Radoszewski started work as CEO of the association in September 2019, taking over for Bill Carteaux, who had run the organization from 2005 until his death in December 2018 from acute myeloid leukemia.
Before joining the Washington association, Radoszewski was CEO of the Plastics Pipe Institute in Irving, Texas.
In the Aug. 2 filing, Radoszewski argued against a motion from the association seeking to dismiss his case.
"As will be made clear as this case moves forward, plaintiff [Radoszewski] did, in fact, temporarily move to Washington, D.C., and took significant steps to plan his personal, outside-working-hours living arrangements," he said in the filing. "Two factors prevented his efforts: the global COVID pandemic and defendant's termination of his employment."
He said "there was no meeting of the minds on a relocation agreement" with the association, including details such as when he would move, for how long and whether he would lease or buy a property.
Radoszewski said the pandemic wrecked havoc on the association, forcing its D.C. office to close for two years and cancel the NPE trade show, its single largest revenue source.
But he said he was able to do his job during his tenure, which lasted from September 2019 until he was fired in late March.
"It is undisputed that few if any of defendant's employees, board members and association members resided in Washington, D.C.," his court filing argued. "Plaintiff's immediate predecessor resided in Florida while he served as CEO."
Radoszewski's filing did not name that person, but it apparently refers to Carteaux.
Between Carteaux's death and Radoszewski's appointment, the association was headed by its chief operating officer, Patricia Long, who was interim CEO.
Radoszewski said he was able to manage the group through the difficult conditions of the pandemic and the cancellation of NPE.
"Plaintiff's two-and-a-half-year tenure with defendant was severely impeded by a 24-month-long office closing, work-from-home protocols, cancellation of defendant's largest convention and revenue generator, all due to the pandemic," Radoszewski's filing said.
He argued in his lawsuit he's owed $609,000, including one year of his annual salary of $546,000, because he was fired without cause.
Radoszewski said that an affidavit filed by the association, quoting its chief financial officer, is an admission by the organization that he was doing his job effectively, since it also refers to him handling day-to-day association business, including hiring and firing employees, presiding over association meetings from the Washington office and testifying in-person before Congress.