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Company (Raytheon), brings this suit for race and national origin discrimination and
tort claims against the Defendant psychiatrist, Dr. Julia M. Reade (Dr. Reade). In 2004,
became mentally disabled since then. Raytheon mandated Li to see Dr. Reade for mental
evaluation. Dr. Reade ignored the harassment, physical intimidation, and false layoff
notice to which Li had allegedly subjected in Raytheon, but viewed Lis reasonable
traits, and viewed such traits were caused by Lis culture background or culture
barrier. In order to cover up Raytheons conduct, Dr. Reade fabricated that Li had pre-
existed mental condition and had took medicine Advil to calm down. In fact, Advil is a
drug relieves pain and swelling and not for mental condition at all. Dr. Reades prejudice
was racially based and national origin based. In 2007, Dr. Reades report was adopted by
the Department of Industrial Accidents Court of Worcester and directly resulted in the
dismissal of Lis mental injury claims. Li now seeks compensation for all damages as
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Parties
1. The plaintiff, Yong Li, was a senior software engineer and worked in Raytheon
Company Marlborough facility for 7 years. Li was a native China. She was
became mental disabled since then, despite Li had no history of mental illness before
that time.
2004, she was paid by Raytheon for Lis mental evaluation. -------------------------------
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Facts
3. Plaintiff was a native China and completed two degrees. She had worked in England
for three different companies as a software engineer. She was hired by Raytheon and
an asset of the team, contributed greatly, as well as Yong was friendly and
pleasured to work with. The human resources (HR) witness form stated She [Li]
discriminated against by her woman leaders only because she is a Chinese. One of
Lis supervisors, Shari Swell, said I dont understand you Chinese. At once, Li
received a paper warning for she went to meetings 5 minutes later, while many others
went to meetings later and had never been blamed. One of Lis supervisors, Gayle
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McEleney, made disparate treatment between Chinese and white. When a Chinese
engineer was incompetent, Ms. McEleney had him laid off. When a white woman
was not qualified at the first line, Ms. McEleney screamed at Li, a mentor, for not
giving the white woman a good training. When a technical dispute occurred between
Li and Lis low-experienced (25 years old) group leader, a task manager, Jen Lewis,
stopped Li for requesting opinions from high-level engineers, but accused Li of using
the technical discussion to attack the group leader. Further, Ms. Lewis made a
5. Raytheon made a sham investigation, and claimed Lis allegation not found but
refused to let Li read the investigator Mattie Ervins report. Soon after, Li voluntarily
6. In 2004, upon her retuned to Marlborough, Li claimed that she was subjected to wide
another state. Li was told that the company was going to layoff and her name was on
the list. When Li found a long-term assignment by her won, her manager denied his
layoff statement and claimed that there was no layoff at all. The ex-task manager, Jen
Lewis, started staring at Li whenever they met alone, Li felt physically intimidated.
The staring repeatedly occurred for eight months (which was a finding of fact in Lis
Workers Compensation court), and eventually caused Li worried about her own
safety. Li addressed her safety concern to Raytheons Human Resources (HR) for
searching guidance.
(interrogation) without Lis knowledge and consent. The counselor John Didio, whom
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Li thought was an investigator, did not address a single of Lis concerns. Instead, he
repeatedly pointed his finger at Li and asked Do you want to kill someone or do you
want to kill yourself? Li was traumatized. Li could not function normally since then
8. On October 7, 2004, Raytheon mandated Li to see the defendant Dr. Julia M. Reade.
Dr. Reade found that Li suffered from a cute mental illness with psychotic features,
and was not fit to work. Raytheon, however, did not heed the report and threatened to
terminate Lis employment if Li did not return to work immediately. Meanwhile, Lis
Disorder (PTSD).
10. Li realized that in 2004 Raytheon surreptitiously submitted Ms. Ervins report to Dr.
Reade. Based on Mattie Ervins report, Dr. Reade fabricated that Li had personality
11. Dr. Reades report failed to state that the evaluation was based on Raytheons
investigator Mattie Ervins report of 2002. Dr. Reade only listed that she received
12. Dr. Reade disregarded the statements in Lis performance review, Yong was friendly
and pleasured to work with. Dr. Reade merely picked up words from Mattie Ervins
report, which described Li as Her co-workers noted that she has a strong
personality, and is opinionated. So that Dr. Reade stated that [Li] has a history of
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interpersonal conflict. In fact, Li had never been told that she was strong
personality or opinionated. Not only her performance review stated Yong was
friendly and pleasured to work with, but also the HR witness-form stated She [Li]
13. Dr. Reade disregarded Lis internal complaint of 2002, which quoted Lis co-worker
William Kerrs email which stated that Li was treated unfair by her woman leaders:
14. Dr. Reade blamed all the technical dispute and the alleged discrimination and
harassment in Raytheon as if Ms. Li has also had some difficulty expressing herself
(and understanding others) in English, a second language for her, and concerns were
or cultural barrier. despite Dr. Reade knew that Li had successfully worked for
three different companies in England before came to Raytheon, despite Dr. Reade
15. Dr. Reade falsely stated that Li took medicine to calm down so-called mental
In fact, Ibuprofen (common brand name: Advil, Motrin, uprin) was an anti-
inflammatory drug, which relieves pain and swelling (inflammation). Li had told Dr.
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Reade during the interview that Li took Advil because she had accidentally a finger
16. Dr. Reade swapped the causes and the results with respected to Lis traumatic
symptom. Dr. Reade referred Lis emails to Raytheons CEO, in which Li protested
Raytheon counselor John Didios question do you want to kill someone which
17. Dr. Reade referred Lis emails, which concerned about her personal safety and
family safety, as threatening emails. Dr. Reade did not mention that it was
Raytheon manager Jen Lewis eight months staring caused Li worried about her
18. Dr. Reade referred Raytheons interrogation, the embedded mental evaluation without
Lis consent, as referral to the EAP, consultation with her supervisor Dr. Reade
did not mention the EAP counselor John Didios question do you want to kill
someone with finger point at and dirty staring at Li, which traumatized Li.
19. Dr. Reade did not view Li as a normal human being who deserves to be angry under
mistreatment, but blamed all of the confliction to Lis culture background. Dr. Reade
referred Lis conduct of sending emails to Raytheon HR or CEO for searching help as
Ms. Li is entirely lacking in insight regarding her own behavior or its effects on
20. In 2007, the Department of Industrial Accidents (DIA) judge adopted Dr. Reades
report to dismiss Lis Workers Comp claim, the word strong personality and
opinionated were used as evidence in the judgment. The DIA judge disregarded the
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court referred psychiatrist Dr. Aspel and Lis own doctors diagnoses, which
21. Pursuant to the state M.G.L. 93, Li had sent her complaint to Dr. Reade and the state
STATUTE OF LIMINTATION
22. Dr. Reades report was written on October 26, 2004. Li received a copy of Dr.
Reades report on September 8, 2005 from DIA Court of Worcester. Accordingly, all
of Lis claims were timely filed to this court on August 14, 2008. The 42 U.S.C.
1981 gives four (4) years statute of limitation. Three (3) years statute of limitation
Count I:
(Violation of 42 U.S.C. 1981)
The actions of the Defendant set forth above constitute race and national origin
Count II:
(Violation of M.G.L. 93 98 Unfair and Deceptive Acts or Practices)
The actions of the Defendant set forth above constitute unfair and deceptive acts or
Count III:
(Defamation)
The actions of the Defendant set forth above constitute defamation in Violation of
WHEREFORE, plaintiff Yong Li requests that this Court order the Defendant to pay Li.
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b. Emotional distress damages;
c. Punitive damages;
d. Attonreys fees (if Li found at any time) and costs as provide for by statute; and
Respectfully submitted,
YONG LI
/s/_
Name: Yong Li
Address: ---
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Tel: --
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CERTIFICATE OF SERVICE