Free Reply to Response to Motion - District Court of Arizona - Arizona

Case 2:O3—cv—O2300-ROS Document 76-2 Filed O1/30/2006 Page10f2

Liz Slaughter-Payne, PHOENIX VA C, (602)277-5551 ext. 6955
PVB9 DEPT CLOSING POSITION SERIES/GRADE
DATE TITLE
99-02381 IRM 2-5-99 COMPUTER SPEC GS-334-5/7/9
98-00781 IRM 1-30-98 COMPUTER SPEC GS-334-7/9
98-02283 OFF DIR 2-11-98 ADMIN OFF ' GS-341-9/11
98-02881 ERS 3-10-98 COMPUTER SPEC INST GS-334-9
98-06081 IRM 4-10-98 COMPUTER SPEC GS-334-7/9/11
98-11481 IRM 4-10-98 COMPUTER SPEC GS-344-7/9
98-10581 IRM 5-22-98 COMPUTER SPEC GS-344-9/11/12
98-16681 IRM 7-10-98 COMPUTER SPEC _ GS-344-7/9
98-1378 HRMD 7-14-98 PER MGMT SPEC GS-201-9/11/Cancelled
98-14583 OPI 7-15-98 PROGRAM ANALYST GS-343-9/11
98-16581 IRM 7-17-98 COMPUTER SPEC GS-334-9/11
98-15283 ICS 8-5-98 SECURITY ASST GS-086-7
98-20481 IRM 10-16-98 COMPUTER SPEC GS-334-9/11
98-21482 HRMD 11-3-98 PER MGMT SPEC GS-201-7/9/11/Cancelled
97-03282 VISN #18 4-7-97 ADMIN OFF GS-341-7/9 ` _
97-04781 MH&8SS 5-2-97 MED ADMIN SPC GS-301-7/9
97-06881 IRM 6-20-97 COMPUTER SPEC ` GS-334-9/11
97-11581 IRM 9-19-97 COMPUTER SPEC GS-334-9/11
97-13781 IRM 11-3-97 · COMPUTER SPEC GS-334-7/9
97-13981 ERS 11-4-97 COMPUTER SPEC INST GS—334-9
97-14881 P IRM 11-15-97 COMPUTER SPEC GS-334-9/11
97-17581 IRM 12-31-97 COMPUTER SPEC GS—334-9/11
I have been subjected to race discrimination, harassment, and reprisal when I was not
selected for any of the above positions. The agency has asserted that the person's
selected was the best·qualified candidates. I feel the agency has exaggerated the
Selected's qualification while casting a negative light on me.
I am alleging that the agency's reason are pretextual, based on several factors including
the findings of the EEO Counselor who conducted a fact-finding on a previous complaint.
The Counselor found several discrepancies whether there was a vacant position; was there
a selection made; and who was selected for the position? Dona Tyson who was the
supervisor at that time stated that she had referred me to Mr. Moore as one of the
selected for one of the Computer Specialist, GS-334-7/9/11 positions. Mr. Moore states
that I was never selected by anyone. The Human Resource Personnel stated that the
position was never announced and was still vacant at the time of the Counselor's fact-
finding process. Above all no notice of selection was sent to me for any of the Computer
Specialist Position in the IRM Department as of March 17, 1999.
In addition, to my previous EEO activities I will base the discriminatory actions on the
atmosphere at this facility, which is racially tense and that this facilities Management
Staff represents the use of the EEO process by employees. The Management Staff at this
facility, does not support the EEO Program in whole, especially the Black Employee
Program, Hispanic Employee Program or The People with DisaBllities Program.
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Case 2:O3—cv—O2300-ROS Document 76-2 Filed O1/30/2006 Page 2 of 2

Case 2:03-cv-02300-ROS

Document 76-2

Filed 01/30/2006

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Case 2:03-cv-02300-ROS

Document 76-2

Filed 01/30/2006

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