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RETURN DATE: AUGUST 1, 2023
CHRISTINA WILLIAMS, : SUPERIOR COURT
:
Plaintiff, :
: J.D. OF HARTFORD
: AT MANCHESTER
v. :
:
PRATT & WHITNEY, A DIVISION OF :
RAYTHEON TECHNOLOGIES :
CORPORATION :
:
Defendant. : JUNE 28, 2023
COMPLAINT
JURISDICTION AND VENUE
1. This action arises under the Connecticut Fair Employment Practices Act (“CFEPA”),
Conn. Gen. Stat. § 46a-60, et seq.; and Conn. Gen. Stat. 31-51q.
PLAINTIFF
2. The Plaintiff, Christina Williams (“Plaintiff” or “Williams”) is a natural person and
resident of the State of Connecticut.
DEFENDANT
3. The Defendant, Pratt & Whitney, a division of Raytheon Technologies Corporation
(“Defendant” or “Pratt & Whitney”), is registered to conduct business in the State of
Connecticut, and conducts substantial business at 400 Main Street, East Hartford, CT
06118, where Plaintiff is employed.
FACTUAL ALLEGATIONS
A. Mrs. Williams’ History of Exemplary Performance.
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4. Williams was the current Director, Military Programs Control & Diagnostic Systems,
PTMS & Accessories. In this role, her job was to manage all programs, customers and
integration, and technical solutions. She had approximately 10 major programs, all
functioning exceptionally well, with very high MFAs (market feedback analysis), as is
shown by data and her performance evaluations.
5. The programs are individually managed by a CIPT (component integrated product team
lead) or program manager. Per the company roles and responsibilities, each CIPT is
responsible and accountable for everything in their program. Williams’ role is to
oversee and manage all military activities, budgets, manpower, customer satisfaction,
technology insertion, obsolescence etc., which she performs at the highest level every
day.
B. Williams Raised Various Good-Faith Concerns and Violations, Pursuant to
Her Rights Guaranteed by Section ... 4 ... Of Article First of The Constitution
of The State of Connecticut, Conn. Gen. Stat. § 31-51q, and is Retaliated
Against.
(a) FADEC Issues.
(1) Elevating Concerns about Bernard Raver’s Conduct.
6. The modular full authority digital engine control (“FADEC”) is a product. Generally,
it takes $100M and 8-10 years of development time. The electronics in it become
obsolete fairly fast and are very expensive to update.
7. Military programs revolutionized the FADEC business, inventing a generic modular
FADEC. Development of the new product is cost shared by multiple customers.
8. Cost sharing creates a lot of issues. Each program has unique contractual requirements,
government property usage requirements, data sharing usage, export compliance,
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marking requirements, security classification levels, and technical requirements. This
makes it very easy to make an error.
9. Bernard Raver (“Raver”) was hired as the product manager that was supposed to roll
up all the individual funding streams, technical requirements, contractual requirements,
and execute a modular FADEC box solution. However, Raver did not adhere program
requirements, director requests, ITC requirements, manage financial performance, risk
posture, and integration requirements.
10. He routinely changed costs, schedules, gave away $1M in broadly leveraged
technology funding to another aerospace company, (documented), all without
consequence. In addition, Raver was disrespectful, and used gender undertone verbiage
with female counter parts. (documented) Williams continually elevated all these
concerns to their shared boss, Howard Jacas. (documented)
(2) Williams’ Ombudsman Complaint for Ethical and Compliance Issues
on the Modular FADEC Team.
11. In late August or early September 2020, Williams filed a formal ombudsman complaint
for ethical and contractual violations on the modular FADEC team – the fact they
would not follow contractual guidance. Mark Pearl concluded after a very short and
shoddy investigation: no wrongdoing, and poor behavior continued.
(3) Impermissible Drive Access by Non-U.S. Citizen.
12. In September, the mod FADEC team brought on an employee, who is not a U.S. citizen,
and impermissibly provided him drive access. Accordingly, this violated military
program contracts and Williams reported this as well.
(4) Reporting Government Contractual Violations Resulting in Stop
Work.
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13. In early February 2022 the government issued a stop work when the FADEC team
overspent their IDWA or contractual allowance. In conjunction with the overspend,
Williams elevated a $1M negative schedule variance to the government. Williams
pushed against modified variance explanation to falsify performance (documented).
Bernard Raver was not tracking the modular FADEC earned value.
(b) Reporting of Ignored Contractual Requirements, Warnings, and
Mistruths.
14. Raver and Williams reported to the same supervisor, Howard Jacas. Raver blatantly
ignored contractual requirements, warnings, and lied - all documented in email. Most
recently April 18-20, he falsely promised that he BAER reviewed data, and the air force
would did not attend specific meetings, all documents were marked appropriately and
logged in. the export compliance database. The BAER Reviewer role ensures
compliance with import/export government regulations by the review and application
of Jurisdiction and Classification (J/C) license that contain technical data.
15. Despite his assurances, air force personnel (Brandon Hoffman) was in the meeting and
tech data was marked no-tech data on the screen, a substantial error. The ITC360 flag
was raised, no log of any weekly meeting was ever placed in export compliance system
(for the months of previous exports), and the slides were found marked incorrectly.
Williams again reported this good faith concern on April 20 and validated on June 3,
2022.
(c) Reporting of Gender Discrimination to ECO and Unequal Pay.
16. In October, Nick Moura, a P5 (principle engineer), was promoted to a P6 (associate
director), and his salary and promotion were sent out to the directors. Yet, he was
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inexplicably making more than Williams. Williams had been an M7 for two years and
had 10 times the responsibility, and his promotion to the level below her – put him over
her. Williams rightfully complained and was given a 9.5% pay correction, which barely
put her at the pay of her subordinates.
17. When Williams was brought in as a director, Louie Celiberti at the time said “don’t let
it bother you that the people working for you make more than you… they have been
here longer.” What Williams did not realize was that she should have been making
what her roles and responsibilities dictate, not her tenure. As acknowledged with
multiple pay corrections, Williams was significantly underpaid as a director.
18. The process of providing full department salaries at merit time, during promotions
requests etc. - has since been eliminated because of this complaint. Williams is in
possession of the entire department pay matrix from February 2021, which shows this
to be true and will be submitted as evidence if it becomes necessary.
19. Further on this point, on February 11, Amy Eich reported Bernard Raver in a meeting
for making gender insinuations and commentary and elevated it to Williams. Williams
complained about gender disparity to Jacas on February 14 and with the ECO February
25. (all documented in email). She also discussed it with Raver directly (email
documented). Again, similar to her prior complaints, nothing was done to remedy the
situation.
20. In June of 2022, Williams was reassigned from her management position to an
independent contributor while Raver was rewarded for poor behavior and gender
discrimination and promoted to a manager within the department in August.
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21. Moreover, as part of a pattern of disparate treatment, Williams, a female, is also held
to a different standard of conduct than male colleagues, which could be shown through
correlating evidence.
(d) Reporting of Multiple International Trade Compliance Violations.
22. Williams reported multiple international trade compliance violations in February of
2022, for incorrectly marking data and/or providing it to someone who should not have
it. Williams’ most recent complaint was on April 18, 2022.
(e) Reporting a Security Breach of Highly Classified Data.
23. Additionally, Williams reported a classified security breach in February of 2022.
Namely, Pratt & Whitney gave a classified program cross section to the foreign partners
of another military program – which became a very serious incident and jeopardized
national security.
(f) Objecting To Being Forced to Sign Outsource Statement of Work – When
Peers Were Being Federally Indicted.
24. On February 24, Williams was forced to sign an outsource statement of work (SOW)
for an outsource supplier to open the classified lab – this was right at the time when
other directors were being federally indicted on wage capping and previously Williams
never had to sign a SOW before. The SOW was for a program with a contract ending
in 10 weeks. The inability of the outsource supplier to bring someone in, in time to
support was unlikely. It was a waste of government funds, as it could not be executed.
Williams provided alternative programs to meet the objective but her supervisor,
Howard Jacas, stayed on the phone insisting, and pressuring her to sign the SOW,
implicitly threatening her job.
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(g) Objecting to Pratt & Whitney’s Response to an Employee Suicide.
25. Unfortunately, a Pratt & Whitney employee committed suicide at the end of 2020. In
2021, Williams raised an ombudsman complaint against Pratt & Whitney’s
mishandling of the situation. Employees elevated to HR three times -- prior to the
suicide – the employee’s urgent need for help, but nothing was done.
26. After the incident, Williams elevated his missing person and worked with local
authorities and she was there to tell the team. Even after mishandling the situation, there
was no onsite social worker support for grieving employees -- nothing. Throughout
2021, Williams’ team raised genuine concerns of anxiety over workplace safety and
nothing was done to address this concern. At the one-year anniversary, Williams again
requested help – and HR still did not assist.
C. After Raising Numerous Good Faith Concerns Nine Times, Williams is
Retaliated Against.
27. After raising countless issues of concern pursuant to her rights protected by
Connecticut General Statute § 31-51q—Williams suffered adverse work actions. After
complaining multiple times, to her severe detriment, Pratt & Whitney took the
following adverse employment actions, via a final warning issued on May 31, 2022.
Williams was (1) abruptly removed from her position as Director of Military Programs,
CDS PTMS and accessories; (2) removed her from the high-potential director talent
pool; (3) re-assigned as an independent contributor; and (4) a negative entry was placed
in the Joint Personnel Adjudications System (JPAS), considerably affecting William’s
long-term employability.
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28. To support its pretextual final write-up, Pratt & Whitney falsely accuses Williams of
"perceived" retaliation, using the terms "embarrassing" and "disappointing" in critical
feedback regarding a presentation, and for other unspecified alleged unprofessional
behavior.
29. These false assertions by Pratt & Whitney are easily refutable. In reality, Pratt &
Whitney retaliated against Ms. Williams for engaging in protected activities by making
multiple complaints.
D. Triggering Action Leading to Pretextual Event.
30. In response to William’s multiple complaints, Pratt & Whitney has subjected her to a
near-constant stream of retaliation and increased harassment, inclusive of Pratt &
Whitney issuing Williams a final written warning on May 31, 2022 to cover up its
retaliatory actions. This warning is pretextual and easily refutable.
31. To explain, at the end of January, Christine Adams (“Adams”) gave a technical
presentation to the program chief engineer for Adaptive programs. Noticeably, the
software page had a table that did not add to the total column. After the meeting,
Williams contacted Adams by telephone and provided her with critical feedback.
32. Specifically, Adams’ slide was ill-prepared and her inability to add drove loss of
customer confidence and was disappointing and embarrassing. There were five
employees in the meeting who witnessed Adams’ ill-prepared presentation and
feedback was given to her privately over the phone by Williams.
33. Adams was software IPT lead, and BLT (broadly leveraged technology) lead for the
modular FADEC. She wanted to transition into programs. In July of 2021, she came up
with a transition plan that when BLT ended, she would "fully" transition into the deputy
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CIPT role. (documented in email) Williams added her to her organizational chart early
January – however, she never shifted. She was trying to still do execute multiple roles.
The transition plan was widely discussed from July-January.
34. Mike Milliken was supposed to backfill Adams to allow for the transition but did not
because he left Pratt & Whitney. Role transition discussions continued before and after
the presentation with mathematical errors.
35. On February 5, Mike Sabatella wrote an email stating that he had concerns about
Adams taking the job. Williams asked her to decide, with Mr. Milliken gone and no
backfill, what she wanted to do. Adams went back and forth. Thus, Williams never
removed her from her organizational chart. In fact, she is still there.
36. At the end of February, Bernard Raver, announced Adams’ as his deputy without any
alignment by Williams’ supervisor, or hers, or Williams. (also documented in email).
On February 14, Williams overheard through her supervisor that she thought Adams
could not have the deputy CIPT role due to performance issues - so Williams addressed
it again with her via email (fully documented). Never once did Williams state that she
could not have it, instead, she just had to transition per her plan in July - fully.
37. Of significant importance, manpower is a full-time job for Williams. Every month, she
reports to the vice president her manpower and key roles. She is 33% under-staffed so
role discussions are an everyday occurrence with everyone. Williams’ role discussion
with Adams was no different. There are documented emails from her supervisor
Howard Jacas and Bill Lamberti during this timeframe really applying pressure for key
role owner identification for classified roles.
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38. As for data integrity -- all cost data came from the life cycle cost study and is fully
documented and time logged from internal experts and external suppliers, (Hardware
and software).
39. Per customer and chief engineer request, all options were formally quoted, documented,
and presented. All data for other programs is based off of this - there is and was never
data integrity issues. There may be a misunderstanding by Jaysharee R that it was told
to the customer they could meet all the advanced programs requirement with the legacy
options- but that never happened, and she was not present at the meeting. The
limitations and shortfalls of all options were made clear – but it’s up to the customer to
decide. (documented)
40. Lastly, as for the key stakeholder alignment. Alignment is required between program
management, program chief engineers, program management office, and customer. It
is not Williams’ job to align every technical input she received. She does not lead by
consensus, as she would not be able to get anything done if she did. -- it is her job to
pull all the facts - present and align on a solution that meets the programs risk tolerance
posture and budget. She gains alignment between the customers, PCE, SIPT, IMPT,
and CIPT. (fully documented).
41. Williams and her team presented in the LCC study-3 options for application software.
The customer chose (documented in email) option 3.
42. Williams gave the technical team an additional day to present their case to a hold out
customer – and that customer continued to still chose option 3. For the next two months,
the software team continually pushed every chance they could get to force the customer
into the corner and change direction. They are still executing option 3.
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43. Pratt & Whitney’s write-up to Williams also accused her of unspecified unprofessional
conduct. Tellingly, not one instance was ever provided to Williams and her file is
devoid of any documented instances.
44. Clearly, Pratt & Whitney retaliated against Williams for raising multiple issues of
public concern. The rights protected by Connecticut General Statute § 31-51q.
45. As shown by the above facts and analysis, Pratt & Whitney used a disingenuous and
legally defective investigation and a final warning to conceal and suppress Williams
for pointing out its own wrongdoings. In point of fact, Williams managed the work
scope of 300+ Pratt & Whitney employees, 100 Collins Aerospace employees, 14 direct
reports, hundreds of millions worth of military contracts, and overseeing of controls
and diagnostics for our national defense. Now, she has suffered a substantial adverse
change in job conditions and potential job growth. “High-potential” is ability to be
promoted two more levels and now Williams has been deemed unpromotable.
COUNT ONE
RETALIATION,
IN VIOLATION OF CONN. GEN. STAT. § 31-51q
46. Plaintiff incorporates paragraphs 1-45, with the same force and impact as if fully set
forth herein at length.
47. Plaintiff was exercising her free speech on matters of public concern by reporting
various good-faith concerns and violations.
48. Plaintiff’s decision to report concerns regarding violations was protected activity,
provided for and compelled by the state of Connecticut.
49. In retaliation for Plaintiff’s good-faith complaints, Defendant subjected Plaintiff to the
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following adverse employment actions, via an unjustifiable final warning issued on
May 31, 2022. Williams was:
i. abruptly removed from her position as Director of Military Programs, CDS
PTMS and accessories;
ii. removed from the high-potential director talent pool;
iii. re-assigned as an independent contributor; and
iv. a negative entry was placed in the Joint Personnel Adjudications System
(JPAS), considerably affecting William’s long-term employability.
50. Plaintiff’s speech is protected by Sections, 3, 4, and 14 of the Connecticut Constitution.
51. The exercise of her rights did not materially interfere with her job performance, nor did
it interfere with her working relationship with Defendant.
52. Plaintiff was retaliated against due to the exercise of her rights guaranteed by the
Connecticut Constitution, in violation of Conn. Gen. Stat. § 31-51q.
53. As a result of his wrongful discharge, Plaintiff has suffered and will continue to suffer
damages including but not limited to lost wages, fringe benefits, health insurance,
emotional and psychological distress, stress, anxiety, and loss of the ability to enjoy
life’s pleasures and activities.
54. Plaintiff seeks compensatory and punitive damages for Defendant’s misconduct.
COUNT TWO
VIOLATION OF CONN. GEN. STAT. § 46A-60(b)(1)
SEX AND GENDER DISCRIMINATION
55. The Plaintiff hereby re-alleges and reincorporates paragraphs 1-45 with the same force
and impact as if fully set forth herein.
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56. As part of a pattern of disparate treatment, Williams, a female, has been held to a
different standard of conduct than male colleagues.
57. Williams was also inexplicably earning less than a male colleague, which she
complained to Defendant about.
58. Plaintiff also suffered adverse employment actions, including, but not limited to, the
following:
i. Via a final warning issued on May 31, 2022, Defendant caused Williams to be:
(1) abruptly removed from her position as Director of Military Programs, CDS
PTMS and accessories; (2) removed from the high-potential director talent
pool; (3) re-assigned as an independent contributor; and (4) a negative entry
was placed in the Joint Personnel Adjudications System (JPAS), considerably
affecting William’s long-term employability.
59. Among the factors that motivated Defendant’s actions were Plaintiff’s sex and gender.
60. As such, Defendant’s actions and conduct are a violation of Conn. Gen. Stat. § 46a-
60(b)(1).
61. As a result of the foregoing conduct, Plaintiff has suffered and will continue to suffer
damages including but not limited to lost wages, fringe benefits, health insurance,
emotional and psychological distress, stress, anxiety and loss of the ability to enjoy
life’s pleasures and activities.
62. Plaintiff is seeking damages as a result of Defendant’s unlawful conduct.
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COUNT THREE
VIOLATION OF CONN. GEN. STAT. § 46A-60(b)(4)
RETALIATION BASED ON SEX AND GENDER
63. The Plaintiff hereby re-alleges and reincorporates paragraphs 1-45 with the same force
and impact as if fully set forth herein.
64. The Plaintiff participated in protected activities by reporting gender discrimination and
unequal pay.
65. In retaliation, Defendant subjected Plaintiff to adverse employment actions, including,
but not limited to, the following:
i. Via a final warning issued on May 31, 2022, Defendant caused Williams to be:
(1) abruptly removed from her position as Director of Military Programs, CDS
PTMS and accessories; (2) removed from the high-potential director talent
pool; (3) re-assigned as an independent contributor; and (4) a negative entry
was placed in the Joint Personnel Adjudications System (JPAS), considerably
affecting William’s long-term employability.
66. Defendant retaliated against Plaintiff by creating a hostile work environment and
making her job more difficult.
67. Among the factors that motivated Defendant’s actions were Plaintiff’s sex and gender.
68. As such, Defendant’s actions and conduct are a violation of Conn. Gen. Stat. § 46a-
60(b)(4).
69. As a result of the foregoing conduct, Plaintiff has suffered and will continue to suffer
damages including but not limited to lost wages, fringe benefits, health insurance,
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Preview
RETURN DATE: AUGUST 1, 2023 CHRISTINA WILLIAMS, : SUPERIOR COURT : Plaintiff, : : J.D. OF HARTFORD : AT MANCHESTER v. : : PRATT & WHITNEY, A DIVISION OF : RAYTHEON TECHNOLOGIES : CORPORATION : : Defendant. : JUNE 28, 2023 COMPLAINT JURISDICTION AND VENUE 1. This action arises under the Connecticut Fair Employment Practices Act (“CFEPA”), Conn. Gen. Stat. § 46a-60, et seq.; and Conn. Gen. Stat. 31-51q. PLAINTIFF 2. The Plaintiff, Christina Williams (“Plaintiff” or “Williams”) is a natural person and resident of the State of Connecticut. DEFENDANT 3. The Defendant, Pratt & Whitney, a division of Raytheon Technologies Corporation (“Defendant” or “Pratt & Whitney”), is registered to conduct business in the State of Connecticut, and conducts substantial business at 400 Main Street, East Hartford, CT 06118, where Plaintiff is employed. FACTUAL ALLEGATIONS A. Mrs. Williams’ History of Exemplary Performance. -1- 4. Williams was the current Director, Military Programs Control & Diagnostic Systems, PTMS & Accessories. In this role, her job was to manage all programs, customers and integration, and technical solutions. She had approximately 10 major programs, all functioning exceptionally well, with very high MFAs (market feedback analysis), as is shown by data and her performance evaluations. 5. The programs are individually managed by a CIPT (component integrated product team lead) or program manager. Per the company roles and responsibilities, each CIPT is responsible and accountable for everything in their program. Williams’ role is to oversee and manage all military activities, budgets, manpower, customer satisfaction, technology insertion, obsolescence etc., which she performs at the highest level every day. B. Williams Raised Various Good-Faith Concerns and Violations, Pursuant to Her Rights Guaranteed by Section ... 4 ... Of Article First of The Constitution of The State of Connecticut, Conn. Gen. Stat. § 31-51q, and is Retaliated Against. (a) FADEC Issues. (1) Elevating Concerns about Bernard Raver’s Conduct. 6. The modular full authority digital engine control (“FADEC”) is a product. Generally, it takes $100M and 8-10 years of development time. The electronics in it become obsolete fairly fast and are very expensive to update. 7. Military programs revolutionized the FADEC business, inventing a generic modular FADEC. Development of the new product is cost shared by multiple customers. 8. Cost sharing creates a lot of issues. Each program has unique contractual requirements, government property usage requirements, data sharing usage, export compliance, -2- marking requirements, security classification levels, and technical requirements. This makes it very easy to make an error. 9. Bernard Raver (“Raver”) was hired as the product manager that was supposed to roll up all the individual funding streams, technical requirements, contractual requirements, and execute a modular FADEC box solution. However, Raver did not adhere program requirements, director requests, ITC requirements, manage financial performance, risk posture, and integration requirements. 10. He routinely changed costs, schedules, gave away $1M in broadly leveraged technology funding to another aerospace company, (documented), all without consequence. In addition, Raver was disrespectful, and used gender undertone verbiage with female counter parts. (documented) Williams continually elevated all these concerns to their shared boss, Howard Jacas. (documented) (2) Williams’ Ombudsman Complaint for Ethical and Compliance Issues on the Modular FADEC Team. 11. In late August or early September 2020, Williams filed a formal ombudsman complaint for ethical and contractual violations on the modular FADEC team – the fact they would not follow contractual guidance. Mark Pearl concluded after a very short and shoddy investigation: no wrongdoing, and poor behavior continued. (3) Impermissible Drive Access by Non-U.S. Citizen. 12. In September, the mod FADEC team brought on an employee, who is not a U.S. citizen, and impermissibly provided him drive access. Accordingly, this violated military program contracts and Williams reported this as well. (4) Reporting Government Contractual Violations Resulting in Stop Work. -3- 13. In early February 2022 the government issued a stop work when the FADEC team overspent their IDWA or contractual allowance. In conjunction with the overspend, Williams elevated a $1M negative schedule variance to the government. Williams pushed against modified variance explanation to falsify performance (documented). Bernard Raver was not tracking the modular FADEC earned value. (b) Reporting of Ignored Contractual Requirements, Warnings, and Mistruths. 14. Raver and Williams reported to the same supervisor, Howard Jacas. Raver blatantly ignored contractual requirements, warnings, and lied - all documented in email. Most recently April 18-20, he falsely promised that he BAER reviewed data, and the air force would did not attend specific meetings, all documents were marked appropriately and logged in. the export compliance database. The BAER Reviewer role ensures compliance with import/export government regulations by the review and application of Jurisdiction and Classification (J/C) license that contain technical data. 15. Despite his assurances, air force personnel (Brandon Hoffman) was in the meeting and tech data was marked no-tech data on the screen, a substantial error. The ITC360 flag was raised, no log of any weekly meeting was ever placed in export compliance system (for the months of previous exports), and the slides were found marked incorrectly. Williams again reported this good faith concern on April 20 and validated on June 3, 2022. (c) Reporting of Gender Discrimination to ECO and Unequal Pay. 16. In October, Nick Moura, a P5 (principle engineer), was promoted to a P6 (associate director), and his salary and promotion were sent out to the directors. Yet, he was -4- inexplicably making more than Williams. Williams had been an M7 for two years and had 10 times the responsibility, and his promotion to the level below her – put him over her. Williams rightfully complained and was given a 9.5% pay correction, which barely put her at the pay of her subordinates. 17. When Williams was brought in as a director, Louie Celiberti at the time said “don’t let it bother you that the people working for you make more than you… they have been here longer.” What Williams did not realize was that she should have been making what her roles and responsibilities dictate, not her tenure. As acknowledged with multiple pay corrections, Williams was significantly underpaid as a director. 18. The process of providing full department salaries at merit time, during promotions requests etc. - has since been eliminated because of this complaint. Williams is in possession of the entire department pay matrix from February 2021, which shows this to be true and will be submitted as evidence if it becomes necessary. 19. Further on this point, on February 11, Amy Eich reported Bernard Raver in a meeting for making gender insinuations and commentary and elevated it to Williams. Williams complained about gender disparity to Jacas on February 14 and with the ECO February 25. (all documented in email). She also discussed it with Raver directly (email documented). Again, similar to her prior complaints, nothing was done to remedy the situation. 20. In June of 2022, Williams was reassigned from her management position to an independent contributor while Raver was rewarded for poor behavior and gender discrimination and promoted to a manager within the department in August. -5- 21. Moreover, as part of a pattern of disparate treatment, Williams, a female, is also held to a different standard of conduct than male colleagues, which could be shown through correlating evidence. (d) Reporting of Multiple International Trade Compliance Violations. 22. Williams reported multiple international trade compliance violations in February of 2022, for incorrectly marking data and/or providing it to someone who should not have it. Williams’ most recent complaint was on April 18, 2022. (e) Reporting a Security Breach of Highly Classified Data. 23. Additionally, Williams reported a classified security breach in February of 2022. Namely, Pratt & Whitney gave a classified program cross section to the foreign partners of another military program – which became a very serious incident and jeopardized national security. (f) Objecting To Being Forced to Sign Outsource Statement of Work – When Peers Were Being Federally Indicted. 24. On February 24, Williams was forced to sign an outsource statement of work (SOW) for an outsource supplier to open the classified lab – this was right at the time when other directors were being federally indicted on wage capping and previously Williams never had to sign a SOW before. The SOW was for a program with a contract ending in 10 weeks. The inability of the outsource supplier to bring someone in, in time to support was unlikely. It was a waste of government funds, as it could not be executed. Williams provided alternative programs to meet the objective but her supervisor, Howard Jacas, stayed on the phone insisting, and pressuring her to sign the SOW, implicitly threatening her job. -6- (g) Objecting to Pratt & Whitney’s Response to an Employee Suicide. 25. Unfortunately, a Pratt & Whitney employee committed suicide at the end of 2020. In 2021, Williams raised an ombudsman complaint against Pratt & Whitney’s mishandling of the situation. Employees elevated to HR three times -- prior to the suicide – the employee’s urgent need for help, but nothing was done. 26. After the incident, Williams elevated his missing person and worked with local authorities and she was there to tell the team. Even after mishandling the situation, there was no onsite social worker support for grieving employees -- nothing. Throughout 2021, Williams’ team raised genuine concerns of anxiety over workplace safety and nothing was done to address this concern. At the one-year anniversary, Williams again requested help – and HR still did not assist. C. After Raising Numerous Good Faith Concerns Nine Times, Williams is Retaliated Against. 27. After raising countless issues of concern pursuant to her rights protected by Connecticut General Statute § 31-51q—Williams suffered adverse work actions. After complaining multiple times, to her severe detriment, Pratt & Whitney took the following adverse employment actions, via a final warning issued on May 31, 2022. Williams was (1) abruptly removed from her position as Director of Military Programs, CDS PTMS and accessories; (2) removed her from the high-potential director talent pool; (3) re-assigned as an independent contributor; and (4) a negative entry was placed in the Joint Personnel Adjudications System (JPAS), considerably affecting William’s long-term employability. -7- 28. To support its pretextual final write-up, Pratt & Whitney falsely accuses Williams of "perceived" retaliation, using the terms "embarrassing" and "disappointing" in critical feedback regarding a presentation, and for other unspecified alleged unprofessional behavior. 29. These false assertions by Pratt & Whitney are easily refutable. In reality, Pratt & Whitney retaliated against Ms. Williams for engaging in protected activities by making multiple complaints. D. Triggering Action Leading to Pretextual Event. 30. In response to William’s multiple complaints, Pratt & Whitney has subjected her to a near-constant stream of retaliation and increased harassment, inclusive of Pratt & Whitney issuing Williams a final written warning on May 31, 2022 to cover up its retaliatory actions. This warning is pretextual and easily refutable. 31. To explain, at the end of January, Christine Adams (“Adams”) gave a technical presentation to the program chief engineer for Adaptive programs. Noticeably, the software page had a table that did not add to the total column. After the meeting, Williams contacted Adams by telephone and provided her with critical feedback. 32. Specifically, Adams’ slide was ill-prepared and her inability to add drove loss of customer confidence and was disappointing and embarrassing. There were five employees in the meeting who witnessed Adams’ ill-prepared presentation and feedback was given to her privately over the phone by Williams. 33. Adams was software IPT lead, and BLT (broadly leveraged technology) lead for the modular FADEC. She wanted to transition into programs. In July of 2021, she came up with a transition plan that when BLT ended, she would "fully" transition into the deputy -8- CIPT role. (documented in email) Williams added her to her organizational chart early January – however, she never shifted. She was trying to still do execute multiple roles. The transition plan was widely discussed from July-January. 34. Mike Milliken was supposed to backfill Adams to allow for the transition but did not because he left Pratt & Whitney. Role transition discussions continued before and after the presentation with mathematical errors. 35. On February 5, Mike Sabatella wrote an email stating that he had concerns about Adams taking the job. Williams asked her to decide, with Mr. Milliken gone and no backfill, what she wanted to do. Adams went back and forth. Thus, Williams never removed her from her organizational chart. In fact, she is still there. 36. At the end of February, Bernard Raver, announced Adams’ as his deputy without any alignment by Williams’ supervisor, or hers, or Williams. (also documented in email). On February 14, Williams overheard through her supervisor that she thought Adams could not have the deputy CIPT role due to performance issues - so Williams addressed it again with her via email (fully documented). Never once did Williams state that she could not have it, instead, she just had to transition per her plan in July - fully. 37. Of significant importance, manpower is a full-time job for Williams. Every month, she reports to the vice president her manpower and key roles. She is 33% under-staffed so role discussions are an everyday occurrence with everyone. Williams’ role discussion with Adams was no different. There are documented emails from her supervisor Howard Jacas and Bill Lamberti during this timeframe really applying pressure for key role owner identification for classified roles. -9- 38. As for data integrity -- all cost data came from the life cycle cost study and is fully documented and time logged from internal experts and external suppliers, (Hardware and software). 39. Per customer and chief engineer request, all options were formally quoted, documented, and presented. All data for other programs is based off of this - there is and was never data integrity issues. There may be a misunderstanding by Jaysharee R that it was told to the customer they could meet all the advanced programs requirement with the legacy options- but that never happened, and she was not present at the meeting. The limitations and shortfalls of all options were made clear – but it’s up to the customer to decide. (documented) 40. Lastly, as for the key stakeholder alignment. Alignment is required between program management, program chief engineers, program management office, and customer. It is not Williams’ job to align every technical input she received. She does not lead by consensus, as she would not be able to get anything done if she did. -- it is her job to pull all the facts - present and align on a solution that meets the programs risk tolerance posture and budget. She gains alignment between the customers, PCE, SIPT, IMPT, and CIPT. (fully documented). 41. Williams and her team presented in the LCC study-3 options for application software. The customer chose (documented in email) option 3. 42. Williams gave the technical team an additional day to present their case to a hold out customer – and that customer continued to still chose option 3. For the next two months, the software team continually pushed every chance they could get to force the customer into the corner and change direction. They are still executing option 3. -10- 43. Pratt & Whitney’s write-up to Williams also accused her of unspecified unprofessional conduct. Tellingly, not one instance was ever provided to Williams and her file is devoid of any documented instances. 44. Clearly, Pratt & Whitney retaliated against Williams for raising multiple issues of public concern. The rights protected by Connecticut General Statute § 31-51q. 45. As shown by the above facts and analysis, Pratt & Whitney used a disingenuous and legally defective investigation and a final warning to conceal and suppress Williams for pointing out its own wrongdoings. In point of fact, Williams managed the work scope of 300+ Pratt & Whitney employees, 100 Collins Aerospace employees, 14 direct reports, hundreds of millions worth of military contracts, and overseeing of controls and diagnostics for our national defense. Now, she has suffered a substantial adverse change in job conditions and potential job growth. “High-potential” is ability to be promoted two more levels and now Williams has been deemed unpromotable. COUNT ONE RETALIATION, IN VIOLATION OF CONN. GEN. STAT. § 31-51q 46. Plaintiff incorporates paragraphs 1-45, with the same force and impact as if fully set forth herein at length. 47. Plaintiff was exercising her free speech on matters of public concern by reporting various good-faith concerns and violations. 48. Plaintiff’s decision to report concerns regarding violations was protected activity, provided for and compelled by the state of Connecticut. 49. In retaliation for Plaintiff’s good-faith complaints, Defendant subjected Plaintiff to the -11- following adverse employment actions, via an unjustifiable final warning issued on May 31, 2022. Williams was: i. abruptly removed from her position as Director of Military Programs, CDS PTMS and accessories; ii. removed from the high-potential director talent pool; iii. re-assigned as an independent contributor; and iv. a negative entry was placed in the Joint Personnel Adjudications System (JPAS), considerably affecting William’s long-term employability. 50. Plaintiff’s speech is protected by Sections, 3, 4, and 14 of the Connecticut Constitution. 51. The exercise of her rights did not materially interfere with her job performance, nor did it interfere with her working relationship with Defendant. 52. Plaintiff was retaliated against due to the exercise of her rights guaranteed by the Connecticut Constitution, in violation of Conn. Gen. Stat. § 31-51q. 53. As a result of his wrongful discharge, Plaintiff has suffered and will continue to suffer damages including but not limited to lost wages, fringe benefits, health insurance, emotional and psychological distress, stress, anxiety, and loss of the ability to enjoy life’s pleasures and activities. 54. Plaintiff seeks compensatory and punitive damages for Defendant’s misconduct. COUNT TWO VIOLATION OF CONN. GEN. STAT. § 46A-60(b)(1) SEX AND GENDER DISCRIMINATION 55. The Plaintiff hereby re-alleges and reincorporates paragraphs 1-45 with the same force and impact as if fully set forth herein. -12- 56. As part of a pattern of disparate treatment, Williams, a female, has been held to a different standard of conduct than male colleagues. 57. Williams was also inexplicably earning less than a male colleague, which she complained to Defendant about. 58. Plaintiff also suffered adverse employment actions, including, but not limited to, the following: i. Via a final warning issued on May 31, 2022, Defendant caused Williams to be: (1) abruptly removed from her position as Director of Military Programs, CDS PTMS and accessories; (2) removed from the high-potential director talent pool; (3) re-assigned as an independent contributor; and (4) a negative entry was placed in the Joint Personnel Adjudications System (JPAS), considerably affecting William’s long-term employability. 59. Among the factors that motivated Defendant’s actions were Plaintiff’s sex and gender. 60. As such, Defendant’s actions and conduct are a violation of Conn. Gen. Stat. § 46a- 60(b)(1). 61. As a result of the foregoing conduct, Plaintiff has suffered and will continue to suffer damages including but not limited to lost wages, fringe benefits, health insurance, emotional and psychological distress, stress, anxiety and loss of the ability to enjoy life’s pleasures and activities. 62. Plaintiff is seeking damages as a result of Defendant’s unlawful conduct. -13- COUNT THREE VIOLATION OF CONN. GEN. STAT. § 46A-60(b)(4) RETALIATION BASED ON SEX AND GENDER 63. The Plaintiff hereby re-alleges and reincorporates paragraphs 1-45 with the same force and impact as if fully set forth herein. 64. The Plaintiff participated in protected activities by reporting gender discrimination and unequal pay. 65. In retaliation, Defendant subjected Plaintiff to adverse employment actions, including, but not limited to, the following: i. Via a final warning issued on May 31, 2022, Defendant caused Williams to be: (1) abruptly removed from her position as Director of Military Programs, CDS PTMS and accessories; (2) removed from the high-potential director talent pool; (3) re-assigned as an independent contributor; and (4) a negative entry was placed in the Joint Personnel Adjudications System (JPAS), considerably affecting William’s long-term employability. 66. Defendant retaliated against Plaintiff by creating a hostile work environment and making her job more difficult. 67. Among the factors that motivated Defendant’s actions were Plaintiff’s sex and gender. 68. As such, Defendant’s actions and conduct are a violation of Conn. Gen. Stat. § 46a- 60(b)(4). 69. As a result of the foregoing conduct, Plaintiff has suffered and will continue to suffer damages including but not limited to lost wages, fringe benefits, health insurance, -14-