Overview of Ryan's Complaint

Ryan's initial complaint is not well drafted and does not state very clearly the basis for the claims it makes, but essentially Ryan's allegations are as follows:

- in 2003, Ryan told people at UL about his beliefs in 9/11 conspiracy theories;

- UL did not act upon his revelations in the manner that Ryan wanted them to;

- so Ryan wrote to NIST to repeat the conspiracy theories, and to accuse NIST of doing a crappy job in its investigation and report, to accuse NIST of failing to "identify the truth about what really happened", and suggesting that "criminal elements within the U.S. government" may have planted explosives in the buildings, etc.;

- Ryan admits that he sent the letter from UL, using UL email address, using his UL title, but says that he was stating his own opinion,  not UL's, and says that UL allowed him to use UL email for personal email, and that the email program "automatically added the UL title of Mr. Ryan to his email";

- Ryan also wrote to some 9/11 conspiracy theory organization and they posted his letter on the internet;

- UL fired Ryan as a result, saying that it was because he misrepresented UL by writing as though he was stating UL's opinion rather than his own personal opinion;

- UL used this as a pretext to fire him "in retaliation for Mr. Ryan exercising his rights and acting to fulfill his duties under the U.S. constitution, the constitution of Indiana, and under federal and state laws";

- UL wrongly terminated his employment because (by writing to NIST),  he exercised his right under the U.S constitution and the state constitution to "petition his government for redress of grievances and to reform his government", and because he was exercising his first amendment rights in his letter to NIST and in his communications with tinhat groups, etal.;

- UL wrongly terminated his employment because (by writing to NIST, etc.), he was exercising his right to "report safety hazards and to disclose material facts in a government investigatino of a (sic) occupational and public safety related incident";

- UL wrongly terminated his employment because he was exercising his right under federal, Indiana and NY laws, "to report potential felonies and terrorist activity";

- UL wrongly terminated his employment because he was defending  the constitution and seeking to petition his government for redress of grievances and seeking to "reform" the government "in the face of actions by persons seeking to subvert" the gov't and alter the
democratic nature of our society;

Therefore, he seeks:

- back pay from November 2004
- $200,000 in front pay or, alternatively, reinstatement to his job;
- $unquantified for cost of relocation and job search;
- $unquantified lost value of medical insurance, retirement plan, benefits;
- $unquantified damages for emotional distress and damage to his reputation;
- $unquantified punitive damages.