[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"doc-detail-199579-en":3,"doc-seo-199579-105":30,"detail-sidebar-cat-0-en-105":91},{"code":4,"msg":5,"data":6},0,"success",{"doc_id":7,"user_id":8,"nickname":9,"user_avatar":10,"doc_module":4,"category_id":11,"category_name":12,"doc_title":13,"doc_description":14,"doc_content":15,"file_id":16,"file_url":17,"file_type":18,"file_size":19,"view_count":20,"is_deleted":4,"is_public":20,"is_downloadable":20,"audit_status":20,"page_count":21,"language":22,"language_code":23,"site_id":24,"html_lang":23,"table_of_contents":25,"faqs":26,"seo_title":27,"seo_description":14,"update_tm":28,"read_time":29},199579,1099523882182,"Alex Sinclair","https://ap-avatar.wpscdn.com/davatar_6f874abed73319feea01a86fa6f0fab8",7,"Healthcare","Citlaly Gomez - Plaintiff’s Response and Memorandum of Law to Defendant’s Motion for Summary Judgment","Plaintiff Citlaly Gomez submits a response and legal memorandum opposing the Defendant’s motion for summary judgment in the Davidson County, Tennessee chancery court action against the Metropolitan Government of Nashville and Davidson County. The filing incorporates detailed responses to the Defendant’s statements of undisputed material facts and the Plaintiff’s statement of additional material facts. It describes repeated sexual harassment and a sexually hostile work environment, including efforts by supervisors and managers to deter reporting and related retaliation following a report of Officer Sutton.","E-FILED  \n9/8/2022 3:56 PM CLERK & MASTER  \nDAVIDSON CO. CHANCERY CT.  \nIN THE CHANCERY COURT FOR DAVIDSON COUNTY, TENNESSEE  \nCITLALY GOMEZ, )  \n)  \nPlaintiff, )  \n)  \nv. ) DOCKET NO. 20-0219-II  \n)  \nMETROPOLITAN GOVERNMENT OF ) 12 PERSON JURY DEMANDED  \nNASHVILLE AND DAVIDSON COUNTY, )  \n)  \nDefendant. )  \nPLAINTIFF CITLALY GOMEZ’S RESPONSE AND MEMORANDUM OF LAW TO  \nDEFENDANT’S MOTION FOR SUMMARY JUDGMENT  \nComes now the Plaintiff, Citlaly Gomez (hereinafter referred to as “Gomez” or“Plaintiff”) and provide this Response to the Defendant’s Motion for Summary Judgment that was filed in this case. Further, see the contemporaneously filed Statement of Additional Material Facts filed by the Plaintiff (including supporting Declaration of Plaintiff and Deposition testimony) . Also, the Plaintiff’s Response to the Statement of Undisputed Material Facts filed by the Defendant.  \nFACTS  \nThe Plaintiff refers the Court to the Responses to each of the claimed Statements of Undisputed Material Facts (hereinafter “SUMF”) and incorporates herein by reference the complete responses to the SUMF into this Response. Additionally, the Plaintiff incorporates by reference the totality of the Statement of Additional Material Facts (hereinafter “SAMF”) filed by the Plaintiff into this Response. For the purpose of an overview and summary, this fact section will not include all facts outlined in the SAMF or SUMF Response – but will provide an overview of the Facts for the benefit of the Court.  \nSEXUAL HARASSMENT OF PLAINTIFF/SEXUALLY HOSTILE WORK ENVIRONMENT AT DEFENDANT  \nThe sexual harassment of the Plaintiff and the Sexually hostile work environment provided to the Plaintiff while at work and working for the Defendant included repeated, grotesque and continuous sexual harassing events directed at the Plaintiff. (See SAMF¶ 1-27 – and detailed list in Brief below) . This sexual harassment of Plaintiff occurred from 2015 from the date the lawsuit was filed on February 24, 2020. (SUMF ¶ 44) . There were no breaks of any significant length of time in the sexual harassment, and certainly no breaks greater than six months. (SUMF ¶ 44) . Throughout the sexual harassment of Plaintiff, she tried her best to make clear to the officers, supervisors and managers that she was not interested in them in a sexual way. (SUMF ¶ 45) .  \nDEFENDANT DIRECTED THE PLAINTIFF (THROUGH MANAGERSAND SUPERVISORS) THAT SHE SHOULD NOT REPORT SEXUAL HARASSMENT TO DEFENDANT  \nThe Plaintiff was advised by supervisors, managers and FTO’s throughout her career at the Defendant that she should not report sexual harassment she experienced at the Defendant because her career would be impacted and nothing would be done about the sexual harassment. (SAMF ¶ 46) . Plaintiff’s ex-husband, who was a Metro Nashville police officer advised the Plaintiff not to report sexual harassment because it would end her career at the Defendant. (SAMF ¶ 47) .  \nEarly in Plaintiff’s career, in early 2016, during her training from her Metro police supervisor FTO Randall, her supervisor FTO Randall told the Plaintiff that she should not report sexual harassment because it would impact her career. (SAMF ¶ 48 and 49) . Further, he told he that she should just “deal with it” instead of reporting sexual harassment because it would be bad for her career and she needed to be smart about it.  \n(SAMF ¶ 48) . Additionally, early on in Plaintiff’s career with the Defendant, Sergeant Pepper, Plaintiff’s supervisor, told the Plaintiff that she should not report sexual harassment because it was just part of her job as a women working in a male-dominated industry. (SAMF ¶ 50) . He further instructed her that she needed to keep it quiet and not report sexual harassment or it would negatively impact her career. (SAMF ¶ 50) .  \nThe Plaintiff took the direction of Defendant Metro police supervisor FTO Randall and Sergeant Pepper (both her supervisors), to heart and it impacted her view of reporting sexual harassment at the ","cbCaispZMrVaSZ3b","https://ap.wps.com/l/cbCaispZMrVaSZ3b","pdf",259154,1,29,"English","en",105,"# Facts\n## Sexual harassment and hostile work environment\n## Direction not to report sexual harassment\n## Reporting sexual harassment and alleged retaliation","[{\"question\":\"What does Citlaly Gomez’s filing respond to?\",\"answer\":\"It responds to the Defendant’s motion for summary judgment in the pending chancery court case.\"},{\"question\":\"How does the filing address the sexual harassment allegations?\",\"answer\":\"It describes repeated, continuous, and grotesque sexual harassment and a sexually hostile work environment, with no significant breaks over the relevant period.\"},{\"question\":\"What does the filing claim about reporting sexual harassment?\",\"answer\":\"It asserts that supervisors and managers advised her not to report and that she was influenced not to use formal reporting processes.\"}]","Citlaly Gomez - 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