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Georgia ADA Retaliation/Wrongful Termination – Goodwill of North Georgia (Smyrna/Marietta) – Seeking Contingency Counsel
**CONTACT:**
Tyrell Dunn (on behalf of employee **Curtis Primes**)
**EMPLOYER:** Goodwill of North Georgia – Retail location: **3205 South Cobb Dr SE, Smyrna, GA 30080** (Smyrna/Marietta). Large employer (500+), so federal damage caps likely at the highest tier.
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TL;DR (for attorneys)
Documented seizure disorder (medical ID). Two earlier ADA incidents (denied accommodation during seizure episode; demotion after hospitalization) + evidence suppression by a manager. Most recent: **9/21/2025**, equipment failure injury → hours later a **coerced, hearsay-based drug test demand** (with District Manager on phone, Store Manager driving, threats about transportation home and termination), employee takes seizure meds that can cause positives → employee declines **under coercive conditions** → **placed on leave** → **now terminated** on **“job abandonment” + “failure to test.”** Video corroboration exists for prior vomiting/slumping episode; HR previously acknowledged manager **withheld** the employee’s signed statement. We want reinstatement and to stop the retaliation; otherwise ready to file EEOC and pursue damages. We prefer **contingency** (paid at recovery).
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## Parties / Roles
* **Employee:** **Curtis Primes** (retail associate; formerly in management). Documented seizure disorder; wears medical ID necklace/dog tag.
* **Complainant/Advocate:** **Tyrell Dunn** (brother), corresponding with HR on Curtis’s behalf.
* **Managers Involved:**
* **Keosha** – Assistant General Manager (AGM) involved in earlier ADA incident and evidence withholding.
* **Jennifer** – Store Manager (initiated 9/21 office meeting; attempted to drive employee to drug test).
* **DeMarcus** – District Manager (on phone during 9/21 meeting; raised termination threat).
* **HR Contacts (email chain):** **Mr. Ivanov, Mr. Bowers, Mr. Saunders** (HR leadership group handling the matter).
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## Chronology (Condensed)
**(A) Prior medical history known to employer**
* Curtis has a **seizure disorder**, wears a visible **medical ID** with his name/condition. Employer aware.
**(B) Earlier incident – hospitalization & demotion**
* Curtis suffered a serious seizure **outside work**, blacked out, woke in an ambulance; was hospitalized.
* On return, instead of support/accommodation, he was **demoted from management to associate**, was unable to clock in for several days, and his management role was quickly filled. We view this as **retaliation** tied to his medical condition.
**(C) Second incident – seizure crisis at work; accommodation denied**
* While on shift, Curtis experienced **classic aura** (headache/dizziness) and **asked to sit**.
* **AGM Keosha** told him essentially to keep the line moving and **denied** the request.
* Curtis, disoriented, **slumped at the register and vomited while serving customers**.
* He was then **taken to the office (no cameras)** instead of being allowed to leave; on exit, in a disoriented state, he accidentally damaged a door; later **collapsed at a bus stop for over 2 hours**.
* He was placed on **“administrative leave.”**
* **HR review later confirmed** the **video shows** him slumped/vomiting at register and **reinstated** him.
* HR also discovered that **Keosha had withheld his handwritten, signed statement**, locking it in a safe, only producing it when HR specifically requested it.
* Note: “Administrative leave” was applied to him as an **associate**, which we contend was an **inconsistent elevation of discipline**.
**(D) Third incident – 9/21/2025 (Keosha’s first day back from leave)**
* Curtis flagged a **damaged dresser** with a loose leg; asked **Store Manager Jennifer** if he should repair (e.g., screw it). She said to "**Grade A it**" (top price).
* While **lifting the dresser alone** onto his flatbed, the leg **failed**, the piece **shifted**, and he **chipped a fingernail**; he taped it for comfort. Jennifer saw the result, asked if he was okay; he said yes and returned to work.
* **Hours later**, after lunch, **Jennifer called him into the office**; **District Manager DeMarcus** was already on the phone.
* Jennifer alleged "**four people said you smell like marijuana**" and directed an **immediate drug test**.
* Jennifer **said she would personally drive him** (with a training manager). During the drive-out prep, **with DeMarcus on the phone**, she asked how he would **get home if he didn’t pass**. DeMarcus warned that **refusal would be termination**.
* **Curtis takes prescribed seizure medication** that can cause positives on some panels. The combo of **transportation threat, termination threat, and medication risk** made this a **coercive, discriminatory demand**. Curtis said he **was not refusing** but **declined under those coercive conditions** (he **walks to work** on weekends and reasonably feared being stranded).
* He was then **placed on leave again**.
* Shortly after we issued a written 4-day resolution notice (9/22 → 9/26), **HR terminated him** on **“job abandonment” and “failure to take drug test.”**
**(E) HR handling**
* The **supportive HR rep** who previously verified the video and reinstated Curtis was out on **vacation**; upon return, we’re told the case was **taken off his desk**.
* We contacted him; he informally indicated he would try to reach higher management, but official action came from others: **termination** for “abandonment/failure to test.”
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## Evidence on Hand / To Preserve
* **CCTV footage** of vomiting/slumping at register (prior incident) – **HR already confirmed it exists and supports Curtis**.
* **CCTV** 9/21/2025: sales floor area where the **dresser leg failed**, register, office, entrance/exit, and any areas showing the escort/drive preparation.
* **Handwritten signed statement** (the one **Keosha withheld**); HR confirmed it was locked in a safe.
* **Email chain** with HR (demands, timelines, 4-day notice, follow-up).
* **Witnesses** (coworkers) who can confirm the **damaged furniture** warnings, the chipped fingernail, and the timing of the drug allegation.
* **Medical records & prescription** confirming seizure disorder and **medication** that may trigger a **false positive**.
* **Texts and notes** of prior **demotion** after hospitalization; scheduling/clock-in issues; **leave** notices; and termination communications.
* Names/titles of decisionmakers: **Keosha (AGM), Jennifer (Store Manager), DeMarcus (District Manager)**; HR leadership **(Mr. Ivanov, Mr. Bowers, Mr. Saunders)** on the email threads.
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## Legal Issues (as we see them)
1. **ADA – Failure to accommodate** (denial of brief, reasonable request to sit during seizure onset → vomiting, collapse).
2. **ADA – Retaliation** (demotion after hospitalization; administrative leave; coerced drug-test demand; suspension/leave; **termination** after asserting ADA rights).
3. **Evidence suppression / spoliation risk** (manager **withheld the signed statement**; need preservation letter for CCTV, witness notes, call logs).
4. **Unsafe workplace practices** (known **damaged dresser** left on floor; injury when leg failed; pivot to drug allegation instead of incident reporting/comp filing).
5. **Coercive/biased testing demand** (threats about **transportation** and **termination**, no accommodation for seizure medication that may **false-positive**).
6. **Wrongful termination / defamation** (false “job abandonment” and “refusal” pretexts following protected activity).
*Venue:* Georgia (Cobb County worksite). **Large employer (500+ employees)** → damages cap tier at the **highest** level for compensatory/punitive under federal statutes.
*Deadlines:* **EEOC charge window applies (time-sensitive)**; we understand Georgia’s private-sector cases have a **short federal deadline** (commonly 180 days) to file an EEOC charge—**we are within it** and ready to proceed.
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## What We Want
* **Primary:** **Immediate reinstatement** and written assurances of **non-retaliation** and proper ADA accommodations going forward.
* If not resolved promptly: **File EEOC** and pursue **back pay, front pay, compensatory/punitive damages, attorneys’ fees**, and corrective injunctive relief.
* We are willing to consider a **pre-suit resolution** if it restores employment and safety and clears Curtis’s record.
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## Representation Requested (Contingency)
* We’re seeking **Georgia employment counsel** to take this on a **contingency basis** (paid from recovery/settlement).
* Strong paper trail and admissions (HR verified video; HR acknowledged the withheld statement).
* We can send a **clean, indexed PDF packet**: timeline, exhibits, HR emails, names, and preservation targets.
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## Current Status (as of **Friday, September 26, 2025**)
* Employer has **terminated** Curtis for **“job abandonment” + “failure to take drug test.”**
* We dispute both as **false pretexts**; Curtis was **coerced**, on **leave**, and asserting **ADA rights**.
* We delivered a **4-day** written notice seeking resolution; no cure; termination followed.
* We have counsel options; one major Atlanta firm declined **due to capacity only** (not case weakness) and urged contacting NELA referrals. We are posting here to connect quickly with a firm ready to engage.
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**If you are licensed in Georgia and handle ADA/retaliation/wrongful termination on contingency, please email or very much preferably text.**
Kindly include your **bar number**, link to your **firm site**, and **earliest availability**. We can transmit a full packet immediately.
Thank you.
440 Glover St SE, Marietta, GA 30060, USA
Negotiable Salary
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