Warren Riley Lawsuit

Case 2:18-cv-14138-JCZ-JVM Document 1 Filed 12/21/18 Page 1 of 23
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
WARREN RILEY * CIVIL ACTION

*
VERSUS *
* NO.:
LATOYA CANTRELL, individually *
and in her official capacity as Mayor of *
the City of New Orleans and * SECTION:
THE CITY OF NEW ORLEANS *
* MAGISTRATE:
*************************
ORIGINAL COMPLAINT
1.
STATEMENT OF JURISDICTION
This Honorable Court also has jurisdiction over this matter pursuant to 28 U.S.C. § 1332, as
the citizenship of the parties hereto is diverse and the amount in controversy exceeds $75,000.00,
exclusive of interest and costs. More particularly, at all times relevant hereto, Petitioner, Warren
Riley, was a resident and domiciliary of the State of Georgia and Defendants, LaToya Cantrell and
The City of New Orleans, are citizens and domiciliaries of the Parish of Orleans, State of Louisiana.
Page 1 of 22
2.
PARTIES
The Petitioner in this cause of action is as follows:
A. WARREN RILEY (Periodically referred to herein as “Petitioner” and/or “Mr.

Riley”) a person of the full age of majority and, at all times relevant hereto, a resident
and domiciliary of the State of Georgia.
3.
The Defendants to this cause of action are as follows:
A. LATOYA CANTRELL, (“Mayor Cantrell”) Individually and in her official capacity

as Mayor of the City of New Orleans, a person of the full age of majority and, upon
information and belief, a resident and domiciliary of the Eastern District of
Louisiana;
B. THE CITY OF NEW ORLEANS, a self-insured municipal corporation authorized

to do and doing business in the Parish of Orleans, State of Louisiana.
4.
All of the above named Defendants are bound jointly, severally and in solido unto your
Petitioner, Warren Riley, in an amount fair and reasonable under the premises, together with legal
interest thereon from the date of judicial demand until paid, and for all costs of these proceedings,
including attorney’s fees, for the following reasons, to wit:
5.
FACTUAL BACKGROUND
Petitioner, Warren Riley, joined the New Orleans Police Department (“NOPD”) in 1981.
After earning a master’s degree in criminal justice and working his way through the ranks, Mr. Riley
was appointed the Superintendent of Police in September 2005. Mr. Riley retired from the NOPD
in May 2010, after twenty-nine (29) years of service.
Page 2 of 22
6.
After retiring from the NOPD, Mr. Riley became a contractor for the U.S. State Department
and was deployed to Haiti to assess the collapse of the criminal justice system following the
earthquake of 2010. Thereafter, Mr. Riley reported to Sydney, Australia, and Prague, Czech
Republic, for disaster preparedness evaluations, at the request of their respective federal
governments.
7.
Mr. Riley was recruited by the Federal Emergency Management Agency (FEMA) in 2012
and, in 2013, received a Top Secret security clearance from the U.S. Department of Homeland
Security. With FEMA, Mr. Riley served as the lead federal official coordinating federal disaster
response and recovery operations eleven times under President Barack Obama and four times under
President Donald Trump.
8.
FACTUAL ALLEGATIONS
In April 2017, during her campaign to be elected Mayor of The City of New Orleans, La Toya
Cantrell contacted Mr. Riley via telephone. During that call, Mayor Cantrell (a mayoral candidate
at the time) advised Mr. Riley that improving the NOPD would be a central issue in her mayoral
campaign and asked Mr. Riley to share his thoughts on the topic with her, which he did.
9.
In July 2017, Mr. Riley was again contacted by then-candidate La Toya Cantrell. During that
telephone call, candidate Cantrell asked Mr. Riley to expound upon his role with FEMA. After a
brief discussion, candidate Cantrell asked Mr. Riley if he would accept the position of Homeland
Security Director for the City of New Orleans if she were to win her campaign for Mayor.
Page 3 of 22
10.
In response to candidate Cantrell’s question, Mr. Riley explained that he was domiciled in
Brookhaven, Georgia, and that he enjoyed his job with FEMA, but that he would consider such an
offer if it was made.
11.
After the July 2017, telephone call, Mr. Riley did not have any contact with La Toya Cantrell,
or her representatives, until November 2017, a few days after the run-off election.
12.
La Toya Cantrell was sworn in as Mayor of The City of New Orleans on May 7, 2018.
13.
After La Toya Cantrell was elected, but before she assumed office, one of her representatives
contacted Mr. Riley and asked if he would meet the Mayor-elect for an initial interview for the
position of Homeland Security Director for the City of New Orleans (periodically referred to herein
as “the position.”)
14.
Mr. Riley agreed to the initial interview and traveled from Atlanta to New Orleans for the
interview at his own expense.
15.
During the initial interview, Mayor-elect Cantrell and Mr. Riley discussed Petitioner’s
qualifications for the position, salary requirements and job benefits. Specifically, Mr. Riley informed
Mayor Cantrell that his salary requirement was a minimum of $180,000 per year for a minimum of
two years, with a pay raise to be awarded at the start of his third year if his job performance was
satisfactory. Mayor-elect Cantrell affirmatively responded to Petitioner by stating “I can do that.”
Page 4 of 22
16.
Mayor-elect Cantrell agreed to Petitioner’s salary requirement and advised that the position
included the use of vehicle owned by The City of New Orleans and a fuel card. Mr. Riley and
Mayor-elect Cantrell shook hands and agreed to the terms of this employment offer.
17.
On March 28, 2017, Mayor-elect Cantrell sent Mr. Riley a text massage that reads as follows:
Warren will u do me a favor? Please can you send your resume to

resumes@forwardtogetherneworleans.com ASAP. I know you
gave me a hard copy, but I need to get in this system for my folks
scheduling calls and interviews.
18.
Petitioner sent his resume to Mayor-elect Cantrell’s staff that same day, in accordance with
the request and Mayor-elect Cantrell sent Petitioner a text message which confirmed that his resume
had been received.
19.
On April 10, 2018, Petitioner received an email from Justin Boone, a member of Mayor-elect
Cantrell’s transition team. Said email confirmed that Petitioner was to participate in a second
interview for the position via video conference on April 11, 2018. That same email advised that the
interview would “be conducted with a panel of domain experts and members from Mayor-elect
Cantrell’s transition team.”
20.
Petitioner participated in the second interview on April 11, 2018, as scheduled.
Page 5 of 22
21.
On April 12, 2018, Petitioner received a telephone call from Mayor-elect Cantrell’s assistant
chief of staff, Liana Elliott. Ms. Elliott asked Petitioner if he would come to New Orleans on
Monday, April 16, 2018 for a final interview for the position of Director of Homeland Security and
Public Safety for the City of New Orleans.
22.
Petitioner made arrangements, at his own expense, to attend the third interview in New
Orleans on April 16, 2018, which included airfare that Petitioner paid for at his own expense.
23.
Petitioner attended the final interview on April 16, 2018, as scheduled. The interview was
conducted by six people, including Mayor-elect Cantrell; John Pouchier, the Mayor-elect’s chief of
staff; Julius Feltus, the Mayor-elect’s special assistant; State Senator Karen Carter; Michelle
Thomas, a former New Orleans Deputy Mayor; and Bob Tucker, a campaign advisor to the Mayor-
elect. After all six of the in-person interviewers finished questioning Petitioner, Mayor-elect Cantrell
telephoned Congressman Cedric Richmond who proceeded to ask Petitioner questions that related
to homeland security. This final interview was in-depth; detailed; difficult, and lasted approximately
one hour and thirty minutes.
[PARAGRAPH 24 BEGINS ON FOLLOWING PAGE.]
Page 6 of 22
24.
On April 22, 2018, Petitioner received a letter from Mayor-Elect Cantrell, a copy of which
is attached hereto as Exhibit 1, which reads as follows:
April 22, 2018
Warren Riley
305 Brookhaven Avenue, NE
Brookhaven, Georgia 30319
Warren:
I am pleased to offer you the unclassified position of Director of the Public Safety
and Homeland Security for the City of New Orleans. This position is of “at will”
service to the City and without privilege of Civil Service standing.
The salary for this position is herein offered at $180,000 annually. This salary is paid
bi-weekly and is subject to applicable federal and state withholdings. The City offers
a mandatory pension plan along with optional medical, dental and vision health care
plan, life insurance, various voluntary deferred compensation plans, and other
benefits.
This offer is conditional upon the successful completion of a background check and
drug screening. Upon your confirmation and acceptance of this offer of employment
background screening will commence. If you accept this offer, please indicate below
and complete the attached background check authorization. Return both documents
to offers@forwardtogetherneworleans.com.
Should you need any additional information. please feel free to contact my Chief of
Staff, John Pourciau, at 225-247-2833.
Sincerely,
s/ Latoya Cantrell
Latoya Cantrell
Mayor-Elect
To accept this job offer, please sign and date below. Return via email to
offers@forwardtogetherneworleans.com
Signature: Date:
Page 7 of 22
25.
That same day, April 22, 2018, Petitioner signed and dated the offer for the position of
Director of Public Safety and Homeland Security for the City of New Orleans and returned the letter
as instructed.
26.
The following day, April 23, 2018, Petitioner received an email from
offers@forwardtogethemeworleans.com which confirmed that the offer and acceptance letter had
been received by the Mayor-elect.
27.
Upon receiving confirmation that his signed offer and acceptance letter had been received,
on April 23, 2018, Petitioner, Mr. Riley, tendered his resignation to FEMA/U.S. Department of
Homeland Security.
28.
On April 23, 2018, Petitioner received an email from Justin Boone that instructed Petitioner
to participate in a conference call with the CAO (Chief Administrative Officer) for The City of New
Orleans, Jerry Sneed of the Orleans Parish Communication District, and Colin Arnold, the Acting
Director of New Orleans Homeland Security. The meeting was scheduled for the following day,
April 24, 2018.
29.
Mr. Montano, Mr. Sneed, and Mr. Arnold participated in the April 24, 2018, meeting in
person and Petitioner called into the meeting from his FEMA office in Atlanta, Georgia. Mr.
Montano introduced himself as the new CAO for the City of New Orleans and Petitioner introduced
Page 8 of 22
himself as the incoming Director of The City of New Orleans Public Safety and Homeland Security.
The purpose of the conference call was to begin forming a strategy for any emergencies that may
arise during the upcoming hurricane season.
30.
The April 24, 2018 meeting was a clear indication that members of the incoming
administration were aware that Petitioner, Warren Riley, was the incoming Director of The City of
New Orleans Public Safety and Homeland Security.
31.
That same day, April 24, 2018, Mayor-elect Cantrell advised Petitioner that she would be
publicly announcing his appointment as the Director of The City of New Orleans Public Safety and
Homeland Security “next week.”
32.
During a telephone conversation that occurred on or about April 25, 2018, Mayor-elect
Cantrell instructed Petitioner to be in New Orleans no later than May 2, 2018, to visit the New
Orleans Real Time Crime Center and interview staff. Petitioner was also advised that the Orleans
Parish Communication District; The New Orleans Office of Emergency Management; New Orleans
Police Department; New Orleans Fire Department; Office of Secondary Employment; and the Office
of Criminal Justice Coordination would be under Petitioner’s supervision.
33.
As instructed, Petitioner requested leave from his job with FEMA and made arrangements
to travel to New Orleans for the week of April 30 through May 4, 2018.
Page 9 of 22
34.
On April 29, 2018, Petitioner received a text message from John Pouchia, the Mayor-elect’s
Chief of Staff. The message reads as follows:
Hey Warren, there was some conversation about having Col. Sneed possibly being
a deputy to you. Wanted to get some input from you. Mayor Elect is open to all
options but suggested that you call Col Sneed to get your take on your comfort with
that idea
Do you have his number?
35.
Petitioner responded that he would contact Col. Sneed, make arrangements to meet with him
during his trip to New Orleans, and report back. Petitioner also informed Mr. Pouchia that he would
be meeting with Colin Arnold, to interview him for the position Assistant Director of Homeland
Security and to gain a better understanding of the current state of the Department.
36.
On April 30, 2018, Petitioner met with and interviewed Col. Sneed; Mr. Arnold; Steven
Gordon, the Director of the Orleans Parish Communications District and Mr. Gordon’s Assistant,
Claude Flot. After completing said interviews, Petitioner reported his impressions to the Mayor-
elect’s Chief of Staff, as was instructed.
37.
On April 30, 2018, Mr. Riley received an email from Justin Boone instructing that a meeting
was being held on May 2, 2018 “to kick off the Cantrell Administration.” The email advised that
attendees would “have the opportunity to meet one another, hear directly from the Mayor-elect and
the senior staff. There will also be time . . . to meet with outgoing officials to gather specific job-
related details and advice.”
Page 10 of 22
38.
On May 1, 2018, Petitioner received an email from Justin Boone which instructed Petitioner
to appear at a press conference on May 2, 2018, “to outline the public safety initiatives moving
forward for the Cantrell Administration.” The email also advised that Mayor-elect Cantrell would
be introducing Petitioner as the new Director of Public Safety and Homeland Security at that press
conference, along with other members of the incoming administration’s public safety leadership
team.
39.
On the morning of Wednesday, May 2, 2018, Petitioner reported to the “meet and greet” held
in the City Council Chambers.
40.
At the “meet and greet,” Mayor-elect Cantrell welcomed and congratulated her new hires and
turned the meeting over to Mr. Pourciau, her Chief of Staff. Mr. Pourciau read the agenda for the
meeting and instructed all Directors, which included Petitioner, to meet with their staff members
after the meeting ended.
41.
As instructed, at the end of the “meet and greet,” Petitioner held a meeting with the New
Orleans Police Superintendent, Michael Harrison; Fire Chief Mike McConnell; the newly hired
Crime Commissioner, Tynisha Stevens; and the acting director of New Orleans Homeland Security
and Emergency Preparedness, Colin Arnold. Petitioner also met with the Director of the Office of
Secondary Employment, later that morning.
Page 11 of 22
42.
During that meeting, Petitioner instructed each Director to compile a list of areas that needed
to be addressed for each respective Department and to begin brainstorming about how to implement
the changes being proposed as they related to making New Orleans a safer city.
43.
Petitioner was then given a tour of the Emergency Management Office in New Orleans City
Hall and was introduced to members of his office staff.
44.
Moments later, Petitioner received a telephone call from Mayor-elect Cantrell. Petitioner was
instructed to meet Mayor-elect Cantrell in an office behind the City Council Chamber inside City
Hall.
45.
Petitioner reported to the office as instructed. Sitting inside the office were Mayor-elect
LaToya Cantrell; her Chief Counsel, Clifton Davis; Public Information Officer, Beau Tidwell; and
Julius Feltus, the Mayor-Elect’s Assistant.
46.
Mayor-elect Cantrell advised Petitioner that his appointment had been “put on pause” and
instructed Petitioner not to attend the press conference that had been called for the purpose of
announcing the members of the incoming administration’s public safety leadership team, including
Petitioner’s position as Director of Public Safety and Homeland Security.
47.
Any reservations that Mayor-elect Cantrell may have had regarding Petitioner’s potential
appointment to the position of Director of Public Safety and Homeland Security were addressed
Page 12 of 22
during Petitioner’s final interview, and certainly before the position had been offered to, and
accepted by, Petitioner, Warren Riley.
48.
Petitioner reiterated that when he accepted the Mayor-elect’s employment offer he tendered
his resignation to FEMA/U.S. Department of Homeland Security and made plans to vacate his home
in Brookhaven, Georgia, in order to move to New Orleans. Mayor-elect Cantrell responded “I’ll get
back with you.”
49.
On May 6, 2018, Mayor-elect Cantrell sent Petitioner a text message and informed him that
he was welcome to attend her inaugural ball on May 7, 2018. In that same message, Mayor-elect
Cantrell informed Petitioner “We will put this to bed this week,” referring to Petitioner’s being
sworn in as the Homeland Security Director for the City of New Orleans and the public
announcement of same.
50.
LaToya Cantrell was sworn in as Mayor of The City of New Orleans on May 7, 2018.
51.
On May 14, 2018, Petitioner was contacted by a member of Mayor Cantrell’s staff and was
instructed to report to the Mayor’s office on May 15, 2018. At all times, Petitioner believed that the
purpose of the meeting with the Mayor on May 15, 2018, was for the purpose of his taking the oath
of office as the Director of Public Safety and Homeland Security for the City of New Orleans.
Page 13 of 22
52.
Petitioner’s next contact with Mayor Cantrell occurred on May 15, 2018, when he reported
to her office for the face-to-face meeting. To Petitioner’s surprise, Bob Tucker, who was not an
employee of The City of New Orleans, accompanied Mayor Cantrell in the meeting inside the
Mayor’s office in New Orleans City Hall.
53.
During that meeting on May 15, 2018, Mayor Cantrell informed Petitioner that “there are
very powerful people who live uptown that do not support you for the position.” After a brief
conversation, Mayor Cantrell advised Petitioner that she would “take care of this situation on Friday
[May 19, 2018].”
54.
On May 16, 2018, Mayor Cantrell telephoned Petitioner and stated “Chief I can’t do it. I’m
sorry. I will not be able to appoint you. I will have to make you whole. I am sorry.” Mayor Cantrell
hung up the telephone without saying another word.
55.
Within ten minutes of said telephone call, Mayor Cantrell issued a formal press release which
states, in pertinent part:
While I believe that Warren Riley is uniquely qualified for a role as our City’s
Director of Homeland Security & Public Safety --- with a resume that includes
serving as the Federal Coordinating Officer overseeing seven federally declared
disasters in just over four years--- I have listened to the people of New Orleans on
both sides, and I have decided not to move forward with his employment.
Mr. Riley’s qualifications are undeniable. As one of a select team of Federal

Coordinating Officers who serve as the president’s representative on federally
declared disasters, he has been a leader in crisis response and emergency
preparedness on the national level.
Page 14 of 22
56.
Despite her express admission that Petitioner is “uniquely qualified for a role as our City’s
Director of Homeland Security & Public Safety” Mayor Cantrell breached the contract for
employment that was offered to and accepted by Petitioner, Warren Riley.
57.
After participating in three extensive interviews, traveling to The City of New Orleans on
multiple occasions, resigning from his employment with FEMA/U.S. Department of Homeland
Security; performing services for The City of New Orleans at the instruction of Mayor Cantrell; and
being “uniquely qualified,” Petitioner, Warren Riley, was never officially hired by Defendant, The
City of New Orleans, under the administration of Defendant, La Toya Cantrell.
58.
At all times relevant hereto, Defendant, La Toya Cantrell, had the authority to bind
Defendant, The City of New Orleans, in a contract for employment with Petitioner, Warren Riley.
59.
In the time that has passed since Defendant, Mayor Cantrell, breached the employment
contract described herein, Petitioner has been unable to secure employment with a salary that is
equivalent to the salary he would have earned as the Director of Homeland Security & Public Safety
for The City of New Orleans.
60.
In the time that has passed since Defendant, Mayor Cantrell, breached the employment
contract described hereinabove, Petitioner has been unable to secure employment with a salary and
benefits that are equivalent to the salary he would have earned if he had not resigned from his job
working for FEMA/U.S. Deparement of Homeland Security.
Page 15 of 22
61.
Defendant, Latoya Cantrell, in her individual capacity and in her capacity as Mayor of the
City of New Orleans, expected Petitioner, Warren Riley, to rely upon the contract of employment
that was offered to Petitioner and that Petitioner did, in fact, accept.
62.
At all times relevant hereto, it was reasonable for Petitioner, Warren Riley, to rely upon the
employment contract that was offered to him by Defendant, Latoya Cantrell, as the terms of the offer
were written in “black and white” and required the signatures of Petitioner, Warren Riley, and
Defendant, Latoya Cantrell, to become enforceable.
63.
Defendant, La Toya Cantrell’s, breach of the contract for employment that was offered to and
accepted by Petitioner, Warren Riley, was an act performed in bad faith.
64.
As a direct result of Defendants’ breach of contract, Petitioner, Warren Riley, has, and
continues to, incur damages, including but not limited to, lost earnings; lost employment benefits;
lost retirement benefits; travel expenses; embarrassment and humiliation; legal fees and costs and
other damages that shall be proven at the trial on the merits of this action.
65.
CLAIMS FOR RELIEF
COUNT I: DETRIMENTAL RELIANCE
Petitioner hereby incorporates by reference Paragraphs 1 through 64.
Page 16 of 22
66.
Louisiana Civil Code article 1967 states, in pertinent part, “a party may be obligated by a
promise when he knew or should have known that the promise would induce the other party to rely
on it to his detriment and the other party was reasonable in so relying.”
67.
“The detrimental reliance theory is a general part of the Civil Law and springs forth from the
idea that in a civil society people should keep their word.” Bains v. YMCA, 969 So.2d 646, 650 (La.
App. 4 Cir. 10/03/07).
68.
Petitioner, Warren Riley, accepted an employment contract that was offered to him by
LaToya Cantrell, during the time she was the Mayor -Elect, and after her being sworn in as Mayor
of the City of New Orleans.
69.
For reasons completely unknown to Petitioner, Defendant, Mayor Cantrell, breached the
contract of employment that had been offered to and accepted by Petitioner, Warren Riley, for the
position of Director of Homeland Security & Public Safety.
70.
Defendant, Mayor Cantrell’s, breach of contract was an act performed in bad faith.
71.
Relying upon the employment contract that he had accepted for the position of Director of
Homeland Security & Public Safety, Petitioner, Warren Riley, resigned from his employment with
FEMA, leaving behind a salary that paid him $170,000.00 per year, with bonus pay and benefits.
Page 17 of 22
72.
Petitioner has been unable to secure employment with a salary and benefits that are
equivalent to the salary he would have earned if he had not resigned from his job working for
FEMA/U.S. Department of Homeland Security.
73.
As a direct consequence of Defendant, Mayor Cantrell’s, breach of contract, Petitioner,
Warren Riley, has, and continues to, incur damages, including but not limited to, lost earnings and
lost job benefits.
74.
Defendant, LaToya Cantrell, in her individual capacity and in her capacity as Mayor of the
City of New Orleans, is liable unto Petitioner, Warren Riley, for all damages caused by the breach
of contract complained of herein.
75.
COUNT II: ENRICHMENT WITHOUT CAUSE
76.
Petitioner, Warren Riley, provided valuable professional services to Defendants, LaToya
Cantrell, in her individual capacity and in her capacity as Mayor of Defendant, The City of New
Orleans, for which Petitioner was not compensated.
77.
Defendants are therefore liable to Petitioner pursuant to Louisiana Civil Code article 2298,
which provides, in pertinent part, “a person who has been enriched without cause at the expense of
another person is bound to compensate that person.”
Page 18 of 22
78.
Petitioner, Warren Riley, demands that Defendants, Latoya Cantrell and The City of New
Orleans, compensate him for the time and valuable professional services he provided prior to the
breach of contract complained of herein.
79.
COUNT XI: VICARIOUS LIABILITY
80.
At all times pertinent hereto, Defendant, LaToya Cantrell, was employed by Defendant, The
City of New Orleans and was acting within the course and scope of her employment.
81.
Pursuant to the doctrine of Respondeat Superior, or vicarious liability, Defendant, The City
of New Orleans, is liable for the acts and/or omissions of LaToya Cantrell, which form the basis of
this litigation.
82.
Alternatively, Defendant, LaToya Cantrell, is individually liable for the acts and omissions
complained of herein.
83.
DAMAGES
Petitioner, Warren Riley, itemizes his damages as follows:
a) Lost Earnings;
b) Loss of employment benefits;
c) Loss of Pension/Retirement;
Page 19 of 22
d) Out-of -Pocket Expenses;
e) Attorney’s fees and litigation costs/expenses;
f) All other damages which shall be proven at the trial of this matter;
g) Any and all other relief which this Honorable Court deems appropriate and equitable
under the circumstances.
84.
The damages sustained and sought by Petitioner, Warren Riley, exceed $700,000.00,
exclusive of interest, costs and attorney’s fees.
85.
ATTORNEY’S FEES
Petitioner and undersigned counsel specifically plead their individual and/or collective right
to recover attorney’s fees from the named Defendants as authorized by law.
86.
All of the Defendants named herein are liable unto your Petitioner, Warren Riley, jointly,
severally, and in solido.
87.
Inasmuch as any of the allegations contained herein are inconsistent, they are deemed to have
been pled in the alternative.
[PRAYER FOR RELIEF BEGINS ON FOLLOWING PAGE]
Page 20 of 22
PRAYER FOR RELIEF
Petitioner, Warren Riley, respectfully prays:
1. That Defendants, La Toya Cantrell in her individual capacity and in her capacity as
Mayor of the City of New Orleans, and The City of New Orleans be duly served with
a copy of this Original Complaint and be cited to appear and answer same and served
according to law as follows:
a.) LaToya Cantrell, in her individual capacity and in her capacity as Mayor of
the City of New Orleans; by and through its agent for service of process, New
Orleans City Attorney, 1300 Perdido Street, 5th Floor, New Orleans,
Louisiana 70112;
b.) The City of New Orleans, by and through its agent for service of process,
New Orleans City Attorney, 1300 Perdido Street, 5th Floor, New Orleans,
Louisiana 70112;
2. That after all legal delays have expired there be Judgment entered herein in favor of
Petitioner, Warren Riley, and against Defendants, La Toya Cantrell in her individual
capacity and in her capacity as Mayor of the City of New Orleans, and The City of
New Orleans, jointly, severally and in solido, in an amount fair and reasonable under
the premises of this matter, plus any other further relief that this Court deems
appropriate, including all costs and attorneys' fees as well as legal interest on all
amounts awarded to Petitioner from the date of judicial demand until paid; and
3. For all other necessary orders and decrees as may be required or are proper in the
premises and for full general and equitable relief amenable under the circumstances.
Page 21 of 22
Respectfully Submitted,
s/ Jonathan C. Pedersen
D. DOUGLAS HOWARD, JR. (No. 7021) (T.A.)

Email: dhowardjr@howardandreed.com
JONATHAN C. PEDERSEN (No. 32290) (T.A.)
Email: jcpedersen@howardandreed.com
839 St. Charles Avenue, Suite 306
New Orleans, Louisiana 70130
Telephone (504) 581-3610
Facsimile (504) 581-7509
ATTORNEYS FOR PETITIONER,
WARREN RILEY
Page 22 of 22
Case 2:18-cv-14138-JCZ-JVM Document 1-1 Filed 12/21/18 Page 1 of 1
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Warren Riley Lawsuit

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Warren Riley Lawsuit

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Case 2:18-cv-14138-JCZ-JVM Document 1 Filed 12/21/18 Page 1 of 23

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF LOUISIANA

WARREN RILEY * CIVIL ACTION

The Petitioner in this cause of action is as follows:

A. WARREN RILEY (Periodically referred to herein as “Petitioner” and/or “Mr.

The Defendants to this cause of action are as follows:

A. LATOYA CANTRELL, (“Mayor Cantrell”) Individually and in her official capacity

B. THE CITY OF NEW ORLEANS, a self-insured municipal corporation authorized

including attorney’s fees, for the following reasons, to wit:

in May 2010, after twenty-nine (29) years of service.

President Donald Trump.

offer if it was made.

interview at his own expense.

satisfactory. Mayor-elect Cantrell affirmatively responded to Petitioner by stating “I can do that.”

Warren will u do me a favor? Please can you send your resume to

had been received.

Cantrell’s transition team.”

Petitioner participated in the second interview on April 11, 2018, as scheduled.

Public Safety for the City of New Orleans.

one hour and thirty minutes.

[PARAGRAPH 24 BEGINS ON FOLLOWING PAGE.]

is attached hereto as Exhibit 1, which reads as follows:

April 22, 2018

been received by the Mayor-elect.

April 24, 2018.

arise during the upcoming hurricane season.

New Orleans Public Safety and Homeland Security.

Homeland Security “next week.”

of Criminal Justice Coordination would be under Petitioner’s supervision.

Chief of Staff. The message reads as follows:

Do you have his number?

elect’s Chief of Staff, as was instructed.

related details and advice.”

in the City Council Chambers.

after the meeting ended.

Secondary Employment, later that morning.

Hall and was introduced to members of his office staff.

Julius Feltus, the Mayor-Elect’s Assistant.

Petitioner’s position as Director of Public Safety and Homeland Security.

accepted by, Petitioner, Warren Riley.

back with you.”

Mayor’s office in New Orleans City Hall.

[May 19, 2018].”

hung up the telephone without saying another word.

states, in pertinent part:

Mr. Riley’s qualifications are undeniable. As one of a select team of Federal

employment that was offered to and accepted by Petitioner, Warren Riley.

City of New Orleans, under the administration of Defendant, La Toya Cantrell.

for The City of New Orleans.

working for FEMA/U.S. Deparement of Homeland Security.

Defendant, Latoya Cantrell, to become enforceable.

accepted by Petitioner, Warren Riley, was an act performed in bad faith.

CLAIMS FOR RELIEF

COUNT I: DETRIMENTAL RELIANCE

Petitioner hereby incorporates by reference Paragraphs 1 through 64.

on it to his detriment and the other party was reasonable in so relying.”

App. 4 Cir. 10/03/07).

of the City of New Orleans.

position of Director of Homeland Security & Public Safety.

FEMA/U.S. Department of Homeland Security.

As a direct consequence of Defendant, Mayor Cantrell’s, breach of contract, Petitioner,

lost job benefits.