Christopher Dalton Thomas v. Deb Haaland, Secretary of the Interior, et al.
DueProcess EmploymentDiscrimina
1. Are minority males who oppose discrimination and illegal activity in good-faith and
terminated without cause entitled to Equal Protection ? If so, why have the Courts offered no
protection for prior EEO activity and used it to further deprive Plaintiff of his rights?
2. Should the Courts and EEOC ignore the EEOC's published "motivating factor " standard for all
federal agencies and arbitrarily apply the "but for" standard because Defendant alleged there
were "suspicions" from unknown sources? Defendant admitted they couldn't identify any
misconduct whatsoever (RE 21 EEOC tr.pg.305 Wyrick Test.).
3. Testimony from England, Wyrick and police prove EEO activity Defendant concealed is the
only substantiated cause for termination. Should the Court falsely assert "temporal proximity" is
the only thing shown and dismiss the case without opportunity for a fair hearing or discovery?
4. Do employees or Plaintiffs in Title VII actions have a Constitutional Right to Meaningful Reply
and be informed of the source of labels or unsubstantiated complaints imposed on them by the
employer, EEOC, and the Court as outlined in 5 CFR § 315.805 ? Plaintiff wasn't informed of the
KPB Appeal or Clarks report, mislead about the cafe complaint and given no opportunity to
respond to Lewis' memo. I don't believe a visitor complained about photos I never took.
5. Do agencies have a right to use police to procure false, off-duty, anonymous reports and enter
them in an employee's work record without substantiating anything? Do unsubstantiated police
reports have probative value in employment in the absence of due process?
6. Body Cam footage proves MACA police procured a rumor from Tour Guide, Chris Clark, after
the interrogation on July 22. Plaintiff was never informed because a visitor never filed a
complaint. How does the Court assert as fact that a visitor filed a complaint at the information
booth on July 14th and attribute Plaintiff's conduct?
7. FCRP Rule 56(a) states a court shall only grant summary judgement if "movant shows there is
no genuine dispute as to any material fact". Should the Court grant summary judgement when
all the Defendant and Courts asserted facts are disproven or disputed?
8. How does a Court base it's decisions on "similarity in accusations" when there are no
accusations against Plaintiff and the Court can't correctly cite what was said or who said it?
Defendant admits "the only formal allegations in this case are those in Plaintiff's fourth
amended complaint"(Def.Res. RE 145 ID#1867).
9. At EEOC Hearings is the Plaintiff entitled to Due Process concerning unsubstantiated police
reports or allegations being used against them? When a Plaintiff files a charge of Gender
Discrimination and Retaliation with the EEOC, do they have a right to identify or cross-examine
the opposite sex?
10. Can Gender Discrimination be evidenced by Bias in complaint procedures, false rumors or
reports of a sexual nature and the use of a previous gender discrimination complaint in
termination?
11. In cases of Retaliation should a case be dismissed because coworkers requested, made or
spread unsubstantiated hearsay complaints? Should Defendant take baseless insinuations from
the transcript of
Are minority males who oppose discrimination entitled to equal-protection