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DOCKET NO. HHD-CV23-6172026-S SUPERIOR COURT
CHRISTINA WILLIAMS JUDICIAL DISTRICT OF HARTFORD
AT HARTFORD
VS.
PRATT & WHITNEY, A DIVISION OF SEPTEMBER 29, 2023
RAYTHEON TECHNOLOGIES
CORPORATION
DEFENDANT’S ANSWER AND DEFENSES TO PLAINTIFF’S COMPLAINT
Defendant, Pratt & Whitney, a Division of RTX Corporation (incorrectly named in the
Complaint as “Pratt & Whitney, a Division of Raytheon Technologies Corporation”), by and
through its attorneys, Seyfarth Shaw LLP, and for its Answer and Defenses to Plaintiff’s
Complaint, states as set forth below. Any specific averment not addressed expressly below is
hereby denied, including but not limited to any and all allegations or insinuations in the section
headings to Plaintiff’s Complaint.
JURISDICTION AND VENUE
COMPLAINT ¶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.
ANSWER:
Defendant admits that Plaintiff purports to bring this action under CFEPA and Conn. Gen.
Stat. § 31-51q. Defendant denies that it discriminated or retaliated against Plaintiff in any way
and denies any remaining allegations in Paragraph No. 1 of the Complaint.
PLAINTIFF
COMPLAINT ¶2:
The Plaintiff, Christina Williams (“Plaintiff” or “Williams”) is a natural person and
resident of the State of Connecticut.
ANSWER:
Defendant admits that Plaintiff is Christina Williams and is a natural person. Defendant
lacks knowledge or information sufficient to form a belief as to the truth of the remaining
allegations in Paragraph No. 2 of the Complaint.
DEFENDANT
COMPLAINT ¶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.
ANSWER:
Defendant admits that Pratt & Whitney is a Division of RTX Corporation, is registered to
conduct business in Connecticut with an address at 400 Main Street, East Hartford, CT 06118
where Plaintiff is currently employed. Defendant denies the remaining allegations in Paragraph
No. 3 of the Complaint.
FACTUAL ALLEGATIONS
COMPLAINT ¶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.
ANSWER:
Defendant admits that Plaintiff is employed by Pratt in the role of Director of
Transformation. Defendant denies the remaining allegations in Paragraph No. 6 of the Complaint.
COMPLAINT ¶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
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military activities, budgets, manpower, customer satisfaction, technology insertion, obsolescence
etc., which she performs at the highest level every day.
ANSWER:
Defendant denies the allegations of Paragraph No. 5 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations of Paragraph No. 6 of the Complaint.
COMPLAINT ¶7:
Military programs revolutionized the FADEC business, inventing a generic modular
FADEC. Development of the new product is cost shared by multiple customers.
ANSWER:
Defendant denies the allegations of Paragraph No. 7 of the Complaint.
COMPLAINT ¶8:
Cost sharing creates a lot of issues. Each program has unique contractual requirements,
government property usage requirements, data sharing usage, export compliance, marking
requirements, security classification levels, and technical requirements. This makes it very easy
to make an error.
ANSWER:
Defendant denies the allegations of Paragraph No. 8 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations of Paragraph No. 9 of the Complaint.
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COMPLAINT ¶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)
ANSWER:
Defendant denies the allegations of Paragraph No. 10 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant lacks knowledge and information sufficient to form a belief as to the truth of
the allegations of Paragraph No. 11 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations of Paragraph No. 12 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations of Paragraph No. 13 of the Complaint.
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COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations of Paragraph No. 14 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant lacks knowledge or information sufficient to form a belief about the truth of the
allegation that Williams “reported this good faith concern on April 20[, 2022].” Pratt denies the
remaining allegations in Paragraph No. 15 of the Complaint.
COMPLAINT ¶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 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.
ANSWER:
Defendant admits that in October 2021, Complainant’s job classification was M7 and had
been M7 for approximately two years. Defendant admits that Moura’s salary was slightly higher
that Complainant’s salary when Moura’s job classification was P6. Defendant admits that
beginning in September 2021, Defendant made a market adjustment to Complainant’s
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compensation and the compensation of other employees in her group to reflect market conditions,
and that Complainant’s salary is now higher than Moura’s salary. Defendant denies the remaining
allegations in Paragraph No. 16 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies that Plaintiff is underpaid as a director, she is only equal with her
subordinates, and any implication that she does not make what her role and responsibilities dictate.
Defendant lacks knowledge or information sufficient to form a belief about the truth of the
remaining allegations in Paragraph No. 19 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 18 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 19 of the Complaint.
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COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 20 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 21 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 22 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 23 of the Complaint.
COMPLAINT ¶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
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the objective but her supervisor, Howard Jacas, stayed on the phone insisting, and pressuring her
to sign the SOW, implicitly threatening her job.
ANSWER:
Defendant denies the allegations in Paragraph No. 24 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 25 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 26 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant admits that on or about May 31, 2022, Plaintiff received a final written warning,
Defendant notified her that it would remove her from the High-Potential Director Talent Pool for
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a period of 60 days, and Defendant made her an individual contributor. Defendant denies the
remaining allegations in Paragraph No. 27 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 28 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 29 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 30 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 31 of the Complaint.
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COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 32 of the Complaint.
COMPLAINT ¶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 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.
ANSWER:
Defendant denies the allegations in Paragraph No. 33 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 34 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 35 of the Complaint.
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COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 36 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 37 of the Complaint.
COMPLAINT ¶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).
ANSWER:
Defendant denies the allegations in Paragraph No. 39 of the Complaint.
COMPLAINT ¶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)
ANSWER:
Defendant denies the allegations in Paragraph No. 39 of the Complaint.
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COMPLAINT ¶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).
ANSWER:
Defendant denies the allegations in Paragraph No. 40 of the Complaint.
COMPLAINT ¶41:
Williams and her team presented in the LCC study-3 options for application software.
The customer chose (documented in email) option 3.
ANSWER:
Defendant denies the allegations in Paragraph No. 41 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 42 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant admits that it issued a final written warning to Plaintiff that referenced
unprofessional conduct. Defendant denies the remaining allegations in Paragraph No. 43 of the
Complaint.
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COMPLAINT ¶44:
Clearly, Pratt & Whitney retaliated against Williams for raising multiple issues of public
concern. The rights protected by Connecticut General Statute § 31-51q.
ANSWER:
Defendant denies the allegations in Paragraph No. 44 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 45 of the Complaint.
COUNT ONE
RETALIATION,
IN VIOLATION OF CONN. GEN. STAT. § 31-51q
COMPLAINT ¶46:
Plaintiff incorporates paragraphs 1-45, with the same force and impact as if fully set forth
herein at length.
ANSWER:
Defendant repeats and realleges its responses to Paragraphs Nos. 1 to 45 of the Complaint
as if fully set forth herein.
COMPLAINT ¶47:
Plaintiff was exercising her free speech on matters of public concern by reporting various
good-faith concerns and violations.
ANSWER:
Defendant denies the allegations in Paragraph No. 47 of the Complaint.
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COMPLAINT ¶48:
Plaintiff’s decision to report concerns regarding violations was protected activity, provided
for and compelled by the state of Connecticut.
ANSWER:
Defendant denies the allegations in Paragraph No. 48 of the Complaint.
COMPLAINT ¶49:
In retaliation for Plaintiff’s good-faith complaints, Defendant subjected Plaintiff to the
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.
ANSWER:
Defendant denies the allegations in Paragraph No. 49 of the Complaint.
COMPLAINT ¶50:
Plaintiff’s speech is protected by Sections, 3, 4, and 14 of the Connecticut Constitution.
ANSWER:
Defendant denies the allegations in Paragraph No. 50 of the Complaint.
COMPLAINT ¶51:
The exercise of her rights did not materially interfere with her job performance, nor did it
interfere with her working relationship with Defendant.
ANSWER:
Defendant denies the allegations in Paragraph No. 51 of the Complaint.
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COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 52 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 53 of the Complaint.
COMPLAINT ¶54:
Plaintiff seeks compensatory and punitive damages for Defendant’s misconduct.
ANSWER:
Defendant denies the allegations in Paragraph No. 54 of the Complaint.
COUNT TWO
VIOLATION OF CONN. GEN. STAT. § 46A-60(b)(1)
SEX AND GENDER DISCRIMINATION
COMPLAINT ¶55:
The Plaintiff hereby re-alleges and reincorporates paragraphs 1-45 with the same force and
impact as if fully set forth herein.
ANSWER:
Defendant repeats and realleges its responses to Paragraphs Nos. 1 to 45 of the Complaint
as if fully set forth herein.
COMPLAINT ¶56:
As part of a pattern of disparate treatment, Williams, a female, has been held to a different
standard of conduct than male colleagues.
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ANSWER:
Defendant denies the allegations in Paragraph No. 56 of the Complaint.
COMPLAINT ¶57:
Williams was also inexplicably earning less than a male colleague, which she complained
to Defendant about.
ANSWER:
Defendant denies the allegations in Paragraph No. 57 of the Complaint.
COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 58 of the Complaint.
COMPLAINT ¶59:
Among the factors that motivated Defendant’s actions were Plaintiff’s sex and gender.
ANSWER:
Defendant denies the allegations in Paragraph No. 59 of the Complaint.
COMPLAINT ¶60:
As such, Defendant’s actions and conduct are a violation of Conn. Gen. Stat. § 46a-60(b)(1).
ANSWER:
Defendant denies the allegations in Paragraph No. 60 of the Complaint.
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COMPLAINT ¶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.
ANSWER:
Defendant denies the allegations in Paragraph No. 61 of the Complaint.
COMPLAINT ¶62:
Plaintiff is seeking damages as a result of Defendant’s unlawful conduct.
ANSWER:
Defendant denies the allegations in Paragraph No. 62 of the Complaint.
COUNT THREE
VIOLATION OF CONN. GEN. STAT. § 46A-60(b)(4)
RETALIATION BASED ON SEX AND GENDER
COMPLAINT ¶63:
The Plaintiff hereby re-alleges and reincorporates paragraphs 1-45 with the same force and
impact as if fully set forth herein.
ANSWER:
Defendant repeats and realleges its responses to Paragraphs Nos. 1 to 45 of the Complaint
as if fully set forth herein.
COMPLAINT ¶64:
The Plaintiff participated in protected activities by reporting gender discrimination and
unequal pay.
ANSWER:
Defendant denies the allegations in Paragraph No. 64 of the Complaint.
COMPLAINT ¶65:
In retaliation, Defendant subjected Plaintiff to adverse employment actions, including, but
not limited to, the following:
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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.
ANSWER:
Defendant denies the allegations in Paragraph No. 65 of the Complaint.
COMPLAINT ¶66:
Defendant retaliated against Plaintiff by creating a hostile work environment and making
her job more difficult.
ANSWER:
Defendant denies the allegations in Paragraph No. 66 of the Complaint.
COMPLAINT ¶67:
Among the factors that motivated Defendant’s actions were Plaintiff’s sex and gender.
ANSWER:
Defendant denies the allegations in Paragraph No. 67 of the Complaint.
COMPLAINT ¶68:
As such, Defendant’s actions and conduct are a violation of Conn. Gen. Stat. § 46a-60(b)(4).
ANSWER:
Defendant denies the allegations in Paragraph No. 68 of the Complaint.
COMPLAINT ¶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, emotional and
psychological distress, stress, anxiety and loss of the ability to enjoy life’s pleasures and activities.
ANSWER:
Defendant denies the allegations in Paragraph No. 69 of the Complaint.
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COMPLAINT ¶70:
Plaintiff is seeking damages as a result of Defendant’s unlawful conduct.
ANSWER:
Defendant denies the allegations in Paragraph No. 70 of the Complaint.
PRAYER FOR RELIEF
Wherefore the Plaintiff prays that this court award:
1. Money damages;
2. Costs;
3. Punitive damages, attorney fees, and expert witness fees;
4. Pre judgment interest
5. Trial by jury; and
6. Such other relief as the Court deems just, fair, and equitable.
ANSWER:
Defendant denies the allegations in the Prayer For Relief paragraph of the Complaint.
AFFIRMATIVE AND OTHER DEFENSES
In addition to its denial of every allegation not expressly admitted herein, Defendant asserts
the following defenses. In asserting these defenses, Defendant does not assume the burden of
proof as to matters that, pursuant to law, are Plaintiff’s burden to prove. Defendant reserves the
right to plead any additional affirmative defenses or other defenses as they become known during
the pendency of this action.
FIRST DEFENSE
To the extent Plaintiff’s claims are based on acts that occurred prior to any applicable
statute of limitations, Plaintiff’s claims are time-barred.
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SECOND DEFENSE
To the extent Plaintiff alleges that any employee of Defendant acted in an unlawful manner,
such conduct, if it occurred, was outside the course and scope of that individual’s employment,
was not authorized or condoned by Defendant, and was undertaken without the knowledge or
consent of Defendant. Thus, Defendant is not liable for any such conduct, if it occurred.
THIRD DEFENSE
Defendant had legitimate, non-discriminatory, and non-retaliatory reasons for each of the
actions taken with respect to Plaintiff’s employment, and even if some impermissible motive was
a factor in any employment decision concerning Plaintiff, a claim Defendant expressly denies, the
same decision(s) would have been reached for legitimate business reasons.
FOURTH DEFENSE
Plaintiff’s claims are barred, in whole or in part, because Defendant exercised reasonable
care to prevent and promptly correct any discriminatory or harassing behavior, and Plaintiff
unreasonably failed to take advantage of any preventative or corrective opportunities.
FIFTH DEFENSE
Plaintiff is not entitled to punitive damages because Defendant made good faith efforts to
comply with all applicable anti-discrimination laws and/or such damages are not available under
the applicable law.
SIXTH DEFENSE
If Plaintiff has failed to mitigate her damages, any recovery must be limited accordingly.
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Dated: September 29, 2023 Respectfully submitted,
SEYFARTH SHAW LLP
By: /s/ Kevin R. Brady
Anthony S. Califano (Juris No. 437745)
Kevin R. Brady (Juris No. 418209)
Seyfarth Shaw LLP
Seaport East
Two Seaport Lane, Suite 1200
Boston, MA 02210-2028
(617) 946-4800
Fax (617) 946-4801
acalifano@seyfarth.com
kbrady@seyfarth.com
Attorneys for Defendant
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CERTIFICATE OF SERVICE
I certify that on September 29, 2023 I served a copy of Defendant’s Answer and Defenses
to Plaintiff’s Complaint via email and first class U.S. mail, proper postage prepaid, to Plaintiff’s
counsel of record at the address set forth below:
Michael McMinn, Esq.
The McMinn Employment Law Firm
1000 Lafayette Blvd., Suite 1000
Bridgeport, CT 06604
michael@mcminnemploymentlaw.com
/s/ Kevin R. Brady
Kevin R. Brady
Preview
DOCKET NO. HHD-CV23-6172026-S SUPERIOR COURT CHRISTINA WILLIAMS JUDICIAL DISTRICT OF HARTFORD AT HARTFORD VS. PRATT & WHITNEY, A DIVISION OF SEPTEMBER 29, 2023 RAYTHEON TECHNOLOGIES CORPORATION DEFENDANT’S ANSWER AND DEFENSES TO PLAINTIFF’S COMPLAINT Defendant, Pratt & Whitney, a Division of RTX Corporation (incorrectly named in the Complaint as “Pratt & Whitney, a Division of Raytheon Technologies Corporation”), by and through its attorneys, Seyfarth Shaw LLP, and for its Answer and Defenses to Plaintiff’s Complaint, states as set forth below. Any specific averment not addressed expressly below is hereby denied, including but not limited to any and all allegations or insinuations in the section headings to Plaintiff’s Complaint. JURISDICTION AND VENUE COMPLAINT ¶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. ANSWER: Defendant admits that Plaintiff purports to bring this action under CFEPA and Conn. Gen. Stat. § 31-51q. Defendant denies that it discriminated or retaliated against Plaintiff in any way and denies any remaining allegations in Paragraph No. 1 of the Complaint. PLAINTIFF COMPLAINT ¶2: The Plaintiff, Christina Williams (“Plaintiff” or “Williams”) is a natural person and resident of the State of Connecticut. ANSWER: Defendant admits that Plaintiff is Christina Williams and is a natural person. Defendant lacks knowledge or information sufficient to form a belief as to the truth of the remaining allegations in Paragraph No. 2 of the Complaint. DEFENDANT COMPLAINT ¶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. ANSWER: Defendant admits that Pratt & Whitney is a Division of RTX Corporation, is registered to conduct business in Connecticut with an address at 400 Main Street, East Hartford, CT 06118 where Plaintiff is currently employed. Defendant denies the remaining allegations in Paragraph No. 3 of the Complaint. FACTUAL ALLEGATIONS COMPLAINT ¶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. ANSWER: Defendant admits that Plaintiff is employed by Pratt in the role of Director of Transformation. Defendant denies the remaining allegations in Paragraph No. 6 of the Complaint. COMPLAINT ¶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 2 military activities, budgets, manpower, customer satisfaction, technology insertion, obsolescence etc., which she performs at the highest level every day. ANSWER: Defendant denies the allegations of Paragraph No. 5 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations of Paragraph No. 6 of the Complaint. COMPLAINT ¶7: Military programs revolutionized the FADEC business, inventing a generic modular FADEC. Development of the new product is cost shared by multiple customers. ANSWER: Defendant denies the allegations of Paragraph No. 7 of the Complaint. COMPLAINT ¶8: Cost sharing creates a lot of issues. Each program has unique contractual requirements, government property usage requirements, data sharing usage, export compliance, marking requirements, security classification levels, and technical requirements. This makes it very easy to make an error. ANSWER: Defendant denies the allegations of Paragraph No. 8 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations of Paragraph No. 9 of the Complaint. 3 COMPLAINT ¶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) ANSWER: Defendant denies the allegations of Paragraph No. 10 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant lacks knowledge and information sufficient to form a belief as to the truth of the allegations of Paragraph No. 11 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations of Paragraph No. 12 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations of Paragraph No. 13 of the Complaint. 4 COMPLAINT ¶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. ANSWER: Defendant denies the allegations of Paragraph No. 14 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant lacks knowledge or information sufficient to form a belief about the truth of the allegation that Williams “reported this good faith concern on April 20[, 2022].” Pratt denies the remaining allegations in Paragraph No. 15 of the Complaint. COMPLAINT ¶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 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. ANSWER: Defendant admits that in October 2021, Complainant’s job classification was M7 and had been M7 for approximately two years. Defendant admits that Moura’s salary was slightly higher that Complainant’s salary when Moura’s job classification was P6. Defendant admits that beginning in September 2021, Defendant made a market adjustment to Complainant’s 5 compensation and the compensation of other employees in her group to reflect market conditions, and that Complainant’s salary is now higher than Moura’s salary. Defendant denies the remaining allegations in Paragraph No. 16 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies that Plaintiff is underpaid as a director, she is only equal with her subordinates, and any implication that she does not make what her role and responsibilities dictate. Defendant lacks knowledge or information sufficient to form a belief about the truth of the remaining allegations in Paragraph No. 19 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 18 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 19 of the Complaint. 6 COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 20 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 21 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 22 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 23 of the Complaint. COMPLAINT ¶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 7 the objective but her supervisor, Howard Jacas, stayed on the phone insisting, and pressuring her to sign the SOW, implicitly threatening her job. ANSWER: Defendant denies the allegations in Paragraph No. 24 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 25 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 26 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant admits that on or about May 31, 2022, Plaintiff received a final written warning, Defendant notified her that it would remove her from the High-Potential Director Talent Pool for 8 a period of 60 days, and Defendant made her an individual contributor. Defendant denies the remaining allegations in Paragraph No. 27 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 28 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 29 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 30 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 31 of the Complaint. 9 COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 32 of the Complaint. COMPLAINT ¶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 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. ANSWER: Defendant denies the allegations in Paragraph No. 33 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 34 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 35 of the Complaint. 10 COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 36 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 37 of the Complaint. COMPLAINT ¶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). ANSWER: Defendant denies the allegations in Paragraph No. 39 of the Complaint. COMPLAINT ¶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) ANSWER: Defendant denies the allegations in Paragraph No. 39 of the Complaint. 11 COMPLAINT ¶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). ANSWER: Defendant denies the allegations in Paragraph No. 40 of the Complaint. COMPLAINT ¶41: Williams and her team presented in the LCC study-3 options for application software. The customer chose (documented in email) option 3. ANSWER: Defendant denies the allegations in Paragraph No. 41 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 42 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant admits that it issued a final written warning to Plaintiff that referenced unprofessional conduct. Defendant denies the remaining allegations in Paragraph No. 43 of the Complaint. 12 COMPLAINT ¶44: Clearly, Pratt & Whitney retaliated against Williams for raising multiple issues of public concern. The rights protected by Connecticut General Statute § 31-51q. ANSWER: Defendant denies the allegations in Paragraph No. 44 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 45 of the Complaint. COUNT ONE RETALIATION, IN VIOLATION OF CONN. GEN. STAT. § 31-51q COMPLAINT ¶46: Plaintiff incorporates paragraphs 1-45, with the same force and impact as if fully set forth herein at length. ANSWER: Defendant repeats and realleges its responses to Paragraphs Nos. 1 to 45 of the Complaint as if fully set forth herein. COMPLAINT ¶47: Plaintiff was exercising her free speech on matters of public concern by reporting various good-faith concerns and violations. ANSWER: Defendant denies the allegations in Paragraph No. 47 of the Complaint. 13 COMPLAINT ¶48: Plaintiff’s decision to report concerns regarding violations was protected activity, provided for and compelled by the state of Connecticut. ANSWER: Defendant denies the allegations in Paragraph No. 48 of the Complaint. COMPLAINT ¶49: In retaliation for Plaintiff’s good-faith complaints, Defendant subjected Plaintiff to the 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. ANSWER: Defendant denies the allegations in Paragraph No. 49 of the Complaint. COMPLAINT ¶50: Plaintiff’s speech is protected by Sections, 3, 4, and 14 of the Connecticut Constitution. ANSWER: Defendant denies the allegations in Paragraph No. 50 of the Complaint. COMPLAINT ¶51: The exercise of her rights did not materially interfere with her job performance, nor did it interfere with her working relationship with Defendant. ANSWER: Defendant denies the allegations in Paragraph No. 51 of the Complaint. 14 COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 52 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 53 of the Complaint. COMPLAINT ¶54: Plaintiff seeks compensatory and punitive damages for Defendant’s misconduct. ANSWER: Defendant denies the allegations in Paragraph No. 54 of the Complaint. COUNT TWO VIOLATION OF CONN. GEN. STAT. § 46A-60(b)(1) SEX AND GENDER DISCRIMINATION COMPLAINT ¶55: The Plaintiff hereby re-alleges and reincorporates paragraphs 1-45 with the same force and impact as if fully set forth herein. ANSWER: Defendant repeats and realleges its responses to Paragraphs Nos. 1 to 45 of the Complaint as if fully set forth herein. COMPLAINT ¶56: As part of a pattern of disparate treatment, Williams, a female, has been held to a different standard of conduct than male colleagues. 15 ANSWER: Defendant denies the allegations in Paragraph No. 56 of the Complaint. COMPLAINT ¶57: Williams was also inexplicably earning less than a male colleague, which she complained to Defendant about. ANSWER: Defendant denies the allegations in Paragraph No. 57 of the Complaint. COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 58 of the Complaint. COMPLAINT ¶59: Among the factors that motivated Defendant’s actions were Plaintiff’s sex and gender. ANSWER: Defendant denies the allegations in Paragraph No. 59 of the Complaint. COMPLAINT ¶60: As such, Defendant’s actions and conduct are a violation of Conn. Gen. Stat. § 46a-60(b)(1). ANSWER: Defendant denies the allegations in Paragraph No. 60 of the Complaint. 16 COMPLAINT ¶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. ANSWER: Defendant denies the allegations in Paragraph No. 61 of the Complaint. COMPLAINT ¶62: Plaintiff is seeking damages as a result of Defendant’s unlawful conduct. ANSWER: Defendant denies the allegations in Paragraph No. 62 of the Complaint. COUNT THREE VIOLATION OF CONN. GEN. STAT. § 46A-60(b)(4) RETALIATION BASED ON SEX AND GENDER COMPLAINT ¶63: The Plaintiff hereby re-alleges and reincorporates paragraphs 1-45 with the same force and impact as if fully set forth herein. ANSWER: Defendant repeats and realleges its responses to Paragraphs Nos. 1 to 45 of the Complaint as if fully set forth herein. COMPLAINT ¶64: The Plaintiff participated in protected activities by reporting gender discrimination and unequal pay. ANSWER: Defendant denies the allegations in Paragraph No. 64 of the Complaint. COMPLAINT ¶65: In retaliation, Defendant subjected Plaintiff to adverse employment actions, including, but not limited to, the following: 17 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. ANSWER: Defendant denies the allegations in Paragraph No. 65 of the Complaint. COMPLAINT ¶66: Defendant retaliated against Plaintiff by creating a hostile work environment and making her job more difficult. ANSWER: Defendant denies the allegations in Paragraph No. 66 of the Complaint. COMPLAINT ¶67: Among the factors that motivated Defendant’s actions were Plaintiff’s sex and gender. ANSWER: Defendant denies the allegations in Paragraph No. 67 of the Complaint. COMPLAINT ¶68: As such, Defendant’s actions and conduct are a violation of Conn. Gen. Stat. § 46a-60(b)(4). ANSWER: Defendant denies the allegations in Paragraph No. 68 of the Complaint. COMPLAINT ¶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, emotional and psychological distress, stress, anxiety and loss of the ability to enjoy life’s pleasures and activities. ANSWER: Defendant denies the allegations in Paragraph No. 69 of the Complaint. 18 COMPLAINT ¶70: Plaintiff is seeking damages as a result of Defendant’s unlawful conduct. ANSWER: Defendant denies the allegations in Paragraph No. 70 of the Complaint. PRAYER FOR RELIEF Wherefore the Plaintiff prays that this court award: 1. Money damages; 2. Costs; 3. Punitive damages, attorney fees, and expert witness fees; 4. Pre judgment interest 5. Trial by jury; and 6. Such other relief as the Court deems just, fair, and equitable. ANSWER: Defendant denies the allegations in the Prayer For Relief paragraph of the Complaint. AFFIRMATIVE AND OTHER DEFENSES In addition to its denial of every allegation not expressly admitted herein, Defendant asserts the following defenses. In asserting these defenses, Defendant does not assume the burden of proof as to matters that, pursuant to law, are Plaintiff’s burden to prove. Defendant reserves the right to plead any additional affirmative defenses or other defenses as they become known during the pendency of this action. FIRST DEFENSE To the extent Plaintiff’s claims are based on acts that occurred prior to any applicable statute of limitations, Plaintiff’s claims are time-barred. 19 SECOND DEFENSE To the extent Plaintiff alleges that any employee of Defendant acted in an unlawful manner, such conduct, if it occurred, was outside the course and scope of that individual’s employment, was not authorized or condoned by Defendant, and was undertaken without the knowledge or consent of Defendant. Thus, Defendant is not liable for any such conduct, if it occurred. THIRD DEFENSE Defendant had legitimate, non-discriminatory, and non-retaliatory reasons for each of the actions taken with respect to Plaintiff’s employment, and even if some impermissible motive was a factor in any employment decision concerning Plaintiff, a claim Defendant expressly denies, the same decision(s) would have been reached for legitimate business reasons. FOURTH DEFENSE Plaintiff’s claims are barred, in whole or in part, because Defendant exercised reasonable care to prevent and promptly correct any discriminatory or harassing behavior, and Plaintiff unreasonably failed to take advantage of any preventative or corrective opportunities. FIFTH DEFENSE Plaintiff is not entitled to punitive damages because Defendant made good faith efforts to comply with all applicable anti-discrimination laws and/or such damages are not available under the applicable law. SIXTH DEFENSE If Plaintiff has failed to mitigate her damages, any recovery must be limited accordingly. 20 Dated: September 29, 2023 Respectfully submitted, SEYFARTH SHAW LLP By: /s/ Kevin R. Brady Anthony S. Califano (Juris No. 437745) Kevin R. Brady (Juris No. 418209) Seyfarth Shaw LLP Seaport East Two Seaport Lane, Suite 1200 Boston, MA 02210-2028 (617) 946-4800 Fax (617) 946-4801 acalifano@seyfarth.com kbrady@seyfarth.com Attorneys for Defendant 21 CERTIFICATE OF SERVICE I certify that on September 29, 2023 I served a copy of Defendant’s Answer and Defenses to Plaintiff’s Complaint via email and first class U.S. mail, proper postage prepaid, to Plaintiff’s counsel of record at the address set forth below: Michael McMinn, Esq. The McMinn Employment Law Firm 1000 Lafayette Blvd., Suite 1000 Bridgeport, CT 06604 michael@mcminnemploymentlaw.com /s/ Kevin R. Brady Kevin R. Brady