Skip to content

Judicial Watch • Packer v Hastings Complaint 03072011

Packer v Hastings Complaint 03072011

Packer v Hastings Complaint 03072011

Page 1: Packer v Hastings Complaint 03072011

Category:General

Number of Pages:36

Date Created:March 7, 2011

Date Uploaded to the Library:February 20, 2014

Tags:Packer, Hastings, 03072011, complaint


File Scanned for Malware

Donate now to keep these documents public!

  • demand_answers

See Generated Text   ˅

Autogenerated text from PDF

UNITED STATES DISTRICT COURT 
FOR THE DISTIUCT COLUMBIA 
WINSOME PACKER, 203 Yoakum Parkway 
Unit 817 
Alexandria, 22304 
Plaintiff, 
Case: 11-cv-00485 
THE UNITED STATES 
Assigned Collyer, Rosemary 
COMMISSION SECURITY 
Assign. Date 3/7/2011 
AND COOPERATION EUROPE 
Description: Employment discrimination 
234 Ford House Office Building 
Washington, 20515 
and 
ALCEE HASTINGS 
5010SW1015tTcrrace 
Miramar, 33027 
and 
FRED TURNER 
8816 Hamess Trail 
Potomac, 20854 
Defendants. 
COMPLAINT FOR DECLARATORY 
AND MONETARY RELIEF AND JURY DEMAND This civil action against the United States Commission Security and 
Cooperation Europe ("the Commission"), U.S. Representative Alcee Hastings, and Fred 
Turner for declaratory and equitable relief and monetary damages for injuries plaintiff Winsome 
Packer has sustained result Mr. Hasting's sexual harassment her and the subsequent retaliation against her for complaining about the unlawful harassment, violation the Section and 207 the Congressional Accountability Ac1, 2U.S.C.1311, seq. and the First and Fifth Amendments the Constitution the United States. For over two years, from January2008 through February 19, 2010, Ms. Packer was forced endure unwelcome sexual advances, crude sexual comments, and unwelcome touching Mr. Hastings while serving the Representative the Commission the United States Mission the Organization for Security and Cooperation Europe. Although Ms. Packer repeatedly rejected Mr. Hastings' sexual attention and repeatedly complained about the harassment the Commission Staff Director, Fred Turner, Mr. Hastings refused stop sexually 
harassing her. Rather, Mr. Hastings and Mr. Turner began retaliate against Ms. Packer
including making threats oftermination-because she continued object Mr. Hastings' conduct. Ms. Packer was particularly vulnerable such threats because she was Republican working for the Democraticallycontrolled Conunission, point that both Mr. Hastings and Mr. Turner used threaten and intimidate her. Eventually, the emotional distress, anxiety, and 
humiliation caused the sexual harassment and retaliation caused Ms. Packer suffer severe health problems and forced her leave her prestigious position. 
Jurisdiction and Venue This Court has jurisdiction over Plaintiff's claims pursuant U.S.C.  1331 
and U.S.C.  1408. Venue proper this district under U.S.C.  139 l(b)(2) because substantial 
part the events omissions giving rise Ms. Packer's claims occurred the District 
Columbia. the alternative, venue proper this district under U.S.C.  1391(b)(J) 
because the Commission can found the Distiict Columbia and there other district which the action may otherwise brought. 
Parties Winsome Packer citizen the Commonwealth Virginia who resides 203 Yoakum Parkway, Unit 817, Alexandria, Virginia, 22304. Ms. Packer became employee the Commission Security and Cooperation Eurnpe May 2007. Ms. Packer "covered employee" under U.S.C. 1301 (3). The United States Commission the Security and Cooperation Europe 
plaintiff's "employing office" under U.S.C.  1301(9)(13) and/or 1301(9)(C). Alcee Hastings citizen the State Florida who resides 5010 101 
Terrace, Miramar, 33027. Mr. Hastings represents the 23rd Congressional District Florida and served the Chairman the Commission during the llO'h Congress, which was from January 2007, through January 2009. the 111 Congress, Mr. Hastings served the CoChainnan the Commission, which was from January 2009, through January 2011. Fred Turner citizen the State Maryland who resides 8816 Harness 
Trail, Potomac, Maryland, 20854. all times relevant this complaint and Ms. Packer's 
claims, Mr. Turner served the Staff Director the Committee and was Ms. Packer's direct 
supervisor. Ms. Packer highly educated and experienced professional, who has dedicated her career policy work. Ms. Packer holds Bachelor Arts International Affairs and Master Public Administration. She has extensive experience professional staff rnemberfirst for the Committee Veterans' Affairs for the U.S. House Representatives and later for 
the Committee Homeland Security for the U.S. House Representatives. Among her many other professional accomplishments, she was appointed United States Delegate the United Nations Commission the Status Women and has worked for various policy think tanks. 
10. From 2003 through December 2006, Ms. Packer served Republican 
Professional Staff Member for the Committee Homeland Security. During this time, the 
Republican Party cunlrolled ilie U.S. House Representatives. the 2006 national election, 
however, the Democrats won majority seats the House Representatives, allowing them gain control that chamber Congress. Pursuant the change leadership, Ms. Packer's 
position was eliminated and she became unemployed starting January 2007. 
11. March 2007, while walking down Street Washington, D.C., Ms. 
Packer encountered Representative Alcee HastingsMs. Packer and Mr. Hastings were 
acquainted with each other through friend Ms. Packer who had served staff member Mr. Hastings' office for many years. During their conversation, Mr. Hastings learned that Ms. Packer was unemployed. response this news, Mr. Hastings informed her that, the new Chair the U.S. Commission Security and Cooperation Europe, was position appoint her the Commission staff. then recommended that she schedule appointment speak w.ith him about applying for position. 
12. Although very interested the work the Commission, Ms. Packer initially 
chose not contact Mr. Hastings about the position because was Democrat and she was 
Republican. However, April 2007, Ms. Packer still had firm employment leads, she 
scheduled meeting wilh Mr. Hastings speak further about potential position. Prior 
meeting with Mr. Hastings, Ms. Packer provided him with copy her resume, which clearly 
indicated her political affiliation with the Republican Party. 
13. the interview, Mr. Hastings did not discuss question Ms. Packer about her 
qualifications for position with the Commission her political affiliation. Instead, simply 
explained that, the new Chair the Commission, wanted make significant staffing changes. Despite her political affiliatio Mr. Hastings offered Ms. Packer position during that April 2007 meeting. 
14. Ms. Packer began working the Commission May 2007, Policy 
Advisor. Fred Turner, the Staff Director, was, and continued be, her supervisor the Commission until February 14, 2010. Prior Mr. Hastings appointing him Staff Director, 
Mr. Turner had served Mr. Hastings' staff for over ten years. number occasions, 
during her first few months the Commission, Mr. Turner indirectly questioned Ms. Packer's 
loyalty Mr. Hastings because she was Republican. For example, Mr. Turner accused Ms. 
Packer writing better speech for Republican member the Commission comparison the speech she had written for Mr. Hastings. another occasio chastised her for including positive comments about U.S. Representative Christopher Smith, Republican Member Congress, letter recommendation from Mr. Hastings the President the Organization for Security and Cooperation Europe Parliamentary Assembly and requested that she remove those comments. addition verbally assuring Mr. Tum her loyalty, Ms. Packer worked extremely hard produce quality work order demonstrate that she was dedicated her position and loyal Mr. Hastings. Mr. Turner's conduct, however, made clear Ms. Packer 
that, Republican, she was more vulnerable her position than other staff members the 
Commission. 
15. December 2007, Mr. Turner met with Ms. Packer inform her that Mr. 
Hastings wanted appoint Ms. Packer the Representative the Commission the U.S. 
Mission the Organization for Secmity and Cooperation Europe. This position was posted 
Vienna, Austria, and was considered many the most prestigious staffposition the Commission. Mr. Turner explained that Mr. Hastings believed her the most qualified staff member for the position because the quality her work and her international work experience. Although flattered the offer, Ms. Packer had reservations regarding the position and expressed them the meeting. Mr. Turner, however, strongly recommended that Ms. Packer try the position for year and promised that, she wished return her position Policy Advisor, she could return the end the year. With this guarantee, Ms. Packer agreed take the position. 
16. Ms. Packer was scheduled assume her post Vienna the Representative the Commission February 2008. January 2008, Ms. Packer was preparing for departure, Mr. Hastings invited her and Mischa Thompson, fellow staff member the Conunission, dine with him alone. When making the invitation, Mr. Hastings expressly requested that they not inform Mr. Turner about the dinner. Ms. Packer found this request strange, but since the invitation also included Ms. Thompson, she accepted. After dinner, while Ms. Packer and Mr. Hastings walked from the restaurant, with Mischa Thompson few paces behind, Mr. Hastings told Ms. Packer that once she had found and settled into her new apartment Vienna, would come Vienna stay with her for week. This comment made Ms. Packer extremely uncomfortable because Mr. Hastings seemed inviting himself visit her personal and romantic capacity, not the Chairman the Committee, since the Chair would never stay staff member)s apartment lieu having lodging his own. Wishing avoid upsetting lvir. Hastings, Ms. Packer simply ignored the comment and said nothing. 
The next day, however, Ms. Packer did inform her officemate, Shelly Han, about the incident and expressed her concern about Mr. Hastings' advances. Ms. Han advised her speak with Mr. Turner about Mr. Hastings' conduct, but Ms. Packer hesitated out fear that, given her status Republican, such complaint would further complicate her relationship with Mr. Hastings and Mr. Turner. 
18. Within week the dinner detailed Paragraph 16, .Hastings called Ms. 
Packer the Commission and inquired about the progress her preparations for departure. 
After only few minutes discussing her departure, Mr. Hastings repeated that when she was settled Vienna, would come and stay with her for week. Mr. Hastings' comment again made Ms. Packer uncomfortable because the implication that was pw-suing romantic relationship with her. Ms. Packer's suspicions were further confirmed when asked where she was currently living. When Ms. Packer replied that she lived Alexandria, Virgjnia, Mr. Hastings annoSince Ms. Packer was not 
unced that should come over "check her." interested hosting Mr. Hastings alone her house, especially given his earlier statements that 
indicated his romantic interest her she responded that she would happy have 'Mr. Hastings and Mr. Turner dinner before she left for Vienna. Mr. Hastings responded, "That's 
all right," and immediately ended the phone call. 
19. Ms. Packer moved Vienna February 15, 2008, and immediately began 
working. Policy Advisor, Ms. Packer's annual salary was $80,000. her new position, Ms. Packer received per diem that raised her yearly income $165,000. 
20. February 2008, shortly after Ms. Packer anived Vienna, Mr. Hastings 
traveled Vierum member congressional delegation. Ms. Packer was sitting with 
several colleagues the delegation room when she first encountered Mr. Hastings during the 
trip. Upon entering the room, Mr. Hastings immediately walked over Ms. Packer the other 
side the room and handed her small bag, which contained music box that had purchased 
for her the Czech Republic. Mr. Hastings did not bring gifts any other staff member. Ms. Packer was embarrassed the special attention paid her the Chairman and was offended that continued pursue her romantically, since she had not responded his earlier attempts initiate relationship. Ms. Packer later gave the music box her co-worker, Mischa Thompson, and told her that she was very uncomfortable with the fact that Mr. Hastings had given the gift and that had done public. 
21. Approximately hour after Mr. Hastings arrived, asked Ms. Packer fetch 
him some ice. then followed her across the room and, once they had reached area where they were out earshot others, again told her that once she had apartment would come stay with her for week. His continued pursuit romantic relationship with her upset Ms. Packer, especially since was now making advances professional settings. 
22. Fifteen minutes after Mr. Hastings made the comment referenced Paragraph 21, 
Ms. Packer asked Mr. Turner, who had accompanied Mr. Hastings the congressional 
delegation, speak privately. Once they had walked private room, Ms. Packer detailed Mr. 
Hastings' recent conduct towards her. She explained th.at the last month Mr. Hastings had 
invited himself three times stay with her Vienna for week and th.at also had invited 
himself visit her her home Alexandria, Virginia. Mr. Turner's first response was ask Ms. Packer she had ever had romantic relationship with Mr. Hastings. Ms. Packer responded that she had never had anything but professional relationship with Mr. Hastings, that she did 
not welcome his advances, and did not want engage romantic relationship with him. Mr. 
Turner initially looked surprised, but then assured Ms. Packer that was glad she came him 
about the matter and that would speak Mr. Hastings and would ensure that knew her 
feelings the matter. Mr. Turner also instructed her call him immediately Mr. Hastings 
ever called tell her that was "getting plane visit [her]." 
23. From March through September 2008, even though Mr. Tmner had promised Ms. 
Packer that would speak Mr. Hastings about the Congressman's attentions towards her, Mr. 
Hastings began call her approximately every other week under the pretense work-related matters. However, within minute two conversation, Mr. Hastings would deviate 
personal matters try arrange time for them see each other. Prior Mr. Hastings' 
expressions romantic interest Ms. Packer, the Congressman had never called regular basis about either personal work-related matters. Upon information and belief, Mr. Hastings 
did not call other staff members similar fashion. 
24. The first time Mr. Hastings called Ms. Packer was March 2008. the call, infonned her that would attending OSCE Parliamentary Assembly Bureau meeting Copenhagen and requested that she join him the meeting. After his advances during his visjt 
few weeks before, Ms. Packer was not comfortable traveling with him non-mandatory meeting such the one Copenhagen, she told him that she was still settling and learning 
her new job responsibilities, which made her unsure she would able travel 
Copenhagen. After the call ended, Ms. Packer immediately called Mr. Turner and informed him ofMr. Hastings' request that she join him Copenhagen and expressed her concern about 
traveling with the Congressman. Mr. Turner counseled Ms. Packer explain Mr. Hastings 
that Mr. Turner had determined that she was not needed the meeting because she was too busy Vienna. Ms. Packer relayed this information Mr. Ilastings and she did not attend the 
Copenhagen meeting. 
25. May 2008, Mr. Hastings traveled Vienna for another meeting. This was the 
first time that Ms. Packer had been arotllld him since the meeting February 2008, when Mr. Turner promised speak Mr. Hastings about ceasing any romantic advances towards her. When Ms. Packer saw Mr. Hastings the meeting, immediately approached her, hugged her with both arms, pressed his body against her body and pressed his face against her face. Prior that instant, Mr. Hastings had never hugged her such manner. Ms. Packer was tlllcomfortable wilh this intimate touching and was particularly upset was done front her colleagues and after Mr. Turner had allegedly counseled him against making any romantic 
advances. 
26. the same day May 2008, referred Paragraph 25, Mr. Hastings repeatedly made sexual comments and around Ms. Packer. First, they rode car alone together meeting Vienna, Mr. Hastings complained Ms. Packer that was having trouble sleeping. Ms. Packer sympathized with Mr. Hastings and replied that, when she has had trouble sleeping the past, she found exercise helpful. Mr. Hastings replied that while exercise worked for some people, "even after sex, continue wide awake." His sexual remark made Ms. Packer uncomfortable, especially after his earlier intimate hug and his prior romantic advances. 

27. dinner that same evening, conversation initiated Mr. Hastings, commented Ms. Packer that the only reason was dating Patricia Williams, the Deputy District Director, was because she had been his cotlllsel his bribery and impeachment trials that resulted his impeachment and removal from the federal bench. also confided her that had been dating another staff member, Vanessa Griddine, but that she was "not worthy." 

Ms. Packer refused discuss Mr. Hastings' romantic involvement with other staff members and changed the topic conversation. 
28. 
Later that evening, however, while Mr. Hastings, Ms. Packer, and several Commission staff members, including the Chief Staff for Mr. Hastings' congressional office, David Goldenberg, another Commission staff member, Alex Johnson, and Ms. Thompson, were the bar the Marriott Hotel, Mr. Hastings remarked Ms. Packer front her colleagues that Janice Helwig, Ms. Packer's predecessor Vienna, had told other people that Ms. Packer was Mr. Hastings' girlfriend. Mr. Hastings then put his arm around Ms. Packer's shoulder and said: "She flatters me." Ms. Packer was embarrassed Mr. Hastings' comment and demeanor that falsely implied that romantic relationship existed between them. 

29. the night progressed and Mr. Hastings consmned more alcohol, began make crude comments Ms. Packer, Ms. Thompson, and Mr. Johnson. Specifically, Mr. Hastings remarked that did not understand how female Members Congress could wear the same underwear from the time the House Representatives went into session the morning until recessed late night. then stated that for that reason could never take female Representative "home with him." then looked directly Ms. Packer and asked her, "What kind underwear are you wearing?" Ms. Thompson and Mr. Johnson both clearly heard the question because they laughed response. Ms. Packer, however, was angry and humiliated both his question and his offensive comments about female Members Congress. That night, Ms. Packer called Mr. Turner and complained about Mr. I-lastings' conduct that day, including about his vulgar questioning her. 

30. 
During this trip, Mr. Hastings reiterated his desire visit Ms. Packer's apartment. Ms. Packer attempted avoid such visit explaining him that she did not have sufficient 

furniture host guests. Mr. Hastings, however, renewed his request the next day while they 
were van with other staff members. Ms. Packer responded that she would happy take everyone the van visit her apartment their way their destination. Mr. Hastings 
immediately declined her offer. 
31. For the duration Mr. Hastings' time Vienna that trip, Ms. Packer experienced very high levels stress when the presence Mr. Hastings and attempted avoid interacting with him because she feared would make additional comments and sexual advances towards her. 
32. For several months after Mr. Hastings May 2008 trip Vienna, continued 
call Ms. Packer regularly. Ms. Packer would often not answer the phone order avoid his 
calls. 
33. July 2008, congressional delegation including Mr. Hastings was scheduled 
attend the annual meeting the OSEC Parliamentary Assembly Astana, Kaz.akhstan. Ms. 
Packer had scheduled her arrival follow Mr. Hastings' arrival several hours. Prior the trip, however, Mr. Turner requested that Ms. Packer change her flight arrive day earlier than the other members the delegation because Mr. flastings had decided travel independent the other Members Congress and, instead, would arriving day before the delegation. 
Since was traveling independently, Mr. Hastings needed staff member facilitate his trip, 
especially one coordinate travel and administrative matters with the U.S. Embassy the Kazakhstani government. 
34. This request caused Ms. Packer significant stress and anxiety because she was 
fearful that Mr. Hastings would take advantage their hcing the country alone and again make sexual advances towards her. She was aJso upset that Mr. Turner assigned her staff Mr. 
Hastings alone after her multiple complaints about his conduct towards her, especially because six other Commission staff members were scheduled staff Mr. Hastings that trip and Mr. Turner could easily have assigned anyone them staff Mr. Hastings and avoided forcing Ms. Packer spend day alone with Mr. Hastings. Nevertheless, Ms. Packer complied with Mr. Turner's request. 
35. Ms. Packer anived Astana, Kazakhstan 4:00 a.m. and the way the 
hotel, the mobile phone her escort from the U.S. Embassy rang. After answered it, informed her that the call was from Mr. Hastings and had requested that she meet him immediately upon arriving. soon she arrived the hotel, Ms. Packer met the 
Congressman, who was alone the delegation hospitality room. Mr. Hastings immediately 
again embraced her closely with both arms, pressing his body against her body, and pressing his 
face against hers. This unwelcome touching was very unpleasant for Ms. Packer and made her very uncomfortable. Mr. Hastings then commented: "You look really good." followed this conunent telling her that had always liked her and wanted "look out for [her] career." Mr. Hastings intention was crystal clear: was sexually attracted Ms. Packer, wanted sexual relationship with her, and would help progress her career she acquiesced his sexual advances. Ms. Packer responded that while she was grateful that wanted help her, she wanted taken seriously professional and did not think was appropriate for her have personal relationship with him. Mr. Hastings argued that one would treat her less than 
professionally because they had personal relationship and that she would continue taken 
seriously. Ms. Packer continued insist that she was uninterested personal relationship 
with him. point the conversation did Mr. Hastings discuss single work-related matter 
with her. The sole purpose the meeting was for him reinitiatc his sexual overtures, even 
though she had repeatedly denied his advances. 
36. 
Later that same moming, Nlr. Hastings required Ms. Packer shop with him the shopping arcades Astana. While they shopped, Mr. Hastings repeatedly complained that Mr. Tumer was cheap and only once had purchased gift for him, which was inexpensive tie. contrasted Mr. Turner with Mr. Goldenberg and Mr. Johnson who explained had given him many expensive gifts. Mr. Hastings repeated statements made clear Ms. Packer that had brought her shopping that she would purchase him gi11. Upset and anxious about the eftect that her rejection Mr. Hastings would have her career, Ms. Packer felt other choice but purchase him shirt and tie. 

37. 
For the remainder their trip Kazakhstan, Ms. Packer suffered from severe stress and anxiety because she feared Mr. Hastings' further advances ifthey were alone. During this trip, Ms. Packer's blood pressure rose precipitously that she was forced see military doctor. She explained the doctor that her stress was caused Mr. Hastings' unwelcome sexual advances. offered her vitamin complex and sleeping aid help her combat the symptoms her stress. 

38. stated paragraph 32, throughout the summer of2008, Mr. Hastings was regularly calling Ms. Packer when was not around her. After Mr. Hastings' repeated sexual advances May and July and his continued telephone calls, Ms. Packer infonned Mr. Turner that she was unhappy her position and wished return Washington, D.C. this point, however, Ms. Packer had become fearful retaliation, because Kazakhstan Mr. Hastings directly linked her career progress with her having personal relationship with him and because she had repeatedly complained Mr. Ttuner about Mr. Hastings' conduct yet Mr. Turner had 

refused take any action protect her. Ms. Packer, therefore, told Mr. Turner that she wished return Washington, D.C., because she felt that the other U.S. Mission representatives, particularly the State Department officials, marginalized her and prevented her from being able fully perform her duties. Although the issue marginalization had been reoccurring problem during her first year Vienna and had contributed some Ms. Packer's dissatisfaction with her position during the first fow months her tenure the position, the real reason she requested the transfer back Washington, D.C., was remove Mr. Hastings' apparent sense entitlement for sexual favors from Ms. Packer because had given her the Vienna posting. Ms. Packer hoped that retmning the Commission's office Washington, D.C., would minimize Mr. Hastings' unwelcome advances. Mr. Turner responded that wou)d talk with Mr. Hastings about possible reassignment for her later time. 
39. 
Throughout the fall 2008, Ms. Packer traveled back Washington, D.C., for consultations every three months and sometimes encountered Mr. Hastings meetings and hearings. During these visits> upon first seeing Ms. Packer, Mr. Hastings would insist hugging her with both arms, pressing his body against her body and his face against her face. Mr. Hastings did not hug others the same manner. Given Mr. Hastings' overt sexual advances, Ms. Packer was made uncomfortable this unwelcome touching. 

40. January 2009, with the opening the Congress, Senator Benjamin Cardin was appointed Chairman the Committee and Mr. Hastings was appointed the CoChair. This shift leadership meant that tvlr. Cardin now led the Commission and was the ultimate decision maker regards personnel issues. 

41. February 2009, Ms. Packer had completed full year her position Vienna, the time period she had originally agreed "try out" the position. Since Mr. Hastings' 

lUlwelcome sexual attention had continued, Ms. Packer still wanted return Washington, 
D.C. Ms. Packer again asked Mr. Turner allow her retwn her old position Washington, D.C., had originally promised. Since she continued concerned about retaliation, Ms. Packer again explained that her desire return was caused her dislike being marginalized the State Dcpat1ment officials the U.S. Mission. Mr. Turner, however, flatly denied her request without providing any explanation. Since several occasions Mr. Hastings complained Ms. Packer that none his staff had ever contributed his campaign given anything back him, feeling extremely pressured, Ms. Packer contributed $1,000 his campaign fund. 
42. April 2009, Ms. Packer attended Parliamentary Assembly Bureau meeting Lisbon, Portugal, with Mr. Hastings and Mr. Turner. the afternoon the first day the meeting, Mr. Hastings traveled Sintra, city north Lisbon, accompanied Mr. Turner and Ms. Packer. went into bar upon their arrival and lVlr. Turner and Ms. Packer separated look around the town. After sightseeing, Ms. Packer found Mr. Hastings the bar alone. When she arrived, was clearly inebriated. Mr. Hastings again told her that had liked her ever since they had first met and that she did not appreciate the help that had given her career. Ms. Packer was very upset that continued pursue sexual relationship with her and explicitly told him that she did not want intimate relationship with him. Mr. Turner then ani.ved and the conversation ended. 

43. 
Later that same night after Commission-related dinner, when Ms. Packer arrived the hotel, Mr. Hastings was sitting the hotel lobby facing the door, apparently awaiting her arrival. Hccause Mr. Hastings had left the dinner upset, Ms. Packer immediately walked over him and inquired was alright. Mr. Hastings responded launching into minute, 

profanity-laced rant, which told Ms. Packer that she was not sport" because she knew 
that "liked" her and that had helped her professionally. then explained her that 
had "come [her] man does woman" and that was very upset that she had infonned 
Mr. Turner about his advances. 
44. then scolded her: "How dare you complain about me! You had better forget about being Republican." Ms. Packer had kept her head down during his tirade, but this last statement she looked him. response, snidely said: "Don't worry. Your job not any danger." Scared that she would lose her job because she rejected his advances and complained about his conduct, Ms. Packer apologized for not living his expectations. response asked her: "Would you like accompany room?" Ms. Packer inunediately responded: "no." then asked whether she wouJd like him accompany her 
her own room. She again said: "no." Clearly exasperated her continued rejections his advances, exclaimed: "Well, what your room number?" The emotional distress and humiliation caused this exchange had made Ms. Packer nauseous and she felt physicaJly weak, but she managed respond: "Excuse sir. have call son." She then rose and walked away tears. 
45. The next morning, Ms. Packer found Mr. Turner and detailed him the events 
the prior day, both the fact that Mr. Hastings continued make sexual advances towards her and 
that had implicitly threatened her job. Mr. Turner responded that, while was sorry that she had endure this treatment, there was nothing could about it. Ms. Packer was devastated the fact that Mr. Turner would not anything protect her from Mr. Hastings' sexual 
harassment. 
46. Ms. Packer next saw Mr. Hastings May 2009 Commission meeting 
Washington, D.C. the meeting, Mr. Hastings rose from where was sitting with the other Members Congress, crossed the room, approached her, and asked her outside the hallway speak with him. Ms. Packer felt she had other choice but accompany him. Once the hallway, Mr. Hastings opened his arms wide and told her give him hug. Ms. Packer felt hum iatcd the demand, but Mr. Hastings had already implicitly threatened her job, she acquiesced and hugged him. usual, Mr. Hastings pressed the front his body against 
hers and pressed his face against hers. Ms. Hastings' unwelcome touching caused Ms. Packer feel physically ill and experience significant emotional distress. Mr. Hastings ended the conversation telling Ms. Packer come his office see him. Ms. Packer was upset 
that she could not respond and instead just walked away. She did not, however, visit him his 
office requested. 
47. July 2009, both Ms. Packer and Mr. Hastings attended Parliamentary Assembly annual meeting Vilnius, Lithuania. The first day the meeting, Ms. Packer entered the meeting hall with colleague from the Parliamentary Assembly. Mr. Hastings was standing with the Secretary General the Parliamentary Assembly. Ms. Packer aclmowledged both officials saying "Hello" and waving. Mr. Hastings replied, "What you mean 'hello?' Come over here and give hug." Ms. Packer felt that refusing would have caused embarrassing situation, she walked over and allowed him hug her. again embraced her with both anns, pressed his body against her body, and pressed his face against her face. This unwelcome touching again caused Ms. Packer serious emotional distress. Later, during another meeting, Mr. Johnson approached her and informed her that Mr. Hastings wanted her accompany him back his hotel hjs car. Ms. Packer explained Mr. Jolmson that she was 
needed the meeting because she was the lead staff member the issues addressed the 
meeting. Ms. Packer was distressed Mr. Hastings' continued sexual harassment that she declined the opportunity dine with the other Committee staff and Mr. Hastings. 
48. 
After Mr. Hastings' conduct Lithuania, which demonstrated that Mr. Turner was not willing protect her from Mr. Hastings, Ms. Packer reported Mr. lastings' sexual harassment her Edward Joseph, who was the Deputy Staff Director the Commission the time and had been appointed that position Senator Cardin. Ms. Packer hoped that, Senator Cardin learned about the harassment she was being subjected to, would act protect her. Mr. Joseph responded that was shocked and sorry that she had through such experience. asked could raise the matter with Senator Cardin's staff and Ms. Packer granted him pe1mission. Within week, Mr. Joseph emailed Ms. Packer directing her file complaint with the Office Compliance. 

49. 
The stress Mr. Hastings' continued sexual advances and attention, and her fear that would begin retaliating against her once realized that she would not succumb his advances, became severe that she began suffer from high blood pressure and evidenced symptoms early coronary artery disease. August 2009, her health had degraded point that she began treated cardiologist Vienna, who prescribed her medications counter the high blood pressure and address the coronary artery disease. She had severe side effects from one these medications, which made her ill for weeks after she began taking it. Since Ms. Packer's health insurance did not cover international medical care, she inctuTed substantial medical costs because these health problems. 

50. the fall 2009, Ms. Packer's fears retaliation were confirmed. Mr. Turner began assign work from her portfolio other colleagues, and began withhold from her 

important information necessary for her perform her job. for example, the Commission's Representative the U.S. Mission Vienna, one her duties was inform her State Department colleagues the Commission's activities. number occasions, however, Mr. Turner would plan ce11ain meetings travel plans for the Commission's members, but would not inform Ms. Packer about the plans. Ms. Packer, instead, learned the information from other sources and sometimes through colleagues from the State Department, which negatively affected her professional reputation and prevented her from adequately performing her responsibilities. Another example Mr. Turner not informing her important information was when the CSCE Commission was planning hold hearing involving the lJ.S. State and Defense Departments. Mr. Turner assigned the hearing preparations another Policy Advisor, who personally 
contacted the Department Defense about the hearing even though Ms. Packer was responsible for military security issues and, such, should have served the liaison. Ms. Packer only learned about the hearing because Defense Department colleague mentioned her. When Ms. Packer asked Mr. Turner why had kept this information from her, refused explain 
and instead responded blaming her for the problems between the Commission's Representative and the other U.S. Mission delegation, even though had previously 
acknowledged that had been the U.S. Mission delegation that had marginalized her. 
51. After several months enduring Mr. Turner's retaliatory conduct, Ms. Packer rep011ed Mr. Hastings' sexual harassment and Mr. Turner's retaliatory harassment Marlene Kaufmann, the Commission's counsel. Ms. Kaufmann responded Ms. Packer's complaint explaining her that "maybe [Mr. Turner] couldn't anything about [Mr. Hastings' conduct] because had his own job worry about." Ms. Kaufmann did not offer Ms. Packer any assistance even suggest that she would investigate the issue. 
52. Seeing end sight the harassment and retaliation, Ms. Packer renewed her 
request Mr. Turner allow her return Washington, D.C., since she was already approaching two years her position Vienna and had only committed one year. Mr. Turner responded the request informing her that Mr. Hastings would coming Vienna February 2010 and would speak her that time about her future. informing Ms. Packer that the Congressman would dete1mining her future the Commission, even though Senator 
Cardin served the Chair and, such, should have made such personnel decisions, Mr. Turner was implicitly threatening Ms. Packer's job. 
53. 
The stress Mr. Hastings' harassment, Mr. Turner's retaliation, Ms. Kaufmann's refusal help, and the implicit threats her job exacerbated Ms. Packer's high blood pressure problems. the end December 2009, while visiting her family Virginia, Ms. Packer collapsed and was rushed emergency room. While Ms. Packer recovered enough released from the hospital that day, the stress was becoming more than her body could handle. 

54. November 2009, Ms. Packer signed serve election observer for the Ukrainian Presidential Election, which was held January. December 2009, however, Ms. Packer learned that Mr. Hastings had decided observe the election well. Upon learning this information, Ms. Packer contacted the person charged with assigning staff specific in cotmtry sites and requested that she placed different location than lvlr. Hastings. Ms. Packer was assigned Odessa and Mr. Hastings was placed Kiev. January 2010, when Ms. Packer aITived Kiev, Ukraine, route Odessa, Ukraine, Mr. Johnson infonncd her that Mr. Hastings was insisting that all Commission staff) except one person, remain Kiev, allegedly for safety reasons. Mr. Jolmson then informed her that had canceled her hotel reservation Odessa. Ms. Packer became very upset about the 
prospect having around Mr. Hastings and eventually broke down Ore.st 
Deychakiwsky, Commission staff member. She informed him that Mr. Hastings had been sexually harassing her for almost two years and that Mr. Turner was now retaliating against her because she rejected Mr. Hastings and complained about his conduct. Once she calmed down, Ms. Packer emailed Mr. Ttll11er discuss how handle the situation. Mr. Turner advised her Odessa despite Mr. Hastings' directive and not tell either Mr. Hastings Mr. Johnson that she was leaving Kiev. Ms. Packer followed Mr. Turner's direction, but experienced ftrrther stress stemming from her concern that she would punished for disobeying Mr. Hastings' directive. 
56. 
Ms. Packer's stress level was high that she experienced chest pain that first night Odessa. The next day, Ms. Packer emailed Mr. Turner asking she could call him speak about her concerns and illness, but did not reply. When she returned Vielllia, Ms. Packer continued experience chest pains and emailed Mr. Turner and Ms. Kaufmallli about her medical problem and asked speak with Mr. Turner that day. Mr. TW1ler responded that would call her the next day. The next morning, however, before Ms. Packer and Mr. Turner spoke, Ms. Packer fainted the middle meeting. When she was resuscitated, the emergency personnel informed her that her blood pressure was the range where she could have suffered stroke heart attack. Extremely upset the events that day and the day before, Ms. Packer confided Carol Fuller, the Charge Affaires for the U.S. Mission the OSCE, about Mr. Hastings' sexual harassment and her anxieties about the retaliation she had been endwing. Because the episode, Ms. Packer was placed additional medication. 

57. 
That night, l.1r. Turner called Ms. Packer and immediately put Mr. Hastings the phone, even though Ms. Parker had just survived very dangerous health episode that was 

caused Mr. Hastings' conduct towards her. Mr. Hastings explained that had heard about her medical episode and wanted assure her that her job was secure and that she should just let him know what she needed order address her health problems. The phone was passed Mr. Turner that point and Ms. Packer told him that she was going consult with her doctors, 
but that she wanted return Washington, D.C., July 2010. Mr. Turner agreed that she could return Washington, D.C. July 31, 2010. Mr. Turner aJso agreed have telephone 
conference with Ms. Packer and Ms. Kaufmann discuss the harassment issues. 
58. 
Over the next several days January 2010, Ms. Packer, Mr. Turner, and Ms. Kaufinann had several conferences about the harassment and they agreed take the matter seriously. They assured Ms. Packer that they had colUlseled Mr. Hastings stop making unwelcome advances towards her and, particular, refrain from hugging her. 

59. January 2010, after the trip Ukraine, Ms. Packer also called Christopher Lynch, the Chief Staff for Senator Cardin's personal office, because she could not trust that Mr. Turner was actually communicating the harassment problem the Senator. Ms. Packer detailed the harassment that she had suffered the hands Mr. Hastings. Mr. Lynch assmed Ms. Packer that Senator Cardin was committed the Committee maintaining harassment-free environment and that Ms. Packer would not lose her joh because she rejected Mr. Hastings' advances and complained about his harassing conduct. Mr. J,ynch, however, did not indicate that the Senator would take any action assist Ms. Packer. 

60. 
Shortly after Ms. Packer spoke Mr. Lynch, Ms. Kaufmann confronted her over the telephone. Ms. Kaufmann told her that Senate Legal Counsel had called her telling her that employee Vienna was asserting that she had hcen subjected harassment and retaliation. Ms. Kaufman accused Ms. Packer contacting the Senate Legal Counsel and then exclaimed 

angrily Ms. Packer: "No one retaliating against you!" Ms. Packer explained that she did not 
call Senate Legal Counsel, but had contacted Mr. Lynch and informed him the harassment and 
retaliation. .Kaufmann kept arguing that one was retaliating against her and that her job was secure. Ms. Kaufmann ended the conversation insisting that they set another telephone conference between Ms. Packer, Mr. Turner, and her discuss the matter. 
61. few days later, tekphonc conference took place between Ms. Packer, Mr. 
Turner, and Ms. Kaufmann. Mr. Turner and Ms. Kaufmann again assured Ms. Packer that they had spoken Mr. Hastings and that she longer had worry about Mr. Hastings acting 
inappropriately towards her. response, Ms. Packer again requested that she permitted 
retum Washington, D.C. 
62. around February 2010, during meeting with Mr. Turner, Ms. Kaufman, 
and Ms. Packer, Mr. Turner informed Ms. Packer that had Mr. Hastings' District Director, who was longtime friend Mr. Hastings, speak Mr. Hastings about his conduct towards Ms. Packer. 1v1r. Turner then counseled her that was not her interest 1v1r. Hastings' interest for her public with complaint and that she should allow him handle the situation. Mr. Turner's comment was clearly intended implicit threat Ms. Packer, which just further heightened her stress levels and further jeopardized her health. February 2010, Ms. Kaufmann wrote Ms. Packer informing her that Mr. 
Tumer had spoken Mr. Hastings about her harassment complaint and that Mr. Hastings had 
promised "sensitive [her] concerns and [to] proceed accordingly." Ms. Kaufmann also 
informed Ms. Packer that both Mr. Turner and Mr. Hastings were "satisfied with [Ms. Packer's job performance." She then confirmed that Ms. Packer would allowed return 
Washington, D.C., before the end the year, likely July. 
During the beginning February 2010, while Ms. Packer was Washington, 
D.C., for medical treatment, she had Mr. Joseph over for dilUler because was leaving the 
Commission. Mr. Joseph inquired about whether the sexual harassment and retaliation continued, which Ms. Packer informed him that did and updated him Ms. Hastings' and Mr. Turner's misconduct since July 2009. Mr. Joseph then informed her that July 2009, hac.l reported the sexual harassment and retaliation Mr. Lynch, who had recommended that Ms. Packer contact the Office Compliance. Mr. Joseph explained that Senator Cardin needed get along with Mr. Hastings and that Mr. Turner was protected Mr. Hastings. 
65. February 18, 2010, Mr. Hastings returned Vienna for the winter meeting 
the OSCE Commission. soon Mr. Hastings saw Ms. Packer, approached her and again pressed his face against hers. This conduct confirmed for Ms. Packer that Mr. Hastings would not change his conduct towards her, even after being counseled multiple people not make 
sexual advances towards her and not hug her. 
66. Mr. Hastings upset Ms. Packer again the next day, f'ebruary 19, 2010. front 
the entire congressional delegation attendance for the meeting Vienna, Mr. Hastings 
demanded that Ms. Packer have her photograph taken with him [thefrl favorite pose." 
order not make scene, Ms. Packer agreed take the photograph with him, even though 
required her place one her arms around him and allow him the same her. Ms. 
Packer was particularly distressed this conduct because she felt that Mr. Hastings was attempting create impression ofintimacy between them amongst the members the 
delegation. Additionally, Mr. Hastings had been counseled that she did not want touched him, yet still insisted using his control over her force her pose way that 
required they touch. After two years unwelcome sexual advances and touching, this 
additional unwelcome touching caused her extreme emotional distress. 
67. 
That evening, Ms. Packer complained writing Mr. Turner and Ms. Kaufmann about Mr. Hastings' conduct earlier that day and the day before. Ms. Packer infonned them that Mr. Hastings continued touch her, she would pursue legal action against him. Mr. Turner responded that would speak with her about the issue the morning, but that Mr. lastings would leaving early the next morning, she did not need worry about encountering him again. 

68. 
The following week, Ms. Packer contacted the Office Representative Christopher Smith, the Ranking Republican Member the Conunission, request Mr. Smith's assistance addressing Mr. Hastings' sexual harassment. Ms. Packer explained detail Mr. Smith's Chief Staff, Mary McDermott, that she had been suffering harassment the hands Mr. Hastings and now was suffering retaliation. Ms. McDermott advised her contact the Office Compliance about Mr. Hastings' and Mr. Turner's conduct. 

69. 
Since was clear Ms. Packer that Mr. Turner and Ms. Kaufinann were unwilling unable stop Mr. Hastings from sexually harassing her, Ms. Packer contacted the Office Compliance from Vienna. She explained Jennifer McCuiston, the Office Compliance Representative the phone, that she was employee with the Commission and was being sexualJy harassed Mr. Hastings and retaliated against her Staff Director. Ms. McCuiston informed her that she had 180 days file Request for Counseling based upon this sexual harassment and retaliation. 

70. March 2010, Mr. Turner again began retaliate against Ms. Packer. Ms. Packer informed Mr. Turner that she intended submit several travel requests for meetings. Mr. 

Turner responded informing her that she would have work very hard convince Senator Cardin that she should able travel since she had decided return Washington, D.C., July, even though the Commissjon staff manual required that all staITtravel part their fulfillment their portfolio duties. Ms. Packer responded that Mr. Lynch had promised her that she would not face any adverse consequences she chose retwn her position Washington, D.C. Mr. Turner refused respond and the conversation ended. 
Because this retaliatory conduct, April 11, Ms. Packer complained 
writing Mr. Lynch about Mr. Twner's conduct, detailing both hls attempt prevent her from traveling and his earlier retaliation excluding her from Conunission correspondence. Mr. Lynch reiterated that Senator Cardin was committed ensure she did not face retaliatory action because her complaints. The next staff meeting after she complained Mr. Lynch, Mr. Twner indicated that her travel requests had now been approved. 
72. Ms. Packer awaited her return Washington, D.C. July, she continued have chest pains and June 15, 2010, was treated the hospital. Her physician informed her that the chest pains were caused stress. 

73. 
Ms. Packer returned Washington, D.C., and resumed her position Policy Advisor for the Committee the end July 2010. 

74. August 2010, Ms. Packer filed complaint with the Office Compliance asserting claims sexual harassment and retaliation. September 2010, Ms. Packer's counseling period ended. 
76. September 17, 2010, Ms. Packer requested mediation. December l0, her mediation period ended. 
COUNT ONE--DISCRIMINATION THE BASIS SEX VIOLATION THE CONGRESSIONAL ACCOUNTABILITY ACT, U.S.C. 1311 SEQ. AGAINST DEFENDANT THE UNITED STATES COMMISSION SECURITY AND COOPERATION EUROPE. 
77. 
Plaintiff hereby incorporates though restated each the factual allegations set forth paragraphs through above. 

78. 
The Congressional Accountability Act (''CAA") prohibits discrimination against employee the basis sex the enjoyment all benefits, privileges, terms, and conditions employment. 

79. all times relevant this Complaint, Plaintiff, employee the United States Commission Security and Cooperation Emope, was "employee" within the meaning the CAA. 

80. 
Mr. Hastings regularly subjected Ms. Packer unwelcome sexual advances, sexually explicit remarks, and unwelcome touching. Even though Ms. Packer repeatedly rejected his advances and complained her direct supervisor about Mr. Hastings' conduct, Mr. I-lastings refused stop making sexual advances towards her and touching her. Instead, Mr. Hastings and his Staff Director, Mr. Twner, repeatedly threatened her job. Mr. Hastings' sexual conduct towards Ms. Packer and the later retaliatory threats Mr. Turner and Mr. Hastings was severe and pervasive that altered the conditions Ms. Packer's employment and created sexually hostile work environment, violation the CAA. direct and proximate result the unlawful sexual harassment, Ms. Packer experienced insomnia, anxiety, depression, high-blood pressme) and developed symptoms coronary artery disease. Ms. Packer has been prescribed medication and under the care physician because the severity her heart problems. 
82. Defendant's actions have directly and proximately caused Ms. Packer substantial damage her future career and professional reputation, humiliation, and pain and suffering. Defendant's actions were wanton, reckless, willful disregard Ms. Packer's legal rights. 
COUNT TWO--RETALIATION VIOLATION THE CONGRESSIONAL ACCOUNTABILITY ACT, U.S.C.  1311 SEQ. AGAINST DF:FRNDANT THE UNITED STATES COMMISSION SECURITY AND COOPERATION EUROPE. 
83. 
Plaintiff hereby incorporates though restated each the factual allegations set forth paragraphs through above. 

84. 
The CAA prohibits retaliation against any employee for engaging opposition what she reasonably good faith believes constitutes lll11awful discrimination under the CAA, including the rejection sexual advances and other forms sexual harassment. 

85. 
Ms. Packer repeatedly engaged protected activity opposing treatment she reasonably believed constituted lll1lawful discrimination, including repeatedly rejecting :tvfr. Hastings' unwelcomed sexual advances and reporting Mr. Hastings' harassing behavior Mr. Turner, the Conunission Staff Director and her immediate supervisor; Mr. Joseph, the Commission Deputy Staff Director; Ms. Kaufmann, the Commission Legal Counsel; :rvtr. Lynch, the Chief Staff for the then Chairman the Commission Senator Cardin; and Ms. McDermott, the Chief Staff for the then Ranking Member for the Commission Representative Smith. 

86. 
Defendant took adverse retaliatory actions against Ms. Packer repeatedly threatening her job the Commission, refusing aJlow her return her position Policy Advisor Washington, D.C., and intentionally marginaJizing her from the rest the U.S. 

Mission the OSCE. Defendant's retaliatory actions were adverse that they would have dissuaded reasonable employee from making supporting charge discrimination. 
87. 
Defendant's retaliatory actions were causally connected Ms. Packer's protected activity. 

88. direct and proximate result the unlawful retaliation, Ms. Packer experienced insomnia, anxiety, depression, high-blood pressure, and developed symptoms coronary artery disease, for which she has been prescribed medication. Ms. Packer remains under the care physician. 

89. 
Defendant's actions have directly and proximately caused Ms. Packer substantial damage her career and professional reputation, humiliation, and pain and suffering. Defendant' actions were wanton, reckless, willful indifference Ms. Packer's legal rights. 

COUNT THREE --SEXUAL HARASSMENT VIOLATION THE FIFTH AMENDJ.1ENT THE CONSTITUTION THE UNITED STATES AGAINST DEFENDANT ALCEE HASTINGS. 
90. 
Plaintiff hereby incorporates though restated each the factual allegations set forth paragraphs through above. 

91. 
The guarantee equal protection the law embodied the Fifth Amendment the Constitution the United States prohibits discrimination employment based upon person's sex, which includes sexual harassment and the creation sexually hostile work environment. 

92. 
Mr. Hastings regularly subjected Ms. Packer unwelcome sexual advances, sexually explicit remarks, and unwelcome touching. Even though Ms. Packer repeatedly rejected his advances and complained her direct supervisor about Mr. Hastings' conduct, Mr. Hastings refused stop making sexual advances towards her and touching her. Instead, Mr. 

Hastings and his Staff Director, Mr. Turner, repeatedly threatened her job. Mr. Hastings' sexual 
conduct towards Ms. Packer and the later retaliatory threats Mr. Turner and Mr. Hastings 
were severe and pervasive that they altered the conditions Ms. Packer's employment and 
created sexually hostile work environment. Defendant did not subject male employees the 
same work environment. 
93. direct and proximate result the unlawful sexual harassment, Ms. Packer 
experienced insomnia, anxiety, depression, highblood pressure, and deveJopcd symptoms 
coronary artery disease. Ms. Packer has been prescribed medication and under the care 
physician because the severity ofher heart problems. 
Defendant's actions have directly and proximately caused Ms. Packer substantial 

humiliation and pain and suffering. Defendant's actions were wanton, reckless, willful 
disregard Ms. Packer's legal rights. 
COUNT FOUR --RETALIATION VIOLATION THE FIRST AND FIFTH AMENDMENTS THE CONSTITUTION THE UNITED STATES AGAINST DEFENDANTS 
ALCEE HASTINGS AND FRED TURNER. 
95. Plaintiff hereby incorporates though restated each the factual allegations set 
forth paragraphs through above. 
96. The First Amendment the Constitution the United States prohibits the 
Federal Government from infringing person' speech unless for compelling interest and 
provided that the restriction both narrowly tailored achieve that goal interest and the 
least restrictive means for achieving that interest. Likewise, the Fifth Amendment prohibits 
retaliation against employee for reporting otherwise opposing unlawful sexual harassment. 
97. Ms. Packer repeatedly engaged speech acts that opposed unlawful sexual 
harassment repeatedly rjecting Mr. Hastings' unwelcomed sexual advances and reporting 
Mr. Hastings' harassing behavior Mr. Turner, the Commission Staff Director and her 
immediate supervisor; Mr. Joseph, the Commission Deputy Staff Director; Ms. Kaufmann, the Commission Legal Counsel; Mr. Lynch, the Chief Staff for the then Chairman the Commission Senator Cardin; and Ms. McDermott, the Chief Staff for the then Ranking Member for the Commission Representative Smith. 
98. 
Defendants took adverse ret;;iliatory actions against Ms. Packer creating hostile work environment repeatedly threatening her job the Commission, refusing allow her return her position Policy Advisor Washington, D.C., and intentionally marginalizing her from the rest the U.S. Mission the OSCE. 

99. direct and proximate result the unlawful retaliation, Ms. Packer experienced insomnia, anxiety, depression) high-blood pressure, and developed symptoms coronary artery disease, for which she has been prescribed medication. Ms. Packer remains under the care physician. 

100. 
Defendants' actions have directly and proximately caused Ms. Packer substantial humiliation, and pain and suffering. Defendants' actions were wanton, reckless, willful indifference Ms. Packer's legal rights. 

RELIEF 
WHEREFORE, Plaintiff prays this Court for the following relief: Enter judgment Plaintiff's favor and against the United States Commission Security and Cooperation Europe for discrimination the basis sex violation the Congressional Accountability Act) .S.C.  1311 seq.; Enter judgment Plaintiffs favor and against the United States Commission Security and Cooperation Europe for retaliation violation the Congressional Accountability Act, U.S.C.  1311 seq.; Enter judgment Plaintiff's favor and against Defendant Alcee Hastings for 
discrimination the basis sex violation the Fifth Amendment the Constitution the United States; Enter judgment Plaintiff's favor and against Defendant Alcee Hastings for retaliation violation the First and Fifth Amendments the Constitution the United States; Enter judgment Plaintiff's favor and against Defendant Fred Turner for 
retaliation violation the First and Fifth Amendments the Constitution the United States; award Plaintiff back pay amount proven trial; award Plaintiff compensatory damages amount proven trial; awa1:d Plaintiff punitive damages amount proven trial; award reasonable attorneys' fees and costs; and 

10. other relief the court deems just. 

Dated: March 2011 Respectfully submitted, 
JUDICIAL WATCH, INC. 

Washington, D.C. 20024 

(202) 646-5172 

(202) 646-5199 (fax) 
Attorneys for Plaintiff Winsome Packer 
UNITED STA TES DISTRICT COURT 
FOR THE DISTRICT COLUMBIA  
WINSOME PACKER,  
203 Yoakum Parkway  
Unit 817  
Alexandria, 22304  
Plaintiff,  
THE UNITED STATES  
COMMISSION SECURITY  Civil Action No.  
AND COOPERATION EUROPE  
234 Ford House Office Building  
Washington, 20515  
and  
ALCEE HASTINGS 5010 10151 Terrace  
Miramar, 33027  
and  
FRED TURNER  
8816 Harness Trail  
Potomac, 20854  
Defendants.  

JURY DEMAND 
Plaintiff demands jury triaJ aJI claims triable. 

Dated: March 2011 Respectfully submitted, 
JUDICIAL WATCH, INC. 

No. 429716) 
Washington, D.C. 20024 

(202) 646-5172 

(202) 646-5199 (fax) 
Attorneys for Plaintiff Winsome Packer