ADDITIONAL ATTACHMENTS to 19 Amended Complaint,, by Plaintiff Cara Wessels Wells. (Attachments: # 1 Exhibit(s) Exhibit B) (Davis, Matthew)¶
Wells v. Texas Tech University, et al, No. 5:23-cv-00060 (N.D. Tex.) · Dkt. 27 · 2023-07-10 · PDF
Text extracted from the PDF; scanned pages were read by OCR. The PDF is the authoritative copy.
I declare under penalty of perjury that the above is true and correct. 11/09/2022 Date RCVD by by EEOC EEOC 11/11/2022 11/11/2022 RCVD Case5:23-cv-00060-H 5:23-cv-00060-H Document Document Filed 07/10/23 07/10/23 Page ID 252 Case 2727 Filed Page11 of of 1 1 Page PageID 252 CHARGE OF DISCRIMINATION [ ] FEPA This form is affected by the Privacy Act of 1974. See enclosed Privacy Act [X] EEOC453-2023-00140 453-2023-00140 Statement and other information before completing this form. and EEOC State or local Agency, if any Name (Indicate Mr., Ms., Mrs.) Dr. Cara Wessels Wells Street Address Home Phone (Incl. Area Code) Date of Birth (281) 728-0491 02/1991 City, State and ZIP Code 220 Barton Creek Drive Dripping Springs, TX 78620 Named is the Employer, Labor Organization, Employment Agency, Apprenticeship Committee, or State or Local Government Agency That I Believe Discriminated Against Me or Others. (If more than two are named, list under PARTICULARS below.) Name No. Employees, Members Texas Tech University Phone No. (Incl. Area Code) > 1,000 Street Address City, State and ZIP Code 2500 Broadway Lubbock, TX 79409 Name No. Employees, Members Phone No. (Incl. Area Code) Dr. Samuel Prien (806) 743-2047 Street Address City, State and ZIP Code 3601 4th Street, Stop 8340 Lubbock, TX 79430 DISCRIMINATION BASED ON (Check appropriate box(es).) DATE(S) DISCRIMINATION TOOK PLACE [ ] RACE [ ] COLOR [X] SEX [ ] RELIGION [ ] NATIONAL ORIGIN Earliest Latest 10/2012 06/16/2022 [X] RETALIATION [ ] AGE [ ] DISABILITY [ ] GENETIC INFORMATION [ ] OTHER (Specify) [ ] CONTINUING ACTION THE PARTICULARS ARE (If additional paper is needed, attach extra sheet(s)): I. Throughout my time at Texas Tech University, I was subjected to harassment and systemic discriminatory conduct by Professor Prien, which was ignored and disregarded by the University despite the issue being brought to their attention several times. The harassment began in 2012 when I was an undergraduate student at TTU assisting in research in Professor Prien's lab and has continued through June of 2022 when I was removed as a mentor at my alma mater and was defamed by the department. II. I faced a clear and noticeable pattern of harassment throughout my time at TTU serving as an undergraduate research assistant, Ph.D. student, lab coordinator, and program mentor. As an example, during annual trips to the American Society for Reproductive Medicine (ASRM) conference, Professor Prien insisted that we share a hotel room despite my discomfort with the suggestion. When I brought this to the attention of administrators at TTU, I was disregarded. The one instance in which I opted to stay with a family member instead, Professor Prien became visibly angry at me. III. I expressed my discomfort with the arrangements and also reached out to administration for assistance, both avenues failed to help me. As a result of my clear discomfort, I faced retaliation from Professor Prien and the University. Prien said that he would "destroy" me in 2019. In the following three years, I made several attempts to bringing this issue to light to professors and administrators. Subsequently, I was removed from my listing as an inventor on TTU publications, removed as a mentor, and heard from a third party that they were instructed by TTU to not work with me. This disparagement of my character is a continuation of the harassment I have been subjected to for almost 10 years now. IV. These are just a few examples of the inappropriate treatment I endured. This treatment was a result of my sex and my attempts to alert administration at TTU were disregarded due to my age and inferior position. The repeated harassment and cover up of inappropriate behavior have not only impacted my emotional and mental wellbeing, but also my professional reputation and employment opportunities. V. I believe I have been discriminated against due to my sex, in violation of Title VII of the Civil Rights Act of 1964, as amended. I want this charge filed with both the EEOC and the State or local Agency, if any. I will advise the agencies if I change my address or phone number and I will cooperate fully with them in the processing of my charge in accordance with their procedures. NOTARY - When necessary for State or Local Agency Requirements Kelly Christine Garcia I swear or affirm that I have read the above charge and that it is true to the best of my knowledge, information and belief. SIGNATURE OF COMPLAINANT Cara Wells SUBSCRIBED AND SWORN TO BEFORE ME THIS DATE Cara Wells (month, day, year) KELLY CHRISTINE GARCIA 11/09/2022 Notary Public, State of Texas Charging Party Signature Comm. Expires 07-22-2024 Notary ID 128938373