Overview
Complainant: Stacie Powers, former CASP employee/contractor.
Respondent: Class-Act Security Protection & Training Academy Inc. ("CASP"), Lawrenceville, GA. Proprietor: Wanda Turner.
Representation: Paul Lipscomb & Phillip Gebauer (business consultants) with employment counsel Job J. Milfort, Esq.
Each allegation below shows:
- Summary — plain-language paraphrase of what it means
- Her Exact Words — verbatim from the amended charge (Roman numeral matches the source document); where the original charge (signed 5/20/2025) makes the same underlying claim, its exact words are also shown, in gold
- CASP Response, Evidence to Look For, and Linked Evidence — left blank, to be filled in as the investigation/analysis continues
This is a working document. As documents, photos, and scans are added to the documents/ folder, they'll be linked into the relevant allegation below.
Source Documents
Original Charge
Signed May 20, 2025
- Bases: Retaliation, Sex, Age (ADEA)
- Alleged date: 3/28/2025 only
- Termination reason given: "fraternizing"
Amended Charge
Executed June 27, 2025
- Bases: Sex, Retaliation, Harassment (sex) — age dropped
- Alleged date range: 12/2023–3/28/2025
- Termination reason alleged: threesome refusal / false theft report
CASP Internal Investigation Report
Exhibits A–H, prepared for Job J. Milfort, Esq. — 130 pages
Background check, Point Blank corporate records, staged-incident evidence, termination transcript, arrest/booking records, and employee interviews (Brandon Turner, Bryant Hendrix, Shawn Owens, Ralph Jerry Vaughn III, Kamika Williams).
Discrepancies: Original vs. Amended Charge
About 5 weeks separate the two filings. In that window the narrative grew substantially in length and severity, while the age-discrimination claim was dropped entirely.
- Hire date: 8/21/2023 → 8/27/2023
- Starting title: "HR Director" from day one → started as "HR Administrator," worked up through several titles
- Eddie Cousin's title: "Chief" (surname "Cousins") → "Chief Financial Officer" (surname "Cousin")
- Age discrimination (ADEA): explicitly alleged in the original → dropped entirely, not checked in the amended charge
- Date range: single day (3/28/25) → 15-month period (12/2023–3/28/25)
- Narrative scope: one core incident → an entire year-long escalation with many new specific incidents not in the original
- Threesome demand timing: immediately after reporting harassment (original) → dated 3/9/2025, just before termination (amended)
- Termination reason: "fraternizing" (original) → threesome refusal + false theft accusation (amended) — mentioned nowhere in the other
- Not in the original at all: Epiphany Wade, birthday dinner, office cameras, Atlanta dispatch scheme, Goodwill/Stone Mountain arrangement, promotion to Captain, "I love and adore you" text, "stand down" instruction, check-theft accusation, destroyed workspace, Brandon Turner's visit, arrest/jail/recording
- Employer info: name, phone number, and employee-count range all differ between filings
- Marital title: "Mrs." → "Ms."
Allegations (Amended Charge — operative document)
I.
SummaryIntroductory paragraph: states her employment dates, names Cousin (CFO) and Turner as harassers, and frames the retaliation (theft accusation + termination) and the three legal theories she's pursuing.
Her Exact Words
Original Charge — EEOC Charge No. 410-2025-07023, signed 5/20/2025"In December 2023, Eddie Cousins, Chief, began subjecting me to ongoing sexual harassment. Wanda Turner, Owner (63), who is Mr. Cousins girlfriend also engaged in the sexual harassment."
Amended Charge — EEOC Charge No. 410-2025-07023, executed 6/27/2025"My name is Stacie Powers. I was employed by Respondent Class-Act Security Protection & Training Academy Inc. (“Respondent”) from on or about August 27, 2023 until March 28, 2025. Beginning in approximately December 2023, Respondent’s Chief Financial Officer, Chief Eddie Cousin, began subjecting me to severe and pervasive sexual harassment. Respondent’s Owner, Chief Wanda Turner, who is Chief Cousin’s girlfriend, also subjected me to sexual harassment. When I began opposing the sexual harassment, Respondent retaliated against me, including by, among several things, accusing me of theft and terminating my employment. Respondent has violated Title VII of the Civil Rights Act of 1964 (“Title VII”) by subjecting me to a hostile work environment based on my sex, quid pro quo sexual harassment, and retaliating against me for engaging in protected activity."
Evidence to Look For
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CASP Response—
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II.
SummaryDescribes her job history/role progression across both admin and operations sides of the company, and claims she was consistently a top performer.
Her Exact Words
Original Charge — EEOC Charge No. 410-2025-07023, signed 5/20/2025"I was hired by the above-named employer on August 21, 2023, as Human Resources Director." (Note: hire date and starting title both differ from the amended charge's account.)
Amended Charge — EEOC Charge No. 410-2025-07023, executed 6/27/2025"I was employed by Respondent from on or about August 27, 2023 until March 28, 2025. I started working for Respondent as a Human Resources Administrator. I reported to Respondent’s Owner, Chief Wanda Turner. Respondent’s business operations consisted of two primary areas: administrative and operations. Throughout my employment with Respondent, I held positions in both areas. I worked as an HR Administrator, HR Manager, HR Director, Office Manager, Accounts Payable and Accounts Receivable, and Dispatcher. I additionally held the positions of Officer, Lieutenant, and Captain. I consistently ranked among Respondent’s highest performers. Additional duties I performed while employed included making check deliveries, visiting client sites with officers, and taking meetings, calls, and working dispatch duties on weekends and after hours."
Evidence to Look For
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III.
SummaryAlleges Cousin began sexual advances/comments the day of her promotion to HR Manager, plus a threat to have her fired if she wasn't "his friend."
Her Exact WordsEEOC Charge No. 410-2025-07023 — Amended Charge, executed 6/27/2025"Chief Turner and Respondent’s Chief Financial Officer, Chief Eddie Cousin, were engaged in a romantic relationship. On or about December 14, 2023, Respondent promoted me from an HR Administrator to HR Manager. That same day, Chief Cousin began making sexual advances towards me. Specifically, Chief Cousin (1) began telling me that I was beautiful, (2) stated that I had a “nice rack,” and (3) claimed that I was “his.” I was uncomfortable by his sexual advances. Chief Cousin stated to me “if you don’t want to be my friend, I will tell her [Chief Turner] to fire you,” or words to that effect."
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IV.
SummaryAlleges a prior harassment complaint by her assistant, Epiphany Wade, was met with termination instead of investigation.
Her Exact WordsEEOC Charge No. 410-2025-07023 — Amended Charge, executed 6/27/2025"The following week, in approximately December 2023, I learned that my then-assistant, Epiphany Wade, reported to Chief Turner that she was being sexually harassed by Chief Cousin. Instead of investigating those claims, Chief Turner fired Ms. Wade."
Evidence to Look For
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V.
SummaryAlleges ongoing harassment including being told she was being watched via office cameras.
Her Exact WordsEEOC Charge No. 410-2025-07023 — Amended Charge, executed 6/27/2025"The sexually harassing comments and behavior continued from approximately December 2023 until April 2024. During this time period, on several occasions, Chief Cousin called me while I was in the office and informed me that he was watching me on the cameras in the office."
Evidence to Look For
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VI.
SummaryAlleges an invitation back to his house after a birthday dinner (other employees present), which she declined.
Her Exact WordsEEOC Charge No. 410-2025-07023 — Amended Charge, executed 6/27/2025"On or about April 22, 2024, following Chief Cousin’s birthday dinner, where several other employees were in attendance, Chief Cousin asked me to come back to his house, stating that he wanted me to “do more work.” I declined."
Evidence to Look For
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VII.
SummaryAlleges a work-pretext visit to his house that turned into a job-security-linked demand for oral sex.
Her Exact Words
Original Charge — EEOC Charge No. 410-2025-07023, signed 5/20/2025"Specifically, I was asked to drop off work uniforms to Mr. Cousins house. When I arrived, Mr. Cousins inappropriately hugged me, and threatened to end my employment if I did not have sex with him."
Amended Charge — EEOC Charge No. 410-2025-07023, executed 6/27/2025"In approximately early May 2024, Chief Cousin instructed me to drop off work uniforms and pick up an officer’s jacket from his house. Chief Cousin told me that Chief Turner could not know that I had his home address. Upon my arrival, Chief Cousin wanted me to tour his house and told me that my job was “safe with him” but stated that he wanted to see my “loyalty to him,” or words to that effect. Chief Cousin then stated that there was “something that he liked” and that he “needed me to do the thing he liked” suggesting I perform oral sex."
Evidence to Look For
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VIII.
SummaryStates she felt forced into sexual activity to keep her job, and that her job duties became centered on Cousin's demands afterward.
Her Exact Words
Original Charge — EEOC Charge No. 410-2025-07023, signed 5/20/2025"Although, I eventually engaged in the sexual acts, I repeatedly made it clear that I was uncomfortable and did not want to do it."
Amended Charge — EEOC Charge No. 410-2025-07023, executed 6/27/2025"I felt I had no choice but to engage in sexual activities with Chief Cousin to keep my job. Following this, Chief Cousin began frequently calling and texting me and regularly requesting to see me. The vast majority of my job duties began orbiting around Chief Cousin’s needs and I was unable to perform my regular job duties."
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IX.
SummaryAlleges Cousin had himself dispatched to Atlanta unusually often, a deviation from normal dispatch procedure.
Her Exact WordsEEOC Charge No. 410-2025-07023 — Amended Charge, executed 6/27/2025"In approximately June 2024, Chief Cousin instructed me and Director, Shawn Owens to dispatch him to Atlanta as much as possible for jobs. This was a change in our standard procedure, as Chief Cousin was typically only dispatched during significant, high-level situations because he lived approximately two hours away, in Bartow, Georgia."
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X.
SummaryAlleges recurring coerced meetups at a Goodwill parking lot leading to sexual acts at his home, continuing about a year.
Her Exact WordsEEOC Charge No. 410-2025-07023 — Amended Charge, executed 6/27/2025"Because we were instructed to dispatch Chief Cousin to Atlanta more frequently, whenever he was in the city, he requested to see me. I was not allowed to decline his requests. Specifically, when Chief Cousin’s was dispatched to Atlanta, he instructed me to meet him in a Goodwill parking lot in Stone Mountain, Georgia. He then required that I leave my car in the parking lot and transported me to his nearby Stone Mountain home. This soon became a regular occurrence, with Chief Cousin’s luring me with work-related requests or tasks before engaging in sexual acts and requiring that I stay at his home on the weekends. This continued for approximately one year."
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XI.
SummaryExplains her fear of retaliation (citing Wade and Turner's sister as prior examples) and describes Cousin becoming controlling/possessive.
Her Exact WordsEEOC Charge No. 410-2025-07023 — Amended Charge, executed 6/27/2025"Because I feared retaliation, and witnessed Respondent terminate employees who complained about Chief Cousin’s sexually harassing behavior in the past, including Ms. Wade and Chief Turner’s sister who was employed as a Seargent, I felt I had no choice but to comply. Chief Cousin soon became controlling and did not want me to interact with any other men or have any male friends."
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XII.
SummaryStates her promotion date, from Lieutenant to Captain.
Her Exact WordsEEOC Charge No. 410-2025-07023 — Amended Charge, executed 6/27/2025"On or about March 2, 2025, Respondent promoted me from Lieutenant to Captain."
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XIII.
SummaryAlleges a romantic text from Cousin, and that Turner, upon seeing it, told her to stand down from her Goodwill duties.
Her Exact WordsEEOC Charge No. 410-2025-07023 — Amended Charge, executed 6/27/2025"On that same day, Chief Cousin sent me a text message saying he loved and adored me and that I was “the one” for him. On or about March 6, 2025, Chief Turner saw the text message Chief Cousin sent to me and instructed me to “stand down” from my job duties at the Goodwill location where I was working."
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XIV.
SummaryStates she tried to resign by phone but was told by Cousin that she could not.
Her Exact WordsEEOC Charge No. 410-2025-07023 — Amended Charge, executed 6/27/2025"Later on that same day, I called Chief Turner several times to inform her of my intent to resign, but she did not answer. I then called Chief Cousin to inform him of the same and he told me that I could not resign."
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XV.
SummaryAlleges Turner proposed a three-way relationship/"threesome," which she refused.
Her Exact Words
Original Charge — EEOC Charge No. 410-2025-07023, signed 5/20/2025"I reported the incident to Ms. Turner, and she told me that I needed to do whatever Mr. Cousins wanted. Furthermore, Ms. Turner insisted that I engage in a threesome with her and Mr. Cousins." (Note: in the original, this follows immediately after the single uniform-drop-off incident, with no date given; the amended charge places it on 3/9/2025, over a year later.)
Amended Charge — EEOC Charge No. 410-2025-07023, executed 6/27/2025"On or about March 9, 2025, Chief Turner informed me that she wanted to make a relationship between me, herself, and Chief Cousin “work.” She stated that I needed to do whatever Chief Cousin wanted and further informed me that she was willing to do whatever to make him happy. Chief Turner then proposed that the three of us engage in a “threesome” because that was what Chief Cousin wanted. However, I informed Chief Turner that I refused to participate in the relationship."
Evidence to Look For
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XVI.
SummaryAlleges Turner threatened termination directly over her refusal to participate.
Her Exact Words
Original Charge — EEOC Charge No. 410-2025-07023, signed 5/20/2025"Mr. Cousins and Ms. Turner continued to threaten my employment if I refused to engage in the sexual acts." ... "No reason was given for the sexual harassment. In fact, Ms. Turner told me that she was the owner, and she could do what she wanted."
Amended Charge — EEOC Charge No. 410-2025-07023, executed 6/27/2025"Chief Turner then told me that if I didn’t want to be in a relationship with them, then Respondent was terminating my employment. When I opposed the retaliatory termination, Chief Turner stated, “I’m the owner and I can do whatever I want,” or words to that effect."
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XVII.
SummaryStates she asked for time to think, intending to use it to find a new job rather than actually comply.
Her Exact WordsEEOC Charge No. 410-2025-07023 — Amended Charge, executed 6/27/2025"I asked Chief Turner for some time to think about her proposal. I did not intend to participate in the relationship but hoped this would allow me time to find new employment."
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XVIII.
SummaryAlleges a check-theft accusation tied to a termination threat, which was disproven when the check turned up in the mailbox.
Her Exact WordsEEOC Charge No. 410-2025-07023 — Amended Charge, executed 6/27/2025"On that same day, Chief Turner called me and accused me of stealing a check from the office and told me that she was terminating my employment. I informed Chief Turner that I had not stolen the check and suggested she check the office’s mailbox, where she in fact found the check."
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XIX.
SummaryAlleges her workspace was destroyed.
Her Exact WordsEEOC Charge No. 410-2025-07023 — Amended Charge, executed 6/27/2025"When I arrived at the office on or about March 10, 2025, Chief Turner had destroyed the area where I worked, including tearing down items from the walls, and trashing the personal items on my desk."
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XX.
SummaryAlleges repeated follow-up calls from Turner over the following days.
Her Exact WordsEEOC Charge No. 410-2025-07023 — Amended Charge, executed 6/27/2025"Over the course of the next few days, Chief Turner persistently called me, inquiring about my decision."
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XXI.
SummaryAlleges Turner deliberately sent her son to the office on 3/20/25 to intimidate her, despite him having no legitimate reason to be there.
Her Exact WordsEEOC Charge No. 410-2025-07023 — Amended Charge, executed 6/27/2025"On or about March 20, 2025, Chief Turner sent her son, Brandon Turner, who himself had been terminated in approximately November 2024 for alleged sexual misconduct, to the office. Brandon Turner had no legitimate reason to be in the office, however I believe Chief Turner sent him to the office to intimidate me."
Evidence to Look For
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XXII.
SummaryAlleges the termination, a false police report of theft, and that all resulting charges were eventually dropped.
Her Exact Words
Original Charge — EEOC Charge No. 410-2025-07023, signed 5/20/2025"On March 28, 2025, I was discharged." ... "I was told that I was discharged for fraternizing." (Note: the original gives "fraternizing" as the stated reason and never mentions a theft report, arrest, jail, or the charges being dropped.)
Amended Charge — EEOC Charge No. 410-2025-07023, executed 6/27/2025"On or about March 28, 2025, I informed Chief Turner that I did not intend to participate in the threesome. Chief Turner then terminated my employment and called the police, falsely reporting that I stole money from the company. When the police arrived, Chief Turner recorded the arrest while laughing. I spent the weekend in jail and all charges against me were eventually dropped."
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XXIII.
SummaryLegal conclusion — asserts the three Title VII claims: hostile work environment, quid pro quo harassment, and retaliation.
Her Exact Words
Original Charge — EEOC Charge No. 410-2025-07023, signed 5/20/2025"I believe that I have been discriminated against because of my sex (female), in violation of Title VII of the Civil Rights Act of 1964 as amended (Title VII), my age (48), in violation of the Age Discrimination in Employment Act of 1967, as amended (ADEA), and subjected to retaliation for engaging in protected activity, in violation of the Title VII and ADEA." (Note: the original also asserted an age discrimination/ADEA claim, dropped entirely in the amended charge.)
Amended Charge — EEOC Charge No. 410-2025-07023, executed 6/27/2025"Respondent has violated Title VII of the Civil Rights Act of 1964 (“Title VII”) by subjecting me to a hostile work environment based on my sex, quid pro quo sexual harassment, and retaliating against me for engaging in protected activity."
Evidence to Look For
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Legal Notes
"Sex" as the Title VII basis
Checking "Sex" as the discrimination basis is not a mismatch for a sexual-harassment claim — quid pro quo harassment and hostile-work-environment claims based on unwanted sexual conduct ARE forms of sex discrimination under Title VII (settled since Meritor Savings Bank v. Vinson, 1986). Her charge language is, if anything, a strong version of quid pro quo — explicit job-threat conditioning appears twice (III, XVI).
The one theory that could realistically apply here is the "personal relationship" defense — that conduct arising from a genuinely mutual relationship, rather than one-sided coercion, doesn't meet the "because of sex" standard. It's a difficult defense to win once explicit job-conditioning language is in the record, and is a legal-strategy call for counsel (Job Milfort), not a factual one.