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Created October 12, 2014 11:51
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legalmd-gist
levels:
- form: '$x.'
num: 1
- form: '$x.'
num: A
- form: ($x)
num: 1
pf: Emery Sayles
pfl: Sayles
df: Henry Welch
dfl: Welch

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

<p>COMPLAINT</p>
<ol>
<li><p>This action arises under the DC Family and Medical Leave Act of 1990 (<a href='http://dccode.org/simple/sections/32-501.html'>D.C. Official Code § 32-501</a> et seq.).</p></li>
<li><p>This court has jurisdiction over this action pursuant to <a href='http://dccode.org/simple/sections/11-921.html'>D.C. Official Code § 11-921</a>. </p></li>
<li><p>Plaintiff, Emery Sayles, is, and at all times relevant to this action was, a citizen of the District of Columbia.</p></li>
<li><p>Defendant Henry Welch, is, and at all times relevant to this action was, a citizen of the District of Columbia.</p></li>
<li><p>Defendant Henry Welch 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.</p></li>
<li><p>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. </p></li>
<li><p>On June 1, 2012, Emery Sayles was hired to serve as the Chief Information Officer for the HBX.</p></li>
<li><p>Among his responsibilities, Sayles was in charge of ensuring a smooth launch of the District's Exchang</p></li>
<li><p>From the date of his hire, Emery Sayles had a perfect record attendance at the HBX.</p></li>
<li><p>In fact, during the run-up to October 1, 2013, when the Exchange was due to go live, Emery Sayles worked on the weekends and on holidays </p></li>
</ol>
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