskye’s “team” ethos was a device he used to harass and 

discriminate against women in the office. Ms. LaFleur was repeatedly passed over for promotions 

because Defendant Wirskye did not believe she was loyal to his “team.” In practice, being on 

Defendant Wirskye’s “team” required being male or, alternatively, being a woman willing to 

drink copious amounts of alcohol with him after work. Wirskye organized out of town weekends 

for male prosecutors to the exclusion of female ones. Defendant Wirskye used his position as 

First Assistant to insist that subordinates revel with him over him alcohol and bawdy, often 

misogynistic, banter. He repeatedly rewarded those who complied with those demands and 

punished by exile from his “team” those who didn’t, like Ms. LaFleur. 

60. “We don’t have policies, we have tendencies” is a phrase used commonly by

Defendant Wirskye. His odd bromide is a telling admission, because in practice, it is violative of 

law prohibiting workplace discrimination and sexual harassment, as well as the Collin County 

District Attorney’s Office Policy Manual regarding the same. The Office has policies that are 

clear and have been in effect since January 3, 2011. For example, the policy against Sexual 

Harassment: 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 27

61. Upon information and belief, Human Resources has never alleged “false data” 

being provided to them by anyone who has reported misconduct at the District Attorney’s Office 

over the years. 

62. Ms. LaFleur was able to push through the emotional and psychological abuse

outwardly, but behind closed doors, she was barely surviving. In fact, Ms. LaFleur made an 

attempt on her own life because of this severe and pervasive discriminatory workplace. Ms. 

LaFleur’s supervisors, including Defendant Wirskye, learned of the young prosecutor’s suicide 

attempt through a back-channel in law-enforcement. The responding officer to Ms. LaFleur’s 

suicide attempt phoned the District Attorney’s Office without Ms. LaFleur’s consent or 

knowledge. Soon after, Chief Pickrell heard Defendant Wirskye’s Chiefs call Ms. LaFleur

“crazy” and make other derogatory and demeaning comments about her mental health. Defendant

Wirskye made disparaging remarks about Ms. LaFleur to her colleagues and peers and in fact her 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 28

supervisor told her to “put her game face on” when she was called to meet with him later on in 

the week. Ms. LaFleur made an attempt on her life on Saturday, and was set to first chair a 

domestic violence trial on the following Monday. Chief Pickrell heard Defendant Wirskye also 

say that Ms. LaFleur made an attempt on her life in an effort to get out of trial. 

63. Defendant Wirskye acted upon his threat to Ms. LaFleur that he would not promote 

her to a felony prosecutor position. She was never promoted to felony – a fact that severely limits 

her earning potential as of today in private practice. Ms. LaFleur receives two court appointed 

cases per month on average and is barely able to make a living. Defendant Wirskye’s harassment, 

discrimination, and abuse of Ms. LaFleur caused her to experience substantial and permanent 

harm, economically, physically, and psychologically. She has since been diagnosed with PTSD 

arising from experiences foisted by Defendant Wirskye in his command over her. 

64. Overwhelmed by Defendant Wirskye’s abuses of her, Ms. LaFleur resigned her post 

at the District Attorney’s Office, forfeiting her life’s dream in exchange for her survival. Ms. 

LaFleur had a final exit interview with Defendant Willis in May 2021, alone and once again with 

the door closed. She told him in detail of the abuses of Defendant Wirskye and Wirskye’s Chiefs. 

The District Attorney acted as though he had never heard this (despite the October 2019 and 

December 2019 letters). He said “I’ve never heard any of this before.” Defendant Willis said, as 

Ms. LaFleur was leaving his office “don’t worry, I’ll keep your secret” and then proceeded to 

give her a full-frontal hug while her arms were stiff beside her body. He rubbed her lower back 

with his hands and pressed her breasts against him. 

65. Ms. LaFleur also reported to Human Resources what transpired under the 

administration of Defendant Willis and Defendant Wirskye. Human Resources told her they had 

never heard any of this before. Ms. LaFleur understood then as she does now that Human 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 29

Resource’s claim of ignorance was untrue, as she had been told by others that they, prior to Ms. 

LaFleur doing so, had reported same or similar abuses to Human Resources. Moreover, the 

Anonymous Letters detailing misconduct committed by Defendant Willis, as well as under his 

authority, had been received in the DA’s Office and in Commissioner’s Court in October 2019 

and December 2019. Ms. LaFleur’s exit interview was in June 2021. 

66. In August 2021, the third of the “Anonymous Letters” appeared, detailing 

misconduct in the DA’s office. Defendant Wirskye deeply resented Ms. LaFleur and took 

deliberate actions to harm her career even after her resignation. Part of Defendant Wirskye’s 

persistent rage toward Ms. LaFleur stemmed from his belief that she was the author of one of the 

Anonymous letters that described his abusive workplace conduct. In a courtroom docket setting, 

Defendant Wirskye expressly accused her of having written such a document. He made this 

accusation in a room full of prosecutors and defense attorneys who were colleagues of hers.

67. To make ends meet after leaving the District Attorney’s Office, Ms. LaFleur 

became certified to teach classes for probationers (Substance Abuse and Anger Management 

Evaluations). Subsequent to her certification, Ms. LaFleur learned the District Attorney's Office 

was refusing to accept probationers' classes taught by her, thus blacklisting her from income

opportunities. Upon further inquiry, Ms. LaFleur discovered that the DA's office will accept an 

un-approved internet class, but not a class taught by her. The ostracizing was without justification 

or any merit-based reason. Ms. LaFleur’s enrollments have gone down considerably because the

Defense Bar understands that the DA’s Office will not accept the probationer's credits, and thus,

it’s pointless for their clients to enroll in classes taught by Ms. LaFleur.

68. It is clear that Defendants Willis, Wirskye, and Collin County have retaliated 

against and harmed Ms. LaFleur for reasons that include her being a female who won’t imbibe
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 30

with her male boss (Defendant Wirskye), for her candid report to HR about harassment and 

discrimination in the District Attorney’s Office and for Defendant Wirskye’s belief that she was 

the author of a letter that described the abusive environment that Defendants Willis and Wirskye 

engender and exploit. 

69. The August 2, 2021, Anonymous Letter (the third) is addressed to First Assistant

Bill Wirskye and cc’s the District Attorney, Greg Willis, Collin County Judge Chris Hill, 

Members of the Commissioner’s Court and the Collin County Human Resources Department. 

The letter describes that the author has been told about the “get wet and stay wet” remark; how 

Defendant Wirskye refers to prosecutors as “motherfuckers;” how Defendant Wirskye referred 

to a prosecutor as a “whore in a whorehouse” and that Defendant Wirskye ordered employees to 

excommunicate former employees by saying “Don’t associate with people who leave” which the 

author identified to be “emotional abuse.” The letter describes that Defendant Wirskye accused 

two prosecutors of having an affair yelling in the office, “are you two fucking”? The letter 

describes a hostile work environment whereby female employees were only allowed to say “good 

morning” to Defendants Wirskye and Willis, disallowing any further communication aside from 

this. The letter describes Defendant Wirskye saying “who fucking raised you” to a female 

attorney who he had accused of speaking out against the office. Routine humiliation is described 

through the “Peter Principle” as the letter outlines – wherein a prosecutor forgot to file a motion 

during trial and was subsequently humiliated publicly and openly in division meetings well after 

the event, resulting in an emotionally abusive work environment. The letter describes Defendant

Wirskye saying, “we don’t have policies, we have tendencies.” 

70. The third letter proceeds on page 2 to describe a time when a female prosecutor 

wore a scarf to work. She was ordered by Defendant Wirskye to remove it because he said it 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 31

looked like she had a hickey on her neck that she was trying to cover up. The letter describes that 

he ordered the prosecutor to never wear a scarf again. The third letter further describes a culture 

of coerced silence and oppression and describes how female attorneys are told to change their 

personalities, remain unnoticed and be less vocal, and ordered to be silent during meetings. The 

third letter describes Defendant Wirskye calling female prosecutors names such as “bitches” 

“sluts” “whores” and “gossips” while demanding that female prosecutors only wear skirt suits

rather than pant suits. The author describes that Defendant Wirskye sends women from the office 

to a convenience store to get a drink for him when he’s thirsty and states that Defendant Wirskye 

demoted a female employee for posting on her own private social media “what she deems cute to 

wear to work.” The letter goes on to describe that “when an employee considers leaving due to 

the above noted situations or perhaps just to find a better suiting job for that individual person, 

the employee is demoted to Auxiliary Court as punishment (humiliating and emotional abuse).” 

Finally, the letter describes that a female employee was a member of a “Working Moms Group” 

and that when Defendant Wirskye found out that she had reached out for support, “she was forced 

to make a decision in one day to quit the group or quit her job.”

71. The third letter closes by saying “To all who have been cc’d on this letter, the above

19 statements are just the ones I have heard about. I implore you to understand that if you were 

to reach out to folks in the office about these situations, you will find, perhaps, many different 

reactions. There are employees who need their job and are/will be afraid to say anything for fear 

of losing their job or retaliation by the organization. And also, just because you may see some 

employees smiling or laughing in the hallway, that does not mean these things aren’t happening. 

There will be some employees who will be relieved that someone FINALLY spoke up on their

behalf as they have been going to work day after day feeling these terrible pressures and having 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 32

to be subjected to your behavior.... Either way, you have an opportunity for growth right in front

of you. CHANGE needs to happen and happen NOW. There is NO room for behaviors such as 

these, Mr. Wirskye, especially in a position of authority such as yours. As stated before, some of 

these bullying and sexual harassment situations have already been reported, but the treatment 

continues to exist.” The letter is signed “A concerned citizen of Collin County.” 2

72. Another letter dated “August 2021” is addressed to DA Greg Willis, Collin County

Commissioners, District Judges, County Judges and the Collin County Human Resources 

Department. This letter begins by saying “Why has nothing changed at the Collin County DA’s 

office in almost two years? What will it take for someone to stop the bullying, sexual and 

emotional harassment that has been occurring over the years? Who in a leadership position should 

be held accountable for the barbaric conditions that the ADA’s work under today. You are all 

complicit in the atrocities that are occurring within your sphere of influence. Attached are letters 

sent to Greg Willis, Commissioners in October 2019 and the recent letters that have surfaced. 

ADA’s current and former are still terrified of the power of influence that Bill Wirskye and Greg 

Willis hold over them. The next step is to send the entire package of information to all television 

stations in the Dallas area to expose the environment in Collin County.” The letter is signed “A 

Concerned Citizen.”

73. Excerpts from the fourth “Anonymous Letter,” dated August 12, 2021, are set 

forth below:

2 AUGUST 2, 2021 Anonymous Letter
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 33

74. A fifth Anonymous Letter, which was also sent during August 2021, begins: “To

Anyone Who Cares About Restoring the Integrity of Collin County” and describes how “Bill 

Wirskye “treats his subordinates, particularly female prosecutors.” The letter says that “the 

trouble...started long before Bill Wirskye arrived. Greg Willis, the current Collin County District

Attorney, is part of the problem.” 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 34

75. The fifth letter continues to describe solo meetings with Defendant Willis where he 

asked personal questions and said “the grooming started with the basics” before he “dove right 

into inappropriate questions” such as inquiring of a female prosecutor the reasons for her divorce. 

The author described that the meeting with Defendant Willis was not optional, and that the 

prosecutor could not afford to quit or get fired, so she answered the questions vaguely instead of 

refusing to answer, “his harassing question.” The author describes in the next paragraph an 

instance where the DA “instructed her to role play.” “She had to pretend that she was him and he 

pretended that he was her. He then switched places with her by placing his hands on her biceps 

then physically turning her around. He then asked this prosecutor what she wanted him to call 

her. Uncomfortable with his sexual innuendos, she asked him what he meant.” “He provided a 

couple of options: “DA [insert her last name] or Madam DA.” “Even though she didn’t want to 

participate in his game, nor did she want him touching her, she felt trapped.” “After his 

monologue, he commented that she looked skinny and then dismissed her to go eat lunch.” 

76. On August 26, 2021, a sixth Anonymous Letter surfaced at 11:46 a.m.

attncollincounty@gmail.com wrote: “A prosecutor is supposed to stand up for victims; protect 

those who cannot protect themselves and be a voice for the voiceless. Working at the Collin 

County District Attorney’s Office under Greg Willis and Bill Wirskye, I lost my voice. I lost it 

because it was strangled from me.” This letter is four pages long and specific, going so far as it 

lists names of prosecutors who have knowledge of the abuse. Although this letter is anonymous, 

it is not short on information, including specific leads that the recipients could have followed up

with for investigation, as noted on the email as well as the commissioners who are also addressed.

The Defendants received this communication, yet failed to act in any reasonable manner to 

address it. 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 35

77. The sixth letter repeats, as other letters have, that Defendant Willis received notice 

of the sexually harassing and abusive environment at the DA’s Office in October 2019. “Willis 

has been told many times, to his face and in written form, about the verbal abuse and sexual 

harassment foisted upon his staff by Wirskye but Willis refuses to act. Willis was sent a letter in 

late 2019, a copy of which was also mailed to every county commissioner, that detailed the abuse 

and toxic work environment at the DA’s office; yet zero action was taken.” It continues, “The 

citizens of Collin County have elected a District Attorney who leaves his employees to be 

victimized by his First Assistant because he refuses to act on the information given to him over 

and over again.” 

78. The sixth letter repeats that letters have been sent to District Court Judges, the media

and others in Collin County, but highlights that the incidents mentioned thus far do not detail all 

of the abuses. There are more, as described in the 26 August letter: 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 36

79. The letter continues: “Also, responsible for letting a toxic work environment take

hold is the Collin County HR Department. There have been multiple exit interviews where they 

have been told in detail about the abuse suffered by those leaving the office. They have left 

employees in a toxic environment. If they have acted it is unknown to those still working at the 

DA’s Office and there has been no change enacted.”

80. The letter describes the power and control dynamics in the abusive DA’s Office.

The author describes an employee of the DA’s Office as being akin to a domestic violence victim. 

The letter also describes the retaliatory environment and what will happen outside the four walls 

of the DA’s office if a victim is to outcry to someone outside the system: “He [Wirskye] knows 

exactly who to say these things in front of, who will back him because they owe him, and how 

far he can push a prosecutor because with one phone call or email he can ensure they don’t get 

hired anywhere. Wirskye tells prosecutors, when they hand in their resignation letter, that as long 

as they “don’t bad mouth” the office then he won’t “bad mouth” them. “Keeping one’s hands 

clean and projecting a positive public persona while causing irreparable psychological damage is 

the hallmark of an abuser.” The letter closes with the sentence “[a]ll we ask is that injustice is 

answered with justice.” 

81. Jane Doe 2 intended to resign before the August Anonymous Letters were
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 37

transmitted to the DA’s Office, Commissioners Court members, news agencies, judges, and 

neighboring District Attorneys. After wide circulation of the August 2021 Anonymous Letters 

had occurred, Defendant Willis gave lip service to cleaning house. He gave Jane Doe 2 hope that 

she could assist him in navigating the damage caused by these revelations and make positive 

workplace changes. Defendant Willis talked her out of resigning under the pretense of presenting 

her the opportunity to do crisis management PR. Defendant Willis acknowledged to Jane Doe 2

that the allegations were concerning and needed to be addressed. 

82. Although he acknowledged the letters, Defendant Willis did not conduct nor 

commission any independent investigation. He made no personnel changes in response to the 

letters nor did he remove Defendant Wirskye from his post. Defendant Willis did not modify his 

own inappropriate behavior or take any affirmative and effective steps to modify Wirskye’s. 

Defendants Willis and Wirskye were very focused on trying to root out who wrote the 

Anonymous Letters but disinterested in making any personal behavioral or workplace cultural 

changes in response to them. 

83. Eventually, Jane Doe 2 resigned for similar reasons as Ms. LaFleur, which include 

sexual harassment and the toxic, discriminatory environment towards her and other women in the 

workplace. Defendant Willis asked Jane Doe 2 to remain publicly vague about her reason for 

leaving– that she was merely “unhappy.” Jane Doe 2 told him exactly why she was leaving, but 

he did not have any interest in remediating the real problems of harassment and discrimination 

he committed, fostered and helped make pervasive.

84. Collin County Commissioners exhibited conscious disregard for the issues

described by the Anonymous Letters. Commissioner Darrell Hale responded as follows to Letter 

#6 about titled, “The Toxic Environment at the Collin County DA’s Office: 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 38

85. At 2:43pm on August 26, 2021 – less than three hours after the original email was

Sent, Commissioner Susan Fletcher fired back a response from her iPhone and from her county 

email address with her official county signature line apparent in her reply. In her reply, she states: 

• “I take issue with the author that they claim a letter with similar concerns was 

“mailed to every county commissioner” in late 2019. 

• “As the author points out, no one has actually made any formal complaints that 

can be properly investigated. Knowing this, exactly how is our HR Department or 

DA Willis supposed to address these anonymous accusations? I would assume that 

professional prosecutors would understand the importance of a credible witness 

(who’s willing to go on the record), or at least the importance of verifiable 

evidence. There are laws to protect employees and there is accountability.” 

• “Of course, if there is ANY truth to these allegations, I would certainly never want 

it to be ignored. But the anonymous nature of this information has all the hallmarks 

of a disgruntled employee (or former employee) seeking revenge. If it’s more than 

that, please come forward, for the sake of all victims. Without the ability to 

properly investigate these claims, there is little that can be done from an official 

standpoint, besides asking questions, which I have already done. To date, there is 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 39

nothing actionable without identifiable victim or witness, as it’s all based on 

anonymous claims.” 

• “To the author of this email, my door has always been open and I would NEVER 

want any of our employees to be harassed or mistreated in any way. I literally 

didn’t know anything of this until I received a request for information last week. 

My mobile number is below, my door remains open...and I will listen.”

86. In her email, Defendant Fletcher claimed to have investigated the misconduct

described in the Anonymous Letters. Yet she also indicated an unwillingness to use any real effort 

to conduct an investigation, rhetorically asking “[e]xactly how is our HR Department or DA 

Willis supposed to address these anonymous accusations?” Obviously, she and other 

Commissioners could have personally interviewed or retained a trained professional to interview

female prosecutors and female investigators on a confidential basis to discern if they knew 

whether what was described in the Anonymous Letters was accurate, plausible and/or a shared 

experience. She could also have interviewed Defendants Willis and Wirskye to obtain an 

assessment of what factual accounts appeared to align among those interviewed and where they 

didn’t. Defendant Fletcher could have performed at least a modicum of effective due diligence 

rather than simply dismiss the Anonymous Letters that described discriminatory, harassing, 

abusive, and reprehensible conduct at the highest levels of the DA’s office, as merely the gripe 

of a “disgruntled employee.” She did none of those things. Kim Pickrell is the Chief Investigator 

in the DA’s office. She wouldn’t have been hard for Commissioners to find for an interview to 

see what she knew and what she had experienced. Defendant Hale also did nothing, as it took 

him only ten minutes to respond to the anguish expressed by the writer of the August 26, 2021

letter, by dismissing the whole matter as not his problem. The Plaintiffs and others like them in 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 40

the DA’s office had nowhere to turn for help, knowing they would be retaliated against by 

Defendants Willis and Wirskye, ignored by the feckless HR Department, and disregarded by a 

Commissioner’s Court that made it unmistakably clear they didn’t care. 

87. In juxtaposition to its conduct, Collin County purports to be an Equal Opportunity

Employer:

 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 41

88. Further, the Collin County Handbook prohibits Harassment of any kind: 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 42

89. Sexual Harassment is also prohibited by not only the laws of the United States of 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 43

America, but by Collin County itself:

90. The Plaintiffs were deceived by Defendants into believing that the Defendants 

would follow the law and their own written mandates to provide a safe workplace. In April 2022, 

several Plaintiffs reported horrific abuses by Defendants Willis and Wirskye to Human 

Resources. Doing so changed nothing other than to intensify their mistreatment by Willis and 

Wirskye. Collin County leadership and Human Resources deemed Defendant Willis to be 

“untouchable” for workplace sexual misconduct and illegal retaliation, while his First Assistant 

is permitted to continue with impunity to refer to women in their workplace and in their presence 

as “bitches,” “sluts,” and “whores,” while publicly imploring them to “get wet and stay wet.” 

91. In early 2022 after it had become clear she would never succumb to his sexual 

advances, Defendant Willis retaliated against Chief Pickrell claiming she spoke ill of him to other 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 44

investigators. This perception caused his mood and temperament to become erratic and on 

February 22, 2022, he berated her in a closed-door meeting and told her expressly that he did not 

like her and did not like speaking with her because she had bad-mouthed him to other employees 

in the office. Chief Pickrell did not know what he was referring to and had not spoken ill of him 

to other investigators. After scolding Chief Pickrell, he told her that if she could “learn” from this 

experience, they could perhaps be “closer than ever before.” From many past interactions, Chief 

Pickrell understood him clearly: if she were to cede to his romantic advances and remain loyal to 

him by keeping silent about these matters, her career would prosper; if she did not, she would be 

marginalized by him. 

92. On March 31, 2022, Defendant Willis took action to make good on this threat. He 

entered Chief Pickrell’s office and sternly told her that he was not going to promote one of her 

investigators into the position he previously told her he would. Defendant Willis was punishing 

Chief Pickrell’s subordinate because he was upset with Chief Pickrell. His tone then shifted and 

wistfully, he added that Chief Pickrell “always looks good.” 

93. Chief Pickrell, at wit’s end after years of sexual harassment and manipulation, went 

to Human Resources to report Defendant Willis on April 6, 2022. After Chief Pickrell shared her 

traumatizing account of events, Human Resources asked her to come back the next day, April 7th

to repeat it all over again with Director Cynthia Jacobsen in attendance. 

94. On April 7, 2022, Chief Pickrell, Deputy Chief Henslee and Jane Doe 1 went to 

Human Resources together and described what they experienced through their interactions with 

Defendant Willis. In the April 7, 2022, meeting, Human Resources told Chief Pickrell, Deputy 

Chief Henslee and Jane Doe 1 that “the DA is untouchable” and that there is nothing that Human 

Resources can do to make the harassment stop or to protect them. In fact, at several points in the
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 45

conversation with Human Resources, Cynthia Jacobson said “let’s be honest, he’s the DA and 

nothing’s going to happen to him.” Jacobsen briefly mentioned they could make a report to the 

EEOC. Ms. Jacobson said that Willis is the DA and “you can go after them civilly” but from the 

HR standpoint, he is “untouchable.”

95. In response to Cynthia Jacobsen’s statement that the “DA is Untouchable,”

Deputy Chief Henslee correctly pointed out that the Collin County Handbook as well as the

District Attorney Policy Manual require him to report sexual harassment and protect him from 

retaliation for doing so. The Collin County Handbook and the District Attorney Policy Manual 

specifically protect those who report sexual harassment, regardless of who they are reporting. 

There is no exception for the District Attorney or anyone else. 

96. There was never any allegation that the Plaintiffs were falsifying their reports or 

information. Indeed, some of what Deputy Chief Henslee reported on behalf of Chief Pickrell 

was consistent with similar manner and means employed by Defendant Willis toward others. One 

of the August letters describes Defendant Willis’ inappropriate inquiries about the employee’s 

personal life in addition to the unwanted hugs described by Plaintiffs. The moaning and rubbing 

of the lower back are consistent across the accounts to Human Resources as are the comments 

about women’s bodies and the descriptions of Defendant Willis’ sexual harassment in the 

workforce, and the closed doors belittling sessions. In the April 7 HR meeting, Erica Johnson 

confirmed that she was not surprised by the allegations and that prior complainants had not 

followed through after their complaints. She said it was too hard and “they gave up.” 

97. Once Human Resources dismissed Chief Pickrell, Deputy Chief Henslee and Jane 

Doe 1, they went back to the District Attorney’s Office. Chief Pickrell and Deputy Chief Henslee

informed Defendant Wirskye that they reported the DA’s sexual harassment to HR that day. Upon
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 46

learning of this report, Defendant Wirskye sighed loudly, put his head on his desk, apologized

and asked, “Are there more than 10?” Defendant Wirskye was clearly unsurprised to learn of 

Defendant Willis’ pattern and practice of sexual harassment. Concerned about reports of his own 

conduct, Defendant Wirskye asked whether the issue of the anonymous letters had come up. 

98. The very next day, on or about April 8th, Defendant Hill attended a closed-door 

meeting with District Attorney Greg Willis at DA Willis’ office. 

99. On the following Monday, April 11, 2022, Defendant Wirskye asked for a meeting 

with Chief Pickrell and Deputy Chief Henslee. He asked them to conceal the fact that they had 

been to Human Resources, and to not tell anyone else in the office about the report. Chief Pickrell

told Wirskye that she already told co-workers Kim Laseter and Evelyn Rutherford. Defendant

Wirskye was angry and became angrier during this meeting – his temperament had changed 

considerably since April 7th. 

100. On May 9th, Defendant Wirskye sent Chief Pickrell a meeting request. In that 

meeting, he stripped Chief Pickrell of her duties and responsibilities, including her supervision 

of the Victims Assistance Coordinators and the Victim’s Assistance secretary (a total of 5 

employees) and supervision of the secretarial staff (more than 20 employees). She was also 

stripped of the privilege of interviewing candidates for secretarial positions, the privilege of

planning the Tree of Angels event, the privilege of organizing the Annual Crime Victim’s 

Luncheon, of being the supervisor of the VOCA Grant, and of being the Foray project liaison for 

the office. Chief Pickrell lost all of these responsibilities when Defendant Wirskye retaliated 

against her because she reported to Human Resources. Additionally, Defendant Wirskye changed 

the chain of command entirely – requiring the entire Investigator staff to report to him, and to 

their individual court chiefs. This had never been done before as the investigators always had a 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 47

separate chain of command, reporting to the Chief Investigator. 

101. The retaliation did not stop with Chief Pickrell. Deputy Chief Henslee was stripped 

of the entirety of his duties as Deputy Chief of the Investigator “chain of command.” For years, 

he assisted Chief Pickrell in supervising the investigators at the DA’s Office, yet on May 9th,

Defendant Wirskye retaliated against him for reporting to Human Resources by assigning him to 

a regular Felony Court. Deputy Chief Henslee would now be working a trial court, which is 

effectively entry level felony investigator work. Defendant Wirskye ordered Henslee to move his 

office immediately and assigned him to an office next to the women’s restroom. In the process 

of moving his standing desk at Defendant Wirskye’s demand, Henslee suffered a bicep tear for 

which he remains injured. The injury required surgery and for Deputy Chief Henslee to take 

Workman’s Comp. Deputy Chief Henslee was stripped of many other duties as well, inherent in 

his former position as Deputy Chief. 

102. Defendant Wirskye did not stop retaliating against Chief Pickrell and Deputy Chief 

Henslee once he had levied these punishments. He next proceeded to concoct a “paper trail” 

whereby he misrepresented Chief Pickrell’s work performance and chastised her for not 

performing duties that he had already removed from her after he demoted her. He contrived 

reasons for why Chief Pickrell had lost responsibilities and began making false statements to 

Human Resources and in her performance review so that he could create the illusion that Chief 

Pickrell was something other than an exceptional employee. Chief Pickrell had an exceptional 

record during her tenure at the DA’s Office. It was only after her report of sexual harassment that 

Defendant Wirskye began to complain about her performance. Not only did Defendant Wirskye 

include these fabricated performance issues in Pickrell’s official performance review, but he also

disparaged and humiliated her during regular Tuesday meetings he uses to repeatedly demean her 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 48

in person and in front of Felony Chiefs. Chief Pickrell rebutted Wirskye’s inaccurate statements 

with proof provided to Human Resources, which remain in her file, complete with exhibits. 

Neither Chief Pickrell nor Deputy Chief Henslee had never been written up in their performance 

reviews prior to reporting the discrimination and harassment. 

103. While Deputy Chief Henslee was on Workman’s Compensation leave due to the 

injury he sustained as a result of Defendant Wirskye’s demand that he move his office himself 

immediately during the demotion, Chief Pickrell was ordered by Wirskye to attend daily and 

weekly humiliating closed-door meetings with Wirskye and his chiefs. Human Resources knew 

Defendant Wirskye to be abusive. Neither Collin County Commissioners nor Human Resources

did anything to help or protect Chief Pickrell nor Deputy Chief Henslee. 

104. As detailed above, Defendant Willis sexually harassed Ms. Le on many occasions.

Once his advances and attempts were rebuffed she was left to navigate the perfidy of Defendant

Willis’ office. On June 22, 2022, Ms. Le was called into Defendant Willis’ office by Defendant

Wirskye. Defendant Willis was present as were some prosecutors, including a Chief. They 

proceeded to interrogate Ms. Le as one might experience in a custodial interview, like she was a 

criminal suspect. Willis, Wirskye and the others were focused on why Chief Pickrell had been

recently spotted in Ms. Le’s office and they collectively insisted upon knowing what Chief 

Pickrell and Ms. Le may have discussed. Ms. Le had no knowledge of why Pickrell and Henslee 

were stripped of responsibilities, and truthfully reported that fact to Willis, Wirskye, and the 

group. Even with that explanation, they continued to pressure Ms. Le to recount everything she 

had discussed with Chief Pickrell in Ms. Le’s office. They persisted until Ms. Le told them

accurately that Chief Pickrell and she had discussed hair conditioner and knee surgery. Satisfied 

that Ms. Le did not have any current intel she could report about Chief Pickrell, Defendants urged 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 49

her to be a mole for them on Chief Pickrell. They instructed Ms. Le to report any further contact 

with Chief Pickrell and to promptly relay to them the content of any conversations with Chief 

Pickrell that may ensue. She did not expressly consent to be the Defendants’ mole, but she did 

not refuse either, for fear of retaliation. Ms. Le understood that if she agreed to be an informant 

for Defendants, her employment would continue, and she would be rewarded. She also 

understood the opposite to be true: those who aren’t loyal to the “team” are further harassed, 

demoted, and/or fired. Ms. Le remained vague to avoid further interrogation or reprisal. 

105. Defendant Willis subsequently said to Ms. Le, “I just want you to know how much 

I appreciate you” and heaped Ms. Le with praise. Ms. Le was suspicious of that praise as purely 

a veiled threat that she must cooperate, an offer of complicity that she could not refuse. After all, 

she had previously been “passed over” for promotion on repeated occasions for reasons other 

than merit. Later that night, another prosecutor called Ms. Le while she was at home, and told 

her that Willis and Wirskye were not entirely satisfied with Ms. Le’s explanations earlier that day 

and that Defendants had asked the friend to be a mole for them on Ms. Le to get more information

out of her. Just days later, Ms. Le received her first exemplary performance rating. Suddenly she 

“exceeded” her performance objectives and received a pay raise. The quid pro quo that the 

Defendants intended could not have been more obvious: she would be promoted and financially 

rewarded if she ceded to their demands to betray and retaliate against sexual abuse and harassment 

victim, Chief Pickrell, and punished if she didn’t. The Defendants were betting they had bought 

her loyalty in this regard. 

106. On Tuesday, July 28, 2022, in another meeting, Defendant Willis asked Ms. Le

what she thought about the previous meeting. Ms. Le told him that she thought the meeting was 

inappropriate and unfair to her, as a six-year prosecutor in the office. Defendant Willis told Ms. 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 50

Le that he was “sorry she was being put in the middle of this without her consent.” In reference 

to Chief Pickrell, Willistold Ms. Le, “Hell yes I want her gone,” but added that that Chief Pickrell, 

was in a “protected class” and that he could not fire her right after her report to Human Resources. 

He went on to “provide context” for Ms. Le and said that the worst allegations that Human 

Resources told him about was that he had invited a female employee to his room at a conference 

and that she declined, he asked her again, and that she declined again. Willis defended himself 

not by denying the allegations, but instead told Ms. Le that he had “not fired or demoted” the 

employee. While he was flippant and dismissive when relaying the allegation to Ms. Le, he 

looked at Ms. Le intentionally and a clear message when he looked her in the eye and said “I 

never touched anyone” – a statement which Ms. Le knew to be a lie, since she had been touched 

more than once by Defendant Willis in a sexually harassing manner as described above. 

107. On July 12, 2022, KERA published a story wherein the defendants are quoted. The 

article in its entirety is produced below: 

The Collin County District Attorney’s Office is having trouble filling entry 

level prosecutor roles — and the DA said the current salaries for those roles 

are putting the county at a competitive disadvantage.

Right now, seven of the 12 misdemeanor prosecutor positions at the Collin 

County DA’s office are open. Misdemeanor prosecutors are typically recent law 

school graduates. Greg Willis, the county’s DA, said other counties are also 

having trouble hiring people for those entry level prosecutor positions. So, they’re 

raising their salaries.

To compete with other counties, Willis said Collin needs to follow suit and raise 

its salaries for those jobs. Otherwise, new law school graduates with student loan 

debts won’t be able to afford to start their career in Collin County.

“It becomes quite a disadvantage, regardless of how wonderful our county is, for 

students with lots of loans, law school debt, to start here,” Willis said.

The average salary for a misdemeanor prosecutor in the most recent fiscal year 

was $65,025, according to data from the Collin County Human Resources 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 51

Department.

The HR department compared that salary rate to salaries from nine other 

counties, including Dallas and Tarrant counties, and the state of Texas. The 

average salary for those was $64,492, putting Collin County above average.

But Willis said those numbers don’t necessarily reflect actual compensation. He 

said entry level prosecutors in Tarrant County end up making 10% more than the 

minimum starting salary, which Collin County HR data lists as an average of 

$61,451 annually.

“They're above us,” the DA said about Tarrant County’s actual pay rates. “Then 

all of a sudden, we're below average.”

The Collin DA said there are smaller counties that aren’t included in HR’s data 

that offer as much as $90,000 for misdemeanor prosecutors.

Salary rates aren’t the only thing impacting staffing numbers at the Collin County 

DA’s office. Prosecutors also are leaving the DA’s office for other positions. 

According to HR data, the projected turnover for 2022 is 22% for attorneys. 

That’s up from a 12.5% turnover rate in 2021.

Cynthia Jacobson, Collin County’s director of Human Resources, said about 74% 

of the turnover in the DA’s office within the past five years was people leaving for 

another job. But even though the turnover rate for attorneys has gone up, 

Jacobson said she’s not concerned.

“The turnover does not bother me,” she said. “You can see it's actually been 

fairly stable.”

Collin County Judge Chris Hill said the natural progression of the careers of 

beginning prosecutors in the DA’s office is either getting promoted or leaving to 

go into private or corporate practice. If the 74% leaving are following that 

natural progression, Hill said he’s not concerned.

What would be cause for alarm, he said, is if they’re leaving for the same position 

they already have in another county.

Jacobson said getting people leaving the DA’s office to do exit interviews has 

been a challenge, so she doesn’t have exact numbers on why people left. 

However, she said she believes most people left to go into private practice.

Overall, Jacobson said the staffing issues in the DA’s office isn’t unusual. Rather, 

she said it’s the nature of the current job market and the low unemployment level.
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 52

“There are about two job openings for everybody looking for a job right 

now,” she said.

108. To put it mildly, the Defendants quoted in this article were less than forthcoming

as to why the turnover rate is so high in the Collin County District Attorney’s Office. While no 

one should be surprised that the Defendants declined to reveal to readers that the DA’s office is a 

hostile, discriminating, and harassing workplace that mistreats many employees, the Defendants 

knew then, as now, that the office toxicity foisted from the top catalyzes much of the turnover. 

This is another example where Defendant Willis and other Defendants concealed from and 

misdirected the public as to the poisonous nature of the DA Office’s workplace ethics and culture. 

V. CAUSES OF ACTION

A. Texas Labor Code/Title VII/§ 1983

109. The factual assertions in paragraphs 17 through 109 are incorporated into section V 

by reference. Plaintiffs sue under the provisions of the Texas Labor Code, 42 U.S.C. § 2000e-2 

and 42 U.S.C. § 1983 for sexual harassment (Tex. Lab Code §§ 21.1412, 21. 142; 42 U.S.C. § 

2000e-2; § 1983), discrimination (Tex. Lab Code § 21.051; 42 U.S.C. § 2000e-2; § 1983), aiding 

and abetting (Tex. Lab Code § 21.056) and retaliation (Tex. Lab Code § 21.055; 42 U.S.C. § 

2000e-2; § 1983). The analysis of unlawful harassment, discrimination and retaliation is the same 

under all of the cited provisions. See Tanik v. Southern Methodist University, 116 F.3d 775, 775 

(5th Cir. 1997) (per curiam) (“The elements of the Title VII claim and the § 1983 claim are 

identical. The court evaluates these claims according to a single analysis.”).

110. All jurisdictional prerequisites for asserting the claims in this lawsuit have been 

met. Each Plaintiff filed a Charge of Discrimination dually with the Equal Employment 

Opportunity Commission and the Texas Workforce Commission. Each received a Notice of

Right to Sue from the EEOC via the DOJ (Jane Doe 1 8/11/22; Jane Doe 2 9/6/22; Ms. Le 9/6/22; 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 53

Ms. LaFleur 9/7/22; Chief Pickrell 9/19/22; Deputy Chief Henslee 9/19/22). This lawsuit is filed 

within 90 days from the receipt of such Notice of Right to Sue. Additionally, each Plaintiff 

received Notice of Right to Sue from the Texas Workforce Commission on October 27, 2022 and 

this lawsuit is filed within 60 days of such receipt. 

1. Sexual Harassment

111. Tex. Lab Code § 21.142 provides that “[a]n employer commits an unlawful

employment practice if sexual harassment of an employee occurs and the employer or the

employer’s agents or supervisors: (1) know or should have known that the conduct constituting

sexual harassment was occurring; and (2) fail to take immediate and appropriate corrective

action.” “Employer” is defined to include “person[s]” who “act directly in the interests of an

employer in relation to an employee.” (Tex. Lab Code § 21.141). The Texas Labor Code defines 

“sexual harassment” as “an unwelcome sexual advance, a request for a sexual favor, or any other 

verbal or physical conduct of a sexual nature if: (A) submission to the advance, request, or 

conduct is made a term or condition of an individual’s employment, either explicitly or implicitly; 

(B) submission to or rejection of the advance, request, or conduct by an individual is used as the 

basis for a decision affecting the individual’s employment; (C) the advance, request, or conduct 

has the purpose or effect of unreasonably interfering with an individual’s work performance; or 

(D) the advance, request, or conduct has the purpose or effect of creating an intimidating, hostile 

or offensive work environment.” Title VII also prohibits sexual harassment in an employment 

context. 

a) Defendant Greg Willis

112. Defendant Willis engaged in unwelcome and pervasive sexual harassment of Kim
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 54

Pickrell, Fallon LaFleur, Vykim Le, Jane Doe 1 and Jane Doe 2. As the Collin County District 

Attorney, Willis has individual liability for the sexual harassment under Tex. Lab Code § 21.141

as well as 42 U.S.C. § 1983. 

i. Kim Pickrell

113. With regard to Pickrell, Defendant Willis’ advances as described at the TDCAA 

welcome reception as well as office conduct involving full frontal hugs while rubbing on her and 

moaning, descriptions of his own arousal, forced role playing and comments on Ms. Pickrell’s 

body were unwelcome, submission to which were implicit terms of her employment, 

unreasonably interfered with her work performance and created an intimidating, hostile and 

offensive work environment. Defendant Willis made it clear by his actions that acquiescence to 

his offensive conduct was part of the job. Any attempt to reject his advances was met with 

hostility and aggressiveness, including demanding that Ms. Pickrell sit in his office while he 

berated and screamed at her. Ms. Pickrell, a seasoned Chief Investigator, became fearful of 

bringing necessary issues to Defendant Willis’ attention and fearful of one on one interaction 

with Defendant Willis, especially in his office. His conduct had a detrimental affect on her work 

environment, which became hostile and offensive to the point that she asked her Deputy Chief 

Investigator to sit in the next room and, when Willis began yelling at her and berating her, she 

might knock on the wall for the Deputy Chief Investigator to come and try to rescue her. 

ii. Jane Doe 1

114. With regard to Jane Doe 1, Defendant Willis also engaged in unwanted sexual 

touching on a pervasive basis, forcing full frontal hugs while rubbing on her and moaning. He 

invited her to his hotel room at a conference and when she declined, began making derogatory 

comments and denigrating her. She understood that acquiescence to his conduct and sexual 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 55

invites/innuendo was a condition of her employment. Additionally, his conduct created such a 

hostile work environment, and had such a detrimental affect on her ability to perform her job, 

that she was forced to transfer. However, that did not end the unwanted and offensive touching, 

which continued even after the transfer. 

iii. Fallon LaFleur

115. Similarly, Fallon LaFleur was subjected to Willis’ unwelcome full frontal hug and

rubbing while moaning. In the context of the situation, this conduct on the part of Defendant 

Willis was severe and created a hostile environment. Ms. LaFleur was seeking advice and remedy 

for Defendant Wirskye’s discrimination, harassment and retaliation and was in an extremely 

exposed and defenseless position as she had revealed very personal information, including about 

how vulnerable she was. Instead of defending her and helping her restore her dignity and self 

worth, Willis took advantage of her exposure to him to grope her and gratify himself, 

exponentially sealing the damage to her psyche and self image. 

iv. Jane Doe 2

116. Jane Doe 2 was also subjected to Willis’ pervasive and unwelcome sexual 

comments and innuendo as described herein that it affected her work environment and ability to 

perform her job. Since Willis’ behavior was allowed to continue unabated, she was constructively 

discharged from her job. During Jane Doe 2’s tenure with the District Attorney, Defendant Willis 

conducted his frequent closed-door meetings with her, just like the others. In those meetings and 

in other office settings, Defendant Willis made sexually suggestive remarks to Jane Doe 2, talking 

about her appearance, her body and her “hotness.” These meetings, the attempted intimacy and 

the continuing sexual innuendo affected Jane Doe 2’s ability to perform her job and created a 

hostile work environment. When the conduct continue unabated, Jane Doe 2 was constructively
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 56

discharged. 

v. VyKim Le

117. VyKim Le was also forced to endure the pervasive and unwanted sexual 

advances and harassment by Willis, who touched her, rubbed her, and trapped her as described 

herein. Defendant Willis repeatedly told her he loved her and “enjoys her” and has asked to be 

invited to her apartment. He asked if she “dreamed” about him “last night.” He asked about her 

dating life, and asked that if she started dating someone if she would tell him. She declined these 

unwanted sexual and romantic overtures. As is his pattern with so many female employees, 

Defendant Willis repeatedly rubbed Ms. Le’s back and moaned while pulling her breasts into his 

body for extended, unwanted hugs. He also held several closed-door one-on-one meetings with 

Ms. Le where he would compliment her on her beauty and appearance causing her to feel 

intimidated, anxious and scared. Other instances of harassment of Ms. Le by Defendant Willis 

include a time when Willis asked that Ms. Le get up from the seat across from his desk, and 

insisted that she moved to the tall bar-height table. Ms. Le was wearing a skirt. She complied, 

and sat in a chair at the tall bar table in his office. Defendant Willis slid his chair over to her and 

stroked her leg with his hand while she was attempting to explain a report. He smiled with 

pleasure as he did this and moaned while he touched her, with his eyes closed. This went on for 

a couple minutes and she was trapped in that moment—frozen in shock and fear. Ms. Le, like the 

other Plaintiffs, felt added intimidation about exposing Defendant Willis for his abuses because 

of the enormous power he wields over the criminal justice system in Collin County. Not only 

have they feared for their jobs by telling the truth, they have feared other types of persecution or 

for their safety because of the fact that Defendant Willis is not just a perpetrator, but one who can 

foist the full weight of prosecutorial wrath. Another instance occurred when Ms. Le was in 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 57

Willis’ office to discuss a business matter. He feigned that he could not find a file on his computer, 

and he asked that she come around to his side of the desk. He suggested that she sit in his tufted 

leather chair, and when she did, he pushed the chair in under the desk trapping her. Defendant 

Willis then began to rub her shoulders in a massaging fashion – firmly – for longer than he had 

touched her leg on the previous occasion. He again moaned in a sexual manner, as he had before 

while he massaged her shoulders. Ms. Le finally accomplished the “task” and scooted her chair 

back to break the encounter at his desk. There was an occasion when Defendant Willis 

summoned Ms. Le to his office and instructed her to stand at a table in the blind spot of his office 

against the wall to the right of his desk. As she stood there, Willis went to get a standing mat that 

was big enough for only one person to stand. He placed it on the floor under the pretext of helping 

her feet while she was wearing heels and then looked her up and down. He stood immediately 

next to her and began rubbing her forearm, sighing and moaning in a sexual manner. He said, 

“sometimes I can’t help myself.” He often said that he “could not help himself” when he was 

around Ms. Le. In truth, Defendant Willis’ pattern and practice of sexual harassment stems from 

his own personal choices, rather than an involuntary compulsion evoked by the magnetism of 

female employees. His workplace sexual conduct is predatory, manipulative, and entirely of his 

own volition. These are some of several examples of how Defendant Willis’ ongoing and 

pervasive sexual harassment interfered with Ms. Le’s performance of her job and created a hostile 

working environment. 

b) Defendant Bill Wirskye

118. Defendant Wirskye also engaged in sexual harassment in violation of the Texas 

Labor Code. He, too, as the First Assistant District Attorney with supervisory and management 

authority over the Plaintiffs, has individual liability for the sexual harassment under Tex. Lab
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 58

Code § 21.141. As described herein, Defendant Wirskye engaged in pervasive and unwelcome 

comments of a sexual nature that created a hostile work environment for the female Assistant 

District Attorneys, including but not limited to Fallon LaFleur, who he called a “whore” in a 

“whorehouse,” as well as constantly referring to all of the women as “bitches,” “whores,” and 

“sluts,” referencing sexual acts and innuendos, including, but not limited to, telling the women to 

“get wet and stay wet” and to sleep their way to the top of the profession. His pervasive and 

unwelcome sexual comments created an intimidating, offensive and hostile work environment 

for the female employees and affected their ability to perform their jobs. The Plaintiffs, as well 

as the descriptions in the anonymous letters, provide details of how Defendant Wirskye’s creation 

of a misogynistic work environment not only interfered with their ability to perform their jobs, 

but created an environment of dread, fear, humiliation, embarrassment, intimidation and affected 

their self images and self worth. 

c) Collin County

119. All Plaintiffs were employees of Collin County as that term is defined in both the 

Texas Labor Code and Title VII. Collin County is vicariously liable for the sexual harassment 

described because the harassment was at the hands of the Plaintiffs’ supervisors. Additionally, 

the County had an affirmative duty to act to prevent workplace discriminatory/harassing conduct 

and to properly respond to employee claims of workplace discrimination/harassment when they 

arise. The County did neither. While it had written policies in place to address 

discrimination/harassment, it took no steps to enforce such policies. There were no actions taken 

to prevent the conduct of Willis and/or Wirskye and when the conduct was reported and/or known 

and/or should have been known, there were no steps taken to address it. In fact, when Pickrell, 

her Deputy Chief Henslee and Jane Doe 1 went to HR to complain specifically about Defendant 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 59

Willis, their concerns were dismissed and they were told that there was nothing that could be 

done. There were six anonymous letters to Defendant Commissioners and Collin County Human 

Resources detailing the conduct of both Defendant Willis and Defendant Wirskye and yet there 

was no action taken by the County to address the problem or help the affected women. 

120. Should it be determined that Defendant Willis was not an employee of the County

sufficiently to impose liability under Title VII and/or the Texas Labor Code, the Fifth Circuit 

recognizes that employers may be liable under Title VII for the conduct of non-employees in the 

workplace when the employer knows of the harassment but fails to act. Frank v. Harris Cnty., 

118 F. App'x 799, 803 (5th Cir. 2004), citing Garziano v. E.I. Du Pont De Nemours & Co., 818 

F.2d 380, 387 (5th Cir.1987). It is clear that Collin County Commissioners and HR personnel 

knew of the harassment/discrimination/retaliation and failed to act on that knowledge. 

2. Gender Discrimination

121. Collin County is liable for the workplace gender discrimination by both Defendant 

Willis and Defendant Wirskye in their roles as District Attorney and First Assistant District

Attorney. They treated the female employees very differently than the male employees, 

including, but not limited to, the use of pejorative terms against women as “bitches,” “whores” 

and “sluts.” The women were publicly humiliated in meetings and instructed they were not 

allowed to wear pants. The continuing harassment was related specifically to gender. Defendant 

Willis treated the women differently than the men based on gender, including physical touching, 

required one on one “role play” in his office and berating them when his advances were rejected. 

Defendant Wirskye treated the women differently than the men, including using pejorative 

names, public humiliation in meetings, degrading comments, and excluding them from activities 

that were “guys only” for the benefit of the male Assistant District Attorneys. Women were 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 60

passed over for promotion in favor of men, particularly if they did not engage in the good ole boy 

environment created by Defendant Wirskye. Particularly, Ms. LaFleur was singled out based on 

gender, treated differently than male prosecutors, called a “whore,” had her wardrobe scrutinized, 

was passed over for promotion, was harassed based on her gender and constructively discharged. 

3. Retaliation

122. Plaintiffs sue Collin County for retaliation against Plaintiffs for good faith reporting

and/or opposing unlawful harassment and/or discrimination under Title VII and Tex. Lab Code 

§ 21.055. 

a. Kim Pickrell

123. Chief Kim Pickrell supervised more employees than Defendant Wirskye himself

before he demoted her. She did so while being burdened with the weight and repetitiveness of 

Defendant Willis’ sexual harassment. For years, Chief Pickrell was required to endure sexual 

harassment from Defendant Willis as a condition of her rank as his Chief Investigator. When 

Chief Pickrell finally made a good faith report of unlawful harassment and discrimination to 

Human Resources, she was punished by Defendant Wirskye and Human Resources and made to 

report to a person (Wirskye) who she knew to be vindictive and emotionally abusive to several 

of her co-workers. Because Chief Pickrell exercised her right to seek help, she suffered retaliation 

and was stripped of the majority of her duties, as well as humiliated and disparaged among her 

subordinates and the Chief Prosecutors. Her file has been tainted with derogatory 

characterizations of her that were fabricated by one or some of the Defendants, as part of their 

vendetta against her for having reported details of Defendant Willis’ misconduct to Human 

Resources. Chief Pickrell is a highly capable career law enforcement professional who is eligible 

to retire in less than 2 years, but has been forced by Defendants to finish out her service to the 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 61

taxpayers of Collin County in a toxic and abusive work environment for the remainder of that 

time, if she is not terminated for her whistleblowing. She is capable of working far past her 

retirement eligibility. 

b. Keith Henslee

124. Deputy Chief Henslee is also a career law enforcement professional, having served

nearly a decade in the Denison Police Department before joining the Collin County District 

Attorney’s Office. He is a United States Navy veteran of the Persian Gulf War. After working his 

way through the ranks, he enjoyed a supervisory position as the Deputy Chief Investigator at the 

District Attorney’s Office. Deputy Chief Henslee followed procedures mandated by both the 

Collin County Handbook and the District Attorney’s Policy manual and reported sexual 

harassment and a hostile work environment to Human Resources. Although the law and his 

employer purported to protect him for reporting Defendant Willis’ unlawful conduct, Defendant

Willis and Defendant Wirskye punished him for making a good faith report of unlawful 

harassment/discrimination by stripping him of his duties and demoting him to a regular felony 

trial court. As part of this retaliatory demotion, he was made to work in a court alongside the 

investigators he had very competently supervised for years.

c. Jane Doe 1

125. Defendant Willis harassed and retaliated against Jane Doe 1 for declining Defendant

Willis’ repeated unwelcomed sexual advances toward her. Defendant Willis harassed and 

retaliated against Jane Doe I’s rebuffing of his advances by beginning a pattern of insults and 

humiliation, including telling her that she thinks like a child and shall therefore be treated as one, 

as well as requiring her to be silent and isolated during meetings, as her input on work-related 

matters was of no importance to him. 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 62

d. Fallon LaFleur

126. Fallon LaFleur was clear in her objections to, and resistance to, Wirskye’s “boy’s

club” approach to the Assistant District Attorneys. She refused to participate in the after-hours 

drinking. She objected to the exclusion of women from out of town events. She reported both 

Wirskye and Wills to Human Resources for their inappropriate conduct. Her opposition to the 

blatant gender discrimination and sexual harassment of women Assistant District Attorneys was 

so apparent to Wirskye, that he concluded that Ms. LaFleur was the author of one of the 

anonymous letters complaining of his conduct and he began to retaliate against her directly, 

accusing her in front of a group of authoring the letter, mocking her, and belittling her publicly, 

resulting in her constructive discharge. After she left the DA’s office, one of her ways to earn a 

living was conducting a probationer class. Wirskye directed all of the Assistant DA’s to refuse to 

accept for credit the classes that she conducted. 

4. Aiding and Abetting

127. Tex. Lab Code § 21.056 provides a cause of action against an employer that “aids, 

abets, incites, or coerces a person to engage in a discriminatory practice.” It is clear in this case 

that Collin County aided and abetted both Defendant Willis and Defendant Wirskye to sexually 

harass, discriminate and retaliate against the Plaintiffs in this case. There were multiple reports 

to Human Resources as well as Collin County’s governing body, the County Commissioners

relating to the discrimination, harassment and retaliation. These reports were made by Collin 

County employees—Kim Pickrell, Keith Henslee, Fallon LaFleur, numerous anonymous letters 

over approximately two years with specific details of sexual and gender harassment, 

discrimination, retaliation and abuse, identifying the wrongdoers and nothing was done to address 

it, knowingly and intentionally allowing it to continue unabated. The conduct of Collin County, 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 63

through its Commissioners and HR personnel, assisted and encouraged Willis and Wirskye to 

continue their illegal actions against Collin County employees. 

B. Individual Liability Under § 1983

128. The County violated the Fourteenth Amendment's guarantee of equal protection 

from sexual harassment. See Southard v. Tex. Bd. of Criminal Justice, 114 F.3d 539, 550 (5th 

Cir. 1997) (noting that sexual harassment in public employment violates the Equal Protection 

Clause and that circuit courts have allowed plaintiffs to assert such claims under both Title VII 

and § 1983) (citations omitted).

1. Liability

129. Plaintiffs sue the Individual Defendants for their conduct as described in this 

lawsuit, including the violation of the Plaintiffs’ constitutional rights under the Fourteenth 

Amendment’s guarantee of equal protection. The conduct of Defendants is analyzed using the 

same analysis applied to Title VII and the provisions set forth in section A above apply equally 

and are incorporated by reference. 

2. No Qualified Immunity

130. Plaintiffs may defeat qualified immunity by showing (1) that the official violated a 

statutory or constitutional right and (2) that the asserted right was “clearly established” at the time 

of the challenged conduct. Cloud v. Stone, 993 F.3d 379, 383 (5th Cir. 2021). As stated, the 

conduct of Defendants violated Plaintiffs’ rights under the Equal Protection clause of the 

Fourteenth Amendment. It has been established since at least 1997 that misconduct such as that 

on the part of Defendants violated individual constitutional rights. See Southard v. Tex. Bd. of

Criminal Justice, 114 F.3d 539, 550 (5th Cir. 1997) (noting that sexual harassment in public 

employment violates the Equal Protection Clause). The conduct of all Defendants was 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 64

objectively unreasonable under the circumstances. Defendant Willis engaged in repeated and 

ongoing sexual harassment and discrimination as well as retaliation, as described herein. 

Defendant Wirskye engaged in repeated and ongoing sexual harassment and discrimination as 

well as retaliation, as described herein. The individual Commissioners were aware of the 

discrimination, harassment and retaliation and were deliberately indifferent to the constitutional 

violations that they had a duty to address. Despite being directly notified of the ongoing 

constitutional violations, the Commissioners refused to take any action and allowed the conduct 

to continue. 

C. County Liability Under § 1983

131. Greg Willis, Chris Hill, Darrell Hale, Susan Fletcher, Cheryl Williams and Duncan 

Webb acted as policymakers for Collin County under these circumstances. When determining 

whether a DA is acting for the county or for the state, Fifth Circuit precedent clearly distinguishes 

a district attorney's “prosecutorial” duties—which are conducted on behalf of the state—from 

those duties that are “administrative or managerial in nature”—which are conducted on behalf of 

the county. See Esteves v. Brock, 106 F.3d 674, 678 (5th Cir. 1997). In this case, the conduct of 

Defendant Willis at issue is unrelated to prosecutorial duties and is purely “administrative.” As 

the Collin County DA, Defendant Willis has the hiring, firing and assignment authority with 

respect to Assistant District Attorneys and personnel in the DA’s office. Defendant Willis abused 

this authority by unlawfully harassing the Plaintiffs and other women on the basis of sex, 

discriminating against Plaintiffs and other women on the basis of sex, allowing his First Assistant

to harass and discriminate on the basis of sex, and using his position to retaliate against those 

who opposed or reported such conduct. Because the policymaker is the wrongdoer, the County 

is liable without the requirement of establishing a formal policy or a pattern of similar wrongful 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 65

conduct. 

132. The Commissioners Court is also a policymaker for Collin County with respect to 

personnel policy for the County in general and the functioning of Human Resources with respect 

to preventing or addressing unlawful harassment, discrimination and retaliation in the workplace. 

The County Commissioners had direct involvement in abetting and allowing Willis and Wirskye 

to harass, intimidate, discriminate, abuse and retaliate against the Plaintiffs and others. There 

were numerous reports, even pleas, to the County Commissioners to take action and stop the 

abuse and such pleas were intentionally and knowingly ignored. The Defendant Commissioners 

were deliberately indifferent to the conduct of the wrongdoers and the plight of their victims. 

133. Alternatively, should the Court require a Monell analysis, the facts establish a 

widespread pattern or practice of conduct that was known to the Commissioners as policymakers 

and allowed to continue. The policies, practices, and/or customs of the County constituted

moving forces of the unconstitutional conduct that proximately caused damages to the 

Plaintiffs. The County failed to prevent or address the ongoing unlawful harassment, 

discrimination or retaliation of which they were on notice and failed to implement effective

procedures governing how such conduct on the part of elected officials, including the District 

Attorney, would be addressed. All of these customs and practices were the moving force of

the constitutional violations that resulted in harm to the Plaintiffs.

D. 42 U.S.C. § 1985(2)

134. If two or more persons in any State or Territory conspire to deter, by force,

intimidation or threat, any party or witness in any court of the United States from attending such 

court, or from testifying to any matter pending therein, freely, fully, and truthfully, or to injure 

such party or witness in his person or property on account of his having so attended or testified, 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 66

or to influence the verdict, presentment, or indictment of any grand or petit juror in any such 

court, or to injure such juror in his person or property on account of any verdict, presentment, or 

indictment lawfully assented to by him, or of his being or having been such juror; or if two or 

more persons conspire for the purpose of impeding, hindering, obstructing, or defeating, in any 

manner, the due course of justice in any State or Territory, with intent to deny to any citizen the 

equal protection of the laws, or to injure him or his property for lawfully enforcing, or attempting 

to enforce, the right of any person, or class of persons, to the equal protection of the laws;3 4

135. Section 1985, in pertinent part, prohibits conspiracies either to deter, by force, 

threat, or intimidation, any party or witness from attending or testifying freely, fully, and 

truthfully in a federal court or to injure any party or witness in his person or property because he 

attended or testified in federal court. See 42 U.S.C. 1985(2) (clause i).1 The statute provides a 

remedy in damages to anyone who is injured in his person or property or deprived of a federal 

right or privilege as a result of an act in furtherance of a conspiracy prohibited under any part of 

Section 1985, including clause one of Section 1985(2). See 42 U.S.C. 1985(3) (clause iii).5

136. If a Collin County District Attorney’s Office employee makes a report of a violation 

of their constitutional rights to HR, the natural progression is that the next step is filing a 

complaint to the Equal Employment Opportunity Commission (EEOC). The EEOC is the 

administrative agency charged with enforcing the laws of Title VII. The step that follows an 

EEOC investigation is a “Right to Sue” letter, meaning that the EEOC is a necessary step in the 

path to federal court. Thus, the Defendants conspired to keep County employees from going to 

3 https://www.law.cornell.edu/uscode/text/42/1985

4 Bradt v. Smith, 634 F.2d 796, 1981 U.S. App. LEXIS 20907 5 https://www.justice.gov/osg/brief/haddle-v-garrison-amicus-merits
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 67

court. 

137. Collin County’s motive in silencing those who have reported violations that occur 

inside the DA’s Office is not only to relieve themselves of the effort it takes to solve a problem, 

but also to keep the complainants away from the EEOC. If the complainants believe that there is 

no recourse for them because “the DA is Untouchable”, it follows that they will also not follow 

their rights up the administrative chain through the EEOC and then to federal court. The motive 

of the County, the DA and the First Assistant is to avoid liability in the court system. They not 

only do not want to be discovered by the public to be the abusers that they are, but they want to 

avoid facing the damage they caused through their discriminatory actions and accountability in a

public forum. Each of these actors conspired to prevent employees of the District Attorney’s 

Office from exercising their right to seek redress for violations of Title VII, and also depriving 

the complainants of due process. “The DA is Untouchable” means that NO ONE can hold the 

DA accountable, not even the court system. The Defendants silence the employees who speak up 

– they intimidate them from seeking counsel to challenge the invidious animus put forward by 

HR. 

138. Claims brought under Section 1985(2) do not require invidious motive. Lack of 

invidious motive is an inadequate basis for dismissing a claim under the first clause of § 1985(2), 

because that clause "contain[s] no language requiring that the conspirators act with intent to 

deprive their victims of the equal protection of the laws." Kush v. Rutledge, 460 U.S. 719, 725,

103 S. Ct. 1483, 75 L. Ed. 2d 413 (1983)6

139. Despite the fact that 1985(2) does not require invidious motive, invidious motive 

exists in the form of a class-based animus. Class Based Animus is clear – women are not safe as 

6 Kush v. Rutledge, 460 U.S. 719, 725, 103 S. Ct. 1483, 75 L. Ed. 2d 413 (1983)
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 68

employees of the District Attorney’s Office. Women are a protected class, a fact which Defendant 

Willis angrily conceded to VyKim Le as the reason he has not yet fired Chief Pickrell for 

reporting his abuses to Human Resources. If the DA is not sexually harassing female employees 

through touching, unwanted sexual hugs, overtures, moaning or inviting a woman up to his room, 

his First Assistant is berating them, calling them pejorative names, and openly disparaging them 

for the simple fact that they are female including stating “[o]pening statements are not like 

fucking a woman, there’s no need for foreplay;” “[g]et wet and stay wet;” and “hot ass 

prosecutors” who are “fuckable.” These are part of the class-based animus. These statements 

should never be permitted in any workplace, much less the one lawyer’s office that has a duty to 

see that justice is done above all else. 

140. While § 1985(2) requires that the conspiracy be aimed at preventing an injured party 

from testifying in court, that could perhaps be foreclosed when the facts point to an administrative 

agency such as the EEOC. To this point, Title VII was not the only cause of action available to the 

plaintiffs in this action. 42 U.S.C. 1983 was also available, and it does not require a Right to Sue 

Letter from the EEOC. The plaintiffs could prevail on 1983 claims based on the facts presented, 

and certainly the defendants intended to silence them from that avenue. 

E. 42 U.S.C. § 1985(3)

141. The Defendants in this case are also liable under 42 U.S.C. § 1985(3), which does 

require an invidious discriminatory intent by the state actor. The animusrequirement is comprised

of two analytically distinct inquiries: (1) whether there is a "qualifying class" and (2) whether the
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 69

defendant was motivated by discriminatory animus against the class. Id. at 269.

7 The second 

inquiry requires a defendant to have been "motivated by a purpose (malevolent or benign) 

directed specifically at [the qualifying class]" by reason of the essential characteristic of that class.

142. The essential characteristic of the class in this lawsuit is that the class is female. 

Females in the district attorney’s office assume positions of power traditionally held by men. 

Chief Pickrell, for example, is the top Investigator in the DA’s Office. To allow a woman to enjoy 

that role under equal protection would have been too far of a leap for the DA, his First Assistant 

and Collin County Government. She had to not only tolerate sexual harassment as quid pro quo

for her Chief position, she had to be consistently reminded that her looks made her an object of 

desire and ultimately, she was not equal to her male peers. 

143. Defendant Wirskye has significant animus towards women. This Complaint is 

replete with examples of his lodging hateful and demeaning, disrespectful, misogynistic slurs that 

can only be meant to hurt, degrade and harass female attorneys and female employees. His animus 

is meant to not only humble the female lawyers under his purview, but also to both personally 

and publicly humiliate and destroy them. He intentionally breaks them down because that is his 

method of exerting power and control.

144. The Defendants’ invidious discriminatory animus preys upon the fear of disclosure 

inherent in female victims of abuse. The data is clear that women are far more likely to be victims 

of physical/emotional/sexual abuse than men. The Defendants take advantage of the fear of 

disclosure, and they gamble that the victims will remain silent. They prey upon the female 

7 Bray v. Alexandria Women's Health Clinic, 506 U.S. 263, 113 S. Ct. 753, 122 L. Ed. 2d 34, 1993

U.S. LEXIS 833, 61 U.S.L.W. 4080, 93 Cal. Daily Op. Service 258, 93 Daily Journal DAR 583
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 70

attorney’s desire to be equal to their male counterparts and treat them worse because they know 

that they’re less likely to outcry because it would make them look weak. They prey upon the 

female attorney’s fear of being judged – of being less than a male DA. They know that for a 

female ADA or LEO to report sexual harassment is jeopardize their career. They know that these 

women would rather suffer than to appear weak or “look like a victim.” All of these Defendants

want to keep their jobs. Some of them have to win elections to do so, thus invidious discriminatory 

motive exists in order to conceal their abusive conduct from voters, taxpayers, and press.

145. Section 1985(3) requires acts in furtherance of the conspiracy. To that end, 

Defendants Willis, Wirskye and a Chief “shook down” Ms. Le on May 28. Then, the DA 

attempted to influence her testimony by gaslighting her into believing “he never touched anyone” 

when he knew full well that he had impermissibly touched Ms. Le himself. After the Anonymous 

Letters came out, Defendant Wirskye said that he “told the DA to stop having closed-door oneon-one meetings with female employees.” Wirskye said that to Chief Pickrell and Deputy Chief 

Henslee. Defendant Hill conspired with Defendant Willis on April 8th, which triggered 

subsequent retaliatory actions in the days that immediately followed. Prior to this meeting, 

Defendant Wirskye was superficially apologetic to Chief Pickrell and Deputy Chief Henslee 

about what they were going through. After Defendant Hill’s visit, the retaliation by Defendant

Wirskye was visible. Collin County HR was also complicit. The Collin County Handbook states 

that reports to HR about sexual harassment are kept confidential. In this instance, Defendants

Willis and Wirskye had knowledge of the names of potential victims that Chief Pickrell provided 

to HR, proving that HR did not keep the report confidential; rather, they informed their codefendant and the co-defendant attempted to silence Ms. Le. That act was in furtherance of the 

conspiracy to silence female employees from telling the truth about the DA’s Office, because that 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 71

would not have been consistent with the core belief that “the DA is untouchable.” Finally, in a 

subsequent meeting once the retaliation began, Defendant Wirskye said to Chief Pickrell and 

Deputy Chief Henslee to “[g]et out of your head and quit playing victim,” a statement made in 

an act to further the conspiracy.

F. 42 U.S.C. 1986

146. "Section 1986 imposes liability on every person who knows of an impending 

violation of section 1985 but neglects or refuses to prevent the violation." Karim- Panahi v. Los 

Angeles Police Dept., 839 F.2d 621, 626 (9th Cir. 1988). Absent a valid claim for relief under 

section 1985, there is no cause of action under 1986. Trerice v. Pedersen, 769 F.2d 1398, 1403 

(9th Cir. 1985). 

147. This claim is evidenced through the exit interviews that have been provided to HR 

over the years. According to Ms. LaFleur, at least 10 reports of harassment/abuse had been made 

to HR during Defendant Willis’ tenure. Additionally, the Anonymous Letters put the County on 

notice of the violations, including the commissioners court. Defendant Susan Fletcher herself 

acknowledges the Anonymous Letters but disregards the County’s duty to investigate pursuant to 

their own policy manual. Defendant Fletcher, rather, is deliberately indifferent to her obligation 

and shames those who so bravely exercised their voice, even if anonymously. None of the 

Commissioner Defendants put forward any agenda item at Commissioners Court or recommended

hiring an independent unbiased investigator to look into the claims asserted through the 

anonymous letters. Their continuing deliberate indifference in the face of known misconduct 

continued to put the women employees of the DA’s office in harm’s way. 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 72

148. The Defendants knew they were violating each Plaintiff’s rights and dared anyone 

one to stop them. It was precisely in this context that Defendant Wirskye told Keith Henslee that 

he didn’t “give a fuck” if the Plaintiffs reported Defendant Willis’ misconduct to HR because the 

DA was “untouchable.” Sadly, Mr. Wirskye had good reason to believe that Defendant Willis was 

“untouchable,” as HR had told several of the Plaintiffs the same thing. While it is true that 

Defendant Willis was independently elected by the voters, the Commissioner’s Court and the 

Human Resources Department had the power and legal duties at all relevant times to investigate, 

discover, and stem the ongoing abuse that Defendants were inflicting upon Plaintiffs and others. 

At all relevant times, the Commissioners had the power and legal duties to fire, demote, reassign, 

and/or reprimand Defendant Wirskye for his hostile and discriminatory work practices. In flagrant 

dereliction of its duties, Collin County chose to look the other way to further empower the abusers 

over its own employees, the abused. The Commissioners’ and Human Resources’ complicity in 

the misconduct of Defendants Willis and Wirskye emboldened those men to believe that although 

they had sworn to uphold the law, they were above it. That time is over. No one is above the law, 

as this case will again demonstrate. 

VI. DAMAGES

149. Plaintiff Kim Pickrell sustained damages including future pecuniary losses including 

future wage loss, loss of wage earning capacity, damage to her professional reputation in the 

community and ability to further her career, emotional pain, suffering, inconvenience, mental 

anguish, loss of enjoyment of life and other nonpecuniary losses for which she is entitled to 

recovery under these causes of action.
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 73

150. Plaintiff Keith Henslee sustained damages including future pecuniary losses including 

future wage loss, loss of earning capacity, damage to his professional reputation in the community 

and ability to further his career, emotional pain, suffering, inconvenience, mental anguish, loss of 

enjoyment of life and other nonpecuniary losses for which he is entitled to recovery under these 

causes of action.

151. Plaintiff Fallon LeFleur sustained damages including lost wages and benefits, future 

pecuniary losses including future wage loss, loss of earning capacity, damage to her professional 

reputation in the community and ability to further her career, emotional pain, suffering, 

inconvenience, mental anguish, loss of enjoyment of life and other nonpecuniary losses for which 

she is entitled to recovery under these causes of action.

152. Plaintiff Vykim Le sustained damages including future pecuniary losses including future 

wage loss, damage to her professional reputation in the community and ability to further her career, 

loss of earning capacity, emotional pain, suffering, inconvenience, mental anguish, loss of 

enjoyment of life and other nonpecuniary losses for which she is entitled to recovery under these 

causes of action.

153. Plaintiff Jane Doe 1 sustained damages, including lost wages and benefits, future 

pecuniary losses including future wage loss, loss of earning capacity, damage to her professional 

reputation in the community and ability to further her career, emotional pain, suffering, 

inconvenience, mental anguish, loss of enjoyment of life and other nonpecuniary losses for which 

she is entitled to recovery under these causes of action.

154. Plaintiff Jane Doe 2 sustained damages, including lost wages and benefits, future 

pecuniary losses including future wage loss, loss of earning capacity, damage to her professional 

reputation in the community and ability to further her career, emotional pain, suffering, 
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 74

inconvenience, mental anguish, loss of enjoyment of life and other nonpecuniary losses for which 

she is entitled to recovery under these causes of action.

155. Plaintiffs individually and in the aggregate are also entitled to declaratory relief that a 

violation has occurred to each individually. Plaintiffs are also entitled to equitable relief in the 

form of an injunction against future discrimination or retaliation individually and in the aggregate.

156. Plaintiffs are entitled to attorneys’ fees, interest on judgment, and costs of Court for 

services rendered in seeking justice in this cause including the trial and appeals.

157. Plaintiffs are also entitled to receive punitive damages because Defendants, individually 

and as an aggregate engaged in harassing, discriminatory and/or retaliatory practices as well as 

engaged in harassing, discriminatory and/or retaliatory practices with malice or reckless 

indifference to the federally protected rights of these aggrieved individuals.

JURY DEMAND

158. Plaintiffs request a trial by jury to the extent allowed by the law.

CONCLUSION

Wherefore, Plaintiffs Kim Pickrell, Keith Henslee, Fallon Lefleur, Vykim Le, Jane Doe 1, 

and Jane Doe 2 request that Defendants Collin County, Texas, Greg Willis, Individually, Bill 

Wirskye, Individually, Darrell Hale, Individually, Susan Fletcher, Individually, Chris Hill, 

Individually, Cheryl Williams, Individually, and Duncan Webb, Individually answer and that on 

final trial, Plaintiffs have judgement against Defendants for compensatory, declaratory, equitable, 

and exemplary damages, attorneys’ fees, expert fees, costs of Court and suit, and interested as 

provided by law, and to any other further affirmative relief to which they may be so entitled.
PLAINTIFFS’ ORIGINAL COMPLAINT AND JURY DEMAND 75

SIMON GREENSTONE PANATIER, P.C.

/s/ Jeffrey B. Simon

JEFFREY B. SIMON

State Bar No. 00788420

jsimon@sgptrial.com

CHARLES E. SOECHTING, JR.

State Bar No. 24044333

csoechting@sgptrial.com

JODEE L. NEIL

State Bar No. 24039848

jneil@sgptrial.com

1201 Elm Street, Suite 3400

Dallas, Texas 75270

Telephone: (214) 276-7680

Facsimile: (214) 276-7699

and

/s/ Susan E. Hutchison

Susan E. Hutchison

State Bar No. 10354100

sehservice@FightsforRight.com

S. Rafe Foreman

State Bar No. 07255200

srfservice@FightsforRight.com

HUTCHISON & FOREMAN, PLLC

500 East 4th St., Ste. 100

Fort Worth, Texas 76102

(817) 336-5533

(817) 887.5471

ATTORNEYS FOR PLAINTIFFS