Criminal and Bar Complaint

Complaint Against: Angela Crawford, Candice Brown, Frank Lawrence, David Harris, Lorena McDowell, Scott Warren, and now moot complaint against Nora.

Capacity: EO by RO, RO, and UHPNC by RO

First, thank you for the limited response in the provision of accommodations for TS. EO is extremely grateful to know that his mother was provided some accommodations to allow her to safely enter and exit SWSC. While we are thankful, it appears that you really did not address the allegations of targeting, retaliation, and creating a hostile work environment, etc., under the color of law1, but, we are thankful. Hence, the possibility of acts of this nature continuing is high and will be discussed shortly.

Angela Crawford

1 Summary: Section 242 of Title 18 makes it a crime for a person acting under color of any law to willfully deprive a person of a right or privilege protected by the Constitution or laws of the United States. For the purpose of Section 242, acts under "color of law" include acts not only done by federal, state, or local officials within their lawful authority, but also acts done beyond the bounds of that official's lawful authority, if the acts are done while the official is purporting to or ………

People who work for the government hold substantial authority due to their position, but this authority is not unlimited. Government officials and employees generally cannot violate the civil rights of people who interact with them. Someone who has suffered a violation of their civil rights at the hands of a state or local government official can bring a Section 1983 claim. Section 1983 (42 USC Section 1983) is a federal law that allows citizens to sue in certain situations for violations of rights conferred by the US Constitution or federal laws. Section 1983 only provides a right of access to state or federal courts, rather than any substantive rights.

A plaintiff who prevails in a Section 1983 claim may be awarded monetary damages, and a court also may issue an injunction. Damages may cover items such as medical bills to treat any injuries, lost wages caused by time missed from work, and any pain and suffering or emotional distress. Punitive damages may be awarded in especially extreme cases. An injunction is a court order that tells someone to do or stop doing something. A court might order a change to policies or procedures that would prevent future violations.

The complaint against Angela Crawford embraces the failure to implement and enforce policies to ensure positions in Wake County Government are subject to EEOC standards and not in violation of civil rights act and the ADA, etc.. How many years does it take to respond to a claim that you are causing or allowing to be caused an environment where supervisors and upper management use their race, ethnicity, and personal prejudice to clear government employment positions for their friends, and/or relative, and, in no fashion have open and competitive hiring practices? The complaint her against here is allegations and belief that she just turns a blind eye to what happens in Wake County government, and thereby willful refuses to carry out the duties she was assigned to ensure county employee are following all federal, state, city, and local laws, ordinances, policies, and/or procedures (see video). Government employees like Candice Brown and Frank Lawrence feel at liberty to govern under their personal prejudices. It is believed and herein alleged that the “Mass Exodus” of Hispanics from WCHS and other departments of Wake County Government was caused or allowed to be caused by the failure to enforce federal, state, city, and local laws, etc., that created or allowed to be created a customary practice wherein employees just “do what they want” and create “hostile work environment” with some of the intended purposes is to “clear government positions”. We are alleging and complaining against her willful, deliberate, flagrant violations of federal, state, city, departmental, policies, procedures, and practices that are designed and enacted to ensure persons are not discriminated against based on race, religion, ethnicity, and more importantly, DISABILITY, AND GENDER.

How long does it take to ensure the county has open and competitive hiring practices? And, is she in the position to have oversight over the hiring and retention practices of Wake County employees. The answer is yes, and, it should not have taken over 3 years to get a policy in place

and take corrective action and not be negligent in performing your duties. We allege her failures and negligence caused or allowed to be caused the injuries to several employees at SWSC. Wake County is paying hundreds of thousands it workman’s compensation and other settlements because, we allege, upon information and belief, the failure to perform her duties.

Candice Brown

It is still difficult to know that Candice Brown felt at liberty to try to force TS to resign by the deprivation, we allege, of an ADA accommodation. We know TS may not be willing to take a firm stance against the acts by Candice Brown, but, we disagree (EO by RO; RO, UHPNC). Hence, this complaint is that Candice Brown is willful abandoning her duties as a supervisor in following first and foremost shelter policy. We also allege that she abandoned her duties by acting under the color of law to violate federal, state, city, and local laws and policies designed and enacted to ensure employees and guest and visitors of the South Wilmington Street Center for Men are safe and the provisions of services is meeting all laws and polices, etc. Again, the environment at SWSC is not safe, we allege, for employees and guests and visitors. Her acts go beyond the unsafe conditions caused by the improper administration and implementation of the low barrier model in the provision of shelter and community based services. We cite the termination of Orlando McClain and the targeting of TS as the current acts to support such a claim (again, this complaint and accompanying videos is not being submitted with the consent or knowledge of either of these two individuals) [TS and OM may decide to pursue things in their own capacities, or not to pursue things and take action, but, we are compelled to complain and take actions regardless of their perspectives; OM should really hire an attorney and collect big time against the

county, we believe]. Primarily, to speak truthfully, this is an attempt to see if the county will take action to stop these acts and then subsequently implement corrective policies and actions to finally reach the intended goal of having open and competitive and nondiscriminatory policies and practices and safe and non-hostile work environments. Is the county able to see the increase danger caused to employees of injury because of the acts of Candice Brown that are alleged? Is threatening allied security an acceptable practice?

Frank Lawrence

Not sure what kind of deal the county made with Frank, but, this complain addresses the claim and allegation that now he is working with Candice Brown to use their personal prejudices, under the color of law, to engage in acts that go against federal, state, city, local, and shelter policies. We are alleging he is flagrantly, blatantly, deliberately targeting employees like TS and OM. He chose not to undo the actions of Candice Brown, and we are alleging (EO by RO, RO) that he engaged in personal attacks on TS and OM to clear the two line staff positions. This is our allegation upon information and belief. We cited in the past these acts and did approach and communicate with the county attorney to address such. Hence, for it to continue and repeat shows this is an engrained customary practice on the part of the county. You all failed to take corrective action, and here we go again. The signature of Frank Lawrence is the only signature that appears on the termination notice of Orlando McClain. Frank allowed Candice to target TS and OM. And, he is cited as having written up TS in the past with bias and prejudice while attempting to defend herself against a hostile guest, as OM did against a hostile guest. Again, Low Barrier concepts did not support the further placing of employees in jeopardy of physical and verbal injury by guest

because supervisors and upper administration willfully, blatantly, flagrantly, violate federal, state, city, and local laws, policies, etc., designed to protect government employees and guest and visitors. When TS was at risk of an attack by a guest, she availed herself of the right to defend herself against an attack, and, instead of protecting her right, she was written up by FL. So too, while the facts are at controversy, it appears OM was being attacked, at least one employee viewed events as such, and, instead of supporting his right to defend himself against a personal threat of bodily injury (although he personally seems to have a lack of insight as to the actual threat of harm he was facing, upon information and belief, this presents as a cultural issue in part), FL supported CB in her attempts to target OM. We are alleging both supervisors are working together in creating a hostile work environment that is extremely dangerous to employees and guests. NO WHERE CAN IT BE FOUND THAT FRANK WROTE UP CANDICE BROWN FOR HER FAILURE TO FILE AN INCIDENT REPORT, IF SHE BELIEVED THE EVENTS OCCURRED ACCORDING TO HER ACCOUNT, OR THAT ANY ADVERSE ACTION WAS EVER TAKEN AGAINST CANDICE AT ALL FOR ACTING UNDER THE COLOR OF LAW IN VIOLATION OF SHELTER POLICY, ETC. Only one synopsis entry, and no incident reports, etc. A reasonable person can conclude the both are working together. We are alleging and complaining that CB and FL are working together in violation of federal, state, city, shelter, and local policies and practices and laws and ordinances that govern the operation of SWSC, under the color of law. Open and competitive hiring cannot exist when you have two supervisory staff members working together, under the color of law, to pursue their personal prejudices.

Scott Warren, Lorena McDowell, Nora and David Harris

The key and operative words are UNLESS THE FAILURE TO COMPLY HARMS THE

EMPLOYEE OR HIS RIGHTS UNDER THIS SECTION (TO INCLUDE THE RIGHT OF SELF

DEFENSE). OM was harmed we are complaining of and alleging by the acts of CB and FL, and

failure to act by DH, LM, Nora, AC, and SW.

It is written, it requires the approval by the department head and review by the County Attorney’s

office. Herein, UHPNC is alleging, upon information and belief, that this did not take place. Had

you reviewed all evidence, we believe a different conclusion would have been reached. Again, in

the dismissal document, only one signature appears, and there is no evidence the matter was

properly reviewed, this is also using a reasonable person standard especially considering Frank

was not even present for the incident in question.

Just the signature of FL. No indication of review by anyone because no other signatures are presen.

Analysis of the charging dismissal document is this, it is written:

Here, it is alleged no reasonable request was issued, and, more importantly Section 3.15 can in no way EVER BE CONSTRUED AS APPLICABLE WHEN THE THREAT OF PHYSICAL VIOLENCE IS RECEIVED BY A GOVERNMENT EMPLOYEE, SWSC STAFF, WHEN CONFRONTING A GUEST FOR VIOLATION OF POLICY, WHOM, AS THE DAVIS NOTE SHOWS AND, A REASONABLE PERSON STANDARD, CAN CONCLUDE THE GUEST WAS PROBABLY HIGH BUT AT MINIMUM WAS ENGAGING IN PROHIBITED ACTIONS. THIS CANNOT BE THE POLICY AND PROTOCOL TO BE USED IN HOSTILE AND THREATENING INCIDENTS THAT MAY CAUSE AN EMPLOYEE TO FIRST THINK AND REACT UPON THEIR OWN IMMEDIATE EMERGENCY PERSONAL NEEDS TO STAVE OFF AN IMMINENT ATTACK. EMPLOYEES HAVE A RIGHT TO DEFEND THEMSELVES AGAINST ASSAULT AND BATTERY.

THIS IS A PUBLIC MATTER, AND THIS DOCUMENT IS A PUBLIC COMPLAINT.

OM claims no consideration of all evidence, and that was raised during the conference:

The employee made this request for evidence and a rehearing (supervisory level) but that was not

responded to by David Harris, Lorena McDowell, Nora, Angela Crawford, or the county attorney.

During the pre-conference dismissal, FL willfully, blatantly, flagrantly, and in a manner

unbecoming a center manager withheld evidence in his possession, and that was a flagrant

violation of Wake County Policy and procedural due process. Employee relations was contacted

and denied OM request that is found in the completed grievance form.

Really guys. Whatever happens at SWSC stays at SWSC seems to be the customary practice. Negligence is being alleged here, upon information and belief, that David, Lorena, Angela, Nora, and Scott failed to perform their investigory and oversight duties. And, also, as has been the contention for many years now, no open and competitive hiring exist by custom and practice in Wake County Government, as evidenced through its departments and complicity by upper management. A guy is losing his career because you all allow prejudice and under the color of law at the higher levels of administration. This is a public complaint and request for a thorough investigation of the matters herein contained. Negligence is the claim against upper administration that entrench these customs and practices that are against the law.

Sincerely,

Reinaldo Olavarria

More in depth video request for a Complaint and Investigation

https://youtu.be/WaCkLvRq7ww

Amended Complaint with Information Specific to the Wake County Commissioners and Wake County Managers.

Named Officers in This Complaint: Matt Calabria, Chair; Sig Hutchinson, Maria Cervania, Susan Evans, James West, Shinica Thomas, Vickie Adamson [Wake County Board of Commissioners, for Federal]; David Ellis, Duane Holder, Ashley Jacobs, Emily Lucas, Chris Dillon, and Denise Forman [County Managers for Federal, Due Diligence]. Lastly, Scott Warren of the County Attorney’s Office.

Background Information

Since 2015, the push of many activities has been to foster the establishment and growth diverse state and local government that are responsive to the citizens they are charged to serve. To that end, litigation both past and presently contemplated is pursued to achieve those goals. Evidence of continued attempts to reach those goals may be found on Reyoadvocacy.org and Reyoadvocacy.com. The showing of unresponsive government officials is shown in the past three months by the failure to respond to pre-litigation attempts to resolve this matter and not go to court, due diligence.

An Analysis of the Core Principles of Wake County will help to present this cause of action.

Wake County Core Value: Act with honesty, transparency and respect in our interactions with co-workers and those we serve. Adhere, without exception, to laws, policies, procedures and professional standards.

Here, the commissioners and county manager failed to respond to complaints regarding the failure to act with honesty by Candice Brown and Frank Lawrence. Here, the commissioners and county managers failed to respond to complaints about transparency with regards to Human Resources Officers Angela Crawford and Tanika Bryant. Here, the commissioners and county managers failed to respond to complains about respect and hostile workplaces with regards to Candice Brown, Frank Lawrence, David Harris, and Lorena McDowell. Here, the commissioners and county managers failed to respond to complaint about non-adherence to laws, policies, procedures, and professional standards with regards to Candice Brown, Frank Lawrence, David Harris, Tanika Bryant, and Lorena McDowell.

Wake County Core Value: Establish high-quality standards for our work. We add value. Measure results and hold ourselves and one another accountable for making progress toward our desired outcomes. Take a logical and data-driven approach to decision making.

Here, the commissioners and county manager failed to respond to complaints regarding high quality of work with regards to acts by Candice Brown, Frank Lawrence, David Harris, and Lorena McDowell. Here, the commissioners and county manager failed to respond to complaints regarding holding Candice Brown, Frank Lawrence, David Harris, Lorena McDowell, Tanika Bryant, and Angela Crawford accountable for failing to abide by and carry out their charged duties

(to date, no one has been held accountable for acts complained of). Here, the commissioners and county manager failed to respond to complaints aforementioned employees and caused or allowed to be caused chaos on the county level with no decision making or leadership evidenced by the commissioners and county managers.

Wake County Core Value: Believe that different backgrounds and experiences strengthen the organization and produce better results. Value inclusion across race, color, national origin, gender identity, age, religion, sex, disability and experience, and strive to reflect in our workforce the diversity of our community.

Here, the commissioners and county manager failed to respond to complaints regarding Candice Brown, Frank Lawrence, David Harris, Lorena McDowell, Angela Crawford, and Scott Warren with regards to open and competitive hiring never being implemented at the county level to embrace the diversity this core value expresses, especially with regards to the employment of the disabled and veterans and persons of Hispanic origin. The resulting workplace is not diverse as the community it serves due to the failure to act by the commissioners and county managers. County employees are allowed to profit from the hiring of their friends and do receive favors for such, upon information and belief, a violation of ethics policy that went un-responded to by the commissioner and managers.

Wake County Core Values: Inspire and empower employees and their families to live their best lives by taking proactive steps to be physically fit and healthy, emotionally strong, financially secure and socially fulfilled. Offer high-quality workplace wellness programs and activities to help achieve personal health goals, as well as the time and tools to support active participation. ……..

Foster a work culture in which different ideas and opinions are encouraged and expected. Listen carefully and speak thoughtfully. Achieve greater success when we work together toward shared goals with mutual respect and cooperation. No one is in this alone.

Here, the commissioners and county manager failed to respond to complaints regarding unsafe conditions created by Candice Brown, Frank Lawrence, David Harris, Lorena McDowell, Tanika Bryant, Angela Crawford, Scott Warren, and Regina Pettyway. One environment cited in complaints regards the South Wilmington Center for Men and the other location was Wake County Human Services. Guests, employees, and citizens are not safe and/or have been subjected to hostile employment and service conditions due to the failure to act by the commissioners and managers.

Wake County Core Values: Continuously improve our work processes and products. Provide a safe environment to be innovative and creative and try new things. When things don’t go as planned, we use it as an opportunity to learn, regroup and begin again. Provide time and resources for individuals to grow and develop both personally and professionally. …….. Commit to making a difference within our community. Actively engage in and enjoy our work. Deliver services that exceed expectations, with courtesy, politeness and sensitivity to the experiences, concerns and feelings of all co-workers and customers.

Here, the commissioners and county manager failed to respond and even acknowledge complaints at all. Typically, within one to two business days, an entity, board, or commission, will respond to any alleged complaints. Here, no response at all was received.

Upon information and believe, the commissioners and county managers are directly responsible for allowing a hostile work environment wherein diversity and multiculturalism are shunned and not to be embraced. That includes the failure to adhere to state laws, for example, with regards to threats1 of harm in the work place by citizens and guest.

More recent acts include the ongoing harassment and retaliation by Candice Brown against Theresa Smith with additional false reports by Candice Brown. More recent acts include the failure to provide evidence to Orlando McClain so that he could properly defend himself against false allegations. More recent acts include Lorena McDowell focusing on “glamor and spotlight” of her position and failing to provide the administrative lead over the programs she is in charge of evidenced by failing to investigate thoroughly the compliant of Orlando McClain.

I need to make sure I performed my due diligence by communicating my concerns and documenting such in writing. Let me say this, there is a video that shows the proper response to a communicated threat2 [really, ensure your safety first, call law enforcement, make a report, and press criminal charges, that’s all folks, but not at SWSC it appears].

Statutory wise, all agencies including boards and commissions are charged with making sure they make attempts to mitigate complaints and avoid going to court. Here, the Wake County Board of Commissioners and the Wake County County managers have established a prima facie case by failure to respond and even acknowledge a complaint. This is now establish and chief cause of

1 Communicating threats a crime that is government by North Carolina General Statute 14-277.1. Under this statute, it is against the law to willfully threaten to injure a person, a person’s spouse, a person’s child, or a person’s property. It is not enough to simply make the threat.

2 https://youtu.be/YwVPISb3nPo

action of this complaint. Your legal counsel is supposed to guide you in these matter and has a charge in complaints regarding criminal activities by Wake County Employees, but, it seems like “no one wants to execute their duties” in a faithful and good faith manner.

Sincerely,

Reinaldo Olavarria