The former Lunenburg County employee who filed a civil suit against the county, County Administrator Tracy M. Gee and her assistant, Nicole Clark, said Monday he was planning to file an addendum to the suit Tuesday.

Robert L. Matthews is suing the county, Gee and Clark for wrongful termination, defamation of character and actions that led to prolonged “pain and suffering” after a “near fatal” dog attack in 2012.

Matthews, who is representing himself and filed a 14-page amended complaint on Dec. 30 in Lunenburg Circuit Court that also demanded a jury trial, is seeking reinstitution of employment; back wages, leave, retirement, health insurance and other benefits; compensatory damages of $100,000 for wrongful termination; $400,000 for “pain, suffering, impairments, disabilities and mental anguish;” and hundreds of dollars in court costs, physician fees and Freedom of Information Act requests.

During a telephone interview Monday, Matthews said he was working on the addendum, which he planned to file with the court at 1 p.m. Tuesday.

He said it would include additional information based on documentation he received from the county through a Freedom of Information Act request concerning what he said are violations and breaches of county policies.

The Dispatch contacted Christopher S. Dadak, the attorney representing the county, Gee and Clark, for comment.

“I expect we will file a response by the end of next week, but we do have 21 days from the filing of the amended complaint,” Dadak said in an email. “We do not discuss specifics of cases that are in active litigation.”

Matthews’ lawsuit stems from what he said is a combination of events starting even before the alleged May 2012 dog attack. In his lawsuit, Matthews alleges he had started working for the county as a building and grounds technician in 2007 and had assistant animal control officer (ACO) duties added in 2010.

Matthews alleges he received no formal ACO training until March 2011. He also alleges that the senior ACO asked Gee in February 2012 to issue them personal protective equipment and additional training or for the two ACOs to work together, but that Gee denied the requests due what she reportedly claimed were funding issues.

Then, on May 20, 2012, Matthews responded to a dog attack call involving an individual who reportedly received “severe facial injuries” and had to be flown to a hospital by helicopter. Matthews said immediately after exiting his vehicle at the scene, the same dog “viciously” attacked him, causing multiple wounds and injuries, “including a near fatal bite to the throat and multiple puncture wounds to the throat, hands and wrists resulting in approximately 200 stitches, three subsequent surgeries and intermittent physical and occupational therapy.”

Matthews alleges in the suit the injuries led to an 11 percent partial disability in his left and right rotator cuffs. All of this, he alleges in the lawsuit, showed the “Defendant contributed to an unsafe working environment by not providing PPE (personal protective equipment), such as eye protection, protective shields and barriers, protective clothing, face, head and hand protective gear, mace or a stun gun.”

Matthews’ lawsuit touches on alleged violations of the Americans with Disabilities Act, Code of Virginia, U.S. Code and the county’s personnel manual.

During Monday’s interview, Matthews said he underwent hospitalization and physical therapy and did not return to work until May 2014. In the lawsuit, he alleges that while working under light duty restrictions, he continued to experience right shoulder pain, leading a September 2015 surgical procedure.

Before that surgery, Matthews alleges, he received a performance review within which it was stated, “(I)t has cost the County a great deal of additional part-time staffing to compensate for Mr. Matthews restrictions. The County has gone above and beyond to accommodate the restrictions, but we must draw the line when it costs us more than our budget to get the job done.” Matthews alleges in the lawsuit that “such documentation within a performance review was intended to harm Plaintiff’s reputation with the current employer or any further employer(s).”

His lawsuit goes on to state he received a certified letter on Dec. 4, 2015, stating he had to return to full-duty work by Dec. 7, 2015 or provide notification he did not intend to, and that failing to report back would be considered a resignation.

In the suit, Matthews alleges he returned to work Dec. 4, 2015, but was told his Family and Medical Leave Act coverage had ended, there was no light duty work available and that he was being terminated. He claims this was in retaliation for receiving worker’s compensation claim coverage “that was costing the County ‘more than our budget to get the job done’ as documented by the Defendant.”

On Monday, Matthews said he actually started the process of asserting his rights at the beginning of 2016 by filing an Equal Employment Opportunity Commission (EEOC) complaint.

“I had called different lawyers and I was told I would have to go through the EEOC,” he said. “It took them a while to do their investigation. Although they told me there wasn’t enough evidence for them to do anything, they sent me a letter stating I had a right to file a lawsuit.”

Matthews said he, again, tried contacting lawyers, but none would take the case, so he turned to the internet to learn how to write the filing himself.