13. Plaintiff was and is qualified to fill these positions.

14. Plaintiff is an experienced teacher.

15. Plaintiff has no restrictions on her license to teach.

16.In August 2008, Plaintiff discovered she was not hired as a teacher, despite  having superior qualifications.

17. Defendant gave inconsistent, untrue and pretextual reasons for why Plaintiff was not hired. Defendant departed from its protocols to deny Plaintiff a position; including inconsistent use (or non-use) of hiring committees, recommendations, and an interview process.Plaintiffs application was not treated consistently with prior subsequent practice. Plaintiff was not granted an interview. Defendant even changed it decision to have a French teacher to avoid Plaintiffs hire. In reality, Defendant, out of impermissible, fixed motives; Defendant failed to hire Plaintiff because Defendant was retaliating against Plaintiff for complaining of gender bias in prior litigation and ever since; and Defendant is institutionally biased against female applicants.