Due to his intellectual disabilities, Jeffrey Liberto was banned from his volunteering
position at Geisinger Hospital, without explanation, and prevented from obtaining
employment. Jeffrey Liberto was then forced to watch Geisinger Hospital upper
management inflict cruel and unusual punishment on his mother while informing him of
why they had banned him from his volunteering position one week earlier. Did Geisinger
Hospital upper management discriminate, harass, and inflict cruel and unusual
punishment on Jeffrey Liberto in violation of Title VII and the VIII Amendment?

Did Geisinger Hospital use Jeffrey Liberto, Luisa 's son, as a means to harass and
psychologically inflict cruel and unusual punishment on Luisa Liberto?

Luisa Liberto was sought out (targeted) by Geisinger Hospital, interviewed by a regular
employee for a position that had never been posted, and hired four months later when the
position was finally posted. She was then subjected to discrimination, harassment, abuse,
blackballing, and cruel and unusual punishment before being wrongfully teiminated..
Did Geisinger Hospital use targeting, discrimination, harassment, blackballing, abuse,
and wrongful termination to inflict cruel and unusual punishment on Luisa Liberto in
violation of Title VII and the VIII Amendment?

Did Geisinger Hospital violate Title VII of the Civil Rights Act, of 1964 & 1990, Title
VII of the Civil Rights Act, 42 U.S.C. s2000e (ADA) 42 U.S.C. 12101; and the XIII
Amendment of the Constitution by inflicting all the above-mentioned acts on Petitioners?

Did Geisinger Hospital discriminate, harass, and inflict cruel and unusual punishment on Jeffrey Liberto and Luisa Liberto in violation of Title VII and the VIII Amendment?