- In or around December of 2022, Plaintiff began treatment for depression with her
primary doctor, Dr. Khan, and a therapist, Dr. Eileen Boland.
- Around this time, work was becoming triggering for Plaintiff. She routinely
received emails from Baldwin stating how horrible the Plaintiff was and belittling her,
exacerbating Plaintiff's depression.
- On or about December 5, 2022, Plaintiff contacted Baldwin and stated that she
needed a leave of absence due to her ongoing struggles with her mental health.
- Baldwin advised Plaintiff to contact Defendant Senior People Experience Partner,
Tameka Henderson ("Henderson"). Plaintiff then mailed Henderson and requested a leave of absence.
- Defendant Manager Robin Oldt ("Oldt") responded to Plaintiff's email and stated
that Plaintiff needed to call and file a claim with Defendant's leave administrator and agent.
- Plaintiff proceeded to contact Defendant's leave administrator and agent and
opened a claim. Plaintiff informed Defendant's leave administrator and agent that she needed go on leave due to her depression.
- Defendant's leave administrator and agent told Plaintiff that they would be sending
the appropriate paperwork to her doctors, who were aware Plaintiff was seeking leave from work.
- Plaintiff leave was scheduled to begin on December 5, 2022, and end on February
5, 2023.
- On or about January 6, 2023, Plaintiff received a text from Baldwin. In said text,
Baldwin stated that she assumed Plaintiff had received a letter from Henderson outlining the separation process and that they needed to pick up Defendant property.
- Plaintiff responded that she was on leave, to which Baldwin replied that Plaintiff
needed to speak with Henderson.
- On or about January 10, 2023, Plaintiff had a meeting with Henderson and Baldwin.
- Plaintiff reiterated that she was on FMLA leave and that her return-to-work date
was February 6, 2023.
19, On or about February 2, 2023, Baldwin reached out once again to Plaintiff asking
if she received a letter from Henderson regarding Defendant assets.
- Plaintiff responded that she had not and that she was still on leave but was returning to work that following Monday.
- Baldwin then stated that Defendant's leave administrator and agent had not
received any paperwork regarding Plaintiff's leave and as such, termination of Plaintiff's
employment was inevitable.
- The following day, on or about February 3, 2023, Plaintiff's medical provider
forwarded Defendant FMLA leave administrator's paperwork, certifying her need for leave.
23, Defendant then terminated Plaintiff's employment on or about February 6, 2020,
despite the fact that her FMLA leave had been approved through February 5, 2023.
- Defendant's leave administrator, following the termination of Plaintiff's
employment, subsequently changed the end date of Plaintiff's FMLA leave from February 5, 2023, to January 27, 2023,
- At all times set forth herein, Plaintiff was an "eligible employee" for medical leave
under the Connecticut FMLA within the meaning of Conn. Gen. Stat. § 31-5 lkk.
- At all times set forth herein, Defendant was an "employer" within the meaning of
Conn. Gen. Stat. § 31-51kk.
source: https://storage.courtlistener.com/recap/gov.uscourts.ctd.154937/gov.uscourts.ctd.154937.1.0.pdf