COMPLAINT
l. This action arises under the DC Family and Medical Leave Act of 1990 (D.C. Official Code § 32-501 et seq.). l. This court has jurisdiction over this action pursuant to D.C. Official Code § 11-921. l. Plaintiff, {{pf}}, is, and at all times relevant to this action was, a citizen of the District of Columbia. l. Defendant {{df}}, is, and at all times relevant to this action was, a citizen of the District of Columbia. l. Defendant {{df}} is, and at all times relevant to this action was, the Executive Director of the District of Columbia Health Benefit Exchange Authority ("HBX"), an instrumentality of the District of Columbia with a legal existence separate from the District government. l. The HBX is responsible for "[e]nabl[ing] individuals and small employers to find affordable and easier-to-understand health insurance" and was created in accordance with the federal Patient Protection and Affordable Care Act. l. On June 1, 2012, {{pf}} was hired to serve as the Chief Information Officer for the HBX. l. Among his responsibilities, {{pfl}} was in charge of ensuring a smooth launch of the District's Exchang l. From the date of his hire, {{pf}} had a perfect record attendance at the HBX. l. In fact, during the run-up to October 1, 2013, when the Exchange was due to go live, {{pf}} worked on the weekends and on holidays