Whatever Gained from somewhere....

Perhaps Stay off My Private Website.

As SCAD private arbitration is over, so would be any form of discovery on my electronics in any way or fashion that could be reverted or diverted to knowledge of SCAD and their partners on the matter.

Any further impediment is not masked in private matters of upholding the law and constitution and proceedings closed with zero award to I after all of this in fact and truth while my rights towards lawyer were impeded up while also documenting exactly what has happened in years after and then during doing the correct thing at SCAD.

As the arbitration is closed, no non-disclosure was had and I am free to tell, publish and talk about any aspect of the case I deem socially acceptable or in other areas where any aspect of attack further at this point would be a file of restraining orders and going from there. 

I professionally thanked the JAMZ for the failure to arbitrate, as no witnesses or discovery was had or brought forth despite asking for such which would fail the court order of Superior Court of Chatham county, but for now, I’ll keep my mouth shut and move on.

Quarter systems start when they start and I would like to move on with my own life and that story ended the way it did. 

It is understood SCAD has my copyright book “No ‘Starving Artist’s” which was produced post college and employment and can be held liable more forward in perpetuity if any connector made and done so towards profit of others and not I. 

I still stand by I don’t need to read what the law firm wrote last in that case.

It was repeat of dismiss on everything despite evidence. 

That was professionally paid in kindness back. 

We have moved past that now and professionally it was nice to work with you.

You have your cases and I have my life. A law novice did what they could despite all odds.

At the very least that non-disclosure is not even remotely cheap if wanted. 

I can only imagine what SCAD has already impeded on for their own self-gain in which not one bit of direct or compensation was accounted for.

In all my right to release anything and everything of globally paid for disrespect towards I, in the most amazing away possible of what is not copyrightable of lesson is The American Dream and most certainly anything of their partnership is a bootleg of CLASSIC.

Fact check me as whatever affordance of their life time is able to me matched and purchased of mine in protect and without the exploit associated in complete distance moving forward.

I was awarded nothing from 3 years of valid claims of harm from SCAD and global MEDIA companies.

That will be forever noted of wasted time and never a further investment in partnership.

­JAMS PRIVATE ARBITRATION

     PHILIP ARTHUR BONNEAU

                                     Petitioner/Plaintiff,

 NO.

5440001247

     THE SAVANNAH COLLEGE OF ART AND DESIGN

)

Respondent/Defendant

CLAIMANT RESPONSE TO RESPONDENT’S MOTION TO DISMISS JUST ABOUT EVERYTHING WITH A FOCUS ON THE DISCRIMINATION SIDE WHILE ADDRESSING “RESPONDENT’S MOTION TO DISMISS CLAIMANT’S

“RESPONSE TO READDRESS ORIGINAL STANCES”

Claimant has been ordered to separate the copyright claims of violation from the original complaints of violations of The Savannah College of Art & Design during employment of discrimination.

Claimant is addressing that order while satisfying any response as efficiently as possible of any outlaying issues brought up in Respondent’s motion and of further state at this time. Copyright aspects in this Response will be minimal unless necessity in connection of Claims and of Relief.

Respondent themselves cover all bases in their motion back and forth between Discrimination Claims and Copyright.

This is Claimant’s official response.

I.              INTRODUCTION

-SCAD is bound to both Student Handbook and Employee Handbook in contract during any aspects of “mutualness”. As employer/employee agreements are bound to regulations within, aspects of that as an entity are binding, but not without consideration of individual entities during operations. Benefits and Paychecks are provided to consider that an agreement until At-Will Termination on either side of the matter. Same is applicable of student/institution in which agreement of payment of services goes in opposite of provide services and a product in which payment is required in continuance done so in any many degree-seeking student wishes to fulfill of financial obligations.

Claimant was a full-time hourly employee between June 2019—Feb. 10, 2022 whom worked at the non-profit entity The Savannah College of Art & Design before being “wrongfully terminated”. Claimant was a Dual Acting active Student of Degree Seeking nature in SCAD’s Master’s Program from Jan. 2020‑ week of Feb. 10, 2022 until their education was “wrongfully suspended” on Feb. 10, 2022.

Claimant’s Final Class was forced to be withdrawn from due to workplace issues combined and reported since April 2021.

Claimant is an alumni of the college with student loans outstanding taken out for 2001-2005 education that entered repayment in May 2024 after Chapter 13 Restructure from 2020-May 2024 in which they are protected from any creditors out balances during that time. Federal Student Loans are Binding of repayment and constitutes contract with creditors to uphold and repay while Claimant was under protection of retaliation from any and all creditors in association with the bankruptcy restructure.

Claimant was a full-time employee twice over at SCAD between Undergrad (2001‑2005) and Masters studies (2020-2022) to complete about 6 years of non-profit work status through the college. Education of the Claimant was a priority and incentive to have and maintain of benefit of during employment and long-term goal of success post Art’s Café and full-time hourly SCAD employment back into the corporate and agency market in which they held experience from 2006—2019.

Between Undergrad of 2001-2005 and then onto masters of 2020-2022, the “free class” benefit of full-time went from non-taxable to taxable income according to IRS which is noted as such in definition and application of such is considered “Taxable Income” of the College and deducted from paycheck in pay-as-you-go structure of education during bankruptcy restructure.

As Claimant completed their studies of Undergrad of Degree in which they can present in any application or job interview, they are an alumni of the college who holds degree in BFA of Graphic Design.

II. Discussion to Respondent’s Argument

Claimant initiated Correspondence with Human Resources on April 13, 2021 in which Human Resources escalated to Federal Compliance procedures involving workplace patterns of mental health affect based on prior diagnosis and experience as well as citing Federal Work Break violations by Supervisor and ignorance of the law on the matter by Human Resources. (Exhibit A – August 2, 2024)

In the documented complaint, SCAD had full awareness of liability during Federal Compliance investigation that involved discovery, zoom testimonies of witnesses and back and forth procedural measures that was concluded on July 1, 2021. (Exhibit B – August 2, 2024)

During that investigation, testimony original and in video was had with Claimant and Co-workers of same status or Supervisory surrounding the claims and mental health aspects raised in concern, as well as establishing SCAD had already violated Federal Work Break Laws in which Claimant was entitled to remedy on the matter and SCAD chose not to inform, educate or provide them with any relief in what was a multiple part good-faith first correspondence with Human Resources on matters of severity outlined.

As in closure email of Exhibit B – August 2, 2024, SCAD in-house legal council is aware of initial complaint and that the investigation took 2 months to come to a conclusion with still no answer of reprieve to reporting/claiming party despite evidence found of liability.

Henceforth in any procedures between SCAD, Claimant and Arbitrator, it is impossible of SCAD to state that they were not aware of severity of effect on prior employment experience of workplace issues prior that resulted in Claimant’s suicide attempt on Feb. 21, 2019 and their subsequent 11-days involuntary medical care while suffering “a mental breakdown” from workplace interference and attacks of outside entities interested in Claimant’s property and continual attacks between at the time of April 13, 2021 HR complaint would make SCAD the 3rd place of business in which that behavior was done so in which Claimant was employed. It is noted SCAD legal is aware, where despite anything of investigation stated, no resolve or fix to the initial complaints and necessity to remedy came from the investigation towards Claimant in knowledge and they were left with the email provided, done so after writing compliance about the months it was taking and continued pattern of confidentiality breaches and Supervisor reactions.

Any reprieve was necessary and essential to the well-being of the Claimant and despite having to ask for information of specific and precise for their own safety and of SCAD’s, that was not provided.

Original letter to Human Resources was in good faith and according to their handbook on employee or student side is not to be retaliated against and taken into consideration of any procedurals or actions from that date on of April 13, 2021.

Claimant has in EEOC provided every email or testimony present of the deterioration of their mental health and the refusal of SCAD to remove claimant or address any issues that did arise and prove to be factual that came from confidential investigations and also the compromise of confidentiality of investigations during the rest of their employment that wrongfully ended on Feb. 10, 2022. This is outlined in Exhibit N – August 2, 2024 of The SCAD Governance Party Sections, Pg. 52 and 53)

SCAD in-house lawyer managed and interacted on all official and timely EEOC and BBB proceedings before relinquishing rights to represent against claimant to Human Resources and the office of Littler for Superior Court of Chatham County and of this Arbitration with JAMS.

There are aspects of this investigation and proceedings that would be unknown of Human Resources, a requirement of SCAD internal ADRPA in which they did not participate in the valid timeline of legal limits in which are met and upheld before filing with Superior Court.

Claimant is well aware of libel and slander by SCAD collectively and through Human Resources on the timeline of events.

As noted of Respondent, many times they have wished to falsely claim of private and legal proceedings that Claimant Abandoned their position at SCAD for one reason or another.

This is slander where on the final date of employment, Claimant was once again a reporting party to Human Resources leading to failure to follow policy towards what can be perceived as escaping personal liability and concealing liability of the college. Subsequently by matters of opinion and biased towards 3rd account action, SCAD’s policy of safe work environment, no retaliation and harm to entity occurred on that date.

This is Marked of Timeline of Events in Exhibits G, H, I and J. Outlining Initial incident report, correspondence with compliance on matter when Human Resources Terminated Reporting Party, the email correspondence where Human Resources and Compliance interacted with prior to the termination email sent by Claimant to do so (not originally provided to Claimant) and then later that evening the closing of compliance investigation the same week and day of valid claims made which contradict procedurals of the original investigation, occurred in a single day and were devoid of due process as Compliance and HR was well aware of SCAD’s long-term liability on the mental health front, ADA claims of removal/reassign and the constant behavior patterns of Madeline Collins and other female coworkers towards Male Claimant.

Based on evidence and timeline, Claimant acted on good faith for over 10-months of issues in which the initial filing of April 13, 2021 could have, and should had been resolved and was not for the safety of claimant and of campus. 10-months mental strain of environment unresolve would be a bit much for anyone, let alone someone with a well-documented moment of past experience leading towards suicide attempt and mental breakdown. Claimant hopes that is considered of Respondent and Judge as this matter has been left open to date in August 2024.

Claimant has questioned Respondent’s notion of timeliness on the matter as legally required areas of Arbitration and Investigation occurred officially with SCAD entity within legal timelines to file according with Federal and State entities. In Exhibit Q, considering those procedures occurred between SCAD in-house legal council and under the Supervision of President Paula Wallace, Human Resources was barred from any proceedings that came procedurally from there as confidential information was obtained and had under law official of the college in questions pertaining to Human Resources and known throughout Compliance investigations. Respondent’s party has already agreed post order to arbitrate in State Court to allow the removal of Human Resource as SCAD’s liability is ascertained and discussed.

Claimant made it very clear to Respondent’s legal council, and to prior compliance officers in investigation, that they do not aid and abet in what has been outlined and ascertained by institution interaction and shared already before arbitration procedures. That statement and stance adheres to SCAD’s governance policy of report while calling into question handlings of Compliance Officers and Human Resources on the matter of SCAD’s known then and continually compounded liability in which to weigh of this arbitration or potential future jury trials.

In post reprieve of doing what is required of position to report and maintain a work environment, Claimant filed for Unemployment Benefits with the State of Georgia. In Exhibit C, SCAD filed in deny of benefits that they had fired Claimant for having a “bad attitude”, which is not the same as subsequent claims of “job abandonment” and willful intention to deny legally allowed benefits to a harmed party of employment events not of their causation. As Respondent placed that in official record of the State of Georgia, an outside party of entity, any further claim that Claimant “job abandoned” should be removed, as they officially submitted to a third party of State that as official response which holds record and account of slander and libel in compound with the already supplied evidence of email chains on day of unemployment of Employee practicing a protected action and themselves.

As State found “bad attitude” to not be just cause and also their own investigation Respondent failed to protect themselves from being liable and showcase that Claimant acted while not failing to perform the duties they where hired for.

As evidence will continue to show, SCAD not only in slander and libel have failed to resolve any of these matters, their continued pattern of date change, falsehoods and detrimental descriptions of real-world, live lawsuit and complaint continues a pattern of their dismiss of employee and human rights on these matters. The State’s Determination of this was 3/22/2022 and holds as legal position of permanent record and official position.

Between Exhibits Exhibits G, H, I and J and C, it could be ascertained SCAD active in motive and pre-meditative measures of attack towards Claimant, despite Claimant protected federally and internally of retaliation and attempt of escape of liabilities compounded during employment and to a stopping point of Feb. 10, 2022, and yet patterned landscape continues post in which EEOC guarantees equal protection of the law and no retaliation of claiming parties regardless of what is presented of them towards “Right to Sue” or “Denial of”.

With that evidence there, Claimant is entitled to full backpay immediately of their salary plus benefits in proof to the arbitrator of events as they unfolded the day of “wrongful termination”.

They could be reinstated at SCAD, but all questions of matter need to be resolved in order to do so. This amount would be $82,393 based on original salary at time of termination of $15.95 an hour for 904 days since date of wrongful termination.  

Respondent has failed to provide in evidence and countenance  of claim in defense by choosing to continually dismiss and discount what has been presented as fact to the EEOC, BBB, Superior Court of Chatham County and in Arbitration proceedings held under the jurisdiction of a Retired Federal Judge from Texas. As they have no basis of defense of countenance  and motion to jury at this point would in support of Claimant while Respondent has burden of proof in which they have not fulfilled at this point towards any and all claims.

“Respondent reiterates Claimant has inundated a state court in Georgia, multiple agencies and now JAMS with dozens of frivolous, nonsensical filings containing baseless claims unsupported by actual fact.”

Response: Claimant is legally allowed to file complaint noting their path of filing to be EEOC, BBB, Superior Court of Chatham County and into the JAMS session, which is SCAD’s own arbitration procedure anyways. Claimant would wish for clarification of which agencies Respondent had inundated that they are not legally allowed to do so while noting in every single one of Claimant’s actual right to file did SCAD actually investigate and provide to any of the entities anything of due diligence or warrant to their nonsensical claims in which doesn’t hold up in wonder of law and due process.

Claimant is well aware of Friday the 13th, 2023 when they failed to adhere to a 30 day deadline of Superior Court while Residing judge never answered Respondent’s questions of 30 days+ weekends as a viable option of argument. Claimant remembers, 30 days is 30 days.

Response to Respondent position on timeliness.

It is noted in SCAD’s own arbitration clauses on both the student and employee side that they have no determination of time-bar of complaint in which arbitration can proceed. As such, of their own private institution, they are banned from any limits of complaint on the matter of timeliness as it would involve outside entity to prevent and uphold as long as they are presented. Claimant has supplied the Student Handbook Arbitration procedures to double down on Respondent’s wish to discuss timelines.

AS there are no time limitation to SCAD’s internal procedures of complaint in any of the verbiage, any mention of such would be in context of Federal obligations and oversight in which they are now attempting to adhere to in support and failed to do so.

Claimant has met all obligations of dates and timelines set forth and not provided by the Respondent in success factor. Respondent has made clear to the court the exorbitant amount of time spent on this matter in which has 3rd party oversight all over it of which Respondent has cited 588 days in their response while dates of April 2021 and Feb. 10, 2022 are taken into consideration.

It is in that aspect, SCAD is bound to the timeliness of schedule of outside entity as none of their procedures preclude the notion of perpetualness and of time and place. In that matter of date and time, SCAD has failed their own procedural rights with the state of Georgia on the matter and have wished to prolong what they illegally cannot not throughout the entire arbitration process in which they wished to dismiss against what is already legally binding.

These are the lifetime charges Claimant has made to the EEOC to date on any matter.

It is to be understood, the first charge from 2019 pertains to prior workplace violations and is a federal protection of claim and written record of what transpired leading towards claimant’s suicide attempt.

Charge two was filed on 2-28-2022 and the investigation was held by the same federal officer who oversaw case #1 in 2019 to support and back up claims in which Claimant filed in awareness of non-perjury doing so of Claimant’s rights. That EEOC charge was filed 18 days after wrongful termination and adheres to the 45-day requirement of EEOC complaint.

EEOC filings by Claimant, Accessed of website July 31, 2024

It will be noted in evidence, where representatives of SCAD absolutely attempted to skew evidence within Federal Investigations by blocking out aspects of checkmarks in Exhibit C in which an unaltered version would be required of resubmit or could be provided by Claimant.

As noted, EEOC neither states for or against any lawsuit and merit and as such, Exhibit C is inadmissible, not only for it’s own skew of Respondent, but it takes summery consideration of facts in and out of Scope in which Investigator oversaw prior and would have their own motive/incentive to say one thing or the other outside of impartialness. As Claimant’s own reportings of the 9-11-2019 have played out as true and valid in the current age with fact, it is of note of incentive and impartialness that would be considered of jury on the matter before proceeding with a “right to sue” anyways.

As Exhibit C of Respondant wishes to skew narrow context of EEOC investigations, Claimant has supplied Exhibit E of more general sense of initial complaint before and during phone interviews with EEOC officers. The process of EEOC is a redundancy process of which should had occurred with Human Resources instead of SCAD legal Council to avoid repeat of evidentiary findings and facts.

There are aspects of Abrams v. Lightolier, 702 F. Supp. 509 (D.N.J. 1989) present of which determination is called into question as untrustworthy or questionable in which witness testimony could be said one way or the other on the matter of pre-existing factors of state of Georgia that were again properly reported federally before any issue with Respondent and similarities continued.

Investigator’s opinion of professional status could be inadmissible as they had privilege to all aspects of investigation and are of sole entity. As Claimant has provided Respondent of the full investigation of EEOC proceedings, they have their own legal council and professionals to call upon as Claimant has possible jury trial to do the same of approach and weight. Investigator Jessica Bessick could be called upon as expert testimony on the matter and would do so of the original complaint of workplace in which resulted in Claimant’s Suicide attempt in 2019. The expert testimony of awareness of pre-cursor of mental health factors are not unwelcomed moving forward and much invited of professional stance in compounded oversight.

Claimant wishes to strike the opinion of Jessica Bessick in consideration and call to attention Respondent’s skew of evidence.

As Respondent seems to allege that the Federal Government acted illegally in their own investigations of discrimination and complaints against a prior employer, it is with caution that they proceed to presume that timelines of government are not important for consideration.

What Respondent has done with their Exhibit C, submitted to the arbitration on July 26, is black barred out any of the possible check marks of a submittance in which did or didn’t apply to the case and then ran with it in skew of the perception of judge and Claimant. Where none of the check marks prior apply and the right to sue was granted. That is a continued pattern of Respondent to manipulate and waste not only the Claimant’s time, but also of any court.

It is also noted that the Federal Investigator, Jessica Bessick, was also the investigator in the 2019 case of Claimant leading to their suicide attempt. It is noted they did not sign the document nor is it dated, but approved by someone else in oversight. In this case Omayra Padilla on September 29,2022.

She could in subpoena of federal testimony speak of prior work experience and landscape in report of the 2019 EEOC investigation and how that did or did not factor into The Savannah College of Art & Design. It was called out in investigation of what travelled into another place of business from prior experience and landscape.

Her testimony of official is called into evidence in awareness that the 45th administration already acted on claimants work “Curated Jellyfish” and have their own mugshot issue to consider in contention of brand of institution or publicly traded company into the current of 46th without biased of any one political party over the other.

It would be understood of Federal Judge, that when Respondent Submitted Exhibit B, as being the end all and be all of what is only the beginnings of EEOC investigations, that they are once again skewing the perception of the matter of court and arbitration.

Considering the Human Resources division of SCAD were not a part of EEOC investigation and proceedings and the legal facilitators to Littler’s retainment, there is a recap of events and timeline to brush them up on.

EEOC investigations began on 2-28-2022.

During that investigation, the lead representative to SCAD was their in-house legal council Chaimann Wang. President Paula Wallace had full access to anything submitted into the EEOC complaint and that has been unspoken oversight of approval of change of arbitration procedures.

In the EEOC investigation, it begins with initial claim, and then phone interview, witness testimony and evidence gathering which Respondent has wished to throw out both the president of the college’s time invested as well as their own in-house legal council which would be far more protective of brand than any outside help or resource available.

As the matter of any EEOC, of Claimant’s opinion, would required Human Resources and not SCAD legal council to oversee, that did not occur, which becomes a matter of awareness of severity of the claim, which of Claimant’s evidence, the SCAD in-house lawyer has been familiar with Mr. Bonneau since his initial April 2021 complaint that got moved to Federal Compliance and investigated properly over the course of around 2 months.

As with any EEOC investigation and submit, the original claim and beginning of investigation goes to the last point of damage and incident, but does not preclude any of prior history as the interaction combines and builds towards any point of filing of ascertain merit of case or not.

Lawfully it is determined that whatever no retaliation policies set in place by private entities for their own legal protection and awareness, Claimant was federally protected by any entity of SCAD on Feb. 28, 2022 and would be of any combination of what arose in 2019 in EEOC claim in which was discussed during investigation procedures and alleged of partnered with Respondent in testimony of which there is no perjury on Claimant’s side. Claimant cited Respondent perjury instantly in Superior Court of Chatham County in which entity and individual can be found liable for.

As that procedure was set in place, the burden of proof would be on SCAD to prove they followed procedure and investigated properly any future claims in which where supplied to Federal Compliance. SCAD has not at this time done so and probably wouldn’t anyways in which any jury would demand procedurals of any claim to either prove liability or escape it.

SCAD has chosen to constantly dismiss and from there discussion is continued.

Claimant is aware of their initial demand, does not know the extent of their rights, is definitely aware of Federal fines of ADA violations and how those compound and has successfully presented the best they could to a landscape of legal help in which Respondent has attacked.

Claimant goes baseline on the discrimination damages, there is no end on the copyright side without proof of safe-guard in which Claimant has provided an option of beginning and that too was dismissed.

During that timeframe before judgement, BBB complaints were filed in which Claimant has requested a full refund of their college investment from an entity deemed capable of doing whatever with the global investment of their entity while noting the double dip of exploit of their SCADpro program.

Claimant wrote during EEOC investigations and of awareness of landscape, “No ‘Starving Artist’s” in which they were attacked during and still saw the book to completion and federal protection of copyright twice over.

Claimant is allowed to file with the Better Business Bureau, just as much as any one else is on any matter of which others are compensated to investigate and rule upon.

Respondent has made sure it is noted that Claimant filed in Superior Court of Chatham County on December 27, 2022. That is Claimant’s legal right to do so and should be a non-issue of discussion of time frame moving forward outside of damages.

Claimant is reiterating that was done in 2022 and currently we are half way through 2024 of the year.

In any court proceedings that have occurred, Respondent violated the 30-day limitation by filing a response on October 16, 2023 of presentation to the court which goes against GA Code § 9-11-12 (2020).

They had until Friday the 13th of of October to file properly in respect of other people’s time to adhere to the legally required 30-day deadline of response of the court and failed to hit that benchmark. Claimant submitted to the court the proper code on the matter once their failured to properly respect timelines of the court in which can be tracked and held accountable towards.

This is July 31, 2024 at the time of writing, where 292 days of violation since have occurred in any conversation moving forward on timeliness of the court.

Claimant understands Respondent’s initial confusion of business days raised in Superior Court on actual days or whatever of calendar days.

As Respondent wished to draw focus of time spent and waste of resources, that date applies in evidence of federal oversight and inundated of granted motions in which unlawfully all fees can be returned on the matter, but I don’t work for Respondent and that is not Claimant’s concern of what they do with their legal council in future interaction.

As it stands, Respondent council can be held civilly of their own accord of any cost that have occurred since October 13, 2023 by Respondent hiring party, which leaves no incentive of Respondent legal team to perpetuate or push this further outside of matter of fact, ethics, law and morality. Based on appliable deadlines and already begun investigation, even if Responding party wished to drop client, enough has been presented to the court to submit summary and judgement.

That should account for moving forward, their client is on a need to know basis as either side is Pro-Bono one way or another here in which at least Claimant attempts to uphold SCAD the best they can on the matter while protecting themselves as well in the face of illegality and ethics.

Respondent’s notion of directness of dates stands clear of Respondent making clear to the court the amount of dates of which can be legally considered of liability. As Claimant has met all Federal Dates and Respondent’s corroborates them, there is not one bit of time limitation set in Respondent’s own procedures to warrant dismiss based on timeliness and should not be entertained moving forward with prejudice of time spent.

Upon the Court’s order to arbitration, Claimant immediate reached out to Respondent to initiate arbitration procedures in which they are legally and of ADRPA bound to initiate.

Respondent not only did not take priority of this matter, but attempted to initiate proceedings with a State Judge they have arbitrated with prior that violates their own ADRPA mandate of Federal Judge required on the matter.

That judge is a member of the JAMS system and could be privately discussed with on the matters surrounding the months of preparation SCAD did or did not have of interaction with a State Judge that was not done so with the full acknowledgement of Claimant, which also violates ADRPA procedures in which they are bound to.

The extensive length to get to this point of actual arbitration of a Texas Federal Judge is within itself lengthy. It is understood that when any conversation of dates and timeliness proceed in any capacity moving forward, Claimant is making sure Respondent is responsible for any date of length attached to this matter. And if claimant doesn’t have that right of opinion, enough fact is presented to the Judge on the matter who actually has jurisdiction on that matter of rule.

Claimant’s rights have been violated State-side on this matter and that is a matter of consideration of making sure ADRPA is followed with federal judge and outside the State of Georgia on the matter.

Respondent constantly wishes to note “Time-barred” as complaints were or were not in original EEOC investigation and Hearings. Respondent has made no testament that they have read the entire investigation and there is no time-bar present in SCAD’s arbitration and ADRPA procedures. SCAD failed to offer arbitration as a remedy at any point prior to lawsuit, which is a constitutional right of citizen in which SCAD has waived any enforcement or desire for ADRPA procedures during the legality of this matter. Claimant has acted in good faith with EEOC, BBB, and Superior Court of Chatham County and this procedure of arbitration, while SCAD has proclaimed over and over their dismiss and non-desire to even proceed in arbitration, investigation, discovery, witness or mutualness unless begrudgingly.

On page 4 of Respondent’s Motion to Dismiss Claimant’s “Response to Re-addressOriginal Stances” they are quoted as “Claimant failed to timely file an EEOC Charge after the alleged denial of his request.”

Claimant is noting this as libel of Respondent of the matter and to strike on this in particular.

Claimant did file timely to EEOC proceedings and there was not a denial on the matter, but as often with EEOC cases, they allow the courts to consider the evidence along with choice of jury or judge. That is a direct falsehood in which Respondent has once again made a false statement to the court system of any of the areas this has been approached.

Human Resources was not a part of the EEOC proceedings in leadership as that was SCAD legal Council, Chaimann Wang. If the claims were to be met as untimely or denied, then it is reiterated that Respondent is attempting to state EEOC investigation and procedures either didn’t happen, or happened illegally, as any “Right to Sue” would not of been issued if Claimant failed any of the prior requirements in which Judge has already said were necessary and of timeline. If Respondent wishes to imply USA Federal branches broke protocol and procedure for one thing or another to occur of an entire investigation of EEOC being illegal, then by all means. Claimant has their own thoughts on the matter of oversight.

This retort must be met with prejudice. Respondent had continued this path despite written and verbal rulings of the judge on the matter.

Claimant is once again trying to perpetuate that an EEOC investigation did or didn’t occur while using the findings of it in evidence as example. EEOC investigation does not replace proper discovery procedures of further complaint of valid claims in which imaginary EEOC investigations would had prevented a right to sue if never occurred.

[1]Due to the historic rise of workplace discrimination cases, “Congress has not addressed whether EEOC reasonable cause determinations are admissible in subsequent employment discrimination litigation. The admissibility issue is entirely case law driven, and the results vary widely from jurisdiction to jurisdiction. The courts are split on (1) when and if reasonable cause or no cause findings are admissible, and precisely how a court should analyze the question; and (2) what role a reasonable cause finding should play in an employer’s motion for summary judgement when a court does admit the finding.”

It is here that it could be discussed, Federal oversight has occurred before any court proceeding trial or private, and would be a stop gap of evidence on some aspects but invites the court in legal proceedings of due process to once again review the evidence in a matter of jury or judge along with opposing councils.

In Johnson v. Yellow Freight Sys. Inc, 734 F. 2d 1304, 1309, (8th Circuit), “Courts regard reasonable cause findings as so probative of discrimination that courts are not allowed to exclude them from evidence, nor should an employer obtain summary judgement when one exists.”

To further quote the article, “The issue of admissibility was not as important as it became with the enactment of the Civil Rights Act of 1991, which made jury trials available in Title VII and ADA cases.”

According to S.1745 — 102nd Congress

Civil Rights Act of 1991 - Title I: Federal Civil Rights Remedies - Amends Federal law to declare that: (1) for purposes of provisions relating to equal rights under the law, the right to make and enforce contracts includes the making, performance, modification, and termination of contracts, and the enjoyment of all benefits, privileges, terms, and conditions of the contractual relationship; and (2) the rights protected by the amended provisions are protected against impairment by nongovernmental discrimination and impairment under color of State law.

As the law goes further in statement, “Allows any party to demand a jury trial if the complaining party seeks compensatory or punitive damages. Prohibits the court from informing the jury of the dollar amount limitations.”

Any aspect of SCAD’s ADRPA and arbitration procedure is to be considered null and void in the face of The Civil Rights Act which has been on the books since 1991. As already discussed Respondent cannot reject or waive the rights of jury trial, nor prohibit it in reckless indifference in matters of constitutional groundings. Those laws and statutes are 33 years old.

“Provides for the burdens of proof which must be met by the various parties when an allegation of an unlawful employment practice is based on an assertion that a particular employment practice or particular employment practices result in disparate impact.”

“Declares that an unlawful employment practice is established when it is shown that a discriminatory basis was a motivating factor, even though other factors also motivated the practice. Allows, when such mixed motives have been proven and the respondent shows it would have taken the same action in the absence of the impermissible motivating factor, declaratory relief, limited types of injunctive relief, and attorney's fees and costs demonstrated to be directly attributable only to the pursuit of a claim under the enforcement provisions of title VII. Prohibits, in such cases, awarding damages or issuing certain types of orders.”

Constitutional rights are not contingent of Private Entity Procedurals, especially those validly discussed to be non-enforceable and bear the burden of time in complaint on the matter.

As Respondent wished to state, “Claimant did not start Arbitration procedures since September 21, 2023”, it is understood good-faith was already outlined and acted upon swiftly. It is not Claimant’s responsibility to initiate arbitration procedures and Respondent has dragged this out enough on the matter. That is again a falsification of role and responsibility in which is peppered throughout their motion.

In response to Memoriam of LAW response

In discussion of Respondent’s claims Claimant has provided claims of relief and did so in the very first zoom meeting of judge and Respondent. As that involves a combined aspect of separation of original complaint leading to “Wrongful Termination” it too has separated the valid copyright concerns separately in discussion. What has failed to occur is discovery, witness testimony and the fundamental portions of SCAD’s own Arbitration procedures that would be similar to any jury trial. Procedurally, SCAD is wishing to wrap up procedures before they have begun, or could be completely ascertained without evidence or cooperation. As those requests have been done so throughout the 3 years of interaction of initial complaint, the compounded damage of pro-long should be in consideration.

As EEOC and court proceedings often have 30, 45, 60, or 90 day limits to respond or act, that is done so of fairness of either claimant or Respondent where financial affordance or limitations are not to factor in the matter of timeliness and deadlines.

Claimant reiterates Respondent has already failed that threshold of respect and duty of position on October 13, 2023 and can and should be held liable for every day after on the matter of strung out and perpetuated to the point of lunacy.

B. Response to Claimant’s Amended Complaint Must be Dismissed

as it is impermissible Shotgun Pleading.

Claimant counters the notion of shot-gun pleading in blanket statements of across the board dismiss of claims and actionable measures since April 13, 2021. Respondent has not provided anything to counter any process of claims that could be fact checked of procedural while proceedings of events have gone 1206 days since April 2021, and 904 since wrongful termination.

Considering Respondent has already violated the 30-day limitation by failing to filing a response within Supreme Court of Chatham County by October 13, 2023 by filing October 16, 2023, The result then should and would had been a default decision with questions of State influence.,

Does the Respondent have any right to dismiss from that date on in any based on GA Code § 9-11-12 (2020) and would failure to respond and wish to dismiss be in the best interest of SCAD wishing to curb liabilities now and future?

Respondent has once called out Claimant’s 20-page motion plus 38-page exhibit. If there is a wish to remove the Evidence aspect of a Response, there is a reason for it in which is separate from the 20-page limit met. It is understood of respect of the Judge, which Claimant has done so in motion. To have Respondent try to state what is and isn’t admissible based on length is laughable in this matter and should be disregarded. The Respondent on page 8 seems to have an issue with the evidence and not the motion itself which satisfies the judge’s requirement and is a consideration of second glance of issue there.

Claimant, again apologizes for length of this response, but think about how much time it saves in the long run or getting to the point and driving discussion.

Respondent wishes to state, “Claimant allege only facts, not his personal beliefs or speculations.”

Claimant will mind the removal of adjectives if done so on either side upon the court. Claimant will do their duty to not going into morose code moving forward and would expect it in return.

Same paragraph written by Respondent in reference, “Vague” – Opinion, “Seemingly Random” – Opinion “Impossible to determine” – Who knows really?”

C. Claimant’s Breach of Contract Claim Should be Dismissed with Prejudice for Failure to Allege Facts to Support a Claim.

Factual Contract in which to state Claim – Employee Handbook, Student’s Enrollment into Master’s Study at The Savannah College of Art & Design. Exhibit M is submitted into evidence of Binding Agreement of Loan in which SCAD benefitted from Claimant’s Undergrad commitment to completion in 2001-2005, still outstanding in the amount of $34,855.45 since 2005 final.

As SCAD has violated their own governance and safe-campus clauses of either handbook, Claimant has stated where they have repeatedly and done so far better between this response on the workplace and Discrimination charges and Copyright on the other to prove breach of contract. As Termination of Employment occurred of a reporting party with prejudice towards at the same time of Student Status Suspended, for unknown reasons, SCAD has in evidence breached their agreement of employee and student to allow for further discussion.

SCAD Employee handbook of Reporting parties, Exhibit O, where complaining policies and “No Retaliation” is called out specifically, while page 52 requires all parties to be reporting, especially of illegal activities in which claimant initiated in April 13, 2021 and did so in any aspects of report towards end of employment and post in EEOC, BBB, Superior Court and JAMS.

SCAD Student Handbook of Student Rights, Exhibit P goes into the Health and Well-Being Policy of SCAD in which is very important on confidentiality and addressing in non-dismissive measures as “SCAD is committed to the success of all students including those of health concerns”. It is here where SCAD expresses not to stigmatize, make suicide prevention a prior and ensure personal information is confidential. Due to the longevity from initial complaint of April 13,2021, with supervisor, HR and compliance completely aware of mental health and supervisor/compliance officer getting more information and background, it is noted that Claimant was actually forced to withstand the opposite of SCAD’s promise in this area, and even exasperated towards Feb. 10, 2022 and thereafter. Claimant has practiced both their employee and student rights in which freedom from discrimination is required along with safe environments that were not. Those are spelled out of policy on pages 46, 57, and 92.

SCAD fails to uphold challenge of landscape based on Student Handbook page of 42 against copyright claims they wish to dismiss in private arbitration and required for their own liability to investigate, report and modify against their “royalty-free” student work policy that violates and harms appliable copyright in which SCAD wishes in wording to devourer and repurpose free of charge.

Response to Existence of Valid Contract

In existence of valid contracts of Employee Handbook, Student Handbook, and Federal Secured Student Loans, the contract of environment is spelled out specifically of one of safe and adherence to their own policies as well as federal and state law.

The enrollment process before a class is even begun is a binding contract between institution and Claimant which was attacked and detrimental to the longevity of Claimant time investment.

In above, as claimant is proving breaches of contract that extend from a period of 10 months employed/educating, there is still a matter of post and complaint and what should be considered confidential of anything that has occurred in these proceedings.

Claimant has been able to ascertain that they were wrongfully terminated against several factors of governance and policy and has stated how that is done so discriminatory based on sex, mental health and them most certainly financial liabilities upon the college before even getting into any notions of Copyright violations or Copyright theft in partnership with other partners of the college.

Resulting Damages on that alone had already been submitted to Superior Court prior to getting into the extensive damage of copyright which was post-poned for arbitration by order of the State Judge.

Due to Wrongful Termination and the illegal combine of detriment to college education, the price point of damage is of degree-seek, in which claimant would had earned and moved on from the entity with towards a lifetime of career choice with a Master’s in Photography Degree earned from The Savannah College of Art & Design.

Claimant’s Initial Price Point of Reprieve which was base price of potential salary to the point of retirement with a standard multiplier attacked to it. In Exhibit R, they mapped out their life plan had they the opportunity to continue college toward Master’s Degree at current place and rate of employment. The equation took the time that cannot be given back of missed degree towards retirement and issues of entity in which current form cannot resolve in non-mutualness. The lifetime total towards retirement age of 70 came to $2, 963, 112.84 with a standard X5 multiplier applied to legal actions to come to a request in Superior Court, before getting into the copyright side of discussion to be $14, 815,564.20sought based on the wrongful termination actions alone.

Respondent notes, “An employee cannot sue to enforce future performance of a terminable at-will employment.”

Claimant responds, “Don’t worry, I am not going back to Art’s Café unless as a patron and find no benefit under current make-model to try to begin to pick up college education after 2.5 years of unnecessary and costly complaint valid of the college. Employee sues for past damage and chance to arbitrate or go to trial when Respondent fails to meet those obligations set forth by their own procedures. Anything of Art’s Café outside scope of SCAD in official capacity would be of private matter in which SCAD has not paid for the copyright works on why that would or would not occur in further explore and fact check.

SCAD as an entity cannot dismiss any claims and they must be investigated properly. As it stands SCAD has failed to do so in this matter and chose to “DISMISS” where if gone to judgement or jury would be looked at as “Failure to Defend against Burden of Proof in Structural Protocol and Procedures,” opening them for liability with questions of further retaliation possible as already proven and claimed.

In footnote of Respondent on page 10, they asked for clarification of student contract. into evidence while SCAD is legally bound to the protection and privacy of all of their students according to the Student Handbook. If Respondent wants to claim that Claimant is not bound to any contract, then once again Claimant is not bound to SCAD’s ADRPA or arbitration procedures and thus has conflicts of ADRPA procedures between Employee Handbook and Student Handbook. Claimant divine’s their undergrad loan into evidence as Exhibit M in reference again of weight.

D. Claimant’s Unjust Enrichment Claim Should be Dismissed with Prejudice for Failure to Allege Facts to Support Such a Claim.

That is on the other side of this and now “how does it feel to be possibly royalty-free as well?” of Respondent, as weight of jurisdiction is considered of failing to factually uphold legal deadlines of response within 30-days within State Court, and then finding refund could be there of entity on the matter of time allot during times of Client wish to “Dismiss”.

I am sure Respondent Client will take that into consideration of what mutualness could be in this matter for everyone. Claimant is friendly about this, and yet knows professionally for now we are in opposition professionally (of novicely, for Claimant).  Claimant just see where whatever this is afterwards is somehow that House is trying to rule all here. "Motion for Trial.” Is always an option on matter’s of copyright claims and not bound to arbitration procedures if agreement is not considered. In regards here there are Monopoly laws to consider of institution and influence where  in reasonable deduction the interest is there on what a 12 person jury’s opinion on what is free or not in college land of unforgiveable student loans.

That is an absolute will 100% without much hanging around of deliberation on the matter which would be a lose for Respondent if went to trial.

The discussion here is SCAD offers 100 degree programs along with 75 minors. [2] From there, SCAD operates on a creative level of forefront of influence across that many industries of which their entity is designed and built of corruptible aspects of “Free-Labor” under their “Royalty-Free” Student Policy.

As anti-monopoly laws and anti-trust are put in place to design hostile take-overs and unfair business practice of market, so to are limitations of business set in place where there are those “Too big to fail” and then “Those not”. It would be here that SCAD is a conduit to industry, while the industry of degree-seek is their original intention of purpose and foundary.

Antitrust is designed to continue with fairness of landscape where here SCAD is in a position of offering product, expertise and time below market value to the market at either free or nominal cost of trade in either SCADpro programs or in competitions done annually at the expense of value known or not to the student who secures student loan or whatever their family income may be.

The Sherman Act is valid to consider here of market while going into the history of SCAD and what was originally the Art Institutes in what was considered at the time, territorial turf wars.

The matter of deceptive practice was discussed in the BBB side of interaction with SCAD in which question of what is and isn’t the product of the college was looked into. The deceptiveness is not a matter of where fact is or isn’t, although it has been clearly outlined where it is, there is the matter of landscape present of possibility of human inclination to consider.

Claimant has attempted to be protective of college during and post, and despite whatever has occurred of life since Feb. 10, 2022, Claimant has remained sound on matters of discussion while noting the landscape ripe of motive in which occurred to I and can be ascertained in evidence provided as well as legally investigated which would be of this arena or of whatever other aspects judicial possible.

Where the monopoly here is in the extensive partnership with industry and the need to control, ascertain and protect the student investment and creative property. The possible outsource or outflux of such would damage the entire professional ecosystem in which a matter of non-payment or lesser pay than fair market is adopted, adapted and then never considered until long-term effects have begun to showcase against the affordability of a college degree or the value against which has been properly discussed on the other side of this.

When stating claim for unjust enrichment, Claimant must prove he provided valuable services to SCAD and (2) at the. Request of SCAD or knowingly accepted by SCAD; (3) SCAD accepted the services without compensating Claimant”

All of that would fall under SCAD’s “Royalty-Free” Student work policy in which they attempt to control global rights of any college investor’s private property during without pay or in some areas would.

Respondent has failed to submit into evidence, any of their procedural investigations to limit liability, that they acted in good-faith of any claim raised by any reporting party and will fail under scrutiny in burden of proof in question of prolong. As copyright claims are clearly outlined of environment and beginnings, both in testimony and other side of claim being during and post employment/education, Respondent would be required to provide investigated measure to debunk claims outside of calling them meritless, frivolous or nonsensical as side-by-side comparisons were made on the matter.

If Respondent wishes not to engage in this aspect of the matter in mutual and private mediation towards arbitration, that is Respondent’s right to modify their ADRPA and any questions of future investors of the entity. Claimant is legally allowed jury trial to any claims of copyright and it would be with prejudice.

Scope of consideration is broken into two sections of this area.

Copyright Damage from time of employment/student (June 2019—Feb.10 2022) in which SCAD’s student rights of work royalty-free within the global market is considered. Here, there absolutely is not a SCAD student loop-hole as “Curated Jellyfish” was federally protected in Copyright in 2019 before becoming an active student and falls under “employee work” at best but always the ownership of creator and claimant.

Copyright Damage from time of post employment/student while in active Federal EEOC protected complaint and procedures while noting SCAD’s “No Retaliation against a reporting party policy) Feb. 10, 2022—present and on-going until landscape curbed and mutualness agreed upon of real world application. Here, there absolutely is not a SCAD student loop-hole and all works are federally protected in copyright.

As there is direct and willful intention to harm complaining party on the matter, there is an emotional damage value here to having their life’s work stolen, translated and then claimant attacked in electronic measures and threatened, as showcased in the evidence of “Audio Attack and I of Churnal Protect.pdf” in which Claimant’s mother is threatened and shot (Audibly and not in real life) in in consideration of witness intimidation and what is non-verifiable audio open for investigative ascertain.

Failure to produce any evidence of investigative, prohibitive measures by the college upon introduction of claims moves towards the opposite of Respondent’s desire to dismiss. According to the SCAD handbook, “SCAD is committed to complying with the U.S. Copyright Act. Thus the SCAD Copyright Compliance Policy encourages and promotes legitimate use of copyright materials by faculty members, staff members and students. SCAD expects all faculty members, staff members and students to comply with the Copyright Act and this policy. Compliance is particularly important with respect to digital technology. The complete policy , as well as copyright compliance guidelines, is available at scad.edu/policies”

SCAD supplies access to the definition of copyright works through their website of citation of 17 U.S. Code § 101 – Definitions

Although SCAD spells out the same translation of the law as Judge Johnson has in early beginnings, the matter of how they obtain is able to be prosecuteable and damages sought. Questions have arose in both Arbitration and in Superior Court of Chatham County within this case of landscape of question as direct references to aspects of Claimant’s work was done in multiple areas of required investigation in books that have not sold one single copy outside of the original of Claimant’s purchase of 1st printed version. As no legal copy exists, the scrutiny of the exploration of infringement is vast and expensive to consider. Ideas may not be protected, but how they go about getting them are, where in this regard no legal version of Claimant’s work have been purchased by SCAD and able to be verified as such in timestamp.

Furthermore, in process of landscape to further back up concerns of predatory of an institution, if ideas are not copyright protected, then the management of partners and conversations of “Student Work” or “Staff or Faculty” becomes a matter of confidentiality and of degree-seeking investors interest to protect. As ideas are done daily at SCAD that are not copyright protected, then the open door of predatory practice exists not only in Claimant’s time as a student, but also questions on how post-employment/post-education the college entity was able to cite and utilize copyright protected works of Claimant, without legally paying for them and during time of complaint to reasonably deduct continual damage laid out to of been occurring of intellectual property while employed and of student status.

SCAD has clearly spelled out the damages copyright infringement does along with penalties on the website of damages, plus any legal actions.

Considering the vulnerability and SCAD’s choice not to defend, comment or plead the 5th on, 47 books of copyright protect are in potential compromise in which SCAD has basically pleaded the 5th by choosing to dismiss the claims. As this would be considered absolutely intentional of side-by-side comparison and in proof of never legally purchasing that fine civilly comes to $6,750,000 dollars in damages to the entity of SCAD alone.

In motion, SCAD’s represented discussed the Claimant’s 2-fold tablet as non-copyright protectable, which would be only awareness to judge and attorney at this time, unless it was discussed with their client in, in which copyright claims had already been made back in 2023 against the entity of SCAD and they have appeared in evidence to proceed in operations of continuing to do so, therefore warranting willful intention of damage, harm and as ascertained to keep Claimant in a matter of vulnerability, poverty and without resolve collectively.

Any of SCAD partners would be liable for the maximum fine, plus any criminal aspects in which would be matter of SCAD’s choice of operations and their choice not to contest of due process, investigation on the matter. Claimant has more copyrights than 47, so the extent of damages could be expanded upon in evidence and in consideration of scope of timeframe during in complaint which Claimant is Federally protected from Retaliation from the Responsible Party.

Claimant is asking judge for summary judgement on this matter as SCAD has chosen to wish to dismiss without supplying evidence to disprove their liability and partnerships at this time.

SCAD in “Exhibit A” has in their possession in which “No ‘Starving Artist’s” is a copyright protected work available for sale in the market which maps out a landscape of infringement, incorporation and the escalation of the matter against Claimant’s rights from 2021 on, written fully and protected in copyright several times over.

As SCAD chose not to discuss the matter nor the evidence in good faith, they are bound to confidentiality and open for copyright litigation of any translation of the work moving forward in market. Claimant has requested a signed agreement from SCAD and Respondent that it was not shared to outside entities during confidential proceedings in which based on their position cannot disprove liability moving forward on the matter based on prior accusations and patterns laid out in court and arbitration proceedings.

SCAD could provide in partnership investigative aspects good-faith efforts of ascertain or that could be done by jury trial, where Claimant asks for Summary Judgement on this matter without prejudice meaning any future claims can be raised against the college in documented behavior since 2021 of landscape of self and partners.

Despite whatever limitation of Copyright Infringement violations possible in affordance, the true damage in any amount to consider is total unreconcilable damages and excessive to consider what the cost of taken creative can do in long term, while noted statues of limitations and placed in complaint of Superior Court conversation and discovery as well as in this private arbitration. The fee applicable is nominal to the years of environment in which was set in evidence of submit in arbitration and laid out of 10 years verifiable in “No ‘Starving Artist’s”.

Claimant has requested a full refund of both their Graduate Masters tuition investment to curb SCAD liability in which any works that could had been mistaken as “royalty-free student work” is removed of possible of the entity to do so for their own liability. This is a request under Federally Protected Student Loans, Scholarships, Grants and then claimants own out of pocket expenses or investment of time towards benefit of.

As SCAD illegally suspended college student studies on Same date of “wrongful termination” they have created damages to a degree-seeking investment where 2 years later have yet to resolve and have not satisfied any court on investigations disproving their liability of damages or conduit of copyright infringement on myself or the student body. Claimant has an obligation to repay student loans as well as take into consideration those who provided Scholarship and Grant to complete courses deemed hazardous to any future investor in current form.

SCAD has all student transcripts of payments to the college of this investment and Claimant has some to provide the figure. From 2001—2005, undergrad tuition was 2, 250 per class, rated at 5 hours per class to a curriculum of 180 hours which equates to $81,000 dollars for completed Undergrad Studies.

For Masters study, as Claimant never received any letter from SCAD explaining their school studies suspension is a violation of the Student Handbook and insult to injury of investment and utilization of benefit and resource to obtain. As that benefit is taxable income, the price per class is in consideration of unfinished degree, and degree that cannot be completed without fundamental changes to college procedure on the employee side or student side of structure during complaint. That total from 2020-Feb. 2022 comes to $4,275 per class (or class capability based on benefit and considering a quarter was missed due to SCAD liability since April 2021 and failure to address or remedy comes to $38,475

Collectively that total comes to $119,475 of college investment minus interest towards repayment of loan taken out in 2001. Claimant requests summary judgement on this amount with prejudice of any copyright confusion the college may have, and without prejudice above if ever continues of infringement of copyright claim. This is requested to curb their future liability and to contain landscape required for any future investment within the college by degree-seeking investors.

Total for this Section: $6,950,475 + any other appliable fines and damages

E. Response to Claim for Failure to Pay Accrued Vacation Time Should be Dismissed because Claimant Cannot Establish Legal Entitlement to Such Pay

Still the original agreement and email on pay out of Accrued Time” initiated by Jonathan Goldstein and then left abandoned by SCAD with no payout to date on the matter. Visual proof of existence denotes Respondent has the same evidence Claimant does on the matter.

Claimant has in Evidence as Exhibit D the agreement to payout in contract and email of official capacity in exception that was never satisfied by Respondent and should be paid out as they forfeited the right of legal discussion on the matter.

This should remove any further aspect of the word, “alleged” from the agreement being of reality has it has been in evidence of EEOC and Superior Court and Arbitration procedures.

Respondent acted on bad-faith on the matter of good faith private discussions and abandoned to adhere to their own legal timelines they wished to impose upon Claimant in equal afford of yet another example of (at this point un-employed “Citizen” and “entity of SCAD” and direct link of “wrongful termination” and a major liability creator of the college for “failure to respond” and “dismiss” good faith application.

Respondent states, “Claimant has not alleged written contract that guaranteed future employment”

This is true, which is why Claimant cannot and should not be treated or referred to as an “employee” of The Savannah College of Art & Design, and thus not bound to their private arbitration procedures as they are not a paid-for entity of and has found constitutional questions pertaining to it which have been presented to court and this arbitration procedure. It is a requirement of SCAD employees to report anything of illegal nature to the college and they are free to do so without harm of retaliation and in consideration of employment by reporting such.

Respondent stated “Claimant did not allege any facts to plausibility suggest he conferred a benefit for which he is not compensated.” (See SCAD student royalty-free policy on Copyright side of procedure)

Claimant enters benefits earned that were promised and never paid to satisfy that benefits were denied. It is here once again email and contract of negotiations of pay out of accrued time off that was never satisfied once Claimant made sure Respondent is not self- indemnifying SCAD for around roughly 1300 for all eternity of any future action against.

Amount Due $1131.13 + Interest + Any Applicable Damages for this section

F. Response to Claimant’s Title VII and ADA Claims Should be Dismissed with Prejudice.

I know the legal word prejudice is quite different the discrimination aspect of such, but I find that hilarious attaching a motion with prejudice to a discrimination Title.

Respondent has failed to submit into evidence, any of their procedural investigations to limit liability, that they acted in good-faith of any claim raised by any reporting party and will fail under scrutiny in burden of proof in question of prolong.

SCAD was Supervising officers were aware of federal violations towards Claimant since April 13,2021 in which Claimant could have received damages from as well as understood from the initial complaint since that they were of a protected class based on mental health and life experience while seeking treatment.

According to SCAD policy that is confidential medical information that was known of all investigative and superiors of directness in matter of this case to date, including those of court.

As the events that continued in documented report leading to wrongful termination focuses heavily on the protected status of mental health and being treated for “post suicide” and “involuntary medical hospitalization for a mental breakdown.

SCAD in full awareness, not only disregarded valid statements and claims when this was effected, but Claimant has been able to lay out example of Male Discrimination, how SCAD may had acted discriminatorily on Claimant in false comparisons of and then lack of evolution from, while citing the added documentation of 2 more female same-position held that was treated more favorably than Claimant, despite evidence.

Considering wrongful termination, and initial federal compliance investigation of favorable treatment of confidential information of liability to Madeline Collins, a series of events took place for 10-months, that upholds claims of discrimination of male and detriment to mental health in now 3 similar-like males under supervision and of documented investigation or report with SCAD. It is possible that SCAD took preferential treatment and protection over a female supervisor of longevity to the school, than a male with valid claims of harm and violations leading to their “wrongful termination” in liable dismissive notions of factual mental health damage in which was confidential to reporting parties and shared in email form of implied and rationalized discussed between departments of confidentiality. (Exhibit I).

The implied notion of longevity to string out the valid claims done so in proper timelines, is indictive of a continue to possible play off an environment leading to potential self-harm again of Compliant to escape liability that simply would not occur.

The internal dismissals are self-evident of the entity and comes through in their constant dismissal of anything of viable claim presented to them in an appearance of “business as usual” approach, while changing other’s perceptions on what is business as usual for the college. That is compounded since every aspect of this matter in which they are bound to no retaliation practices and have set of a chain of events in which years of damages are to be accounted for before even getting into each area of violation individually.

1. Claimant’s ADA and Title VII Claims are Time Barred by the Applicable Statue and Limitations as He Failed to Timely Initiate Arbitration within ninety days of the Right to Sue Notice.

Incorrect and already showcased of how all due process is still in rotation and statues of limitations on the matter. As claimant engaged with legal Federal mediation proceedings with both SCAD in-house legal council, Chaimann Wang under the direct supervision of the President Paula Wallace, there is no such time-bar to consider on the matter.

What is time sensitive is the matter of complaint that Human Resources choose not to participate directly in EEOC or BBB proceedings before the award of “Right to Sue”. No where in their own arbitration procedures has any date or time table to denote structure in which to counter in complaint and Claimant has adhered to anything Federal and State on the matter.

Claimant made certain to legal council and SCAD the criminal aspects that have occurred and made sure in prior arbitration agreements to by-pass Human Resources on the matter as it constituted aiding and abetting against damaging parties within the Respondent’s entity, who on Superior Court of Chatham Country, perjured themselves in introduction anyways in which Claimant can seek damages against.

The proper forum and timeline is EEOC and then onto the courts.

As not everyone works for SCAD or those with their own tweaked and polished arbitration clauses, all must adhere to Federal and State Rights which supersede any and all of private entity of employment as they are entity of land non-contingent of employment opportunity in fairness.

Events follow of process of EEOC-BBB-Superior Court-Arbitration where all is active throughout timeline and cannot be barred while noting SCAD’s excessive timeframe to initiate and begin arbitration procedures during timeline of active complaint.

SCAD’s arbitration process makes no mention of EEOC proceedings as a requirement and here Respondent wishes to make up and modify their procedures to wrap around this discussion. As the entity is not set up for success of any dispute between “employee” or “Citizen”, the EEOC is a requirement to curb the mediation of discussion in which SCAD failed to contain and uphold in business practice while removing any mention of rights to “employee” that they must file with the EEOC if they are to enter into any legality with the college. The college would be required to mention this in future applications and as it stands they cannot in times of non-mutualness. Otherwise the college strips “citizen” rights of future legalities and do not inform any complaining party of their rights.

That is factual as Jonathan Goldstein, never in employment complaint suggested EEOC or arbitration procedures for the compounded ADA valid claims and workplace discrimination in which they and their department self-governed in combined oversight and interaction with Federal Compliance interconnected through SCAD email address while citing multiple breaches of confidentiality occurred in matters of Compliance investigations and subsequent moments of mental health effect of major impact documented and met over by multiple staff/faculty at SCAD which could testify on the matter including Madeline Collins, Mark Staples, Federal Compliance Officers, and managers of Art’s Café who can note mental decline from prolong exposure to an unhealthy work environment and reasonable request for accommodation or transfer/interview occurred with at least upholding Federal Break Laws in which SCAD was in violation of since April 2021 and submitted in original complaint in evidence.

On page 15 of Respondent’s Motion

“Claimant’s misapprehension that the EEOC’s Right to Sue Required him to file in court rather than arbitration, despite the ADRPA’s explicit arbitration mandate, amount to excusable neglect”

Discussion here is on the enforceable or non-enforceable aspect of “employee” or “Citizen”.

Georgia is an at-will state, where according to Bowman Law, “You may terminate an employee for a good reason or bad reason or no reason at all, as long as you don't violate any anti-discrimination laws, and you may decide the terms and conditions of the employment.”[3]

The definition of the word termination is defined by Oxford as ”the action of bringing something or coming to an end. "the termination of a contract"

As SCAD at-will terminated Claimant, along with Suspend their Student Status at the same time, on Feb. 10, 2022. SCAD had voided any enforceable aspects of their policy upon Claimant as they cease to compensate and removed all advantages of student and employee of SCAD in separation which was presented to the state, falsely of Feb. 17, 2022.

As SCAD does not supply Claimant a paycheck, health care, or any of the other advantages of being funded by the college or any institution, the path of complaint to EEOC is a requirement of law for any time-limit to be considered all the way to court.

This is when “Citizen” went to the “Un-employment Office” which means they are no longer an “employee” of an entity officially.

To pull from Official Georgia law of definition of “employee”, Found in  GA Code § 34-9-1 (2022)

Employee” means every person in the service of another under any contract of hire or apprenticeship, written or implied, except a person whose employment is not in the usual course of the trade, business, occupation, or profession of the employer;”

For sake of discussion, “Citizen” remains and in Georgia definition denotes they are no longer “an employee” of SCAD as SCAD has released them from any bounds of building or benefit in definition. Claimant is aware, they are always an “Alumni” of the School, and that can never be interchanged from based on their 2001-2005 undergrad of Graphic Design. Once they become “Citizen” status, they are bound by Constitution of Public Entity and not ADRPA of private.

Claimant had a right to work and do so free of any detriment which was internally brought up procedurally before going to the EEOC. Claimant was an active student at the time in degree seeking nature of Master’s in Photography, where at 1 course a quarter would of guaranteed around 5-6 years employment with educational benefit to Claimant to retain employment and incentive to continue education. That was robbed of them on Feb. 10, 2022 despite wishing to transfer, interviewing for other positions, non-advancement of position despite absorbed duties non-compensated and any other aspects of not one single problem before April 2021 writing to Human Resources and a downward spiral of employment experience leading to Feb. 2022.

Now, if SCAD had at any time, which they did not before Superior Court wanted best success of resolve, they would had initiated their own suggestion of Arbitration while mediation was occurring of which all time limits are bound to. It is a legal requirement to go through that process, and SCAD at best wished to continue in Claimant’s ignorance of the law and then perhaps be surprised when they learn one or two things along the way.

Despite anything of SCAD’s wish to enforce a non-constitutional arbitration procedure, the right to sue remains in constitutional protection and valid in The Civil Rights Act of 1991 of “citizen” despite whatever moniker of “employee” any entity wishes to use or enforce. As Claimant is not an “employee” of the college, at best “former employee” is to be used moving forward, but Claimant prefers “Citizen”.

Procedurally, if EEOC is mediation and that was successfully entertained by in-house SCAD legal and president, then the arbitration of court is choice on either side, as SCAD’s wording denotes they too can defer to court at any time in arbitration proceedings.

As Superior Court ordered Arbitration, it was SCAD’S own lack of deadline to initiate it and draw it out to where it is now.

Claimant questions that Respondent would wish for Arbitration procedures back then to be under the complete supervision of the entity who “wrongful terminated” them and then had months of evidence stacked against them in ADA requests and initial complaints. That would occurred with complete ignorance to the factual state and federal dates required to file an actual court case on the matter. Respondent would not of looked out for Claimant’s best interest and that is the right of “Citizen”. Case in point is here we all are in Arbitration and all Respondent wants to do is “dismiss, dismiss, dismiss” in what reasonable jury can look at in evidence and due process.

Claimant also notes that if there was any issue on timeliness or timeliness of claim and procedure, The State of Georgia in Superior Court of Chatham County would not have “ordered to arbitrate” and closed any future discussion on the matter.

That order to arbitrate was done so on September 6, 2023. If there was to be any time-barred matters then, it would had been ruled upon before “Order to Arbitrate” under “GA Section 9-9-5 - Limitation of time as bar to arbitration” in which Respondent’s wish for such was presented to the court, but not ruled upon and would not apply in replacement of order.

If Claimant is to take SCAD’s own 90 days clause of time-bar and apply from time to order to arbitrate and then SCAD actually doing so, they may have once again time limited them out from defense and noting a pattern of leaving the claimant in a position of detriment, harm and non-relief in which could be considered “pricing out or waiting out” where statues of limitations and responses must be upheld to prevent further.

SCAD failed to initiate formal arbitration proceedings until April 30th, 2024 upon the first preliminary meeting with Judge Johnson, which is 237 days from date of order. Claimant requested arbitration to begin on September 21, 2023, 15 days after the court order while the 588 days benchmarked in Respondent’s motion is of their own burden and not of Claimant for Judge to consider the price of non-discussion, avoidance and procedural failings in which the institution is bound to.

SCAD is responsible for initiation of Arbitration proceedings, and had attempted to fail their own arbitration procedures by hiring a retired State Judge Wright in which they have arbitrated with before and wishing to remove the process from the JAMZ overview as well in which they are affiliated with before the selection of Out-Of-State Federal Judge Johnson of Texas.

As arbitration involves discovery and witness testimony, SCAD has failed to arbitrate as the procedurals here constitute mediation in absence of either and their desire to not move forward on any notions of the process of arbitration by their request of dismissal of all claims multiple times over.

That would be 330 days since order to arbitration in which they had no desire in “dismiss” to satisfy the State of Georgia’s ruling to do so. As SCAD wished to mediate a complete dismissal of all things to arbitrate, thus failing their own procedures in preventing liability and doing due process in any complaint of worthy of investigation and ascertain of truth.

It is in this regard, SCAD has failed to protect themselves from outside scrutiny on the matter, which was the same pattern behavior of dismissal of valid claims while employed and as a student of the college.

With that in mind, it has been 903 days since wrongful termination under the scrutiny of evidence already supplied by Claimant to the EEOC, BBB, Superior Court and the JAMZ portal in which SCAD has failed to provide any evidence in response to validate that they took any bit of this seriously on the matter despite evidence and good-faith the entire time.

Considering the initial complaint of known SCAD liability and landscape began on April 13, 2021. The length of SCAD’s liability in which they have excessively drawn out this matter comes to 1206 days in which protection was bestowed upon Claimant on the matter and the course of actions present from that point on to “wrongful termination” is riddled with aspects of disregard of mental health, valid complaints of affect on ADA protected class status, confidentiality and work-place violations.

Post “wrongful termination” the motivational aspects of reasoning of attack, kept in place and continual awareness of availability of landscape of copyright violations leads to further motive and a necessity to shut down and secure Claimant’s safety and property in accordance to the law.

According to GA Code 9-9-9, Power of subpoena; enforcement; use of discovery; opportunity to examine documents; compensation of witnesses.

(a)   The arbitrators may issue subpoenas for the attendance of witnesses and for the production of books, records, documents, and other evidence. These subpoenas shall be served and, upon application to the court by a party or the arbitrators, enforced in the same manner provided by law for the service and enforcement of subpoenas in a civil action.

That could resolve any of the questions where scope of damages need to be ascertained while summary partial judgements could be had on the matter. The spirit of mutualness is present to obtain and the longevity of length of complaint should be taken into consideration of the Judge on the matter of where Claimant notes some level of requested relief, and yet the compounded claims and what are federal violations and federal interest are astronomical to consider of layperson.

On Page 15 of Respondent’s motion. “had until December 29,2022 to file his title VII and ADA claims in proper forum – arbitration with JAMS.” As initiator of arbitration befalls on SCAD, the timeline before getting to the JAMS network is not a requirement of biased to an arbitrator. The selection process of arbitration began 15 days after order and proceeded with a series of non-eligible retired judges and then once selected and agreed upon a wish to change judges from Respondent to outside JAMS network based on affordability and State regionality.

Amendment XIV of the Constitution does apply in this manner, “No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.”

As Claimant was wrongfully terminated by a self-governing private entity, equal protection is to be upheld of constitutional rights of equal protection. As failure of procedure had already occurred in a negative towards “employee”, now “Citizen”, it would be assumed of a disadvantage to begin procedurals of a private entity in which self-interest and motive were present since April 13, 2021 on matters of legality, demanding uphold of “Citizen’s” arbitrator of choice and always available of the judicial branch and court of the same affordance of equal protection and impartial of any payment possible of private arbitration. That does not reflect impartialness isn’t present in private arbitration, as the court and jury trial is afforded of all citizens based on the solidification of the S 7th amendments of rights to jury trail in “In Suits at common law, where the value in controversy shall exceed twenty dollars, the right of trial by jury shall be preserved, and no fact tried by a jury, shall be otherwise re-examined in any Court of the United States, than according to the rules of the common law.”

Between Amendment 14 and the preserve of the 7th, it could be discussed that no private entity’s “arbitration” process of “employee” can ever surpass the public entity’s “judicial” process of “citizen”. Claimant made a valid stance on this is Superior Court of Chatham county and continues the discussion with the noted language, as defined by Georgia law or difference of the word “employee” and the difference of status of “Citizen”. ADRPAs are designed while still employed, not post. [4]

In Superior Court, Claimant attached the 13th amendment of slavery to SCAD’s arbitration procedure in it’s current form. As SCAD wishes to identify any individual current or post as “employee”, those of post are considered “employee without compensation or benefit” which constitutes private entity ownership over someone once agreed upon workplace settings had passed. In that regard, Amendment 14 resolves any prior rule or ownership in agreement in which doesn’t surpass the constitution and cannot be challenged by any state law on it’s validity or enforceability “Post-Employment” or “Un-employed”. The adoption of the title “Citizen” is appropriate for any procedural matters of private entity where variance of procedures are designed to prevent any complaint of Court and of good-faith while under “employee” status.

As noted by Respondent, Claimant meet the deadline towards arbitration originally with the chosen superior Court of Chatham county, 88 days from right to sue granted by Federal Mediator of EEOC.

ARDPRA, in it’s existing form is similar in the same process, but Human Resources replaces EEOC, and private arbitration replaces the court (to an extent and then not at all). Once “wrongful termination” occurred in which Claimant did receive unemployment benefits, which would ratify with The State of Georgia” that wrongness occurred and “slander” is found of SCAD on their official determination of “Insult to Injury”. (Exhibit C, Department of GA Labor Determination)

Questions of SCAD’s legality is also in question in matters of motive and presentation to State and Federal areas with (Exhibit F – August 2, 2024), where claimant has found the correct in-correct filing with the state of Georgia with a Feb. 19th, 2022 termination date, which was actually the 10th, (wrongly stated by Claimant as being the 17th). This claim of State brings into questions matters of motive of copyright claims later on “non-copyright protectable concepts of 2-fold e-readers in unpaid for copyright material”.

1.     Claimant’s Fails to Sufficiently Allege a Discriminatory Discharge Claim Based on His Race or Gender, and Disability

Respondent took time on this section as 5 pages are spread out on the matter of case. It is of claimant’s responsibility to cite examples of those of same position and class in order to prove this.

Respondent has tried to steer their official response away from the mental health or factual ADA claims in which they have been presented with enough evidence to state one way or the other on.

Respondent wished not to deal with evidence in which they could have supported their best efforts of duty according to handbook and law and fail in all capacity to do so.

Their continual notion of dismissal and discredit is not without notice as for the last 3 years they have no evidence of good faith or valid claim that they approach such in a manner of them doing due diligence that wouldn’t warrant arbitration or law-suit anyways.

The stance of college is “Nothing to see here”, while harm was done, is done and their acceptance rate is noted of “Royalty-free”.

Claimant has 4 areas they have to satisfy in order to Uphold Title VII.

1.     Protected Class (In this circumstance, male & Caucasian)

2.     Qualified for the job (and others of higher ranking and position to warrant transfer (Exhibit N, Resume supplied to HR, Supervisors and Executive Team of SCAD)

3.     Suffered adverse employment action, (Termination by inadequate investigation with female entities of known hostility, written testimony resentment, daily complaint and non-vocalization in the same kitchen, priorities of responsibility and singling out of the sole male and able to showcase in evidence it was directional, false and motivated based on biased treatment favorably female over male of already reported and protected party since April 13, 2021. Slander present in Unemployment where outlined below will showcase what is already in evidence from EEOC proceedings in summery

4.     Treated less favorably than similarly situated individuals outside protected class is more than apparent on the matter of both male and Caucasian, as all similar employed were female, 2 African American, 1 Caucasian, and Supervisor A naturalized citizen from Spain. It is understood in this notion that yes, Caucasian is a protected class from African Americans and vice versa.

Respondent has difficulty on page 16 as saying Claimant “fails to allege any facts-let alone sufficient facts – to plausibly suggest SCAD terminated his employment because he was Caucasian and Male”.

As the incident report was filed day of and shortly after removing themselves from the hostile work environment that was unsupervised, the events leading to termination came from the perspective of the previously claimed hostile employee managers (Both African American and Female, who had already brought slanderous and wrongful complaint to HR). As no others were on site, despite Claimant reaching to Supervisor, Human Resources and Compliance, it is reasonable to deduct Claimant’s termination came from the female perspective of incident without proper investigation and despite Claimant’s best efforts to document, maintain a healthy work environment and also proper cite problem areas in which Supervisor treated the female managers more favorably than Claimant on not just procedural notions of men lifting boxes, but also of breaks and clock outs which Female Managers known were an issue before beginning to make problems for male Claimant in the workplace of false accusations or of job performance.

Inequality, the resulting termination was from the benefit of the doubt for months of the female side while ignoring the male side of valid major mental health concerns instantly raised back in April 2021, properly reported all accounts possible and ascertained of 2nd and 3rd hand account of constantly belittled and discounted at the expense of perspective of female supervisor who had already been noted of being liable for damages, and SCAD with since April 2021.

It is fact that current legal council of Respondent was not present for the EEOC testimony and investigation, as that was SCAD’s in-house legal council in which all accuracy of timeline of employment was provided by Claimant to the constant disregard of private entity.

Upon Right to Sue granted by EEOC and then obtaining of all documentation within the case (barring my specific copyright protected responses according to The Freedom of Information Act), was received and then found of withheld evidence that was not provided to the Claimant in which the relief of the matter could had occurred during the EEOC proceeding toward conclusion.

Considering the notion that EEOC failed to provide evidence of investigation to Claimant which would have resolved their case then and there in 2022 of what was known, there is biased and consideration of fact when it comes to the landscape of make/model and what Claimant tried to protect/preserve and retain while their own life threatened.

It is a requirement of the EEOC to investigate federal contractors and that information is not present of prior nor of SCAD which too is contracted by The United States of America.

It is an understanding of Claimant, EEOC does not pick up legality but weighs on it, and of such Claimant has done the best they can outside of influence of current structure or of self-defense in which was originally, and should be considered private matters, now may public by 3rd party.

That evidence was weighed, noting the liability of entities within SCAD leading to the wrongful termination, and provided back to SCAD legal council, who did not choose to respond or interact at the time any conclusion of the compliant.

The same was sent of selective evidence to the other 3 parties of their provable liability, and yet SCAD made no attempt to resolve this matter leading to the Superior Court of Chatham County filing as continued bad-faith practice occurred.

Once Littler was hired, the same package supplied to In-House SCAD lawyer was sent to Respondent in once again good faith and all prior evidence before proceeding with Trial. That evidence was also confidentially provided to the Superior Court of Chatham County in the beginning and not searchable of public record as it was provided by hand to the county clerk.

Claimant did not “abandon” their job, despite Respondent’s wish to say so. If Claimant “abandoned” their job, they would not have filed an incident report nor contact their supervisor via text of a major problem on Feb. 10, 2022. SCAD continued to falsify with multiple reasons on why Claimant is no longer employed at SCAD with multiple entities in which is again wrong, slanderous and against governance of a reporting party in which they lost not only their employment, but their education at the same time because of such.

Claimant has in testimony, called out the break structure and dismiss of abuse of the two African-American manages of same work class by Supervisor Madeline Collins and Human Resources when it was pointed out multiple times. Jonathan Goldstein was made aware of this within the presence of Mark Staples, who both would have awareness of the initial work-break issues that began in April 2021, and were detrimental mentally to 2 of the males, including Claimant at the time. Choice of investigation or discount would denote again gender-biased.

Noted that Claimant’s sexuality was only known to Madeline Collins and Wanda Ward where to a degree Matt Kubiak, Caitlin Barnabee and their baker Caleb. It would be unknown to human resources and most certainly unknown to the 2 African American Managers that began employment interactions with Claimant in Dec. 2021 and riddled with complaints of leading up to “wrongful termination” on Feb. 10, 2022.

It would be in question of that on the male discrimination side of assumption of any claims by the 2 African American managers that came after Claimant noted to Supervisor and brought up in meetings of both of them riding the clock and Madeline Collins giving preferential dismissiveness to the matter despite evidence.

This would hold valid in skew of matters in which incidents reported and investigative employee performances had where in evidence Jonathan Goldstein manipulated the situation to suggest problems of Claimant in which were countered pre-meeting in evidence and then after in response of employee review in which outdated version was submitted to the EEOC by SCAD and finalized version authorized by Mark Staples in authentication and of sent to Jonathan Goldstein of being fact.

Neither Jonathan Goldstein or the 2 African American managers would know my sexuality of homosexual during employment and any suggestion of interest sexually hinted at or direct would be considered false, presumed of male normative sexuality and a question in which cannot be countered at this point.

It would, and could be proven and stated, claimant had not touch a woman sexually since their finance when they were 20 and that being valid of the only woman they ever had sex with in their life while going off on a 20 year journey internally of what did occur during that time and backed on poverty levels of unable to support in life moving forward.

It would be noted that I do not disclose my sexuality at places of employment in the 2 since SCAD, noting I did not at the Two prior to SCAD, and pretty much affirmed the notions of such based on interactions and assumptions of actions of senior leadership at 3rd before SCAD.

As Claimant has known Madeline Collins and Wanda Ward for over 20 years, it was inevitable and in full awareness that they knew back when I was 20/21 and in continued relationship ever since. At best, indirect inference and some awareness of other 2 managers, but kept at a minimum without much discussion on the matter.

When finding an Apples to Apples comparison of same class, same status to denote the gender-biased against males of Madeline Collins, Claimant cited of question and behavior in confidence of Madeline Collins treatment towards I and how that could or could not be similar to what occurred with a former SCAD manager, Chase Davis, of mental detriment in which is recorded in Compliance Zoom investigative files from 2021.

Chase Davis, was a same status manage of The Gryphon, a same building restaurant of Art’s Café at The Scottish Right on Bull St. in Savannah, GA. Prior to Claimant’s employment, an altercation occurred from long-term interaction between the manager Chase and Madeline Collins. They suffered a mental break, allegedly came back to The Gryphon after a heated bought of text messages, and was subsequential arrested and convicted for multiple arson for a period of 5 years in 2019-2020 if I recall correctly.

In comparison of same aspects of discrimination not only on the male side, but also of mental health and how SCAD proceeded forward on that with employee record of Madeline Collins, would be combined with not only Claimant’s own testimony, but that too of Jullian Mick, who of male and physical mental detriment all had negative impact of job performance and longevity based on patterned behavior of Madeline Collins in which SCAD would have full files on as they were reported to Human Resources and Madeline’s Supervisor Mark Staples resulting in changes of Work-Break procedures and employee meetings to validate areas where discrimination occurred along with procedural negligence of the college based on past experience of multiple apple-to-apple factors.

(A consideration of SCAD’s considerable investment in years of dismissal with awareness of  USA v. Chase Davis, No. 20-10253, 11th Circuit 2021) and 4:19-cr-00090-RSB-CLR)

Quotes of Appeal to be called into testimony.

“He also argues that the government’s theory that he was motivated by anger over a work dispute was contradicted by testimony of his good mood during that same time frame”

“And a reasonable trier of fact could find that the following evidence established Davis’s guilt beyond a reasonable doubt: testimony about Davis’s repeated attempts to sabotage the restaurant through the canceling of checks, reservations, and work shifts in the hours surrounding the fires; text messages just hours before the fires that showed Davis’s anger about a work decision; surveillance footage putting Davis at the scene around the time of illumination in the windows at the Gryphon; and Davis’s incriminating written statement to investigators”

What is noted in this appeal, before doing a freedom of information act request is the context of repeat patterned behavior of issue and “disgruntled” by Chase Davis, which denotes problematic areas of interaction between Davis with Plaintiff knowing at this point the interaction is in reference to his direct supervisor Madeline Collins.

It is noted that text messages were exchanged leading up to the arson, and that complaint was had that went unresolved and unaware at this point if Chase Davis went through SCAD procedure to address those outside of direct interaction with Madeline Collins.

It is possible, especially on the Madeline Collins side, that there is discrimination based on mental health by both her, human resources and SCAD based on prior experiences and re-experience of how to handle the matter of effect negative in prolonged exposure of work-place interactions and non-resolve.

It is noted in the April 2021 Federal Compliance interview, the effect of mental health was noted and discussed in confidentiality based on interactions, citing objective facts and then personal liability of Madeline Collins and SCAD, that will prove all the way to the “wrongful termination” that mental health was made aware of being damaged and then prolong exposure to non-resolve occurred, where despite best efforts of Claimant were not resolved, prevented and exasperated to the point of in-efficiency to not only do their job, but to participate in their continued education and leading to the point of class withdraw during their final quarter of mutual employee/student benefit.

The text messages cited in Davis’ case, does give alarm of discrimination as the same instance occurred prior to Mr. Davis’ mental break and personal decision to commit arson at The Scottish Rite temple. This would be called into question of Mental Health and ADA violations leading to termination as Madeline Collins relinquished her duties of position by not responding to the text messages and later Johnathan Goldstein termination Claimant although they were the reporting party.

Jonathan Goldstein, while terminating Claimant via phone calls of multiple, refused to answer if they spoke to Madeline Collins on the matter of incident, which inclines to the point of discrimination of mental health and awareness of prior incident of liability and personal responsibility of themselves towards harmful and lasting damage within a workplace, despite Claimant’s best efforts to report, document and remedy any situation that arose instantly and then over extended period of time, claimed, reported both to HR and federal compliance to question of Johnathan Goldstein’s dismissive statements of valid claims in email, which alludes to the not only their own negligence or of SCAD’s of learned protections of safe-environment, but infers that the implied conversation of mental health was had with others and dismissive in pattern of which valid and seriousness wad present.

The statement made in official email is dismissive and calls into question ADA aspects of mental health and confidence in which may had been broken and showcased in patterned behavior of Jonathan Goldstein to not uphold integrity of confidentiality not only in Federal Compliance investigation awareness, but then of standard Human Resource procedures.

It is in this area, that claimant can absolutely attest one either side of the matter of discrimination based on their federally protected mental health in which was known affected prior, treated and then beginning to be healed in initial entry to the SCAD workplace in 2019, harmed in April 2021 and exasperated to depleting points leading up to Feb. 2022.

It is understood, SCAD’s negligence of action and validity of investigation and looking into is compromised by 2nd and 3rd hand accounts of actions where it is noted that SCAD and Madeline Collins liabilities were known, expressed and shared in breach of federal compliance confidentiality since April 2021 and directly link reasons why compliance interviews addressed immediately what had occurred, wished to resolve and SCAD as entity chose not to remedy, prevent and continued on in patterned areas of which have cost not only the claimant years of discussion on the matter while they could had moved on with their life, but also the incarceration of another in which depending on how the events leading up to the arson, could had been prevented and showcase patterned behavior of Madeline Collins and SCAD.

It is noted Claimant is not Chase Davis, did not do anything wrong at SCAD and was an expected long-term employee guaranteed to be there through the entire course of their Master’s education towards complete, which would had been around 5 years of service.

It is noted, Claimant had no problem with their job prior to April 2021, and would had done anything to stay at SCAD to complete their Masters, as to earn one through GPA and course of study would had secured the surety of employment at the very least in an educational role post college. Claimant would had no issue with their employment as Assistant Manager at SCAD during that time, and the change of behavior and interaction after reporting in April 2021 for the first time to HR lead to detriment of employment by a reporting party.

Claimant did their best efforts of working with Supervisor and then so of HR in all instances while noting there are unsolvable aspects that arose due to reporting workplace conditions and then requesting transfers, reasonable accommodations of proper investigation and procedure and then earned titles in which the opportunity of interview occurred 3 times without advancement or shuffling based on known problem areas that became detrimental to Claimant in 2nd hand slander that was also showcased by SCAD officially external and internally by 3rd hand account in official capacity.

It is noted in testimony of the Davis case, that Claimant’s direct supervisor, Matt Kubiack, also testified in the case and was aware of the mental health break that occurred and knew Chase Davis in professional capacity as Art’s Café is interconnected to The Gryphon in the building of Scottish Rite. Matt Kubiak’s background is in social work and those with disability, so any future testimony of mental health effect and occurrence of behavior of Madeline Collins towards all 4 of the cited male incidents comes with awareness that 3 of the 4 all have valid mental health claims of hinderance and harm based on workplace conditions and would be considered expert of their profession and objective while citing their own experience of male biased patterned behavior of Madeline Collins and known reporting of 2 of the 4 on the matter while unknown to Claimant any reporting of Chase Davis or their own.

On page, 19 of Respondent, Claimant is well aware of prior people’s positions on definitions. “To plead a hostile work environment claim, Claimant must show, 1) T”HE”Y belong to a protected class; (2) he was subjected to unwelcome harassment, (3) the harassment was based on his membership of a protected group; (it was severe or pervasive enough to alter the terms and conditions of employment and create a hostile or abusive working environment; and 5 the employer is responsible for that environment under a theory of either vicarious or direct liability.”

Definition of the word hostile denotes the word as “Unfriendly, antagonistic” that does not preclude any notions of separation to report outside of “Self” and “Others” in definition. This is a claim of a hostile work environment in which discriminatory aspects of character trait can be ascertained to know a difference between claiming hostile work environments and those that are done so under the added value of making sure an individual identifier of past behavior can be applied to it in group defense of.

SCAD. Has in email form stated to claimant, it is absolutely OK to discriminate against others of the same class and identifiers. I disagree, but I am making sure a difference of opinion is on that as Discrimination is such and there are such things in the world as White on White Crime where even if a slur is uttered to someone of seemingly similar it would be considered to be discriminatory and a matter if the events were of each other knowing personally or professionally on the matter.

It is here, protected class established. Secondly of initial April 2021 reporting to HR and the subsequent Federal Compliance, the gender specific aspects of Madeline’s comments of “Penis” said in hostility is also in the surrounds of what entered into the workplace in which would be SCAD’s obligation to report and investigate, which did so under a 2 month timeframe of Federal Compliance, witness testimony and then non-reveal of any findings from such or reprieve of report, leaving Claimant in a state of “Breakdown” and then “carrying on in silence” on the matter with no resolve claims and basically, “Business as usual, anything else doesn’t involve you.” Being the sense of the end of 2-month investigation in which was compromised in confidentiality multiple times over by witnesses, supervisors and Human Resources. That is outlined in EEOC testimony where the original incident of suicide attempt in Feb. 2019, carry over into the institutional boundaries of college employment/student and left unresolved to this very day on the matter.

The behavior was noted. Outside approached Supervisor when seemingly of electronic advantage thought there was a “Let’s get him to attempt suicide again” feeling to the matter which continued post-employment, which makes any copyright aspects severely concerning in evidence discovery and possible subpoena of original Federal Compliance for some form of reprieve that should had occurred while employed.

Claimant has not abandoned their claims as Respondent has noted when discussing the 58 page Amended Complaint, (20 page, plus 38 of Evidence). Claimant apologizes for the length of this one, but it does expedite to the point moving forward it gets more and more precise while considering timeline of events since April 13, 2021.

What is curious to note is again the Job Abandonment of Duty of Madeline Collins on Feb. 10, 2022. Did she indirectly discriminate based on their past history with Chase Davis on Mental Health issues she had directly caused and exasperated, and then did the same with Claimant here where known since April 2021, and had full personal, and professional awareness of some aspects of the suicide attempt of 2019 pre-employment. Why she didn’t respond to text messages on date of “wrongful termination” is again biased to the female supervisor despite them failing to do their hired duties of Supervision and respond while reporting party filed incident report and was terminated because of it while they retained position at SCAD.

This would had been reviewed and discussed in an actual working federal compliance investigation, in which would had been considered of facts of claim and discrimination in awareness of disability, past patterns and willful intention to harm.

It is without a doubt from April 13th, 2021 SCAD and entities within attempted to escape liabilities and did so in manners that attacked protected class instead of preserve and protect it, despite the same supervisor responsible in part to another employee’s own mental break towards areas of self-harm and incarceration of which they at the time were sentenced to 5 years.

4.     Claimant Fails to State a Discriminatory Discharge Claim Based on His Unspecified Disability

Claimant provided background to SCAD and Federal Compliance in email and in Federal Compliance Investigation on the scope of their disability on April 13, 2021 and subsequent proceedings on the matter. Supervisor Madeline Collins and Manager Wanda Ward knew further of scope and damage of 2018—2019 workplace experience leading to suicide attempt and involuntary hospitalization before employment, and during the initial months of back to employment from “a mental breakdown” and “suicide attempt” and knew I was seeking treatment on the matter.

There are multiple instances in Federal Compliance and in HR meetings held with other supervisor employees in which this was known, looked at and considered during time of employment to the final day of such where Jonathan Goldstein’s failure to investigate properly a reporting party and continue to allow an employee in a heighten stressed and discriminatory-biased position is documented and in evidence of more than one occasion towards wrongful termination. Treatment aspects have been submitted in prior evidence and any aspects of what is not unspecified has been and could had been respected while claimant was a full-time employee while also a degree-seeking student toward master’s degree and priority to them along with stable employment in a “safe-space” of supervisors Claimant had known for 20 years to readjust to what occurred prior of prolonged aspects within a work environment.

There is the Workplace Break Law violations since around April 2021 and the severity of claims when similar patterns of Jan./Feb 2019 reappeared into a global institution of which is not the same as a regular place of business and under far more security and scrutiny to consider.

A request for full investigation of Federal Compliance from the April 2021 incident to ascertain what in part was already discussed in workplace either candidly and respect, chose aspects to stay away from certain topics with I, or the anger and hostility of Madeline Collins who may or may not of had awareness of what occurred, who came in and of knowing the severity and damage that others were attempting to do, had done and then spiraled towards end of employment on Feb. 10, 2022 to no subsequent reprieve during, despite report or afterwards by the College on the matter.

The damages there do go between civil and criminal, and the investigation is a remedy of which Claimant is professional enough to ascertain to determine scope of damage and motive on the matter. Since then, the transfer of my works have been of perpetual leave I in the dark despite side-by-side comparison on the copyright right and then the environment in which I was left in despite wish to remove from and be able to readjust and take care of myself from what did again become a silent breakdown after a year and half of healthy recovery from one prior and the creation of “Curated Jellyfish” during, before starting School and rebuilding for a Master’s degree in which at least Claimant could always be a teacher had nothing worked out corporately post-graduation. That was lost.

Claimant has written objectively the best they could of the events of 2018-2019 of the prior workplace environments and copyright protected them in expansion of their own EEOC testimony left unresolved which constitutes a degree of factuality and ownership of experience and perspective that goes beyond simple testimony that would had been attached to the name anyways in any legal proceedings. This is done so in their book, “Chasing Jabberwocks” which was manuscript on own accord and never on SCAD computers as something personally to overcome for themselves before finalizing and publishing in 2024.

The initial impact of recovery from a mental break down and suicide attempt is found at the forefront of Claimant’s work in “Curated Jellyfish” in which has repeatedly been cited in side-by-side comparison of copyright infringe by The Walt Disney Corporation during employment/education and in post, in which they have no deniability of awareness of what occurred of suicide attempt, knowing something happened and would have to read “Chasing Jabberwocks” to know exactly what occurred of first hand perspective leading to a suicide attempt.

In either of SCAD or outside entities who have financially benefitted from my works without monetary compensation to I, mental health and then personal strength to overcome landscape and perspective is all over those books of undeniable of question and proof.

It would be inexcusable of outside entity to allow that environment to spread into the everyday life, let alone throw in the face of the author creator that they are making money off their property and noting of landscapes prior of mental health impact towards suicide attempt, but then prolonging the exposure and expanding upon it with the possible likelihood that suicide attempt would occur again and theft of property would become unknown, swept under the rug, and life continued in patterned behavior within of either got away with attempted murder and grand art theft, but then also a false sense of privilege to continue those areas with others in which morality and law balances out eventually.

When it comes to abuse of SCAD resources, there does become a stopping point of shared evidence to a point of optics to work towards vs. continual and perpetual work against.

That evidence has already been submitted in testimony and evidence in which individual at-will choice of continuance is probably considered of personal liability against SCAD resource of reason in which is being reviewed of this arbitration and of Federal Judge, while should be reviewed internal of trustee and trust. That is more so an understanding towards HR where claimant was adamant of noting behaviors to escape liability and in similar pattern, paint a victim as a detriment to the college in discredit similar to Chase Davis, in which they are not, and in which claimant is, or was, a major asset to the college.

Claimant has already stated that multiple perspectives and evidence is required to prove discrimination. A singular claim of such would denote internal possible biased while considering of matters of self-protection and defense of what would be presumed discrimination by reporting party and then actions of defending party. Claimant can uphold and protect that they strongly understand the important of filing anything of complaint officially within the adult world. This was done so for the first time in 2019, with major implication of such on the matter before moving on with their life and then continuing their passions of art, expression in visual or literary in which life account is remembered and could be reflected upon at any time.

The events leading up to Claimant removing themselves from “Hostile Work Place” can be attributed to “Fight or Flight” that was documented and experienced in multiple people of a break down during a performance meeting that Claimant wasn’t even the problem to begin with as they were met with ganged-up hostility by 3 female managers and blamed for aspects in which Human Resources already had the evidence and choice to remove or prevent that meeting from ever occurring and chose not to.

There is no singular answer SCAD could provide of why leave myself in an environment, where in subsequent complaints I wrote compliance “I will prosecute to the full extent of the law.” And then in final in-person compliance meetings members of the prior workplace in Atlanta were spotted in Savannah, while at SCAD the confidential meeting was breached and was being discussed in the SCAD property floor above and cited during testimony of that occurring.”

As burden of reason rests with SCAD on the prolong of non-transfer/hire/raise are in consideration, it becomes inexcusable in the fact of what had already occurred to prior employee Chase Davis and myself in combination as procedures should had and would had changed, which makes all the more detrimental and failure of internals to have Human Resources Director of confidence from day one, dismiss mental health in email form as if it was casual to consider the lack of duty and responsibility to protect employee or student and I both on that.

SCAD would have the burden of proof against them of all Compliance Claims and investigations which are 3rd party held along with note of longevity of investigations, seriousness and how the same discount spread by Jonathan Goldstein of 2nd and 3rd hand and the discriminatory aspects of Madeline Collins’ 2nd hand factors to 3rds, especially when they had known liability since April 2021 on either side of those named.

Claimant finds this dismissal of unawareness to be false and a compounded problem for SCAD in liability and negligent in context of Apples-to-Apples comparison of report involving the same supervisor in both male discrimination and moving forward mental health discrimination based on their own prior past experience and liabilities towards end of employment, despite 20 years connected and stated in initial complaint.

Claimant did not respond to text messages on day of “wrongful termination” with falls under their own possible mental health disability discrimination of their own experience and negligent of the college to allow similar instances to occur with multiple male entities in document.

5.Claimant Fails to Accommodate Claim Should be Dismissed as suck Claim is Time-Barred and Fails as matter of law.

Claimant’s Accommodation is at the fore-front of what would be trial or private arbitration. It is required for ascertain of multiple ADA violations and is not time barred in any aspect, as SCAD had all the time while Claimant was employed to take any report of an employee or student serious, especially in consideration of life, the maintain of it, as something more than qualified in transfer instead of what was documented in EEOC investigations and testimony.

The only thing that Fails as matter of law, was SCAD’s requirement to take seriously and remedy then and remedy now. Claimant has meet all time requirements on the matter.

As SCAD was made aware of mental health aspects prior of severity at time of April 13, 2021 letter to Human Resources, and repeatedly shared with Supervisors, Superiors, Federal Compliance officers and Human Resources in utmost confidentiality towards time of wrongful termination, their dismissive of mental health claims is compounded of not only Claimant’s experience, but 2 others (male) and 1 that suffered their own damages from dismissals and failure to adapt based on cited experience with the college and future employee/students.

II.Response to Claimant’s Failure to Accommodate Claim Fails Because Requested Accomodation was not reasonable under the ADA.

It will be remembered of statement of Jonathan Goldstein upon one of the several times for request of transfer, interview or be removed that Claimant was told “We can’t just put you anywhere.” Despite resume being provided and then subsequent interviews for Manager position of the Café, which at least would had alleviated salary towards non-compensated work absorption anyways, prospect for Photographer of SCAD at events, Art Director Position in their Graphic Design Department and then subsequently the SCADpro Director/SCAD artsales Director position, facilitate by the president of the college while events were proceeding at Art’s Café and HR in constant detriment to self and school.

Hiring and Relocation is done so through Human Resources to allege willfulness in failure to Advance and ignoring of ADA requests in which Claimant was qualified for multiple positions and wished to remain at SCAD to complete their masters study while being full-time hourly status employee.

Lack of Accommodation and Transfer comes under the direct questioning of procedures, actions documented and motive of Jonathan Goldstein, Director of Employee Success at SCAD. Jonathan Goldstein, of their own liability refused to remove employee/student from a well-documented landscape with evidence of incidents of reported Supervisor in apples-to-apples of class and status in which Claimant had not ever worked with and was made aware of events during employment of what occurred.

SCAD had all the resources and capabilities to take any claim serious on the matter and acted in total disregard during employment, and in awareness of full evidence to SCAD in-house lawyer and Paula Wallace in EEOC oversight by end of EEOC proceedings, and then onto Superior Court and Arbitration proceedings.

Those complaints were protected by Federal Compliance and by being a reporting party of the school in good-faith of misconduct, illegality in which was harmed multiple times during employment and post on the matter.

According to SCAD handbook, this is against procedure.

803: Open Door Policy

The university is committed to encouraging an open

and frank atmosphere in which an employee can bring

employment problems, complaints, suggestions or

questions to the university.

An employee is encouraged to first discuss

the problem, concern or disagreement with his

or her supervisor. If this cannot resolve the issue,

the employee is encouraged to submit his or her

concerns to the next level of management. An open

door policy means that an employee may discuss his

or her issues and concerns with human resources,

the compliance officer, the Title IX coordinator or

ombudsman, who will listen to the concerns and

make a recommendation for resolution.

As Incidents were report to Compliance multiple times of actions and patterns of SCAD employees/staff leading to the wrongful termination date. Federal Compliance closed out Investigative procedures on Feb. 10, 2022 (day of incident) and the following date of reporting incident and termination that occurred on such saying their investigation was complete.

As the “wrongful termination” is ascertained as Human Resources interacted with Federal Compliance with dismissals of claims and without investigation, done so biasedly of their own liability, SCAD and their own governance failed in interaction and failure to provide in this case proper investigative means of once originally took months and interviews to do, to damages of not only lost employment of a reporting party, but education suspended the same day, which should had been unrelated. As SCAD has not and chooses not to go into investigative aspects that could be presented evidence and due process on the matter, they cannot disprove their liability already proven.

Complainant does not know the exact amount of damage from prolonged exposure to an environment in which they reported in April 13, 2021, confidentiality of investigation was breached with known effect on mental health and then continued patterns of which Supervisor knew of mental health effect, continued to act detrimentally in full awareness of their own liabilities as well as handling Human Resource Officer with multiple cited incidents of “failure to advance, move or resolve matters of environment required of stability and pacification based on past employment experience of work-place leading to suicide attempt and 11 days involuntary care and active treatment of from the start of insurance with The Savannah College of Art and Design). The disregard of Human Resources on valid claims in email form was in awareness of Federal Compliance officer who chose to close the case on a reporting party of incident on the matter, knowing in prior complaints the landscape can be looked at between initial complaint and final date of Feb. 10, 2022 of 10 months of unresolved, dismissed and discounted besides best efforts of Claimant to report, request and continue on with their education and employment concurrently.

Claimant would ask the judge and Respondent, as well as the potential jury to consider the awareness of affordance of all evidence at the end of EEOC proceedings of SCAD and then in continued good faith of position before Superior Court filings on December 27, 2022 to current date of time of this submit of August 2, 2024 with Respondent’s full awareness of effect on mental health during employment and post in complaint and continued attack on in non-mutualness and same pattern of dismissal of valid claims.

CLAIMANT’s INITIAL COMPLAINT AND DATE NOTED OF TIME SPENT SINCE

Here I am back to original complaint.

Although Claimant’s Motions are extensively long, they are still conservative in the long-run of trial to consider in fairness of what is morality and

G. Calculations of Pro Se Legal Fees

As claimant was forced into Pro Se matters of civil litigation due to landscape and electronic attacks provable of copyright materials, evidence and witness intimidation, Claimant is calculating legal cost of time based on Averages in the State of Georgia based on billable hours.

According to Clio.com[5], the average billable cost of attorney on Civil Litigation comes to $352 dollars per hour. As there is no separation of time between client and claimant, there is 24 hour weight and availability on the matter of which they have discussed in a timely manner proven of law and landscape between EEOC, BBB, Superior Court of Chatham County and JAMS arbitration that the hours to date on the matter of August 2, 2024 comes to 21,696 hours since date of “wrongful termination”. That amount comes to $7,636,992

Claimant request Summary Judgement without prejudice on the matter as SCAD has failed to arbitrate in both discovery and witness testimony at this point of 904 days since Feb. 10, 2022 of wrongful termination of a protected employee, done so with prejudice and awareness of their own liabilities.

Questions of the matter of copyright legal fees present themselves of consideration of same appliable timeframe or when evidence became aware to Claimant of possible copyright violations by entity and submitted to the court in compound of federally protected landscape of “no retaliation” during complaint and report, especially when in legal matters of State Superior Court in duration. That average is $369 dollars per hour which comes to $8,005,824. Claimant is flexible of timeframe on the matter to either the time of begin of BBB complaint in which copyright is discussed, the beginning of creation of “No ‘Starving Artist’s” or the date of submit of copyright protect of preparation of copyright law landscape or time, date of evidence submitted of awareness of probable infringement by SCAD post education/employment and time of complaint on Student Catalog for 2023-2024, or the date of submit official on the matter within Superior Court in 2023.

The difficulty of Respondent keeping claimant in extended periods of time under duress, disadvantage and in bad-faith of discussion procedures required of arbitration should be taken into consideration against their own legal fees in which can be quantifiable and billable. SCAD acted willfully to prolong any matter while employed and post to non-resolve where their full request to dismiss is indicative of their patterned behavior how they operated during employment in which they were required to stop-gap, resolve and remedy and chose not to. As continual dismissals occurred, the landscape compounded and Claimant had to resort to “acting law novice” as civil rights were violated during employment and post.

Possible Request of Remedy of fair market median value in the state of Georgia comes to $15,642,816 in applicable legal investment. Law school figures could be taken in account here of real-world application of over 2 years of internship on the matter, but the professional stance of same market application remains of professional median, while making a point.

CONCLUSION

It is understood this is private arbitration proceedings, where in awareness of landscape, there is no freedom of the press during this, as it invites morality, ethics and equal protection according to the law on the matter of privacy, privacy laws and how that is applicable collectively and in areas of profession and possible exploit or preserve and protect in according to the 14th Amendment.

Questions of the prolong of proceedings original to where they are now are in consideration of 3rd party judge as well as outside legal council. Inclinations do lead to Obstruction of Justice several road stops over on this life path, while others may consider vanity of the matter of which best to partner with than be on the wrong side of the looking glass in observation of microscope.

The question of life’s invest, the college investment and then intellectual property protect is present in what is binding agreements in some places, the workplace and college being one of them vowed of which to “safe campus” and that being strongly suggested of mental health and equal protection based on protected class, while noting students are of a different level of added protection from employees/faculty/staff for a variance of reasons which were brought up in caution to SCAD in-house legal council multiple times between EEOC and BBB proceedings before Superior Court kicked off awareness to the Human Resources department that did not participate directly in prior proceedings, would be of SCAD in-house council and president the level of awareness they did had, and then the failures of their own department laid out between Superior Court and Private Arbitration of perjury, wrong dates to escape liabilities while drawing attention to days to justify copyright theft and escape liabilities to claimant, state of Georgia and Federally, well before any possible International Questions that may come from this now private arbitration.

It is noted in 2019 copyright protect and prior towards it, then when stating anything of weighed value in which has impact of life and structure, it is important to do so objectively to the best of one’s ability, as the emotion-based action/reactions/terminology or justifications are taken into considerance towards ascertain objectively. Discrimination by definition is an attack on differences based on protected individuality identifiers, where even as children we learn our differences protected or not in schoolyards and systems before relearning the similarities present prior to separations and based on morality and ethics. To discuss discrimination is noted of something of self needing protection and a long-history behind it to denote that there is a community that can uphold one way or another from like experience. From differences discussed comes the similarities not bound to any one identifier, but universal to consider. As one race can be of any minority at one point, that is environmental in which can be gauged of variable and equality present to look past that in any workplace situation.

The same applies to sex, where that too is a matter of understanding females may have had their history prior of discount, hard roads or battles of suggested call-out that invites future discrimination of opposite male based on their compounded life, regardless of the advance of society on equal protections noting anyone strife and perseverance from it. That would be a matter of how things are reflected upon, called out or looked upon where I understand my own small part in areas towards equality denotes understanding we living in a world very quickly changing in landscape due to the invite of the internet to understand and connect. This is seen in many landscapes and generations now living in a far more aware society than the struggles that came before noting people’s memories and what they do with it is their business to consider of personal or professional choice, in which I am strongly documented and grounded on in the matter as it does build to rabbit-holes of controlled thoughts and actions.

One of my favorite quotes still is telling an Ex before I hit 30, that we need to “be mindful of the memory of one another as we are going to be with each other the rest of our lives within our minds”. That holds true and engrained some 13 years established towards proven scientifically, emotionally and professionally of expect testimony of my life’s investment on the matter.

It would be noted in Paula Wallace’s own book “Lessons in Life” and her social media posts in which there is apparent recollection and call-out of men prior in her own start-up and recollection of it post success. A fondness present there of understanding there was not many, if any female, examples that I have seen to denote in fairness that landscapes have changed and I have in adult never participated or been of environment of gender biased male prior, which can most certainly be attested to 3 years working for an International Bridal Company Corporately on the matter. Objectively, the male persecution can be present in example of anyone based on their life experience and is also noted of generations adult that grew up in the 50s and 60s and yet society moved on and so have them. A great point of example would be former President Barack Obama, signaling in marriage equality of the LGBTQIA+ community, and being pre-empted by Joseph Biden on the matter. The evolve notions of community and understand come hand and hand with the internet where we are collectively learning empathy and affordance at a far greater pace than prior of worlds of corded telephone and home being very closed doors to perspective outside the television, radio and editorial prints of daily, weekly or monthly.

In any identifier is a matter of self-protection, there is a big difference of those of repeat pattern in which story builds and is told. This is understood greatly in the “WOKE” aspects of this time as well as “Cancel Culture” where education of history collectively and of self is required to be as objective as possible on the matters of heart and of great importance.

That objectivity rests here on the discrimination side and is ever so more present on the copyright side, noting in examples as old as the Bible of the understanding the influence of money on society and seeing where that has gone into the internet age of capabilities to be all the more objective and protective of any case of matter to look at in investigate, and obligated to never dismiss in certain areas, such as this one, according to The Savannah College of Art & Design handbook.

For the reason of testimony above based on morality, true prior combined of no perjury, Claimant respectfully requests this Arbitrator not discount one bit of claim in which SCAD has left Claimant in vulnerable for 1206 days and at the comprehension of total loss of their assets in which are protected by copyright 70-95 years past my death in which full claim of copyright infringement can be made at any time of landscape set and known while reporting all incidents in good faith to SCAD and self since April 13, 2021.  

Claimant has been left at a detriment of which they are not a lawyer, and the damages are extensive to which Claimant have been alone this entire time on while events at SCAD and partners may see the difference of non-resolve and resolve when it comes what anyone could afford of compassion, consideration and upholding the land or institution that pays salary anyways from the global nest eggs of future generations of copyright holders and investors.

Claimant is unable to account for emotional distress or the entire scope of compound matter in which SCAD has left Claimant vulnerable to while initial it is proven of their federal violations against Claimant and past employees in Supervisor capacity.

Claimant has to the best of the ability gone above and beyond in what is combined testimony and beginning aspects of scope of tangible damages that can be reconciled in accordance to law in arbitration or jury trial.

No matter what claims here are provided of damages, outside the bar of prior notion of median salary or highest stakeholder salary to consider if Respondent infringed upon the Claimant during complaint for the benefit of the institution while claimant in detriment, the grand told is perhaps not even a QI or at most Q2 equivalent to a single year’s salary of presidential pay which accounts for 3-6 months budget already accounted for tops.

Claimant is attempted to stop gap of continued patterns of determinantal harm to claimant provable and against Title VI and Title VII claims. It was SCAD’s failure of procedure follow at the heart of the matter of self-preserve of entities in supervisory or liable prevent positions in which SCAD’s self interest has been acted on by those against one of good faith and protection once doing so.

At the very least, moving forward the word “Dismissed” is addressed as something not legally advisable of mandatory protocol to curb liability in case of arbitration or lawsuit, in which SCAD has failed to provide in evidence.

Respectfully submitted,

Dated:

Aug. 2, 2024

Electronic Sign – Philip Arthur Bonneau

Name:

Philip Arthur Bonneau

Title:

Self-Represented, Former Student, Former Employee, Alumni

Address:

2309 New York Ave.

Address:

City, State, Zip:

     Savannah, GA 31404

Phone:

     404-786-6261

Fax:

E-Mail:

     philip@philipbonneau.com

Attorney No.:

     Self-Represented

[1]In-House Quarterly Defense Summer 2014 pages 30-35

://www.pecklaw.com/wp-content/uploads/2022/05/The_Evidentiary_Impact_of_EEOC_Reasonable_Clause_Determinations-1-3.pdf, 2014 Accessed July 31, 2024

[2] https://www.scad.edu/academics/programs?location=all&program=all&school=all

[3] https://www.thebowmanlawoffice.com/services-provided/employer-services/georgia-is-an-at-will-state/ Accessed July 31, 2024

[4] I can see why they keep me in this. There are very good stances here of future application of landmark on matters, and yet a move towards mutualness and resolve of prior issues is the point of matter of owned perspective of Citizen “Claimant”.

[5] https://www.clio.com/resources/legal-trends/compare-lawyer-rates/ga/#:~:text=rates%20in%20Georgia.-,Hourly%20rates%20in%20Georgia,with%20the%20average%20being%20%24286.

1

JAMS ARBITRATION PHILIP BONNEAU

Claimant,

v.

THE SAVANNAH COLLEGE OF ART & DESIGN, INC.,

Respondent.

JAMS REF NO. 5440001247

You could not sue if me if wanted to.

You would have to adhere to the SCAD handbook of private arbitration in which I argued of unconstitutional anyways.