Plaintiff filed suit against the U.S. Department of Homeland Security alleging disability discrimination, hostile work environment, and retaliation. This is Plaintiff's third attempt to file suit before the Court.  Plaintiff has revised his Complaint each time in an effort to satisfy pleading requirements.  Plaintiff's most recent Complaint claims he was employed by the Defendant as a Transportation Security Officer at Palm Beach International Airport in West Palm Beach, Florida.  Plaintiff alleges he notified his supervisors of his disability, specifically ADHD, and requested an accommodation after he experienced adverse symptoms when utilizing a new procedural technique.  Plaintiff claims he made several requests for accommodation and notified several supervisors of the issue.  Plaintiff maintains he was not accommodated and rather was given a "Letter of Counseling." Plaintiff claims several members of management intentionally humiliated him when he was attempting to comply with the new policy, and as a result, Plaintiff alleges he was working in hostile work environment.  Plaintiff maintains that he was constructively terminated as a result of his disability and request for an accommodation. 

Plaintiff's Complaint is not lacking in factual allegations; however, the Complaint is oddly drafted, repetitive, and confusing.  Plaintiff paid the filing fee in full and is in the process of attempting to serve Defendant.  However, Defendant has not been served with process to date.  Plaintiff must serve Defendant by January 8, 2020. If interested, please email FLSD_ProBono@flsd.uscourts.gov