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 Health Benefit Exchange Marketplace ("Marketplace"). 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 Marketplace was due to go live, {{pf}} worked on the weekends and on holidays. l. By all accounts, {{pfl}} had an excellent performance record in his role at the HBX. l. On October 15, 2013, {{pfl}}'s mother grew suddenly ill with a rare disorder of the brain, which required long-term hospitalization. l. From October 15, 2013, through January 15, 2014, {{pf}} took 12 weeks' leave pursuant to the Family and Medical Leave ("FMLA"). l. During that time, the HBX continued to operate without any reduction in the quality of service, due largely to the quality of the team that {{pfl}} had put together. l. On January 30, 2014, {{pfl}}'s mother's condition took a turn for the worse. l. That day, {{pfl}} approached {{df}} to inform his of {{pfl}}'s need to take additional 3 weeks' leave to care for his mother. l. {{pfl}} reminded {{dfl}} that he had not taken any leave before October 15, 2013. l. During that meeting, although Welch did not explicitly refuse, he made the following statement to Sayles: "Are you kidding me right now? You just took 3 months off. If you take any more leave, you might as well forget about having a job when you get back." l. On January 31, 2014, in spite of Welch's attempt to interfere with Sayles's statutory right to take leave, Sayles took 2 weeks' leave to care for his mother. l. On February 17, 2014, when Sayles returned, Welch informed Sayles that he had received the Executive Board's approval to terminate Sayles, effectively immediately. l. Less than six months after the termination of {{pfl}}'s employment, on August 4, 2014, Sayles filed a complaint in the Office of Human Rights ("OHR"), alleging interference with and retaliation for {{pfl}}'s exercise of his DC Family and Medical Leave Act rights. l. On September 1, 2014, OHR issued its determination of no probable cause.