1. hobbies and interests
2. arts and crafts
3. knitting

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PARTIES AND JURISDICTION
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At all times hereinafter mentioned, Plaintiff CHAD WILLIAMS (hereinafter
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“CHAD WILLIAMS or PLAINTIFF”) is a resident of the District of Columbia. This action
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arises from actions taking place in within the District of Columbia This court has subject matter
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jurisdiction pursuant to D.C. Code § 11-921 and personal jurisdiction over defendant(s). The
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allegations herein relate to defamation per se, breach of contract and defendants’ infliction of
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tortious injury on Plaintiff in the District of Columbia.
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2. At all times hereinafter mentioned, Defendant #1 NONPROFIT ROUNDTABLE
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OF GREATER WASHINGTON (hereinafter “ROUNDTABLE”), a 501(c)(3) nonprofit
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corporation organized under the laws of the District of Columbia and doing business in The
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District of Columbia.
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3. At all times hereinafter mentioned, Defendant #2 VOLUNTEERS OF AMERICA -
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CHESAPEAKE (hereinafter “VOAC”), a 501(c)(3) nonprofit corporation organized under the
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laws of The State of Maryland and doing business in The District of Columbia.
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4. At all times hereinafter mentioned, Defendant #3 VOLUNTEERS OF AMERICA,
(hereinafter “VOA”), is a 501(c)(3) nonprofit corporation organized under the laws of The State
of Virginia and doing business in The District of Columbia.
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5. At all times hereinafter mentioned, Defendant #4 RUSS SNYDER, is the Chairperson
of the Board of Directors of the Nonprofit Roundtable, and President & CEO of Volunteers of
America - Chesapeake, and member of the Board of Directors of Volunteers of America conducts
business on behalf of those corporations in The District of Columbia.
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6. At all times hereinafter mentioned, Defendant #5 DIANA LEON TAYLOR ,
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(hereinafter “DIANA TAYLOR”), was and is the President & CEO of the Nonprofit
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !2
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Roundtable of Greater Washington and conducts business on behalf of the organization in The
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District of Columbia.
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7. At all times hereinafter mentioned, Defendant #6 DEBBIE JARVIS, is the VicePresident of Corporate Citizenship & Social Responsibility at Pepco Holdings and conducts
business on behalf of the corporation in The District of Columbia.
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8. Through their conduct at issue, defendants also purposefully avail themselves of laws
and jurisdiction of the District of Columbia.
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FACTS
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9. On or about June 15, 2013, Defendant RUSS Snyder entered into a six-month
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contractual agreement, with an automatic one- month extension if not ended by either party, with
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CHAD WILLIAMS on behalf of Volunteers of America - Chesapeake (VOAC), a nonprofit
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501(c)(3) corporation, located at 7901 Annapolis Road, Lanham, MD 20706, which is an affiliate
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of Volunteers of America National Services, a 501(c)(3) cooperation located at 1660 Duke Street,
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Alexandria.,VA..22314.
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10. A copy of the written contract, which is dated June 15, 2013, is annexed to this
Complaint and is hereby adopted by reference.
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11. In particular, the contract provides that VOAC would compensate Plaintiff $10,000 a
month for full-time contractual services defined under Exhibit A of the contract titled Project
Assignment Under Consulting Agreement.
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12. The purpose of the contract was to “bridge” MR. WILLIAMS until such time that
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VOAC on or around October 1, 2013 or at the earliest opportunity, or soon thereafter, would hire
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him as a full-time employee, with benefits as its Vice-President of Housing Development &
Asset Management.
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !3
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13. The Plaintiff was initially recruited by RUSS SNYDER on or about March 21, 2013
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for this contract work during a lunch at the restaurant DC Coast, located at 1401 K Street, NW
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Washington, DC 20005.
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14. On or around mid- August 2013, PLAINTIFF, was requested by Jack Hollerbach, to
start holding regular office hours similar to other VOAC executive leadership team members (i.e.
Vice-President level employees) and interacting with staff as a Vice-President level employee.
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15. On September 1, 2013, PLAINTIFF started making regular contributions to the
Volunteer of America - Chesapeake to either the Employee Benevolence Fund, General
Operations or Homeless Services Division. The total annual contribution made by PLAINTIFF
between September 1, 2013 to June 30, 2014 to the organization was $1,200.
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16. On or around mid- September 2013, with the anticipation of an October 1, 2013
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employment hire, PLAINTIFF was provided by Human Resources with an Employee Handbook,
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the organization’s Policies and Procedures Manual, a building entry key card, and company
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email account. The PLAINTIFF was also requested to start participating in meetings of the
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Executive Leadership Team, Program Leadership Team, Business Development Team and Board
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of Directors’ Finance Committee. However, on October 1, 2013 or no time soon thereafter was
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PLAINTIFF hired.
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17. On or about January 15, 2014 the contract was verbal extended with the PLAINTIFF,
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by Jack Hollerbach, the Executive Vice-President & CFO, of Volunteers of America -
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Chesapeake, on behalf of RUSS, to March 31, 2014.
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18.
On or about March 31, 2014 the contract was verbally extended with the
PLAINTIFF, by Jack Hollerbach on behalf of RUSS Snyder, to June 30, 2014.
19. Mid June 2014, RUSS Snyder publicly announced at the organization’s
Administrative/Central Office monthly staff meeting, and made official, that PLAINTIFF would
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !4
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effectively start as the Vice-President for Housing Development & Asset Management on July 1,
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2014 or soon thereafter.
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20. On or about June 30, 2014 the contract was verbal extended with the PLAINTIFF, by
Jack Hollerbach on behalf of RUSS Snyder, to July 31, 2014.
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21. On the afternoon of August 14, 2014, RUSS Snyder informed the PLAINTIFF that
he was going into another direction with the position and would not be formally hiring
PLAINTIFF. The employment contract was verbally extended, at this meeting, with the Plaintiff,
by RUSS Snyder in the presence of Jack Hollerbach, to October 31, 2014, with the option for the
PLAINTIFF to thereafter provide part-time contract work until July 31, 2015.
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22. The Plaintiff and RUSS became acquainted on or about October 6, 2011 through their
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service together on the Board of Directors of the Nonprofit Roundtable of Greater Washington
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(ROUNDTABLE).
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23. On or about in early June 2013 DIANA TAYLOR was recommended by RUSS
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Snyder to the Board of Directors of the ROUNDTABLE for hire as the organization’s President
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& CEO DIANA TAYLOR started as the President & CEO of the ROUNDTABLE of June 16,
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2014. The ROUNDTABLE’s Board of Directors officially confirmed this recommended hire on
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or about in early July 2013.
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24. PLAINTIFF along with the majority of others in the Nonprofit Roundtable
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community had no prior acquaintance, knowledge or background of DIANA TAYLOR’s
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experience working in the known nonprofit sector of the Nonprofit Roundtable community.
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25. RUSS SNYDER and DIANA TAYLOR became acquainted, in the summer of 2012,
as members of the Leadership Greater Washington Class of 2012. TAMARA SMITH and FRED
WALLS are also members of the same class and serve on the Board of Directors of the Nonprofit
Roundtable of Greater Washington.
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !5
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26. RUSS Snyder encouraged each ROUNDTABLE Board member to have a one on one
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meeting with DIANA TAYLOR before the next schedule board meeting in September 2013 in an
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effort to help orientate DIANA TAYLOR into her new position, and the nonprofit roundtable
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sector.
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27. On or about December 8, 2013, DIANA TAYLOR initiated a text message and or
phone call to PLAINTIFF and asked to meet with him. This meeting was the first time
PLAINTIFF had the opportunity to meet one on one with the new President & CEO of the
ROUNDTABLE. The PLAINTIFF and DIANA TAYLOR meet at Woodmont Grill, located at
7715 Woodmont Ave, Bethesda, MD. At the dinner meeting, DIANA TAYLOR discussed some
grant raising and fundraising challenges she was having at the ROUNDTABLE, she talked about
her rational for wanting to terminate ROUNDTABLE employee Nana A. Oppong, she spoke
about her recent divorce and personal financial problems, and went in detail on her dating life
and meeting Michael Brown, who she meet on Match.com. The PLAINTIFF talked to DIANA
TAYLOR about the ROUNDTABLE jointly hosting a benefits concert fundraiser, similar to the
“Made in America” tour, with the United Way of the National Capital Area to help fund special
grants to ROUNDTABLE members focused on arts, culture and education. The PLAINTIFF
witnessed DIANA TAYLOR being emotional distraught and talking extensively with great
concern regarding her personal financial situation. DIANA TAYLOR also informed PLAINTIFF
that if it wasn’t for her “deep personal friendship” with RUSS Snyder that she used to “influence
him to waive the financial credit background check during her hiring process,” she would not
have been hired as the President & CEO of the ROUNDTABLE.
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28. The ROUNDTABLE’S Board of Directors was not informed by RUSS of this wavier
in the financial credit background check and report.
29. On or around December 16, 2013, PLAINTIFF feeling concerned for DIANA
TAYLOR’s emotional state as a result of her divorce and financial circumstances with the
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !6
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intended effort to cheer her mood, invited DIANA TAYLOR and her boyfriend to join the
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PLAINTIFF and his girlfriend, Rita Lewis, for New Year’s Eve drinks at the POV Lounge in the
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W Hotel, located at 515 15th Street, NW, Washington, DC 20004, to meet some of his
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girlfriend’s friends in the music and entertainment industry. Rita Lewis is the Promotions
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Director for Radio One. DIANA TAYLOR declined the offer indicating that her boyfriend,
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Michael Brown had to work a music event that night.
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30. On or about December 28, 2013, DIANA TAYLOR contacted PLAINTIFF to
inquire whether the invitation to join him and his girlfriend for drinks was still available. The
PLAINTIFF informed DIANA TAYLOR that the invitation was still open. DIANA TAYLOR
thus informed PLAINTIFF that she and her boyfriend would be joining him and his girlfriend for
drinks, and to socialize with Rita’s friends and associates in the music and entertainment
industry.
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31. On December 31, 2013 around 10:30 PM DIANA TAYLOR and her boyfriend
arrived at the W Hotel to have drinks with PLAINTIFF and his girlfriend. During talks over
drinks DIANA TAYLOR again informed PLAINTIFF, this time in the presents of his girlfriend,
that if it were not for her “deep personal friendship” with RUSS SNYDER that she used to
“influence him to waive the financial credit background check during her hiring process,” she
wouldn’t have been hired as the President & CEO of the ROUNDTABLE.
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32. After the POV Lounge New Year’s Eve event ended on January 1, 2014 around 2:00
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AM, DIANA TAYLOR and her boyfriend joined PLAINTIFF and his girlfriend for a late night
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snack of hamburgers, fries, coke and water. DIANA TAYLOR and her boyfriend left the
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PLAINTIFF’s and his girlfriend at 4:00 AM. DIANA TAYLOR sent the PLAINTIFF a text
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around 5:00 AM to inform him that she and her boyfriend safely arrived home.
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CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !7
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33. Just four days later on January 5, 2014, DIANA TAYLOR sent PLAINTIFF and his
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girlfriend Facebook “friend requests.” Although PLAINTIFF was initially hesitant in accepting
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the Facebook friend request to his private personal page, he would reluctantly accept. The
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PLAINTIFF informed DIANA TAYLOR through Facebook messaging that this was his private
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page and not his public page.
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34. A copy of this Facebook messaging, on January 5, 2014, is annexed to this Complaint
and is hereby adopted by reference.
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35. On January 16, 2014, DIANA TAYLOR her son, PLAINTIFF’s girlfriend,
PLAINTIFF’s daughter, PLAINTIFF’s high school friend, Melvin Russ McCray, and
PLAINTIFF would meet up for snacks and drinks inside the Verizon Center, located at 601 F
Street, NW Washington, D.C. 20004 before the start of the Jay-Z concert. DIANA TAYLOR and
her son and PLAINTIFF and his party sat in separate sections of the Verizon Center.
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36. On or around end of January or early February DIANA TAYLOR reached out to
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PLAINTIFF and his girlfriend and inquired about getting together for a weekend getaway.
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DIANA TAYLOR, DIANA’s boyfriend, PLAINTIFF’s girlfriend and PLAINTIFF scheduled a
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weekend getaway to Atlantic City for the weekend between February 22 - 24, 2014.
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weekend getaway did not occur due to last minute changes in PLAINTIFF’s girlfriend schedule.
The
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37. On February 24, 2014 PLAINTIFF’s fellow ROUNDTABLE Board member, and
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Treasure of the Roundtable, AMANDA ANDERE, current President & CEO of Wider
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Opportunities for Women, and former Executive Director of FACET, shared a financial report on
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the status of the ROUNDTABLE’s alarming financial situation that was hidden from the entire
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Board of Directors since DIANA became President & CEO. In addition, AMANDA informed
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PLAINTIFF that staff were starting to question DIANA’s company credit card usage. After
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !8
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receiving the report and recalling the comments that DIANA made about her financial
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circumstances, PLAINTIFF conducted a public court record search on DIANA LEON TAYLOR
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and discovered she had a Bankruptcy, Federal and State Tax Liens of $150,000, and Confessed
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Judgments of $2.5 million.
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38. PLAINTIFF was extremely shocked and surprised at what he discovered in the public
court record. Since he specifically recalled a discussion with RUSS Snyder in which he
mentioned that in his search for an Executive Vice- President & CFO at Volunteers of America
Chesapeake that he was adamant about not hiring any individual in any executive positions with
recent bankruptcies, tax liens, collections and/or confessed judgments.
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39. This policy clearly did not apply to his friend DIANA LEON TAYLOR with whom
he developed a close “personal friendship” starting in the summer of 2011.
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40. During the evening of February 24, 2014 in a phone conversation with AMANDA,
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the PLAINTIFF revealed that DIANA TAYLOR had $150,000 in Federal and State Tax Liens
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and $2.5 million in confessed judgments before she was hired, and also had an additional
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significant amount confessed judgment entered against her from Eagle Bank only a few months
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after she started her position as President & CEO of the ROUNDTABLE. Plaintiff stated to
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AMANDA this might be an indicator of DIANA’s inability to properly fiscally manage the
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organization’s finances and distract her from her duties and responsibilities.
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41. PLAINTIFF also informed AMANDA during this discussion that DIANA informed
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him that RUSS, in clear breach of his fiduciary duty to the ROUNDTABLE, waived her financial
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credit background check. The PLAINTIFF advised her as a member of the ROUNDTABLE’S
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Executive Committee that she should inquire from RUSS Snyder into whether a credit and
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financial background check had actually been conducted. AMANDA informed PLAINTIFF that
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CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !9
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she learned from ROUNDTABLE staff that DIANA TAYLOR had asked her staff to research
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information regarding the process of filing Bankruptcy soon after she started her position.
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42. AMANDA did not follow up with RUSS on whether a credit and financial
background check had been properly conducted on DIANA TAYLOR. AMANDA in the same
phone call insisted that PLAINTIFF should be the one to approach RUSS on this matter.
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43. During the phone conversation AMANDA expressed concerns regarding PLAINTIFF
and if he questioned RUSS about DIANA TAYLOR’S financial circumstances did he fear losing
his job with VOAC. PLAINTIFF respond “No”. The PLAINTIFF told AMANDA he believes
that the there is a clear separation with being a member of the Board of Directors of the
ROUNDTABLE and being a contract-employee at Volunteers of American - Chesapeake where
RUSS is his supervisor. Those distinctions and positions are separate and should not have any
bearing on him exercising his legal fiduciary responsibilities as a Board member of the
ROUNDTABLE.
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44. In Mid April 2014, the PLAINTIFF, after a ROUNDTABLE Membership committee
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meeting informed Mary Agee, President & CEO, Northern Virginia Family Services, and
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previous Chairperson of the ROUNDTABLE’S board of directors that a public court record
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search would reveal that DIANA TAYLOR had $150,000 in Federal and State Tax Liens and
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$2.5 million in confessed judgments. Mary Agee encouraged PLAINTIFF to have a conversation
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with RUSS Snyder on this discovery.
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45. On the morning of May 1, 2014 a confidential executive session of the Board of
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Directors of the Roundtable was held to discuss the performance of DIANA TAYLOR. At this
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meeting Plaintiff was the first board member to articulate his dissatisfaction of DIANA
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TAYLOR’s performance, and provided evidence and facts to support his claims including
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DIANA TAYLOR falsifying a report of individuals and organizations she had meet with during
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !10
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her tenure at the ROUNDTABLE, the misrepresentation of membership dues, an ineffective
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leadership on grant development and fundraising, and the current financial predicament of the
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organization depleting its Reserves and having raised no additional operating funding resources.
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46. Debbie Jarvis (“DEBBIE”) a fellow ROUNDTABLE board member phoned
conferenced into this confidential executive session.
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47. During the afternoon of May 1, 2014 in a telephone conversation with fellow
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ROUNDTABLE board member AMANDA ANDERE informed the PLAINTIFF that she learned
from ROUNDTABLE staff that the confidential executive session had been compromised by
DEBBIE JARVIS secretly connecting DIANA TAYLOR so that she could listen to the entire
Board of Directors confidential executive session conversations.
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48. On May 2, 2014 in an email exchange between RUSS Snyder, KERRIE WILSON
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and AMANDA ANDERE the breach in confidentiality of the executive session of the Board was
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acknowledged. RUSS informed KERRIE, AMANDA and the PLAINTIFF that he was “…
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thinking through my response to this information and will keep you informed”
49. RUSS did not give any response to DEBBIE JARVIS’ alleged violation of the
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confidentiality of the Board’s confidential executive session.
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50. A copy of the email exchange is annexed to this Complaint and is hereby adopted by
reference.
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51. At the May 1, 2014 executive session of the Board of the Directors of the
ROUNDTABLE it was agreed that a “360 degree” evaluation of DIANA TAYLOR’s
performance would be conducted. The evaluation would be completed by or around June 20,
2014.
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52. The Board of Directors of the ROUNDTABLE had scheduled to complete DIANA
TAYLOR’s initial evaluation in March 2014. However RUSS did not allow this goal to be
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !11
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reached . May 1, 2014, was the first time RUSS in his authority as Chairperson allowed an
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executive session of the board to occur to evaluate DIANA TAYLOR’s performance, although
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the Board previously after each regular session had an executive session to evaluated the status
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performance of the prior President & CEO, CHUCK BEAN who is now the Executive Director
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of the Metropolitan Washington Council of Governments.
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53. After the May 1, 2014 Board of Directors meeting of the ROUNDTABLE, DIANA
TAYLOR contacted RUSS seeking a cause to immediately remove the AMANDA ANDERE,
SHANNON STEEN, KERRIE WILSON and PLAINTIFF from the Board of Directors of the
ROUNDTABLE. DIANA TAYLOR later communicated her efforts during a conference call with
nonprofit leaders that was witnessed by CLIFF YE a board member of the ROUNDTABLE.
DIANA TAYLOR’s efforts were being supported by TAMARA SMITH, President & CEO,
YWCA National Capital Area, FREDRIC WALLS, Managing Director of Foundation &
Endowment Specialty Practice, and DEBBIE JARVIS, Vice-President of Corporate Citizenship
& Social Responsibility.
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54. TAMARA SMITH and FRED WALLS are members of Leadership Greater
Washington Class of 2012 with DIANA and RUSS.
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55. On or around May 6, 2014 DIANA deleted her Facebook friend connection to
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PLAINTIFF’S private page. It is now believed that DIANA used the time period between May 1
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to May 6, 2014 to search for potential postings that could be publicly harmful to PLAINTIFF or
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support his removal from the Board of Directors of the ROUNDTABLE and/or cause the
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termination of his employment contract with Volunteers of America - Chesapeake which would
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in fact potentially cause him to resign or be asked to leave from the Board of Directors of the
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ROUNDTABLE.
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CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !12
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56. On or about June 20, 2014 the PLAINTIFF meet with RUSS who informed him that
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12 of 16 board members provided an unsatisfactory performance evaluation of DIANA. Those
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board members that provided positive performance evaluations of DIANA TAYLOR included
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TAMARA SMITH, DEBBIE JARVIS, HERB TILLARY and one other board member that
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PLAINTIFF has no knowledge. The PLAINTIFF believes this person to be RUSS Snyder.
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57. A July 17, 2014 special meeting of the Board of Directors of the ROUNDTABLE was
scheduled by RUSS for the Board of Directors of the ROUNDTABLE to evaluate and make a
determinations on DIANA TAYLOR’s continued tenure in the position as President & CEO of
the ROUNDTABLE.
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58. On or about July 3, 2014 RUSS informed PLAINTIFF that he had a breakfast
meeting with DIANA TAYLOR, that morning, and that he informed her of the evaluation
sentiment of the ROUNDTABLE’s Board of Directors, staff, members and funding partners.
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59. On July 7, 2014 the ROUNDTABLE received DIANA TAYLOR’s letter of
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resignation from her position as President & CEO of the ROUNDTABLE. In her resignation
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letter addressed to RUSS SNYDER and KERRIE WILSON, DIANA TAYLOR made allegations
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of a hostile work environment created by ROUNDTABLE Board members and staff as the basis
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for her resignation. The PLAINTIFF was not named in her initial complaint against the
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ROUNDTABLE.
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60. The July 7, 2014 resignation letter listed several complaints against unnamed Board
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members and staff that allegedly created a hostile work environment. The resignation letter also
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requested that the board settle these claims with a 12 months severance package totaling
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$180,000. At the time of this filing the ROUNDTABLE had already paid 4 months of this
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severance package totaling $60,000, which was obligated to be paid to her in her employment
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contract signed by RUSS SNYDER.
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !13
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61. A copy of the communication of resignation and requested severance terms is
annexed to this Complaint and is hereby adopted by reference.
62. A copy of DIANA TAYLOR LEON TAYLOR’S employment contract is annexed to
this Compliant and is hereby adopted by reference.
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63. The PLAINTIFF along with other board members were hindered and/or prevented, by
RUSS, from seeing DIANA TAYLOR’s employment contract during her tenure. When the
contract was finally revealed to give justification for the 4 months of severance obligated under
her resignation, the PLAINTIFF along with many other board members were shocked and
appalled at the salary package of $180,000 annually, when the founding and previous President
& CEO was paid $130,000 after 10 years in the position. The PLAINTIFF was also shock that
the ROUNDTABLE would be obliged to pay 4 months of severance upon resignation instead of
the normal practice of an employee to be paid out from their vacation leave or one week’s pay
for each year worked.
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64. Mid- June 2014, RUSS Snyder publicly announced to employees at Volunteers of
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America - Chesapeake’s Administrative Central Office monthly staff meeting, that PLAINTIFF
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would effectively start as the Vice-President for Housing Development & Asset Management on
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July 1, 2014 or soon thereafter.
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65. On or about June 30, 2014 the PLAINTIFF’s employment contract with Volunteers
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of America - Chesapeake was verbal extended by Jack Hollerbach on behalf of RUSS Snyder, to
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July 31, 2014.
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66. On July 8, 2014, RUSS Snyder and Plaintiff met to discuss DIANA’s resignation and
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terms of her severance request. It was during this meeting that PLAINTIFF informed RUSS of
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DIANA’s public court records of $150,000 in Federal and State Tax Liens and $2.5 million in
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Confessed Judgments, bankruptcy filing that are causes for her severance compensation request
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !14
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of 12 months totaling $180,000. The PLAINTIFF also asked RUSS did he insure that the search
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firm conducted a financial background and credit and financial background report check. RUSS
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brushed off the question.
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67. On July 10, 2014 after exchanges of communication between DIANA’s legal counsel
and RUSS SNYDER, RUSS received a follow up communication regarding her original demand
letter in which she alleged hostile work environment. It was in her follow up letter, DIANA for
the first time alleges that the PLAINTIFF sexually harassed her during the New Year’s Eve party
on December 31, 2013.
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68. A copy of this follow up email is annexed to this Complaint and is hereby adopted by
reference.
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69. In this follow up communication the PLAINTIFF is specifically identified by name,
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and continues to be the only Board member or staff person mentioned by name in the Nonprofit
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Roundtable’s industry domain with allegations claimed by DIANA that created a hostile work
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environment as a result of this false claiming of sexual harassment.
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70. The PLAINTIFF and RUSS would meet to discuss these allegations. In this meeting
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RUSS informed Plaintiff of DIANA’s allegations against him. RUSS specifically stated to
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PLAINTIFF that DIANA TAYLOR had provided him with emails and text communications to
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him that support her claims. Plaintiff immediately requested from RUSS copy of DIANA’s
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statement, emails and texts that were supported her claims. RUSS refused to provide the
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statement, emails and texts. RUSS only allowed PLAINTIFF to quickly glance at the statement
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and then he verbally summarized DIANA’s claims against PLAINTIFF without providing all the
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stated documentation he claimed to receive that supported her allegations. RUSS articulated
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DIANA’s claims to PLAINTIFF in a way that indicated that DIANA would be taking separate
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legal action against PLAINTIFF. RUSS also informed PLAINTIFF that the ROUNDTABLE’s
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !15
1
resources would not be used to defend him with this manner, although it would be used to defend
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the claims against other board members. In addition, RUSS informed PLAINTIFF that it would
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be best if PLAINTIFF resigned or took a “ leave of absence” from the Board of Directors until
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the ending of his term scheduled for September 30, 2014.
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71. PLAINTIFF disagreed with RUSS’s articulation of the circumstances and his
recommended action the PLAINTIFF should take. PLAINTIFF informed RUSS that he would
be immediately filing a civil complaint against DIANA for defamation.
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72. RUSS went on to demand that the PLAINTIFF take a leave of absence until the end
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of PLAINTIFF’S Board term which was scheduled to end on September 30, 2014, thus
effectively having PLAINTIFF resign position from the Board of Directors of the
ROUNDTABLE. In addition, RUSS specifically told PLAINTIFF he could no longer participate
in ROUNDTABLE Board of Director meetings, programs or activities, and therefore
PLAINTIFF should consider his tenure on the Board of Directors of the ROUNDTABLE to have
ended.
73. The PLAINTIFF adamantly and immediately denied DIANA’s claims of sexual
harassment.
74. later that same day, RUSS sent an email to PLAINTIFF telling him that he was being
put on an involuntary “leave of absence” from the Board of Directors of the ROUNDTABLE.
75. A copy of this email is annexed to this Complaint and is hereby adopted by reference.
76. RUSS in his position has no authority vested within him by the organizations Bylaws to place any rightfully elected Board member of the ROUNDTABLE on “leave of absence.”
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77. Continuing into the meeting RUSS stated that the ROUNDTABLE’s Directors &
Insurance company’s assigned counsel, MATT RANCK, of Eccleston & Wolf, would conduct a
full independent investigation into DIANA’s claims against Board members and staff, and ANN
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !16
1
NOVAK, a Human Resource Consultant, would be hired to specially investigate DIANA’s
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specific claims of sexual harassment against Plaintiff. RUSS informed Plaintiff that both the
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Directors & Insurance company’s counsultant and Human Resource consult would report to him
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with ongoing, information collected, statements and communications of the investigation.
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78. The following week on or about July 15, 2014, the PLAINTIFF was again strongly
discouraged by RUSS from participating in the ROUNDTABLE’s Membership Committee
meeting which the PLAINTIFF is the Chairperson. At this time PLAINTIFF started to become
alienated, depressed and fearful of the impact of DIANA TAYLOR’s false claims.
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77. On or about July 15, 2014 Russ cancelled the Special Meeting of the
ROUNDTABLE’s Board of Directors that was being held to make a determination on DIANA’s
tenure, claims and severance request. In that email RUSS asked all board members to maintain
this situation of DIANA’s claims in strict confidentiality.
78. At this time, DIANA’s claims against Plaintiff had started to become known to those
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outside of the ROUNDTABLE and into the nonprofit roundtable community.
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79. On or about July 21, 2014, Plaintiff obtained legal counsel.
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80. On July 22, 2014, PLAINTIFF sent RUSS an email communicating under the advice
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of Counsel that he would not be taking an imposed upon him leave of absence from the Board of
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Directors of the ROUNDTABLE, and additionally stated that RUSS had no authority under the
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organization’s By-Laws to impose such action.
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81. A copy of this email is annexed to this Complaint and is hereby adopted by reference.
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82. Also, on July 22, 2014, after completing a meeting with the Howard County Housing
Commission, with Jack Hollerbach, Executive Vice-President & CFO, Volunteers of America Chesapeake. PLAINTIFF informed JACK that PLAINTIFF would not be in the office tomorrow
morning since he had a ROUNDTABLE Board of Directors meeting. JACK responded “Russ
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !17
1
informed me you would no longer be participating in Nonprofit Roundtable board meetings
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anymore, because you had step down off the board as a result of you facing some serious
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allegations.” The PLAINTIFF was shocked, emotionally hurt, and further depressed that a non
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member of the ROUNDTABLE’S Board of Directors was aware of the allegations made against
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PLAINTIFF.
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83. In addition, on July 22, 2014, the PLAINTIFF received a phone call from RUSS in
response to his email that he would not be taking an imposed leave of absence. RUSS angrily
disagreed with this response, and insisted that PLAINTIFF was receiving bad legal counsel and
should not adhere to the advice of his counsel. RUSS informed PLAINTIFF that it would not be
good for him to show up at tomorrow’s Board of Directors meeting of the ROUNDTABLE, and
that some board members have already been told that PLAINTIFF had taking a leaving of
absence, and therefore would not be expecting PLAINTIFF to attend.
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84. On July 23, 2014, PLAINTIFF attended the ROUNDTABLE’s Board of Directors
meeting at the offices of TOM RAFFA. The PLAINTIFF received shocked looks when he
arrived to the meeting. At the meeting RUSS had the ROUNDTABLE’s outside General
Counsel, ALISA BABITZ, with the Law firm Gibson & Dunn, distribute a Confidentiality
Policy. ALISA went over the Confidentiality Policy and explained each member’s fiduciary duty
to maintain confidentiality within the ROUNDTABLE during with any and all communications,
documents and notes, with specific regards to this investigation. RUSS SNYDER asked all
Board members to adhere to the confidentiality policy.
85. A copy of this Confidentiality Policy is annexed to this Complaint and is hereby
adopted by reference.
86. At this meeting RUSS informed the Board of Directors that an investigation into these
claims would start the following week.
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !18
1
87. At or around August 4, 2014, RUSS sent out an email through his Executive
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Assistant, CHRISTINE LONGFORD-DIXON, scheduling interviews for Board members to
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participate in the investigation with MAT RANCK. RUSS through CHRISTINE LONGFORD-
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DIXON asked PLAINTIFF to do his interview first before anyone else.
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88. On August 8, 2014, CHRISTINE LONGFORD-DIXON entered PLAINTIFF’s office
and pushed him again to schedule his interview.
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89. On August 8, 2014, PLAINTIFF received a phone call from GLEN O’GILVIE,
President & CEO of the Center for Nonprofit Advancement. GLEN informed PLAINTIFF that
RUSS had informed him and his organization’s Board of Directors that PLAINTIFF was at the
center of sexual harassment allegations. GLEN went on to state that these allegations are holding
up the ROUNDTABLE and CENTER from moving forward with a pending merger urged
PLAINTIFF to influence ROUNDTABLE Board of Directors to settle with DIANA TAYLOR.
PLAINTIFF informed GLEN that the allegations and claims against him are false and he
believed settlement would give validity to her claims.
90. PLAINTIFF felt pressured by GLEN, during the phone call, to influence the
ROUNDTABLE’s Board of Directors to settle with DIANA TAYLOR.
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91. PLAINTIFF later discovered that a text messaged that PLAINTIFF and GLEN had
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discussing DIANA’S performance was shared by GLEN to DIANA. This text message
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conversation of DIANA TAYLOR’S performance was so widely shared that ROB MALONE,
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Chief Business Development Officer, at Volunteers of America - Chesapeake approached
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PLAINTIFF about the text message and questioned his evaluation of DIANA TAYLOR’S
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performance.
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92. On or about August 11, 2014 RUSS sent PLAINTIFF and email pushing him again to
schedule his interview.
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !19
1
93. On or about August 13, 2014, PLAINTIFF sent RUSS an email requesting on the
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parameters of the interview and still emphasizing that PLAINTIFF has yet to receive the
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statement, emails and texts claimed by DIANA TAYLOR to support her allegations of sexual
4
harassment. The email was forwarded by RUSS to MATT RANCK.
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94. On or about August 14, 2014, MAT RANCK replied to the email and attached
DIANA’s statement and text communication between PLAINTIFF and GLEN O’GILVIE where
PLAINTIFF discussed with GLEN his evaluation of DIANA’S performance. No emails as
claimed by RUSS were ever received to have provided evidence of sexual harassment as
claimed by DIANA. This after a month of requesting this information.
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95. It is the PLAINTIFF’s belief that RUSS intentionally misrepresented to PLAINTIFF
that he received text messages and emails from DIANA TAYLOR that gave evidence to sexual
harassment. PLAINTIFF believes these efforts were done in an effort to hasten his removal from
the Board of Directors of the ROUNDTABLE and thereby eliminate any resistance or opposition
to settling DIANA TAYLOR’s unfounded sexual harassment claims that would reward his close
friend and Leadership Greater Washington Classmate with an $180,000 pay out.
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96. Also on or about the late afternoon of August 14, 2014, MAT RANCK, coincidentally
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received an email from DIANA’s attorney with an attached screenshot of a March 28, 2014
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Facebook post by PLAINTIFF. The Facebook post offered nothing to support the false
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allegations against PLAINTIFF for sexual harassment. The Facebook post expressed
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PLAINTIFF’S excitement in working for Volunteers of America - Chesapeake (VOAC) in a
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partnership with Volunteers of America National Services on a Developer’s Agreement with the
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Howard County Housing Commission to build a Day Resource Center & 35 units Single-Room
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Occupancy facility in Jessup, MD.
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CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !20
1
97. On August 18, 2014 around 4PM, PLAINTIFF with his legal counsel, John L-R
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Poindexter, participated in the investigative interview process with MAT RANCK and ANN
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NOVAK. PLAINTIFF answered all questions truthfully in full detail. PLAINTIFF also later
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provided Facebook messages, emails, pictures, and list of witnesses to disprove and defend
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against DIANA’s allegation claims of sexual harassment.
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98. During the PLAINTIFF’S interview, MAT RANCK never mentioned that he received
an email regarding PLAINTIFF’S “March 28, 2014” Facebook post that was provided to him by
DIANA. MAT RANCK forwarded this Facebook post to RUSS.
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99. The PLAINTIFF’S Facebook post was solely shared with RUSS and not the entire
the Executive Committee of the Board of Directors as were the wishes of the Board of Directors
of the ROUNDTABLE as was voted on at the July 23, 2014 board of directors meeting. It was
later discovered by the Executive Committee and thereafter the full Board that RUSS SNYDER
withheld other received communications including emails, exchanges of communications, and
received documents, along with conducting backdoor discussions not authorized by the Board of
Directors in association with the investigation and other information that should have been
shared with the full Board of Directors of the ROUNDTABLE including DIANA’s actually
employment contract that he singularly signed and the unfiltered emails of DIANA’s resignation
through her attorney. The withholding of information was so egregious that DEBBIE JARVIS in
an email to the entire Board of Directors suggested that RUSS’s term as Chairperson should be
discussed.
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100. On the morning of August 19, 2014, one day after PLAINTIFF’S interview with
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MATT RANCK AND ANNA NOVAK, RUSS terminated Plaintiff’s employment contract with
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Volunteers of America - Chesapeake (VOAC).
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CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !21
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101. A copy of the Termination Letter is annexed to this Complaint and is hereby adopted
by reference.
102. In summary the letter states that RUSS SNYDER terminated PLAINTIFF’S
employment contract and withdrew his following offer for him to provide continued contractual
services after the conclusion of the current contract period, because in his determination
PLAINTIFF violated VOAC’s Confidentiality Policy and PLAINTIFF’s contractual agreement
confidentiality clause by posting on social media back on March 28, 2014 of the success,
performance, structuring and accomplishments of the Howard County Guildford Rd. DRC &
SRO deal. In the process of terminating PLAINTIFF, RUSS asked PLAINTIFF “You are not
going to keep participating in the Board meetings after this are you?”
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103. PLAINTIFF, despite pressure from RUSS, did continue to carry out his Fiduciary
Duty and participated in the September 4, 2014 regular meeting, and the September 23, 2014
special meeting of the ROUNDTABLE board of directors.
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104. On September 18, 2014, the ROUNDTABLE received an amended demand for
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severance from DIANA through her attorney for an additional 12 months of compensation in
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addition to the already previous demand of 12 months. Therefore making DIANA’s total
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severance demand a total of $360,000.
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105. On September 18, PLAINTIFF sent a letter to the ROUNDTABLE’s Executive
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Committee that articulated what he believed to be damages to him caused by false allegations by
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a ROUNDTABLE employee, DIANA LEON TALOR, and breach of confidentiality, by RUSS
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SNYDER and DEBBIE JARVIS. The PLAINTIFF in the letter stated his belief that RUSS
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SNYDER, DEBBIE JARVIS, MAT RANCK, ROUNDTABLE, and VOAC were liable for
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damages in the form of loss of earnings, general damages, and attorney fees that unjustly lead to
25
the termination of PLAINTIFF’s employment contract with VOAC, industry reputation damage,
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !22
1
and emotional pain and suffered caused by individuals and individuals acting on behalf of
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corporations.
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106. On September 23, 2014, the ROUNDTABLE held a special meeting of the Board of
Directors to receive the official independent investigative report conducted by MATT RANCK
on behalf of the ROUNDTABLE’s Directors & Officers Insurance. The reported as presented
found no merit to DIANA’s claims against any board member or staff of the ROUNDTABLE,
including the specific allegations against PLAINTIFF for sexual harassment. However, RUSS
SNYDER and TAMARA SMITH, DIANA LEON TAYLOR’s Leadership Greater Washington
Classmates, who had received proxy votes from DEBBIE JARVIS and HERB TILLARY, both
pushed the Board of Directors to settle DIANA TAYLOR’s initial and additional demand now
totaling $360,000.
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107. At the September 23, 2014 special meeting of the ROUNDTABLE’s Board of
Directors a special Personnel Committee, to be chaired by KERRIE WILSON, was set-up to
investigate, evaluate and make recommendations to the Board of Directors to resolve this matter.
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108. On September 25, 2014, PLAINTIFF received a letter from JEREMY SCHNEIDER
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with the law firm of Wilson Elser Moskowitz Edelman & Dicker LLP requesting PLAINTIFF’s
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attorney contact him to discuss PLAINTIFF’s letter to the ROUNDTABLE’s Executive
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Committee that stated claims against Volunteers of American - Chesapeake and RUSS SNYDER
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for breach of confidentiality and breach of contract.
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109. The PLAINTIFF has not received any communication to his letter from the
ROUNDTABLE.
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110. On October 2, 2014 an email discussion occurred that examined a way to appoint
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Board members terms that ended along with PLAINTIFF’s, scheduled for September 30, 2014,
25
back on to the Board in an effort for these board members to still be engaged in the discussions
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !23
1
of resolving DIANA TAYLOR’s claims and PLAINTIFF’s claims with Breach of
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Confidentiality. PLAINTIFF was the only board member of that term ending group that was not
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invited back on to the Board for this short period of time to continue his input into these
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discussions.
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111. A copy of this email is annexed to this Complaint and is hereby adopted by
reference.
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112. On October 27, 2014, PLAINTIFF made a public statement regarding the
circumstances of this incident, how it has created personal and financial damages and the
negative image now of his character and reputation in the Nonprofit Roundtable industry, that
includes 300+ nonprofit leaders, local government officials and business executives who are
members of the Greater Washington Board of Trade, and the general Greater Washington
Metropolitan public. PLAINTIFF also made a public statement to inform those stakeholders of
the facts surrounding the termination of his employment contract with Volunteers of America Chesapeake.
113. On
October 30, 2014, after PLAINTIFF went public, TAMARA SMITH and
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DEBBIE JARVIS resigned their positions on the board of directors of the NONPROFIT
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ROUNDTABLE.
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114. On or about October 30, 2014, PLAINTIFF’s attorney received a threatening letter
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from VOAC’s legal counsel demanding PLAINTIFF cease and desist from telling the public the
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truthful facts of this entire incident.
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115. On November 6, 2014, the ROUNDTABLE Board of Directors held a regular
scheduled meeting.
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CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !24
1
116. The PLAINTIFF after 3 months has received no resolution of his grievances in the
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form of an appropriate apology from all who have caused him direct and indirect personal,
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professional and financial damages.
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117. The Defendant DIANA TAYLOR is looking at huge financial pay out at the
expense of the ROUNDTABLE contributors. This despite
ROUNDTABLE’s own internal
investigation decided there was no merit to DIANA’s harassment claims. These baseless
claims in which she knowingly and intentionally falsely accused PLAINTIFF could lead to
unjust earnings of $360,000. She would receive this pay out operating in collusion with RUSS
SNYDER, DEBBIE JARVIS, FRED WALLS, and TAMARA SMITH who abused their positions
of authority within their respective organizations and breached their Fiduciary duty to the
ROUNDTABLE.
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118. Defendant DIANA TAYLOR also representing the NONPROFIT ROUNDTABLE
OF GREATER WASHINGTON knowingly and maliciously defamed PLAINTIFF in an effort
to support her false claims for hostile work environment, with the intent of having PLAINTIFF ,
who had become aware of her dire financial circumstances, removed from the Board of Directors
of the ROUNDTABLE and/or have his employment contract terminated with Volunteers of
America - Chesapeake with the hopes that removing PLAINTIFF from the discussions of the
Board of Directors would expedite RUSS SNYDER’s push on board members to settle his close
personal friend, and Leadership Greater Washington Classmate DIANA LEON TAYLOR’S,
unfounded claims and demand of $360,000.
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119. Defendant RUSS SNYDER and also representing VOLUNTEERS OF AMERICA
23
- CHESAPEAKE and VOLUNTEERS OF AMERICA knowingly terminated PLAINTIFF’s
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contract under threats of blackmail, from DIANA LEON TAYLOR through her attorney, and
25
therefore interfered with PLAINTIFF’s employment contract by using unjustified privileged
confidential information obtain as the Chairperson of the ROUNDTABLE for an invalid
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !25
1
termination of PLAINTIFF’s contract through his position as President & CEO of Volunteers of
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America - Chesapeake and as a board member of Volunteers of America.
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120. Defendants RUSS SNYDER and DEBBIE JARVIS knowingly neglected their
Fiduciary Duties as Board members of the Nonprofit Roundtable of Greater Washington by
breaching confidentiality that caused tortious interference in PLAINTIFF’s contract with
Volunteers of America - Chesapeake.
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CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !26
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FIRST CAUSE OF ACTION
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AGAINST DIANA LEON TAYLOR
and NONPROFIT ROUNDTABLE OF GREATER WASHINGTON
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(DEFAMATION PER SE)
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121.
Defendant and/or in representation of their corporations made public false
allegations against PLAINTIFF and/or were accessories in the
public false allegations and
claims against PLAINTIFF, who is not a public figure. PLAINTIFF repeats and realleges and
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incorporates by reference the allegations in paragraphs 1-120 above with the same force and
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effect as if herein set forth.
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122. Defendant(s) is liable for loss of earnings, general damages and punitive damages
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SECOND CAUSE OF ACTION
AGAINST RUSS SNYDER and DEBBIE JARVIS
(BREACH OF FIDUCIARY RESPONSIBILITY)
123. Defendant(s) breached their fiduciary responsibilities by breaching confidentiality
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agreement regarding the false allegations and claims against the PLAINTIFF.
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repeats and realleges and incorporates by reference the allegations in paragraphs 1-120 above
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with the same force and effect as if herein set forth.
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PLAINTIFF
124. Defendant(s) are liable for loss of earnings, general damages and punitive damages.
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CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !27
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THIRD CAUSE OF ACTION
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AGAINST DIANA LEON TAYLOR, RUSS SNYDER, and NONPROFIT ROUNDTABLE
OF GREATER WASHINGTON
(TORTIOUS INTERFERENCE WITH A CONTRACT)
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125. PLAINTIFF repeats and realleges and incorporates by reference the allegations in
paragraphs 1-120
above with the same force and effect as if herein set forth. Defendant(s)
tortiously interfered with PLAINTIFF’s contract when he used the March 28, 2014 Facebook
post as the basis for terminating the PLAINTIFF’s contract with VOAC. This action was done in
clear violation of the ROUNDTABLE’s confidentiality agreement regarding the internal
investigation of DIANA TAYLOR’s accusations.
126. Defendant(s) are liable for loss of earnings, general damages and punitive damages.
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FOURTH CAUSE OF ACTION
AGAINST RUSS SNYDER, VOLUNTEERS OF AMERICA - CHESAPEAKE,
and VOLUNTEERS OF AMERICA
(BREACH OF CONTRACT)
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127. PLAINTIFF repeats and realleges and incorporates by reference the allegations in
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paragraphs 1-120 above with the same force and effect as if herein set forth. Defendant(s)
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without appropriate contractual grounds breached contract with PLAINTIFF.
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128. Defendant(s) are liable for loss of earnings, general damages and punitive damages.
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CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !28
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FIFTH CAUSE OF ACTION
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AGAINST DIANA LEON TAYLOR and RUSS SNYDER
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(FRAUD and UNJUST ENRICHMENT)
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129. PLAINTIFF repeats and realleges and incorporates by reference the allegations in
paragraphs 1-120 above with the same force and effect as if herein set forth. Defendant(s)
fraudulently conspired against PLAINTIFF to unjustly enrich DIANA LEON TAYLOR
130. Defendant(s) are liable for punitive damages.
WHEREFORE, Plaintiff CHAD WILLIAMS demand judgment as follows:
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(a)
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Defendants Diana Leon Taylor also representing the Nonprofit Roundtable of
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Greater Washington for the following relief: (1) a public statement that Diana’s
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allegations and claims of sexual harassment and any statements in public and
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private supporting Diana’s allegations and claims are and have been false and
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were and have not been with merit; (2) alternatively to specific performance, a
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money judgment in the amount of $375,000 (Three-hundred and seventy-five
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thousand dollars) for loss of earnings, general damages, pain and suffering, and
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punitive damages;
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(b)
On the first cause of action (Defamation), judgment against
on the second cause of action (breach of fiduciary responsibility),
judgment against Defendants Russ Snyder and Debbie Jarvis for the following relief:
(1) a public statement acknowledging their breach of fiduciary responsibility; (2)
an injunction that prevents each defendant(s) from serving on a corporate board
doing business in the District of Columbia for 10 years; (3) a money judgment in
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !29
1
the amount of $375,000 (Three-hundred and seventy-five thousand dollars) for loss
2
of earnings, general damages, pain and suffering, and punitive damages; (4) a
3
money judgment in the amount of $540,000 (Five-hundred and forty thousand
4
dollars) for punitive damages to be paid as a donation to the Nonprofit Roundtable
5
of Greater Washington.
6
(c)
7
on the third cause of action (tortious interference of contract), judgment
against Defendants Diana Leon Taylor, Russ Snyder, and Debbie Jarvis for the
8
following relief: (1) specific performance of contract; (2) alternative to specific
9
performance, a money judgment in the amount of $375,000 (Three-hundred and
10
Seventy-five thousand dollars) for loss of earnings, general damages, pain and
11
suffering, and punitive damages;
12
13
(d)
Defendants Russ Snyder, Volunteers of America - Chesapeake, and Volunteers of
14
America, for the following relief: (1) specific performance of contract remaining
15
to be paid on contract by way of money judgment in the amount $25,000
16
(Twenty-five thousand dollars); (2) in addition to specific performance, a money to
17
judgment in the amount of $125,000 (One-hundred and twenty-five dollars) for
18
loss of earnings, general damages, pain and suffering, and punitive damages.
19
20
on the fourth cause of action (breach of contract), judgment against
(e)
on the fifth cause of action (fraud), judgment against Defendants Diana
21
Leon Taylor and Russ Snyder for the following relief (1) a money judgment in
22
the amount of $540,000 (Five-hundred and forty thousand dollars) for punitive
23
damages to be paid as a donation to the Nonprofit Roundtable of Greater
24
Washington.
25
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !30
1
(f)
other relief, together with the above relief, that this Court issue a
2
judgment against all Defendants for costs, fees, attorneys’ fees, and interest and
3
such other legal or equitable relief that is appropriate.
4
5
6
7
8
Dated:
November 18, 2014
9
10
11
12
13
14
________________________
John L-R Poindexter
150 G Street SW
Washington, DC
202.656.0517
[email protected]
DC BAR#979808
15
16
17
18
19
20
21
22
23
24
25
CHAD WILLIAMS VS. NONPROFIT ROUNDTABLE OF GREATER WASHINGTON, VOLUNTEERS OF
AMERICA - CHESAPEAKE, VOLUNTEERS OF AMERICA, RUSS SNYDER, DIANA LEON TAYLOR,
DEBBIE JARVIS - !31
Thanks all. I am thinking through my response to this information and will keep you informed.
Russell K. Snyder |President/CEO
Volunteers of America Chesapeake | [email protected]
7901 Annapolis Road | Lanham, MD 20706 | www.VOAchesapeake.org
Main: 301.459.2020| Direct: 240.764.2631|Fax: 301.459.2627
Guided by our Core Values: Caring, Respect, Faith, Quality and Trust, Volunteers of America
Chesapeake's mission is to inspire self-reliance, dignity and hope through health and human
services.
-----Original Message——
From: Kerrie Wilson [mailto:[email protected]]
Sent: Friday, May 02, 2014 12:24 PM
To: Chad Williams; Amanda Andere; Russell Snyder
Subject: Breach of Confidentiality
Hey Chad and Amanda - I told Russ what was learned about the breach of confidentiality of
executive session. Russ also had talked with Diana last night and talked with her about board
expectations and the performance review cycle.
We will follow up with the board. Best case scenario it was a hey you need to really step up
board is concerned as we all have coaches and shared with her. If it was more than that well
address.
I personally want to express my appreciation to both Russ and Chad for your direct response and
willingness to take on hard issues. I believe the course that was laid out to determine the work
and role of our sector through convos with leaders is a start and the rest will sort out.
Just wanted to thank you for alerting to the concern.
Sent from my iPhone
From: Bolden, A. Scott [mailto:[email protected]] Sent: Monday, July 07, 2014 12:48 PM
To: Russell Snyder
Cc: '[email protected]'
Subject: Employment of Diana Leon-Taylor with the Nonprofit Roundtable of Greater
Washington.
Dear Russ,
Please be advised that this law firm has been retained by Diana Leon-Taylor in connection with
resolving her employment with the Nonprofit Roundtable of Greater Washington (hereinafter
“the Roundtable”), as President/CEO of the organization. Please direct all further
communications regarding this matter to the undersigned. If you have outside employment
counsel, please forward this email to them promptly, and request that they contact me as soon as
possible.
In this regard, and pursuant to the At-Will Provisions of her Offer letter, dated June 7th, 2013,
please accept her 120 day notice of termination of her employment terms—without cause. You
will acknowledge that pursuant to the employment terms of her offer letter, the Roundtable is
required to pay Ms. Taylor four (4) months of severance pay, expense reimbursement, benefits,
paid vacation and holidays. And while my client acknowledges these terms as described in her
offer letter, Ms. Taylor will further request the Roundtable to provide her with an additional eight
(8) months of severance pay, a confidentiality agreement regarding her settlement with the
organization, an agreed upon reference letter from the Roundtable to assist her in her search for
future employment and, given the publicity surrounding her appointment a year ago, an agreed
upon joint press release or separate press releases between the parties, announcing her
resignation from the organization.
Under the circumstances, the above-referenced terms for resolution of her employment status
with the Roundtable is quite reasonable, and I urge the Roundtable to accept them, rather than
face a long, expensive, public lawsuit that the Roundtable does not want and cannot financially
afford--my client would prefer to avoid, as well. Notwithstanding the forgoing, please know that
Ms. Taylor is resolute in her determination to be properly compensated for working in a hostile
work environment she has had to endure over the last year, created by the Roundtable Board, and
possibly based in part, on her protected class status, including, but not limited to:
the failure of the Executive Committee to meet with Ms. Taylor, “…within 60 days of
employment…to set performance goals against which measurement will occur…” in violation of
her employment terms and the organization’s Bylaws;
the failure of the Board to do an annual performance evaluation of Ms. Taylor within a year of
her hire, pursuant to the terms of her employment;
insubordination of Ms. Taylor’s Deputy Director and other staff--encouraged and supported by
members of the Executive Committee and the Board--by their direct contact with the Deputy
Director and other members of Ms. Taylor’s staff, without her knowledge or prior approval;
defamation of Ms. Taylor by certain members of the Board in their communications with
Roundtable members, vendors and partners, blaming Ms. Taylor for the Roundtable’s budget
deficit;
verified breaches of certain terms of her employment and requirements under the organization
Bylaws;
threats of bodily and professional harm by at least one Board member in March of 2014 in
connection to her joint efforts with other Board members to remove you as Chair;
negligence in financial oversight by the Chair of the Finance Committee in 2013-14, when the
Roundtable board approved an unbalanced budget;
being hired, but not advised, of the Roundtable’s efforts and negotiations to combine, and
otherwise merge with the Center for Nonprofit Advancement, and subsequently being excluded
from merger meetings and discussions regarding the possible merger; and
enduring conflicts of interest by sitting Board members who either applied for the President/CEO
position and/or demanded Ms. Taylor hire them for another position at the Roundtable.
More importantly, there is ample evidence that you, as Chair of the Board, were repeatedly and
continually advised of Ms. Taylor’s complaints and concerns regarding the above-referenced
work conditions, but reportedly, did nothing to address these issues. To be sure, you and other
Board members were advised that:
certain board members who had applied for the President/CEO position were defaming
Ms. Taylor, as well as, demanding Ms. Taylor hire them for other positions at the Roundtable
after Ms. Taylor was hired as CEO—a clear conflict of interest. Your response—“irrelevant”;
the Chair of the Finance Committee was continuously unavailable. Your response—“he
answers my calls…”
certain board members were defaming Ms. Taylor and blaming her for the budget deficit,
when Ms. Taylor had no input on the 2013-14 budget and the Board had approved the deficient
budget, prior to and shortly after, Ms. Taylor was hired. Your response—“those board
members support the President/CEO;
You were again advised that a certain board member was defaming Ms. Taylor and
accusing her of misappropriating Roundtable funds in June of 2014. Your response—None;
that the Vice Chair of the Board was demanding a job from Ms. Taylor and essentially
wrote her own job description in March, 2014. Your response—None;
that one board member had threatened Ms. Taylor professionally and personally in April,
2014 in connection to her joint efforts with other Board members, to remove you as Chair . Your response—None; and
Roundtable staffers were complaining that Deputy Director was undermining Ms.
Taylor’s leadership; that the executive committee was requesting information directly from the
deputy director; that the executive committee was meeting privately with the deputy director,
without the knowledge of Ms. Taylor, thereby creating a hostile work environment for
Roundtable staff. Your response—None.
Indeed, even the Roundtable Employment Handbook at page 7 under “Complaint Policy”,
requires and encourages employees who have complaints about the President/CEO to complain
to the Board Chair. Here, Ms. Taylor, as a direct report to the Board, properly complained to the
Board Chair regarding all of these matters. Yet, no internal investigation was done by the Board,
as required under handbook; there does not seem to be any evidence that any interviews of staff
and/or Board members were done; and there was no follow up with Ms. Taylor to confirm any
investigation was done or that these matters were addressed in any meaningful way. Unfortunately, Ms. Taylor was left on her own to defend herself, protect her staffers, while
serving a Board that had no interest in serving her or following, even the most basic human
resource policies or procedures, for addressing issues. As a result, Ms. Taylor has suffered
significant emotional, physical and financial distress.
Please know that I do not write to you without having reviewed several Roundtable documents,
as well as a number of interviews with Roundtable staffers. Hence, there are documents and
witnesses that have confirmed these facts and circumstances, and there is more than enough here
to file a state or federal lawsuit against the Roundtable to protect Ms. Taylor’s interests and
employment rights. Therefore, to avoid the embarrassment of a public lawsuit containing these
significant factual allegations and to protect the interests, rights and reputation of both parties, I
highly recommend that both parties discuss resolution of this matter before a complaint is filed
against the Roundtable.
Please let me know when we can meet to discuss further. I am on travel today and tomorrow, but
Wednesday-Friday, I am pretty flexible to meet and discuss. Thanks.
. Scott Bolden Managing Partner Washington, D.C. Office
[email protected] Reed Smith LLP 1301 K Street, NW Suite 1100-- East Tower Washington, DC 20005 Phone: 202-414-9266 Fax: 202-414-9299
From: "Bolden, A. Scott" <[email protected]>
Date: July 10, 2014 at 1:25:53 PM EDT
To: Russell Snyder <[email protected]>
Cc: "Bolden, A. Scott" <[email protected]>
Subject: Employment of Diana Leon-Taylor with the Nonprofit Roundtable of
Greater Washington.
Russ,
Thanks for your acknowledgement(s). In that regard, it is my understanding that items 1-2 are in the process of, or have been
completed. And while I appreciated your interim efforts in investigating Ms. Taylor’s
allegations, your note below does not address the other terms for resolving Ms. Taylor’s issues—
the extension of her severance by an additional eight (8) months; confidential settlement
agreement; an agreed upon reference letter; and probably more pressing, short term, is any public
statement(s) to be made by the NPRT and/or my client regarding her termination of her
employment. Neither party should be interested in a public “swearing contest” and I think we
should agree on what that statement will be – publicly or privately. My client is prepared to
agree that no comments should be made by either party at this juncture, at least until we can
determine whether there will be a resolution of Ms. Taylor’s allegations or that a lawsuit will be
filed. Please confirm the position of the NPRT regarding statements to the media and third
parties.
Moreover, it is my hope that your internal investigation will be completed in a most
efficient manner, however, I am not convinced that it should substantially delay any settlement
discussions between the parties. Indeed, you, other board members and staff are witnesses and
therefore, already aware of these concerns raised by Ms. Taylor. Please let me know if, and
when, NPRT is willing to discuss these issues. Otherwise, we will proceed with the lawsuit.
Lastly, there is one other distasteful factual allegation that I neglected to disclose in my
original email because I wanted to discuss it in person with you and/or your attorney. Since I am
now unclear when that will be, please investigate the following facts that appear to be more than
sufficient to sustain a claim of sexual harassment under federal and DC law.
Chad Williams, a sitting NPRT board member, invited Ms. Taylor to dinner at the Four
Seasons in Baltimore to which she advised him she had a boyfriend who was taking her out of
town. Because of the location and the suggested late time, Ms. Taylor thought this was a strange
invitation compared to other lunches and dinners that had been arranged by other board members
when she first started at NPRT. She declined the invitation, indicated she was leaving town with
her boyfriend, but agreed to have dinner with him on another date at a DC location. Later, they
did have dinner at a local DC restaurant where Mr. Williams indicated that he wanted NPRT to
host a concert fundraiser headlined by JayZ and Wale – two hip hop artists. To be sure, Mr.
Williams invited her, and later, her boyfriend, to a New Year's Eve dinner and party at the W
Hotel--allegedly to meet the manager for the above-referenced artists. At the New Year’s Eve
dinner, the manager never showed up that night, but Mr. Williams did invite both, Ms. Taylor and
her boyfriend to join him and his date at a “swingers club,” as well as to The Penthouse, a strip
club in DC. His date added that Mr. Williams had a preference for women with body parts
similar to Ms. Taylor. Ms. Taylor and her boyfriend were highly offended, visibly shaken by
these statements and left the restaurant.
Despite this incident, and given the financial circumstances of the organization, Ms.
Taylor still discussed the concert as a fundraising concept with a number of her colleagues, but
advised Mr. Williams that the NPRT should not participate in a concert due to the risk associated
with such a project. Mr. Williams was visibly unhappy with her decision. After this discussion,
Ms. Taylor sought to avoid Mr. Williams because he made her feel uncomfortable. She also
feared losing her job because of her position on the concert idea, Mr. Williams’ offensive
comments at the New Year’s Eve dinner, and he worked for the same company as her Board
Chair (Volunteers of America). Subsequently, Mr. Williams would become her fiercest critic, and
even texted a NPRT partner a message that argued that Ms. Taylor was responsible for losing
millions of dollars of NPRT funds during fiscal year 2013-14. Obviously, we can provide those
text(s) for your review, as well as witnesses to the New Year’s Eve comments by Mr. Williams. There is at least one other NPRT current employee we have spoken with, who will confirm that
Mr. Williams has asked her out, used inappropriate suggestive language in conversations at the
office and made her feel uncomfortable.
Please let me know when we can further discuss and resolve these issues in an efficient
and amicable manner. Thanks.
. Scott Bolden Managing Partner Washington, D.C. Office
[email protected] Reed Smith LLP 1301 K Street, NW Suite 1100-- East Tower Washington, DC 20005 Phone: 202-414-9266 Fax: 202-414-9299
From: Russell Snyder
Sent: Tuesday, July 08, 2014 8:57:19 PM
To: Bolden, A. Scott
Subject: RE: Employment of Diana Leon-Taylor with the Nonprofit Roundtable of
Greater Washington.
Good evening Scott. This e-mail will acknowledge receipt of your correspondence regarding
representation of Diana Leon Taylor in her employment matter with the Nonprofit Roundtable of
Greater Washington, Inc. On behalf of the Nonprofit Roundtable Executive Committee and as
Board Chair, we also acknowledge your client’s reliance upon the terms of her Employment
Letter and her position that she is providing the prescribed 120 days notice to terminate her
employment under the assertion that she is terminating without cause, effective July 7, 2014. In
furtherance of our fiduciary responsibility to the corporation, the Nonprofit Roundtable
Executive Committee, while reserving the Board’s right to make a future determination that Ms.
Leon Taylor’s employment be terminated with cause, is exercising its option pursuant to the
Employment Letter to relieve Ms. Leon Taylor from her duties, effective immediately while
continuing to pay her full salary per the agreement. As a terminated employee we ask that your
client comply with the following—
1. No further access to NPRT files, email, data, building, stakeholders and property and ask that
she not communicate with employees, Board members or other stakeholder as she has had her
duties relieved.
2. Your client should be made aware to make arrangements to return NPRT equipment including
cell phone, laptop, iPad and any or all personal or electronic files that may have been issued to
her
.
We will initiate an internal investigation of the allegations contained in your e-mail sent July 7th,
2014. Once we have completed the internal investigation, our legal counsel will be contacting
you directly regarding the status and characterization of Ms. Leon Taylor’s termination.
Best regards,
"
Russell K. Snyder |President/CEO
Volunteers of America Chesapeake | [email protected]
7901 Annapolis Road | Lanham, MD 20706 | www.VOAchesapeake.org
Main: 301.459.2020| Direct: 240.764.2631|Fax: 301.459.2627
Guided by our Core Values: Caring, Respect, Faith, Quality and Trust, Volunteers of America
Chesapeake's mission is to inspire self-reliance, dignity and hope through health and human
services.
From: Russell Snyder Sent: Tuesday, July 15, 2014 12:49 PM
To: Chad Williams
Cc: '[email protected]'
Subject: Leave of Absence from Nonprofit Roundtable of Greater Washington
Dear Chad –
This is follow-up to our discussion and meeting today regarding the allegations against you
brought forward by A. Scott Bolden, counsel to former NPRT President/CEO Diana Leon Taylor,
in his July 10, 2014 to me as Board Chair of the Nonprofit Roundtable of Greater Washington
(NPRT). The NPRT Executive Committee has reviewed those allegations and based on the
information provided is placing you on an involuntary leave of absence from the NPRT Board of
Directors, Committees and any other NPRT activity until further notice while an internal
investigation is being conducted surrounding the circumstances contained in the allegations. We
appreciate your conforming to the decision of the NPRT Executive Committee in this potential
legal matter while the investigation is being completed.
Please give me a call should you have any questions.
Best regards,
"
Russell K. Snyder |President/CEO
Volunteers of America Chesapeake | [email protected]
7901 Annapolis Road | Lanham, MD 20706 | www.VOAchesapeake.org
Main: 301.459.2020| Direct: 240.764.2631|Fax: 301.459.2627
From: Chad Williams Sent: Sunday, July 21, 2014 05:40 PM
To: Chad Williams
Subject: Leave of Absence from Nonprofit Roundtable of Greater Washington
Russ –
This is to acknowledge receipt of this email communication and my solid willingness to comply
fully with this decision, on this particular matter, of the NPRT’s Executive Committee. I look
forward to an expeditious and thorough investigation of these allegations. I will reserve my right
to seek outside legal counsel, if I determine it is warranted and exercise any civil complaint legal
filing options I deem appropriate during and after a completed investigations, against any and all
parties, if these allegations and the actions of the accuser will/or cause me any reputational
professional or personal damages. In addition, any resolved agreements with the accuser on this
matter or others will only be binding on the Nonprofit Roundtable, as an entity, the organization’s
Board of Directors and will have no binding on me in exercising the protection of my civil
liberties.
Sincerely,
Chad Williams | Executive Consultant, Housing Development & Asset Management
Volunteers of America Chesapeake | [email protected]
7901 Annapolis Road | Lanham, MD 20706 | www.VOAchesapeake.org
Main: 301.459.2020 | Direct: 202.812.7200 | Fax: 301.459.2627
From: Chad Williams Sent: Monday, July 22, 2014
To: Chad Williams
Subject: Leave of Absence from Nonprofit Roundtable of Greater Washington
Russ –
I will not be accepting an involuntary leave of absence from the Nonprofit Roundtable's Board of
Directors, Committees and any other activities while a "so called" internal investigation is
conducted into the expected allegations of our former President & CEO Diana Leon Taylor.
The position I have taken is supported by our organization's By-Laws, Articles of Incorporation,
other normal acceptable precedence of procedures for the notification and resolution of these
type of matters.
1) The Executive Committee nor its Officers, individually, have the authority to place a Board
Member on involuntarily "Leave of Absence".
2) I have not been officially presented with a notice of complaint against me for the expected
allegations of sexual harassment. A notice that states in details the specific alleged actions with
dates and times, witnesses collaborations, and any supporting documents that are all signed
under oath by the Ms. Diana Leon Taylor.
3) Ms. Diana Leon Taylor is no longer the President & CEO of the Nonprofit Roundtable. She
has resigned "Without Cause". Therefore there is no current supervisor-subordinate relationship
that would require our interaction in my role as a Board Member while a "so called" internal
investigation is conducted.
4) I have become aware that Ms. Diana Leon Taylor has placed allegations against other Board
Members. I have no knowledge to the specific facts of those allegations, but I'm currently
unaware that those Board Members have also been asked to take an involuntary "Leave of
Absence". If this is the fact, then the request you and the Executive Committee have asked is
discriminatory and in violation of the protection clause.
5) It is my understanding from briefly reading the email that the date of these expected
allegations against me were brought to your attention a couple of days after receiving and you
acknowledge Ms. Diana Taylor's attorney original email that she was exercising her option to
resign and seeking extra compensation as a result of Board Members, that didn't include me, that
created a hostile work environment Ms. Taylor. I find this highly suspicious, since the only time
Diana is mentioning these expected allegations is after she has resigned and are stating these
allegations with it being tied to a quid pro quo for extra compensation beyond what is warranted
in her contract if she resigns.
6) I have been informed and I can provide witnesses that are willing to state that Diana started to
conspire to remove me and others from the Board of Directors after our March and/or May
Board meeting after our private discussions during an Executive Session regarding her
performance were revealed by Debbie Jarvis which has all been acknowledged. A. The Executive
Committee has taken no action against Ms. Jarvis for breeching this confidentiality. B. Ms.
Taylor's expected allegations are deemed retaliatory actions for me exercising my fiduciary
oversight/supervision authority as a board member.
I look forward to an expeditious and thorough investigation of these allegations. I will reserve
my right with my legal counsel, if I determine it is warranted to exercise any civil complaint
options I deem appropriate during and after a completed investigations, against any and all
parties if these expected false allegations or any unlawful actions of the Board of Directors to
force me to take an involuntary leave of absence causes me any reputational professional or
personal damages. In addition, any resolved agreements with Ms. Taylor on this matter or others
will only be binding on the organization’s Board of Directors and will have no binding on me
exercising any civil litigation I deem appropriate against Ms. Taylor or the Nonprofit
Roundtable's Board of Directors.
Sent from my iPhone
From: Kerrie Wilson [mailto:[email protected]] Sent: Thursday, October 02, 2014 10:39 AM
To: Board of Directors
Cc: Walter Smith ([email protected]); Margaret O'Bryon; Amy Fishman Kurz
([email protected])
Subject: [NPRT Board] Update for the Roundtable Board
All, in Russ’s absence I wanted to give you a quick update. A special board meeting held September 23. Minutes of that meeting will be presented for board approval
at our next meeting.
The board heard updates on the matters that were the subject of the special meeting. To ensure continuity
in our deliberations for resolving employment matters as we have entered a new fiscal year and seated a
new board, the board appointed a personnel committee to continue the work that was being overseen
previously by the Executive Committee. I was asked to chair a personnel committee that includes other
members of the former executive committee, and to bring recommendations for board action to resolve
these issues. We will provide more information, but in the meantime please feel free to contact me by
email or at 703-628-4876 if you have any questions.
In the meantime, please join me in thanking Amy and staff, and board member Lidia Soto-Harmon, for
their great work on the Board-CEO Summit. It was well-attended by members and yielded great
discussion and dialogue which Amy summarized in the email to members you should have received. At our September 4 meeting, the board approved strategies and a work plan for moving forward as an
advocate, convener and action on issues in our region. Our membership campaign is underway and the
board is aware of the revenue targets we have set for each month. Please renew your dues today and
contact Amy or Jon to help the Membership Committee with outreach to our members.
Every day we change lives. Our sector is integral to building healthy, thriving and connected communities
by strengthening and partnering with the public and private sectors. The Roundtable has an important and
unique role to play in ensuring that work continues—particularly as our region recovers from the effects
of the recession. Thank you for your work and service as stewards of this organization. Kerrie B. Wilson
Chief Executive Officer
Reston Interfaith has a new name. Our mission stays the same.
11150 Sunset Hills Road, Suite 210, Reston, VA 20190
[email protected] Ph 571.323.9571/ Cell 703.628.4876
www.cornerstonesva.org
Join Cornerstones on Facebook and Twitter
United Way #8177 / CFC #90617
On Thu, Oct 2, 2014 at 3:22 PM, Lidia Soto-Harmon <[email protected]> wrote:
Here is the relevant size of the board from the Nonprofit Roundtable Bylaws. We currently have
16 slots being filled by board members, our board can go up to 21 members. So we do have
plenty of vacancies that we can fit Walter and Margaret into. Amy is going to redraft the current
board with the vacancies by class (term) so we have a better feel for which slot we can put our
incoming members.
Lidia
"
Lidia Soto-Harmon
Chief Executive Officer
Girl Scout Council of the Nation’s Capital 4301 Connecticut Avenue NW, Suite M-2
Washington, DC 20008
202-274-3319
Building girls of courage, confidence and character, who make the world a better place.