SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES

Size: px
Start display at page:

Download "SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES"

Transcription

1 HELMER FRIEDMAN, LLP Andrew H. Friedman, P.C. (S.B. # ) 2 Gregory D. Helmer (S.B. #150184) 3 Courtney Abrams (SB # ) National Blvd., Suite Culver City, California Telephone: (310) Facsimile: (310) Attorneys for Plaintiff PATRICIA MARQUEZ SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES PA TRICIA MARQUEZ, an individual, v. Plaintiff, CLIFFORD J. TAITT, an individual; MACLEAN SKY, LLC, a limited liability company; MACLEAN-FOGG COMPONENT SOLUTIONS, LLC, a limited liability company; MACLEAN-FOGG, an entity of unknown business form; MACLEAN-FOGG COMP ANY, a corporation; and DOES I through 50, inclusive, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. BC COMPLAINT FOR DAMAGES (1) HARASSMENT ON THE BASIS OF SEX [Gov. Code 12940(j)] (2) ASSAULT AND BATTERY (3) FAILURE TO PREVENT HARASSMENT [Cal. Gov't Code 12940(k)] (4) RETALIATION [Gov. Code 12940(h)] (5) VIOLATION OF CALIFORNIA LABOR CODE SECTION (6) WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY (7) FAILURE TO PAY ALL WAGES [Labor Code 200 et seq.] (8) VIOLATION OF CALIFORNIA LABOR CODE SECTION (9) INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS (10) NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS DEMAND FOR TRIAL BY JURY

2 1 Plaintiff PA TRICIA MARQUEZ (hereinafter "MS. MARQUEZ" or "PLAINTIFF") 2 complains and alleges as follows: 3 4 INTRODUCTION 5 1. Defendant CLIFFORD J. TAITT is a sexual predator. And his employer, 6 MACLEAN SKY, LLC, MACLEAN-FOGG COMPONENT SOLUTIONS, LLC, MACLEAN- 7 FOGG COMP ANY, INC., and MACLEAN-FOGG (hereinafter collectively referred to as 8 "MACLEAN") not only knew about and ratified and condoned his unlawful behavior, but also fired 9 MS. MARQUEZ because she complained about both his sexually harassing conduct toward herself 10 and others, and about MACLEAN's rampant violations of the law. Indeed, throughout MS. 11 MARQUEZ's employment as a Human Resources Manager at MACLEAN, defendant TAITT, MS. 12 MARQUEZ's direct supervisor, engaged in pervasive sexual harassment, assault and battery directed 13 towards MS. MARQUEZ and numerous other female employees including, among other things: Raping them; Exposing his penis to them; Groping their breasts; Pressuring them for oral sex (i.e., "blow jobs"); Touching (or attempting to touch) their vaginas; Leering at them; Making comments to them about the size of his penis; Commenting upon the size and shapes of their bodies; and Using derogatory gender-based names to refer to women (such as "bitch," "cunt" and "whore") When defendant MACLEAN's female employees, including MS. 26 MARQUEZ, resisted defendant TAITT's advances, the retaliation was swift. Defendant TAITT, 27 with the blessing of defendant MACLEAN, would attempt to bribe the female employees (including 28 MS. MARQUEZ), into staying silent. When that failed, defendant MACLEAN, heeding defendant 2

3 1 TAITT' s direction, fired them All of this was done with the full knowledge and ratification of defendant 4 MACLEAN. Indeed, defendant MACLEAN was well aware of defendant TAITT's abuse, and, even 5 after MS. MARQUEZ repeatedly complained to MACLEAN's corporate Human Resources 6 department, MACLEAN took absolutely no corrective action. Instead, managers in defendant 7 MACLEAN's corporate Human Resources department told MS. MARQUEZ that defendant 8 TAITT's actions were "nothing," and denigrated the victims of the harassment, calling them "crazy." In addition to this pervasive sexual harassment, defendant MACLEAN - who 11 is a United States goverrnnent contractor - has no qualms with engaging in other widespread 12 unlawful conduct, including the employment of undocumented workers, and forcing its non-exempt 13 hourly employees to work more than eight (8) hours per day without paying overtime. Despite MS. 14 MARQUEZ's complaints, defendant MACLEAN refused to take any type of corrective action. MS. 15 MARQUEZ was simply informed that this conduct was "fine," and thus the rampant illegalities 16 continued JURISDICTION AND VENUE The Court has personal jurisdiction over the defendants because they are 21 residents of and/or doing business in the State of California Venue is proper in this county in accordance with Section 395(a) of the 24 California Code of Civil Procedure because the defendants, or some of them, reside in this county, 25 and the injuries alleged herein occurred in this county. Venue is also proper in this county in 26 accordance with Section l 2965(b) of the California Government Code because the unlawful 27 practices alleged by MS. MARQUEZ in violation of the California Fair Employment and Housing 28 Act [Cal. Gov't Code 12940, et seq.] were committed in this county. In the alternative, venue is 3

4 1 appropriate in this county in accordance with Section 395(a) and Section of the California 2 Code of Civil Procedure because defendants and MS. MARQUEZ contracted to perform their 3 obligations in this county, the contract was entered into in this county, and because the liability, 4 obligation and breach occurred within this county. 5 6 PARTIES 7 7. Plaintiff PATRICIA MARQUEZ is an individual who, at various relevant 8 times during the events alleged herein, resided in Los Angeles County, State of California. MS. 9 MARQUEZ was employed by defendants MACLEAN SKY, LLC, MACLEAN-FOGG 1 o COMPONENT SOLUTIONS, LLC, MACLEAN-FOGG COMP ANY, INC., and 11 MACLEAN-FOGG, an entity of unknown business form, as a Human Resources Manager from 12 October 26, 2013 to December 19, MS. MARQUEZ is informed and believes, and thereon alleges, that 15 defendants MACLEAN SKY, LLC, MACLEAN-FOGG COMPONENT SOLUTIONS, LLC, 16 MACLEAN-FOGG COMPANY, INC., MACLEAN-FOGG, an entity of unknown business form, 17 and DOES 1 through 25 (collectively hereinafter referred to as "MACLEAN" or "the Company"), 18 and each of them, are, and at all times herein mentioned were, limited liability companies, 19 corporations or other business entities qualified to and doing business in the State of California. MS. 20 MARQUEZ is further informed and believes, and thereon alleges, that defendant MACLEAN's 21 principal offices are located in the State of California, and that said defendants are and were, at all 22 relevant times mentioned herein, "employer[ s ]" within the meaning of Sections 12926( d) and (j)(4)(A) of the California Government Code MS. MARQUEZ is informed and believes, and thereon alleges, that defendant 26 CLIFFORD J. TAITT (hereinafter "TAITT") is an individual who, at all relevant times herein 27 mentioned, was employed as defendant MACLEAN's General Manager and MS. MARQUEZ's 28 supervisor. As such, defendant TAITT was an officer and/or managing agent of defendant 4

5 1 MACLEAN and held supervisory authority over MS. MARQUEZ. MS. MARQUEZ is informed 2 and believes, and thereon alleges, that defendant TAITT is an individual who, at various relevant 3 times during the events alleged herein, resided in Los Angeles County, State of California, and was 4 and is a citizen of California The true names and capacities, whether corporate, associate, individual or 7 otherwise of defendants DOES I through 50, inclusive, are unknown to PLAINTIFF, who therefore 8 sue said defendants by such fictitious names. Each of the defendants designated herein as a DOE is 9 negligently or otherwise legally responsible in some manner for the events and happenings herein 10 referred to and caused injuries and damages proximately thereby to PLAINTIFF, as herein alleged. 11 PLAINTIFF will seek leave of Court to amend this Complaint to show their names and capacities 12 when the same have been ascertained At all times mentioned herein, defendants, and each of them, were the 15 agents, representatives, employees, successors, assigns, parents, subsidiaries and/or affiliates, each of 16 the other, and at all times pertinent hereto were acting within the course and scope of their authority 17 as such agents, representatives, employees, successors, assigns, parents, subsidiaries and/or affiliates MS. MARQUEZ is informed and believes, and thereon alleges, that each 20 defendant named in this Complaint, including DOES 1 through 50, inclusive, knowingly and 21 willfully acted in concert, conspired and agreed together among themselves and entered into a 22 combination and systemized campaign of activity to, inter alia, damage MS. MARQUEZ and to 23 otherwise consciously and/or recklessly act in derogation of MS. MARQUEZ's rights, and the trust 24 reposed by MS. MARQUEZ in each of said defendants, said acts being negligently and/or 25 intentionally inflicted Said conspiracy, and defendants' concerted actions, were such that, to the 28 information and belief of MS. MARQUEZ, and to all appearances, defendants and each of them, 5

6 1 represented a unified body so that the actions of one defendant were accomplished in concert with, 2 and with knowledge, ratification, authorization and approval of each of the other defendants MS. MARQUEZ is informed and believes, and thereon alleges, that 5 defendants MACLEAN SKY, LLC, MACLEAN-FOGG COMPONENT SOLUTIONS, LLC, 6 MACLEAN-FOGG COMPANY, INC., and MACLEAN-FOGG, an entity of unknown business 7 form, have common management, centralized control of labor relations, common ownership and 8 financial control, overlapping employees and interrelated operations such that these entities operated 9 as a single, integrated enterprise with regard to the employment of MS. MARQUEZ. MS. 10 MARQUEZ is further informed and believes, and thereon alleges, that defendants MACLEAN SKY, 11 LLC, MACLEAN-FOGG COMPONENT SOLUTIONS, LLC, MACLEAN-FOGG COMPANY, 12 INC., and MACLEAN-FOGG, an entity of unknown business form, were her joint or co-employers At all times set forth herein, the acts and omissions of each defendant 15 caused, led and/or contributed to the various acts and omissions of each and all of the other 16 defendants, legally causing the injuries as set forth FACTS COMMON TO ALL CAUSES OF ACTION Defendant MACLEAN is one of the world's leading suppliers of fastener 21 components (such as nuts and bolts), and other types of component parts for diverse industries 22 including, among others, automotive, military and defense, electronics, aerospace, wind power and 23 mining industries. Defendant MACLEAN - a United States government contractor - has over thirty 24 (30) manufacturing facilities in North America alone, and annual sales in excess of $1 billion On or about October 26, 2013, MS. MARQUEZ, an individual with an 27 extensive background in Human Resources, started employment with defendant MACLEAN as its 28 Human Resources Manager at its Commerce, California location. At all times during her 6

7 1 employment, MS. MARQUEZ's direct supervisor was MACLEAN's General Manager, defendant 2 TAITT Despite defendant MACLEAN's motto that its "integrity is never 5 compromised," MS. MARQUEZ learned on her first day that, in reality, defendant MACLEAN has a 6 practice of lying to its employees, the government, and the public Among other things, when she was first hired, MS. MARQUEZ was informed 9 that initially, MACLEAN would falsely hold her out as a "contractor" - even though she was 1 O actually hired, treated and taxed as an employee. Defendant MACLEAN explained to MS. 11 MARQUEZ that it had fired its previous Human Resources Manager, Lorraine Faber, under the false 12 pretext that MACLEAN was eliminating the position, and it wanted to avoid being sued by Ms. 13 Faber for wrongful termination Approximately three (3) months later, on or about February S, 2014, defendant 16 MACLEAN then presented MS. MARQUEZ with afake offer letter, confirming afake start date of 17 March 3, At this time, defendant TAITT also informed MS. MARQUEZ that she would be 18 provided with a raise and three (3) weeks of vacation. When MS. MARQUEZ asked defendant 19 TAITT to memorialize this raise and vacation in writing, defendant TAITT dictated a statement 20 outlining the terms of this agreement, including MS. MARQUEZ's acceptance of the fake "job 21 offer," and instructed MS. MARQUEZ to sign at the bottom (which she did). Notwithstanding 22 defendant MACLEAN's promises, and consistent with defendant MACLEAN's practice of lying to 23 its employees, MS. MARQUEZ never received the raise or the vacation time Moreover, in an unlawful effort to reduce its tax payments to the United States 26 government and the governments of various states, MACLEAN engages in an intentional and 27 unlawful pattern and practice of falsely classifying employees as "contractors" and thereby not 28 paying the federal and state employment taxes that it is legally obligated to pay. 7

8 1 22. As defendant MACLEAN's Human Resources Manager, MS. MARQUEZ 2 was responsible for, among other things, ensuring MACLEAN's legal compliance, counseling 3 employees and supervisors, conducting performance reviews for MACLEAN's employees, and 4 hiring and terminating employees Nevertheless, unbeknownst to MS. MARQUEZ when she accepted 7 defendant MACLEAN's offer of employment, her direct supervisor, defendant TAITT - who was 8 previously fired from another employer for his sexual harassment of female employees - had a 9 pattern and practice of creating a sexually hostile and intimidating work environment for female 1 O employees. This environment included, among other things, the following inappropriate sexual 11 conduct: Raping female employees; Using derogatory gender-based names to refer to women (such as "bitch," "cunt" and "whore"); Groping female employees; Leering at the breasts, buttocks and bodies of female employees; Making inappropriate sexual remarks about the clothing and bodies of female employees; Speculating aloud about what he thought (or hoped) the female employees would be like in bed; Attempting to have sexual relations with the female employees; Exposing his penis to the female employees; and Engaging in other sexually harassing conduct that created a sexually hostile work environment. 25 When the female employees resisted and/or opposed his sexual conduct, defendant TAITT would 26 either attempt to bribe them with "raises," or, if that failed, instruct MACLEAN to fire them (which 27 it did, in accordance with his requests). 28 8

9 1 24. Indeed, almost immediately upon the commencement of her employment, 2 defendant TAITT began to subject MS. MARQUEZ to a barrage of sexual harassment, including, 3 among other things, the following: 4 5 A. 6 7 Defendant TAITT flirted with MS. MARQUEZ on a routine basis and asked her to have sex with him, making comments such as, "we can have a good time together." B. Defendant TAITT assaulted and battered MS. MARQUEZ by grabbing her breasts C Defendant TAITT constantly talked about sex and attempted to engage MS. MARQUEZ in sexual conversations. For instance, defendant TAITT, who is African American, routinely asked MS. MARQUEZ, "Have you ever been with a black man? You wouldn't regret it. Once you go black you won't go back!" D Defendant TAITT constantly discussed using sex toys, the different types, shapes and sizes and asked MS. MARQUEZ if she had ever used any of them. MS. MARQUEZ immediately protested this conduct to defendant TAITT. Instead of ceasing this conduct, defendant TAITT persisted informing MS. MARQUEZ, "Don't tell me you've never used any." He went on to describe a particular toy that MS. MARQUEZ could take into the shower, attach it to the shower wall and then use it "hands free." MS. MARQUEZ was offended and humiliated E. 28 Defendant TAITT told MS. MARQUEZ to comfort a female employee going through a marital separation, directing MS. MARQUEZ: "Tell her how to 9

10 satisfy her man since you are older than her and have more experience." When the female employee subsequently reconciled with her husband and became pregnant, defendant TAITT informed MS. MARQUEZ: "She must have done something right." 5 6 F After learning that a female employee was in a relationship with a younger man, defendant TAITT informed MS. MARQUEZ that the female employee "only wanted him for sex because he was younger and he had stamina." Defendant TAITT then asked MS. MARQUEZ if she would "sleep with a younger guy just for pleasure." G Defendant TAITT stared at MS. MARQUEZ's body in an inappropriately sexual manner (focusing on her breasts and buttocks) and made sexually inappropriate comments about her body. For example, defendant TAITT informed MS. MARQUEZ that he liked "Latinas because you [referring to MS. MARQUEZ} have curves, big breasts and butts and nice legs." MS. MARQUEZ was disturbed and offended not only by defendant TAITT's comment, but also by the thought that defendant TAITT had not only been staring at, but also evaluating her body H When defendant TAITT overheard MS. MARQUEZ telling a female colleague that she planned to go to the gym more, defendant TAITT informed MS. MARQUEZ that she "look[ed] hotter with more curves." I Defendant TAITT used sexually degrading epithets and profanity to describe female employees who he did not like, informing MS. MARQUEZ that these women were "sluts," "whores," "cunts," and "bitches." MS. MARQUEZ protested his use of this language to defendant TAITT. Defendant TAITT just IO

11 1 laughed and continued using these slurs. 2 3 J. Defendant TAITT made comments to MS. MARQUEZ about the size of male 4 genitalia, including, among other things, how he believed Asian men had 5 small penises, and how large his penis, as an African American man, was in 6 comparison. Defendant TAITT informed MS. MARQUEZ that he would 7 obviously be "a better lover," he "never had any women complain," and MS. 8 MARQUEZ just needed to look at his "shoe size" in order to know that he had 9 a "huge cock." K. Defendant TAITT objectified MS. MARQUEZ on the basis of her gender and 12 national origin, telling her that he wanted "a Latina because they are 13 homebodies, like to cook and take care of their men." L. Defendant TAITT constantly made comments about MS. MARQUEZ's 16 appearance, telling her she was "beautiful," and that her "predecessor had 17 nothing on her." MS. MARQUEZ desperately wanted defendant TAITT's sexual harassment to 20 stop, but she was also terrified of reporting his harassment to her corporate supervisors, and resisting 21 defendant TAITT's advances because defendant TAITT made it clear that if someone crossed him, 22 they would be fired and MACLEAN corporate would take his side. In fact, a female receptionist, 23 Charlette Beltran, warned MS. MARQUEZ that her predecessor, MACLEAN's previous Human 24 Resources Manager, Lorraine Faber, had reported defendant TAITT's sexual harassment to corporate 25 and protested his advances, and was fired shortly thereafter. Ms. Beltran also notified MS. 26 MARQUEZ that the same thing happened to another female employee, Lorran Wixom, who resisted 27 defendant TAITT's harassment. Thus, MS. MARQUEZ tried her best to keep her head down, stay 28 quiet, and do her job. 11

12 1 26. However, MS. MARQUEZ soon realized that defendant TAITT's sexual 2 harassment against MS. MARQUEZ was not limited to sexual harassment directed at her. 3 Defendant TAITT also created a sexually hostile work environment for MS. MARQUEZ by 4 engaging in sexually harassing conduct towards other women in MS. MARQUEZ's presence, and by 5 virtue of the fact that these other women would complain to MS. MARQUEZ about defendant 6 TAITT's misconduct. Indeed, MS. MARQUEZ often witnessed defendant TAITT making sexual 7 advances and comments to multiple other female employees in the office. Defendant TAITT's 8 harassment of other women included, among other things, the following: 9 10 A Suggesting to a female employee who was going through a separation from her husband that she was not "pleasing her husband in bed," that she should ask her husband "what he wanted her to do for him in bed," and that she should "rent a hotel room and have sex with him like [she] had never done it before." B. Engaging in pervasive quid pro quo sexual harassment including: I. II. Exposing his penis to female employees in his office. For example, defendant TAITT would invite female employees into his office, close the door, pull his pants down and then inform them: "If you don 't want to lose your job, you know what you have to do," or "ff you want a promotion, you know what you have to do." Promising promotions and raises to female employees in exchange for sex. 27 C. Touching and attempting to touch the vaginas of female employees

13 1 D. Raping female employees (and then threatening to fire them if they disclosed 2 his unlawful conduct). 3 4 E. Asking female employees to take off their shirts, telling one female employee 5 that he liked her breasts and wanted to see them. 6 7 F. Telling a female employee that he "wanted to see what was between her legs." 8 9 G. Informing a female employee that he "wanted to impregnate her." H. Making thrusting motions in front of a female employee and telling her that he 12 wanted to have sex with her I. Groping the breasts of female employees J. Caressing and hugging female employees, telling them that they needed "some 17 love." K. Telling a female employee that her "ass was going away," and that she should 20 "buy smaller pants so [she] could show off [her] ass." L. Pressuring female employees to have sex with him. MS. MARQUEZ is 23 informed and believes and thereon alleges that defendant TAITT forced at 24 least two (2) of these employees to have sex with him M. Commenting on female employees' looks, telling them they were "beautiful." N. Telling a female employee that she was "too young not to have a sexual 13

14 1 2 3 appetite," after learning that she was having problems with her husband, and inviting her to a motel to have sex with him. Defendant TAITT also offered this female employee a new car in exchange for sex P. 8 Giving a female employee a motel address so they could meet to have sex. Cornering female employees in his office and pressuring them to give him blow jobs Q Speculating aloud about what he thought (or hoped) the female employees would be like in bed, saying things like, "!bet she is really kinky in bed" and "Asians are really kinky in bed." R. Stalking female employees on social media using fake accounts S. 17 Standing over female employees while they were sitting at their desks and staring down their shirts or blouses T. Leering at female employees' breasts U Making comments about the size of male genitalia, and his penis in particular. As he did with MS. MARQUEZ, he informed other female employees that his penis was large because he was an African American man, "once you go black, you never go back," and the female employees just needed to look at his "shoe size" in order to know that he had a "huge cock." Thus, although she was afraid of being fired, MS. MARQUEZ felt obligated 28 to inform MACLEAN corporate about defendant TAITT's conduct, and so, in or about February 14

15 1 2014, when MS. MARQUEZ first witnessed defendant TAITT's sexual harassment towards other 2 female employees, she immediately reported his illegal conduct to her corporate supervisor, Timothy 3 White. Rather than initiating an investigation or taking any type of corrective action in response to 4 MS. MARQUEZ's complaints, Mr. White took no action whatsoever; MS. MARQUEZ received 5 MACLEAN's message loud and clear - it would take no steps to investigate or stop defendant 6 TAITT's harassment Indeed, despite defendant TAITT's relentless pursuit of MS. MARQUEZ and 9 other female employees, defendant MACLEAN - when faced with complaints about defendant 1 o TAITT' s sexual harassment - refused and failed to take any corrective action that would stem the 11 tide of defendant TAITT's advances. Instead, in response complaints by its female employees, 12 including MS. MARQUEZ, defendant MACLEAN either took no corrective action whatsoever, or 13 fired them - oftentimes at defendant TAITT's direction - making up clearly false and pre-textual 14 reasons for doing so For instance, after resisting defendant TAITT's harassment, and reporting his 17 conduct to Human Resources, a Production Coordinator named Sulay Tapia took medical leave. 18 When she attempted to return from her leave of absence, MACLEAN fired her, using the pre-textual 19 reason that she abandoned her job while she was on leave. This reason was false. In fact, when MS. 20 MARQUEZ sent Ms. Tapia's personnel file to her corporate supervisor, MS. MARQUEZ saw 21 unequivocal evidence in the file that Ms. Tapia had diligently kept MACLEAN informed of her 22 condition, provided MACLEAN with her required medical documentation, and timely contacted 23 defendant MACLEAN to inform it that she would like to resume her position Another time, in early June 2014, a female receptionist, Charlette Beltran, 26 reported to MS. MARQUEZ that defendant TAITT had made sexually harassing comments to her, 27 including among other things, speculating that her divorce with her husband was because Ms. 28 Beltran was "not pleasing him in bed," and telling her that she needed to "buy smaller pants so [she] 15

16 1 could show off[her] ass." Although MS. MARQUEZ immediately reported this harassment to her 2 corporate supervisor, Mr. White, MACLEAN took absolutely no corrective action whatsoever. 3 Instead, Mr. White scoffed at MS. MARQUEZ's disclosure, stating: "Patty, it's really just a 4 comment, it's nothing." Yet another time, on or about September 12, 2014, MS. MARQUEZ was 7 instructed by defendant TAITT to terminate a female employee named Maria Marroquin, a Lead in 8 defendant MACLEAN's Drill Department. Ms. Marroquin had a perfect performance record. 9 Unbeknownst to MS. MARQUEZ, until she met with Ms. Marroquin during the termination 1 O meeting, Ms. Marroquin had also been subjected to unrelenting sexual harassment by defendant 11 TAITT. After MS. MARQUEZ informed Ms. Marroquin of her termination, Ms. Marroquin burst 12 into tears, and, through sobs, informed MS. MARQUEZ that defendant TAITT had been harassing 13 her continuously for a long time, including among other things, telling her he wanted to have sex 14 with her, giving her a motel address so they could meet to have sex, exposing his penis to her in his 15 office and saying "if you don't want to lose your job, you know what you have to do." When Ms. 16 Marroquin resisted, defendant TAITT gave MS. MARQUEZ the directive to terminate her. Ms. 17 Marroquin has filed a lawsuit for sexual harassment, retaliation and sexual battery, which is currently 18 pending in Los Angeles Superior Court (Case No. BC ) Immediately after Ms. Marroquin's termination, on September 12, 2014, MS. 21 MARQUEZ reported Ms. Marroquin's allegations of sexual harassment to Mr. White, and a 22 corporate Human Resources Manager, Cindy Burdorf. When MS. MARQUEZ reported Ms. 23 Marroquin's allegations of sexual harassment to Mr. White, he was dismissive. He called Ms. 24 Marroquin "a crazy woman," and said his job was to "protect Barry's [referring to Barry MacLean, 25 the Company's owner] interest, not Maria's." MS. MARQUEZ also confronted defendant TAITT 26 about Ms. Marroquin's allegations. In violation offeha and the California Labor Code, defendant 27 TAITT illegally told MS. MARQUEZ to "stop advocating for all of the employees." 28 16

17 1 33. The next day, on or about September 13, 2014, MS. MARQUEZ attended an 2 employee retreat in Utah with Mr. White. During this retreat, MS. MARQUEZ again complained to 3 Mr. White about defendant TAITT's sexual harassment. Among other things, MS. MARQUEZ 4 emphasized that defendant TAITT had not only sexually harassed Ms. Marroquin, but defendant 5 TAITT had a pattern and practice of sexually harassing MS. MARQUEZ and other female 6 employees. MS. MARQUEZ urged Mr. White to reinstate Ms. Marroquin and also pressed him to 7 take corrective action. In response, Mr. White just laughed and told MS. MARQUEZ that Ms. 8 Marroquin's reinstatement was not going to happen because Ms. Marroquin had alleged sexual 9 harassment against defendant TAITT. Mr. White again asserted that his job was to "protect Barry's 1 o interest and money." During this same conversation, MS. MARQUEZ also complained to Mr. 13 White that defendant MACLEAN was engaged in other illegal conduct including, but not limited to, 14 employing undocumented workers, misclassifying employees as independent contractors, and failing 15 to pay all wages owed to its employees, including overtime wages, in violation of California law. In 16 particular, with respect to the undocumented workers, MS. MARQUEZ disclosed that these 17 individuals did not even have social security numbers. MS MARQUEZ also objected that, although 18 many workers at MACLEAN were working over twelve (12) hours per day, the Company was 19 illegally depriving these employees of the overtime wages to which they were entitled. Instead, the 20 Company was only paying "straight time" wages for hours worked in excess of eight (8) per day In response to MS. MARQUEZ's complaints about MACLEAN's wage and 23 hour violations and undocumented immigrant employees, Mr. White informed MS. MARQUEZ that 24 it was "fine" because the workers were only "contractors," not employees. Nevertheless, MS. 25 MARQUEZ persisted. MS. MARQUEZ reiterated to Mr. White that these workers were, in fact, 26 employees as they were on the Company's payroll, and regardless, it was illegal to employ 27 undocumented workers and not pay these individuals all wages to which they were entitled. Mr. 28 White condescendingly instructed MS. MARQUEZ not to worry about it - it was "fine." Mr. 17

18 1 White's apathetic attitude was consistent with defendant TAITT's attitude, to whom MS. 2 MARQUEZ also complained about this issue earlier in the month, and who seemed similarly "fine" 3 with MACLEAN's illegal activity After MS. MARQUEZ reported defendant TAITT's sexual harassment of 6 Maria Marroquin to Mr. White, defendant MACLEAN purported to conduct an investigation, during 7 which MS. MARQUEZ interviewed several witnesses who corroborated that defendant TAITT had 8 indeed engaged in pervasive sexual harassment, and who affirmed they that had also been harassed 9 by defendant TAITT. MS. MARQUEZ also interviewed a male witness, Ramiro Rosales, who 10 reported to MS. MARQUEZ that the Company's Controller, Agnes Abrigo -a close friend of 11 defendant TAITT who had previously worked with him, and had a sexual relationship with him at 12 another company- had sexually harassed him, including, among other things, asking him to have 13 sex, making sexual comments, and asking him to meet her outside of work. MS. MARQUEZ 14 promptly reported her findings to Mr. White and Robert Whitney, the Company's President of 15 Engineering Plastics, and its Vice President of Human Resources Despite MS. MARQUEZ's conclusive findings against defendant TAITT, her 18 initial findings against Ms. Abrigo, and her general findings of a sexually charged, hostile work 19 environment, defendant MACLEAN never took any corrective action, much less prompt and 20 effective action, to prevent future harassment. Accordingly, defendant TAITT's harassment 21 continued unabated. The Company also never reported the results or findings of its investigation to 22 MS. MARQUEZ, and when MS. MARQUEZ asked Mr. White about the outcome of the 23 investigation, he refused to share the Company's conclusions, vaguely telling her: "Don't worry 24 about it." Moreover, defendant TAITT and Ms. Abrigo were thereafter allowed to 27 retaliate against, and demote the male employee who reported Ms. Abrigo's sexual harassment to 28 MS. MARQUEZ. When MS. MARQUEZ protested this demotion to defendant TAITT, and 18

19 1 informed him that this was unlawful retaliation, defendant TAITT retorted: "I wish I could just fire 2 him." In the ensuing three months, defendant TAITT continued his campaign of 5 sexual harassment without reproach, and MS. MARQUEZ continued to feel humiliated, offended 6 and frightened by his conduct. Nevertheless, because MS. MARQUEZ had witnessed defendant 7 MACLEAN repeatedly ratify defendant TAITT's sexual harassment and retaliation against its 8 employees who reported illegal conduct, she was fearful of reporting any further sexual harassment. 9 Indeed, it was not until defendant TAITT physically assaulted MS. MARQUEZ that she reached her 1 o breaking point and knew that she had to stand up for herself On or about November 17, 2014, defendant TAITT appeared in MS. 13 MARQUEZ's office doorway under the pretense of discussing performance reviews and budgetary 14 issues. After entering MS. MARQUEZ's office, defendant TAITT shut the door and approached 15 MS. MARQUEZ where she was sitting behind her desk. MS. MARQUEZ, who became nervous at 16 defendant TAITT's close proximity, asked him to sit down across from her in the chair in front of 17 her desk. Instead, defendant TAITT, without saying a word, immediately and forcefully grabbed 18 both of MS. MARQUEZ's breasts MS. MARQUEZ, who was humiliated and disgusted, recoiled in pain. After 21 screaming at defendant TAITT and demanding to know what he was doing, defendant TAITT 22 offered an absurd explanation: "I was trying to reach for your mouse." Defendant TAITT then 23 pleaded, "Don't make a big deal about this." MS. MARQUEZ informed defendant TAITT that his 24 conduct was "totally unacceptable," she was going to report his assault to corporate, and directed 25 him to leave her office immediately The next day, on or about November 18, 2014, MS. MARQUEZ, having 28 spent the previous evening wrecked with anxiety, humiliation and disgust over defendant TAITT's 19

20 1 assault, met with defendant TAITT to specifically complain that he was subjecting her and other 2 female employees to a barrage of sexual harassment, all of which needed to stop. MS. MARQUEZ 3 objected to defendant TAITT that his conduct was creating a hostile work environment and reiterated 4 that she would be contacting her corporate supervisor to report the foregoing conduct On November 19, 2014, MS. MARQUEZ memorialized this meeting in an 7 to defendant TAITT. In her , MS. MARQUEZ again objected to defendant TAITT's 8 rampant sexual harassment, and wrote: Hello Cliff, I am ing you this as confirmation in regards to our conversation yesterday. You are aware that you have created a sexually hostile environment which is making me very uncomfortable, the leering and sexual remarks are inappropriate. I do not appreciate hearing about female bodies and male body parts (sizes). I also want you to know that the incident where you grabbed my breast is completely unacceptable and I know it was not an accident. Sorry that I am putting this in writing, I will be contacting corporate to make them aware. 20 (Emphasis added) Later that day, after receiving MS. MARQUEZ's , defendant TAITT 23 entered her office. Defendant TAITT was clearly incensed, and, with nostrils flaring, threatened that 24 he would swiftly replace MS. MARQUEZ if she ever disclosed his sexual harassment to 25 MACLEAN's corporate human resources. MS. MARQUEZ responded: "I'm going to do what I 26 have to do." A few hours later, defendant TAITT entered MS. MARQUEZ's office yet 20

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, WEST DISTRICT 9 10 11 12 13 14 15 16 17 18

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, WEST DISTRICT 9 10 11 12 13 14 15 16 17 18 JAMES W. JOHNSTON ATTORNEY AT LAW 00 S. Flower Street, Suite 10 Los Angeles, California 001 State Bar No. (1) 1- Attorney for Plaintiff IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO,

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES 9 10 11 12 13 14 15 16 17 18

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES 9 10 11 12 13 14 15 16 17 18 JAMES W. JOHNSTON ATTORNEY AT LAW 00 S. Flower Street, Suite 00 Los Angeles, California 001 State Bar No. (1) 1- Attorney for Plaintiff IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOMEWHERE ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOMEWHERE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Harvey C. Berger (SBN POPE & BERGER 0 West "C" Street, Suite 100 San Diego, California 1 Telephone: (1-1 Facsimile: (1 - Attorneys for Plaintiff PLAINTIFF SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND

More information

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES (SPACE BELOW FOR FILING STAMP ONLY) LAW FIRM OF KAISER, DEBIASO. ANDREW AND SWINDELLS SUMfTOMO TOWER NINTH FLOOR 444 WEST OCEAN BOULEVARD LONG BEACH, CALIFORNIA 90802-4516 (310) 590-8471 ERIC C. DEMLER

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA Case:-cv-0 Document Filed0// Page of Michael Millen Attorney at Law (#) Calle Marguerita Ste. 0 Telephone: Fax: (0) -0 mikemillen@aol.com Attorney for Plaintiff UNITED STATES DISTRICT COURT NORTHERN DISTRICT

More information

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) )

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) Case :-cv-00-loa Document Filed 0// Page of 0 Bradley Jardis, vs. Keith M. Knowlton, L.L.C. SBN 0 S. Rural Road, Suite 0, PMB# Tempe, Arizona -00 (0 -; FAX (0 - Keith M. Knowlton - SBN 0 Attorney for Plaintiff

More information

York); and in case of your failure to appear or answer, judgment will be taken against you by

York); and in case of your failure to appear or answer, judgment will be taken against you by t - SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK CELIA CLARK, -against- Plaint#, MORELLI RATNER PC, BENEDICT P. MORELLI, DAVID L. SOBILOFF, and DAVID S. RGTNER, YOU ARE HEREBY SUMMONED to

More information

GUIDANCE ON SEXUAL HARASSMENT FOR ALL EMPLOYERS IN NEW YORK STATE

GUIDANCE ON SEXUAL HARASSMENT FOR ALL EMPLOYERS IN NEW YORK STATE ANDREW M. CUOMO Governor HELEN DIANE FOSTER Commissioner GUIDANCE ON SEXUAL HARASSMENT FOR ALL EMPLOYERS IN NEW YORK STATE STATUTORY REQUIREMENTS Sex discrimination is unlawful pursuant to the New York

More information

SEPARATION AGREEMENT AND GENERAL RELEASE. into by and between ( Employee ) and ( the

SEPARATION AGREEMENT AND GENERAL RELEASE. into by and between ( Employee ) and ( the SEPARATION AGREEMENT AND GENERAL RELEASE This Separation Agreement and General Release ( this Agreement ) is made and entered into by and between ( Employee ) and ( the Agency ) (collectively, the Parties

More information

) Verified c-o-m-p-la-in-t- --;o~~&"-a~a~e~a6d4 0. Plaintiff, ) Demand for Jury Trial. Defendants. ) Over $25,000.00 ----------------------------~)

) Verified c-o-m-p-la-in-t- --;o~~&-a~a~e~a6d4 0. Plaintiff, ) Demand for Jury Trial. Defendants. ) Over $25,000.00 ----------------------------~) \\.. I' 1 1 1 1 ORIAEDCOPY ~~G'NAL F'L~~rt LeOS Angeles Superior Michael B. Eisenberg, Esq. #0 EISENBERG & ASSOCIATES 0 Wilshire Blvd, Suite OC1 1 Los Angeles, California 00 =... Telephone: () 1-1 John

More information

DEPARTMENT OF PUBLIC WORKS MANAGEMENT MANUAL

DEPARTMENT OF PUBLIC WORKS MANAGEMENT MANUAL DEPARTMENT OF PUBLIC WORKS MANAGEMENT MANUAL Personnel Directive Subject: PROCEDURE FOR PREVENTING AND/OR RESOLVING PROBLEMS RELATED TO SEXUAL HARASSMENT ADOPTED BY THE BOARD OF PUBLIC WORKS, CITY OF LOS

More information

INVESTIGATIONS GONE WILD: Potential Claims By Employees

INVESTIGATIONS GONE WILD: Potential Claims By Employees INTRODUCTION INVESTIGATIONS GONE WILD: Potential Claims By Employees By: Maureen S. Binetti, Esq. Christopher R. Binetti, Paralegal Wilentz, Goldman & Spitzer, P.A. When can the investigation which may

More information

Case 3:10-cv-02236-DRD Document 31 Filed 05/05/11 Page 1 of 9

Case 3:10-cv-02236-DRD Document 31 Filed 05/05/11 Page 1 of 9 Case 3:10-cv-02236-DRD Document 31 Filed 05/05/11 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO DAVID ASHE Plaintiff, CIVIL NO. 10-2236 ( DRD ) vs. DISTRIBUIDORA NORMA,

More information

CASE 0:12-cv-02811-RHK-SER Document 1 Filed 11/02/12 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) ) )

CASE 0:12-cv-02811-RHK-SER Document 1 Filed 11/02/12 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) ) ) CASE 0:12-cv-02811-RHK-SER Document 1 Filed 11/02/12 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA File No. Julius Chad Zimmerman, Plaintiff, v. Dave Bellows, in his individual and official

More information

Compliance Plan False Claims Act & Whistleblower Provisions Purpose/Policy/Procedures

Compliance Plan False Claims Act & Whistleblower Provisions Purpose/Policy/Procedures CATHOLIC CHARITIES OF THE ROMAN CATHOLIC DIOCESE OF SYRACUSE, NY and TOOMEY RESIDENTIAL AND COMMUNITY SERVICES Compliance Plan False Claims Act & Whistleblower Provisions Purpose/Policy/Procedures Purpose:

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA EASTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) NATURE OF THE ACTION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA EASTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) NATURE OF THE ACTION IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA EASTERN DIVISION EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff, v. SAFELITE GLASS CORP. Defendant. CIVIL ACTION NO. COMPLAINT

More information

Plaintiff Carol Parker ( Plaintiff ), residing at 32 Coleman Way, Jackson, NJ 08527, by her undersigned counsel, alleges the following upon personal

Plaintiff Carol Parker ( Plaintiff ), residing at 32 Coleman Way, Jackson, NJ 08527, by her undersigned counsel, alleges the following upon personal UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY CAROL PARKER, on behalf of herself and all others similarly situated, v. Plaintiff, PARADE ENTERPRISES, LLC, No. 3:14-CV-08084-MAS-DEA AMENDED COMPLAINT

More information

Labor & Employment Law Update

Labor & Employment Law Update , California 90071, California 92260-4305 Wrongful Termination/Retaliation for First Quarter 2007 WRONGFUL TERMINATION Catherine Coble, Esq. Public employer has immunity against direct liability for wrongful

More information

Case 1:14-cv-14355 Document 1 Filed 12/08/14 Page 1 of 7 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS COMPLAINT

Case 1:14-cv-14355 Document 1 Filed 12/08/14 Page 1 of 7 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS COMPLAINT Case 1:14-cv-14355 Document 1 Filed 12/08/14 Page 1 of 7 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS GEORGE THOMPSON, Plaintiff, v. C.A. No. 14-14355 THOMAS BARBOZA, Defendant. INTRODUCTION

More information

COMPLAINT WITH JURY DEMAND. of police reports in bad faith. Plaintiff claims that Defendants acted willfully, wantonly and in

COMPLAINT WITH JURY DEMAND. of police reports in bad faith. Plaintiff claims that Defendants acted willfully, wantonly and in Weld County, Colorado, District Court, 901 9 th Avenue Greeley, CO 80631 970.351.7300 Plaintiff: vs. Defendants: JENNIFER BELL, individually and on behalf of all others similarly situated, BRADLEY PETROLEUM,

More information

UNITED STATES DISTRICT COURT DISTRICT OF HAWAII. Case No.: CV-06-00~CK-LEK

UNITED STATES DISTRICT COURT DISTRICT OF HAWAII. Case No.: CV-06-00~CK-LEK MARY A. WILKOWSKI 4622 304C Iolani Avenue Honolulu, Hawai 96813 Telephone: (808) 536-5444 FacsImile: (808) 591-2990 E-Mail: maw808@aol.com Attorney for Plaintiff-Intervenor DORIS F ALETOI UNITED STATES

More information

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL DIVISION

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL DIVISION IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL DIVISION LAURA HIMES-RUETH, CASE NO.: Plaintiff, vs. DR. MANUEL ABREU and ALL CARE MEDICAL CONSULTANTS PA, a

More information

Chapter 07300 and 07400 SUPERSEDES MANAGEMENT BULLETIN 99-09

Chapter 07300 and 07400 SUPERSEDES MANAGEMENT BULLETIN 99-09 STATE OF CALIFORNIA DATE: 07/23/03 NO. 03-07 EXPIRES: Indefinite DEPARTMENT OF JUSTICE JUS 400 (REVISED 7/85) DISTRIBUTION: A - MANAGEMENT MANAGEMENT BULLETIN B - MGMT & SUPERVISORY X C - ALL EMPLOYEES

More information

The Basics of Sexual Harassment

The Basics of Sexual Harassment The Basics of Sexual Harassment Sexual Harassment is a violation both of Federal Law and the laws of most states. For employers, it is fairly easy to take steps to prevent sexual harassment and to defeat

More information

Case 1:15-cv-07513-RMB-AMD Document 1 Filed 10/15/15 Page 1 of 12 PageID: 1

Case 1:15-cv-07513-RMB-AMD Document 1 Filed 10/15/15 Page 1 of 12 PageID: 1 Case 1:15-cv-07513-RMB-AMD Document 1 Filed 10/15/15 Page 1 of 12 PageID: 1 Law Offices of Swati M. Kothari, LLC Swati M. Kothari, Esq. 712 East Main Street, Suite 2A Moorestown, New Jersey 08057 (856)

More information

Case: 1:16-cv-00951 Document #: 1 Filed: 01/22/16 Page 1 of 18 PageID #:1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

Case: 1:16-cv-00951 Document #: 1 Filed: 01/22/16 Page 1 of 18 PageID #:1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Case: 1:16-cv-00951 Document #: 1 Filed: 01/22/16 Page 1 of 18 PageID #:1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION PAMELA ANDERSON, Individually and ) as Independent

More information

Metropolitan Jewish Health System and its Participating Agencies and Programs [MJHS]

Metropolitan Jewish Health System and its Participating Agencies and Programs [MJHS] Metropolitan Jewish Health System and its Participating Agencies and Programs [MJHS] POLICY PURSUANT TO THE FEDERAL DEFICIT REDUCTION ACT OF 2005: Detection and Prevention of Fraud, Waste, and Abuse and

More information

FORM INTERROGATORIES EMPLOYMENT LAW

FORM INTERROGATORIES EMPLOYMENT LAW ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): TELEPHONE NO.: FAX NO. (Optional): E-MAIL ADDRESS (Optional): ATTORNEY FOR (Name): SUPERIOR COURT OF CALIFORNIA, COUNTY OF SHORT

More information

Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43

Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43 Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43 Calvin L. Keith, OSB No. 814368 CKeith@perkinscoie.com Sarah J. Crooks, OSB No. 971512 SCrooks@perkinscoie.com PERKINS COIE LLP

More information

IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMA * *

IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMA * * IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMA vs. Plaintiffs, CIVIL ACTION NUMBER CV-99-792 Defendants. COMPLAINT 1. Plaintiffs, Bryan K. Bunten and Lisa Bunten, are over the age of nineteen (19) years

More information

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA Case 2:11-cv-00225-KDE-SS Document 1 Filed 02/02/11 Page 1 of 15 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA ) MARIO CACHO and ANTONIO OCAMPO, ) ) Plaintiffs, ) No. v. ) ) SHERIFF

More information

CITY OF LOS ANGELES SEXUAL ORIENTATION, GENDER IDENTITY, AND GENDER EXPRESSION DISCRIMINATION COMPLAINT PROCEDURE

CITY OF LOS ANGELES SEXUAL ORIENTATION, GENDER IDENTITY, AND GENDER EXPRESSION DISCRIMINATION COMPLAINT PROCEDURE CITY OF LOS ANGELES SEXUAL ORIENTATION, GENDER IDENTITY, AND GENDER EXPRESSION DISCRIMINATION COMPLAINT PROCEDURE The policy of the City of Los Angeles has been, and will continue to be, to promote and

More information

Regulations for the Prevention of Sexual Harassment

Regulations for the Prevention of Sexual Harassment Regulations for the Prevention of Sexual Harassment IDC Herzliya is actively working to create an academic and work environment free of sexual harassment. IDC Herzliya views sexual harassment and maltreatment

More information

SETTLEMENT AGREEMENT AND GENERAL RELEASE. There is no one size fits all. However, there are some general terms that are usually in the agreement.

SETTLEMENT AGREEMENT AND GENERAL RELEASE. There is no one size fits all. However, there are some general terms that are usually in the agreement. SETTLEMENT AGREEMENT AND GENERAL RELEASE There is no one size fits all. However, there are some general terms that are usually in the agreement. Payment Terms. Parties should agree on the amount if money

More information

EMPLOYMENT PRACTICES LIABILITY ENDORSEMENT

EMPLOYMENT PRACTICES LIABILITY ENDORSEMENT ENDORSEMENT NO: This endorsement, effective 12:01 am, policy number forms part of issued to: by: THIS ENDORSEMENT CHANGES THE POLICY. PLEASE READ IT CAREFULLY. EMPLOYMENT PRACTICES LIABILITY ENDORSEMENT

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION WAYNE WILLIAMS, on behalf of himself and all others similarly situated, v. Plaintiff, PROTECT SECURITY, LLC. Defendant.

More information

Sexual Harassment, Prevention and California Law

Sexual Harassment, Prevention and California Law Sexual Harassment, Prevention and California Law Sexual Harassment in the Workplace Sexual harassment is a form of sex discrimination that violates Title VII of the Civil Rights Act of 1964. Title VII

More information

Case3:15-cv-01367 Document1 Filed03/24/15 Page1 of 9

Case3:15-cv-01367 Document1 Filed03/24/15 Page1 of 9 Case:-cv-0 Document Filed0// Page of 0 David M. Poore, SBN Scott A. Brown, SBN 0 BROWN POORE LLP 0 Treat Blvd., Suite Walnut Creek, California Telephone: () - dpoore@bplegalgroup.com James Mills, SBN LAW

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA

SUPERIOR COURT OF THE STATE OF CALIFORNIA Paul L. Hoffman, CSB #1 Michael D. Seplow, CSB # 0 K. Arianne Jordan, CSB # 1 SCHONBRUN DeSIMONE SEPLOW HARRIS & HOFFMAN LLP Ocean Front Walk Venice, California 01 Telephone: ( -01 Fax: ( -00 Gloria Allred,

More information

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA. No.

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA. No. ' 2 TERRY GODDARD The Attorney General Firm No. 14000 II Sandra R. Kane, No. 0042 4 IIAssistant Attorney General 125 West Washmgton 5 IIPhoenix, Arizona 8500 Telephone: (602) 542-8862 6 IICivi~Rights@azag.gov

More information

VNSNY CORPORATE. DRA Policy

VNSNY CORPORATE. DRA Policy VNSNY CORPORATE DRA Policy TITLE: FEDERAL DEFICIT REDUCTION ACT OF 2005: POLICY REGARDING THE DETECTION & PREVENTION OF FRAUD, WASTE AND ABUSE AND APPLICABLE FEDERAL AND STATE LAWS APPLIES TO: VNSNY ENTITIES

More information

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA. Complaint. Credit Extension Uniformity Act 73 P.S. 2270, et seq.

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA. Complaint. Credit Extension Uniformity Act 73 P.S. 2270, et seq. UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA Michael XXXX : Civil Action v. : Enhanced Recovery Corp. : Complaint Jurisdiction & Venue 1. This is an action under the Fair Debt

More information

Female client hired male Attorney for an insurance claim. While Client s husband was away in

Female client hired male Attorney for an insurance claim. While Client s husband was away in DISCIPLINARY DECISIONS IN OTHER JURISDICTIONS MISSOURI In re Howard, 912 S.W.2d 61 (Mo. 1995) Female client hired male Attorney for an insurance claim. While Client s husband was away in the Army, Attorney

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA CONSENT DECREE. Introduction

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA CONSENT DECREE. Introduction IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA EQUAL EMPLOYMENT OPPORTUNITY ) COMMISSION, et al, ) ) Plaintiff, ) ) Case No. 04-4126 ) THE VANGUARD GROUP, INC. ) ) Defendant.

More information

1 2 3 4 5 [ATTORNEY NAME] (ATTORNEY STATE BAR NUMBER) [ATTORNEY EMAIL ADDRESS] [LAW FIRM NAME] [LAW FIRM STREET ADDRESS] [LAW FIRM CITY/STATE/ZIP CODE] [LAW FIRM TELEPHONE NUMBER] [LAW FIRM FAX NUMBER]

More information

ADMINISTRATIVE POLICY: HEALTH AND SAFETY POLICY TITLE: Sexual Misconduct

ADMINISTRATIVE POLICY: HEALTH AND SAFETY POLICY TITLE: Sexual Misconduct ADMINISTRATIVE POLICY: HEALTH AND SAFETY POLICY TITLE: Sexual Misconduct Pursuant to Title IX of the Higher Education Act of 1972 ( Title IX ) Fox Valley Technical College ( FVTC or the College ) prohibits

More information

The State of Sexual Harassment in America: What is the Status of Sexual Harassment in the US Workplace Today?

The State of Sexual Harassment in America: What is the Status of Sexual Harassment in the US Workplace Today? The State of Sexual Harassment in America: What is the Status of Sexual Harassment in the US Workplace Today? Steven V. Cates, DBA, SPHR Lynn Machin, Kaplan University, USA ABSTRACT The purpose of this

More information

SEXUAL HARASSMENT DISCRIMINATION COMPLAINT PROCEDURE

SEXUAL HARASSMENT DISCRIMINATION COMPLAINT PROCEDURE SEXUAL HARASSMENT DISCRIMINATION COMPLAINT PROCEDURE The policy of the City of Los Angeles is to promote and maintain a working environment free of sexual harassment, intimidation, and coercion. Sexual

More information

SETTLEMENT AGREEMENT AND RELEASE

SETTLEMENT AGREEMENT AND RELEASE SETTLEMENT AGREEMENT AND RELEASE This Settlement Agreement and Release ( Agreement ) is made and entered into by and between Cheryl Coryea ( Coryea or Plaintiff ), and Rochester Independent School District

More information

S tj M M ONS UNION LEAGUE CLUB, PI ai nti ff Demands a Trial by Jury. Index No. Plaintiff, TO THE ABOVE NAMED DEFENDANT:

S tj M M ONS UNION LEAGUE CLUB, PI ai nti ff Demands a Trial by Jury. Index No. Plaintiff, TO THE ABOVE NAMED DEFENDANT: SCANNED ON 311912012 f' r V. UNION LEAGUE CLUB, Plaintiff, Index No. S tj M M ONS PI ai nti ff Demands a Trial by Jury TO THE ABOVE NAMED DEFENDANT: YOU ARE HEKF,HY SUMMONED to answer the complaint in

More information

COUNTY OF ORANGE. False Claims Act and Whistleblower Provisions Policy and Procedures

COUNTY OF ORANGE. False Claims Act and Whistleblower Provisions Policy and Procedures COUNTY OF ORANGE False Claims Act and Whistleblower Provisions Policy and Procedures COUNTY OF ORANGE FALSE CLAIMS ACT AND WHISTLEBLOWER PROVISIONS POLICY AND PROCEDURES I. Purpose. The County of Orange

More information

LABOR AND EMPLOYMENT ALERT

LABOR AND EMPLOYMENT ALERT November 2006 LABOR AND EMPLOYMENT ALERT SEXUAL HARASSMENT AND RETALIATION IN THE WORKPLACE: WHAT NONPROFITS NEED TO KNOW When it comes to the law of sexual harassment and retaliation, nonprofit organizations

More information

Question 11 February 2013 Selected Answer 1

Question 11 February 2013 Selected Answer 1 Question 11 February 2013 Selected Answer 1 1. Yes, Hospital is liable for Dan's wrongful debt collection under the TDCA. The Texas Debt Collection acts prohibits a specifically enumerated list of specific

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOLANO. Defendants. ) THE PARTIES

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOLANO. Defendants. ) THE PARTIES '. 1 6 MILLSTONE PETERSON & WATTS, LLP Attorneys at Law GLENN W. PETERSON, ESQ (SBN 6 Lava Ridge Court, Suite Roseville, CA 661 Phone: -80-8 Fax: -80-8 Attorneys for Plaintiff Otto W. Giuliani ENDORSED

More information

North Shore LIJ Health System, Inc.

North Shore LIJ Health System, Inc. North Shore LIJ Health System, Inc. POLICY TITLE: Detecting and Preventing Fraud, Waste, Abuse and Misconduct POLICY #: 800.09 System Approval Date: 6/23/14 Site Implementation Date: Prepared by: Office

More information

COURT-ORDERED SEXUAL HARASSMENT POLICY Robinson v. Jacksonville Shipyards, Inc. 136 L.R.R.M. (BNA) 2920 (N.D. Fla. 1991)

COURT-ORDERED SEXUAL HARASSMENT POLICY Robinson v. Jacksonville Shipyards, Inc. 136 L.R.R.M. (BNA) 2920 (N.D. Fla. 1991) COURT-ORDERED SEXUAL HARASSMENT POLICY Robinson v. Jacksonville Shipyards, Inc. 136 L.R.R.M. (BNA) 2920 (N.D. Fla. 1991) Title VII of the Civil Rights Act of 1964 prohibits employment discrimination on

More information

Fraud, Waste and Abuse Prevention and Education Policy

Fraud, Waste and Abuse Prevention and Education Policy Corporate Compliance Fraud, Waste and Abuse Prevention and Education Policy The Compliance Program at the Cortland Regional Medical Center (CRMC) demonstrates our commitment to uphold all federal and state

More information

MEMORANDUM. 2. Public Health Solutions responds to questions and reports of fraud, waste, and abuse quickly.

MEMORANDUM. 2. Public Health Solutions responds to questions and reports of fraud, waste, and abuse quickly. MEMORANDUM To: Public Health Solutions staff providing Medicaid reimbursable services From: Jane Levine, Vice-President/General Counsel Re: Preventing Medicaid Fraud Summary of Public Health Solutions

More information

Workplace Anti-Harassment Policy (Alberta)

Workplace Anti-Harassment Policy (Alberta) Workplace Anti-Harassment Policy (Alberta) Intent It is public policy in Canada to recognize the dignity and worth of every person and to provide for equal rights and opportunities free of discrimination.

More information

HERITAGE FARM POLICY AND PROCEDURES. Policy: False Claims Act and Whistleblower Provisions

HERITAGE FARM POLICY AND PROCEDURES. Policy: False Claims Act and Whistleblower Provisions HERITAGE FARM POLICY AND PROCEDURES Policy: False Claims Act and Whistleblower Provisions Date: October 8, 2013 Rationale: It is Heritage Farm s intent to make sure all claims are submitted in a timely

More information

Case 4:15-cv-00146-RH-CAS Document 1 Filed 03/17/15 Page 1 of 19 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION

Case 4:15-cv-00146-RH-CAS Document 1 Filed 03/17/15 Page 1 of 19 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION Case 4:15-cv-00146-RH-CAS Document 1 Filed 03/17/15 Page 1 of 19 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION CHRISTOPHER M. JENSEN, v. Plaintiff, LEON COUNTY, FLORIDA,

More information

The Brody School of Medicine Policy and Procedure Manual

The Brody School of Medicine Policy and Procedure Manual I. Purpose The purpose of this policy is to inform all employees, contractors, and agents of the Brody School of Medicine ( BSOM ) about (i) the federal False Claims Act; (ii) North Carolina Medical Assistance

More information

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS ) FOR THE FIFTH JUDICIAL CIRCUIT COUNTY OF RICHLAND )

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS ) FOR THE FIFTH JUDICIAL CIRCUIT COUNTY OF RICHLAND ) STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS ) FOR THE FIFTH JUDICIAL CIRCUIT COUNTY OF RICHLAND ) Kevin Dunbar, ) Civil Action No. ) Plaintiff, ) COMPLAINT ) (Jury trial demanded) vs. ) ) (Breach

More information

Case 1:12-cv-01676-RLV-AJB Document 1 Filed 05/14/12 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

Case 1:12-cv-01676-RLV-AJB Document 1 Filed 05/14/12 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION Case 1:12-cv-01676-RLV-AJB Document 1 Filed 05/14/12 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION BRENDA L. HONEYCUTT, * * Plaintiff, * * v. * CIVIL ACTION

More information

WESTFIELD PUBLIC SCHOOLS SEXUAL HARASSMENT POLICY

WESTFIELD PUBLIC SCHOOLS SEXUAL HARASSMENT POLICY File: ACAB WESTFIELD PUBLIC SCHOOLS SEXUAL HARASSMENT POLICY I. Introduction It is the goal and policy of Westfield Public Schools to promote a workplace and learning environment that is free of sexual

More information

PART THREE: TEMPLATE POLICY ON GENDER-BASED VIOLENCE AND THE WORKPLACE

PART THREE: TEMPLATE POLICY ON GENDER-BASED VIOLENCE AND THE WORKPLACE PART THREE: TEMPLATE POLICY ON GENDER-BASED VIOLENCE AND THE WORKPLACE Draft Organization s Bulletin The Secretary-General, for the purpose of preventing and addressing cases of Genderbased Violence (as

More information

August 2007 Education and Membership Development Department

August 2007 Education and Membership Development Department August 2007 Education and Membership Development Department Table of Contents Title VII of the Civil Rights Act of 1964 3 What is Sexual Harassment? 3 4 How Can Sexual Harassment Occur? 4 5 When is an

More information

What to Do When Your Witness Testimony Doesn t Match His or Her Declaration

What to Do When Your Witness Testimony Doesn t Match His or Her Declaration What to Do When Your Witness Testimony Doesn t Match His or Her Declaration Russell R. Yurk Jennings, Haug & Cunningham, L.L.P. 2800 N. Central Avenue, Suite 1800 Phoenix, AZ 85004-1049 (602) 234-7819

More information

PREVIEW PLEASE DO NOT COPY THIS DOCUMENT THANK YOU. LegalFormsForTexas.Com

PREVIEW PLEASE DO NOT COPY THIS DOCUMENT THANK YOU. LegalFormsForTexas.Com Form: Plaintiff's original petition-wrongful Death [Name], PLAINTIFF vs. [Name], DEFENDANT [ IN THE [Type of Court] COURT [Court number] PLAINTIFF'S ORIGINAL PETITION 1. DISCOVERY CONTROL PLAN 1.1 Plaintiff

More information

HealthStream Regulatory Script

HealthStream Regulatory Script HealthStream Regulatory Script Sexual Harassment in the Workplace Version: May 2008 Lesson 1: Introduction Lesson 2: What Is Sexual Harassment? Lesson 3: Responsibilities of Employers and Employees Lesson

More information

ADMINISTRATIVE POLICY SECTION: CORPORATE COMPLIANCE Revised Date: 2/26/15 TITLE: FALSE CLAIMS ACT & WHISTLEBLOWER PROVISIONS

ADMINISTRATIVE POLICY SECTION: CORPORATE COMPLIANCE Revised Date: 2/26/15 TITLE: FALSE CLAIMS ACT & WHISTLEBLOWER PROVISIONS Corporate Compliance Plan AD-819-0 Reporting of Compliance Concerns & Non-retaliation AD-807-0 Compliance Training Policy CFC ADMINISTRATIVE POLICY AD-819-1 SECTION: CORPORATE COMPLIANCE Revised Date:

More information

Undocumented Workers Employment Rights

Undocumented Workers Employment Rights Undocumented Workers Employment Rights YOUR LEGAL RIGHTS 1. What legal rights do I have as an undocumented worker? With a few exceptions, undocumented workers enjoy the legal rights and remedies provided

More information

NOYES HEALTH ADMINISTRATION POLICY/PROCEDURE

NOYES HEALTH ADMINISTRATION POLICY/PROCEDURE NOYES HEALTH ADMINISTRATION POLICY/PROCEDURE SUBJECT: DETECTION AND PREVENTION OF POLICY: 200.161 FRAUD, WASTE, AND ABUSE EFFECTIVE DATE: June, 2012 ISSUED BY: Administration TJC REF: None PAGE: 1 OF 5

More information

Mastery Test--Common Preventing Workplace Harassment California Supervisory Edition

Mastery Test--Common Preventing Workplace Harassment California Supervisory Edition Mastery Test--Common Preventing Workplace Harassment California Supervisory Edition 1. An individual filing a sexual harassment complaint must personally be the intended target of the behavior? Incorrect.

More information

AN ACT IN THE COUNCIL OF THE DISTRICT OF COLUMBIA

AN ACT IN THE COUNCIL OF THE DISTRICT OF COLUMBIA AN ACT IN THE COUNCIL OF THE DISTRICT OF COLUMBIA To amend the District of Columbia Procurement Practices Act of 1985 to make the District s false claims act consistent with federal law and thereby qualify

More information

0 HealthAlliance. of the ~udsoti vallevtm J / YOUR PARTNERS IN HEALTH

0 HealthAlliance. of the ~udsoti vallevtm J / YOUR PARTNERS IN HEALTH 0 HealthAlliance of the ~udsoti vallevtm J / YOUR PARTNERS IN HEALTH Policy: Compliance with Applicable Federal and State False Claims Acts Initiated: January 1,2010 Reviewed: Revised: Reference: Responsible

More information

IN THE CIRCUIT COURT OF JACKSON COUNTY SIXTEENTH JUDICIAL CIRCUIT STATE OF MISSOURI

IN THE CIRCUIT COURT OF JACKSON COUNTY SIXTEENTH JUDICIAL CIRCUIT STATE OF MISSOURI IN THE CIRCUIT COURT OF JACKSON COUNTY SIXTEENTH JUDICIAL CIRCUIT STATE OF MISSOURI STEPHANIE BRUNO, 3900 NW 60 th Place Kansas City, Missouri 64151 and JOHN AND C.D. BRUNO, 4702 NW Linden Rd Kansas City,

More information

SEXUAL HARASSMENT POLICY STATEMENT

SEXUAL HARASSMENT POLICY STATEMENT SEXUAL HARASSMENT POLICY STATEMENT The company is committed to providing a workplace that is free from all forms of discrimination, including sexual harassment. Any employee's behavior that fits the definition

More information

JEFFERSON CIRCUIT COURT JUDGE DIVISION. MELISSA ROWE, Individually and as Mother and Next Friend of E.R

JEFFERSON CIRCUIT COURT JUDGE DIVISION. MELISSA ROWE, Individually and as Mother and Next Friend of E.R NO. MELISSA ROWE, Individually and as Mother and Next Friend of E.R VS. COMPLAINT JEFFERSON CIRCUIT COURT JUDGE DIVISION PLAINTIFF LANA KAELIN c/o Eastern High School 12400 Old Shelbyville Road Louisville,

More information

Case: 1:15-cv-09957 Document #: 1 Filed: 11/04/15 Page 1 of 10 PageID #:1

Case: 1:15-cv-09957 Document #: 1 Filed: 11/04/15 Page 1 of 10 PageID #:1 Case: 1:15-cv-09957 Document #: 1 Filed: 11/04/15 Page 1 of 10 PageID #:1 JACLYN PAZERA Plaintiff, IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION v. Case No.

More information

ADMINISTRATIVE POLICY MANUAL

ADMINISTRATIVE POLICY MANUAL SUPERSEDES: New PAGE: 838.00 POLICY: 1. It is the policy of Onondaga County hereinafter referred to as the County, to comply with all applicable federal, state and local laws and regulations, both civil

More information

Sexual Harassment Awareness

Sexual Harassment Awareness Sexual Harassment Awareness Orientation: This week s on-line assignment is about sexual harassment in the school and the workplace. We are discussing this subject because sexual harassment is an illegal

More information

VILLAGECARE CORPORATE COMPLIANCE POLICY AND PROCEDURE MANUAL ORIGINAL EFFECTIVE DATE: JANUARY 1, 2007

VILLAGECARE CORPORATE COMPLIANCE POLICY AND PROCEDURE MANUAL ORIGINAL EFFECTIVE DATE: JANUARY 1, 2007 VILLAGECARE CORPORATE COMPLIANCE POLICY AND PROCEDURE MANUAL SUBJECT: COMPLIANCE WITH FEDERAL AND STATE FALSE CLAIMS LAWS AND DETECTION AND PREVENTION OF FRAUD, WASTE AND ABUSE LAST POLICY REVISION EFFECTIVE

More information

Bender s Article on MCAD Sexual Harassment Guidelines. by David B. Wilson 1. Introduction

Bender s Article on MCAD Sexual Harassment Guidelines. by David B. Wilson 1. Introduction Bender s Article on MCAD Sexual Harassment Guidelines The Massachusetts Commission Against Discrimination s Sexual Harassment Guidelines: Blueprint for Proper Behavior in the People s Republic of Massachusetts

More information

Case 2:10-cv-01224-JCM-LRL Document 1 Filed 07/22/10 Page 1 of 8

Case 2:10-cv-01224-JCM-LRL Document 1 Filed 07/22/10 Page 1 of 8 Case :0-cv-0-JCM-LRL Document Filed 0//0 Page of Reno, NV ( -00 Fax ( 0-0 0 Mark R. Thierman, NV# laborlawyer@pacbell.net THIERMAN LAW FIRM, P.C. Reno, Nevada Tel: ( -00 Fax: ( 0-0 David R. Markham, CAL#

More information

FIRST AMENDED CLASS ACTION AND COLLECTIVE COMPLAINT AND JURY DEMAND

FIRST AMENDED CLASS ACTION AND COLLECTIVE COMPLAINT AND JURY DEMAND District Court, Denver County, Colorado 1437 Bannock Street Denver, Colorado 80202 GUILLERMO ARTEAGA-GOMEZ, Individually and on behalf of all others similarly situated, DATE FILED: January 22, 2015 6:02

More information

SEXUAL HARASSMENT. Taylor s Special Care Services, Inc. Simon Pop, MBA Chief Operating Officer 2015-2016

SEXUAL HARASSMENT. Taylor s Special Care Services, Inc. Simon Pop, MBA Chief Operating Officer 2015-2016 SEXUAL HARASSMENT Taylor s Special Care Services, Inc. Simon Pop, MBA Chief Operating Officer 2015-2016 1 Agenda Overview-Why talk about sexual harassment? Why get training? Statistics What is sexual harassment?

More information

Plaintiffs, Defendants. PLEASE TAKE NOTICE that Plaintiff, Rebecca Weston, hereby accepts the Offer of

Plaintiffs, Defendants. PLEASE TAKE NOTICE that Plaintiff, Rebecca Weston, hereby accepts the Offer of 07/15/2034 12:01 973-539-3130 Prom: D Bayle Loflls 201-488-7D29 To: Kalhryn Haffleld SCHENCK PRICE SMITH Date: 7/14/2004 Time: 12:45:04 PM PAGE 04/11 Page 3 of 5 LAW OFFICE D. GAYLELOFTIS 210 RI\/ER STREET

More information

UNITED STATES DISTRICT COURT IN THE CENTRAL DISTRICT OF CALIFORNIA. Case No.:

UNITED STATES DISTRICT COURT IN THE CENTRAL DISTRICT OF CALIFORNIA. Case No.: Case :-cv-0 Document Filed 0// Page of Page ID #: 0 Caree Harper SBN 0 LAW OFFICES OF CAREE HARPER The Howard Hughes Center 0 Center Drive West Suite 00 Los Angeles, CA 00 () -0 Tel. Email: inyourdefense@aol.com

More information

THE COUNTY OF MONTGOMERY POLICIES AND PROCEDURES FALSE CLAIMS AND WHISTLEBLOWER PROTECTIONS

THE COUNTY OF MONTGOMERY POLICIES AND PROCEDURES FALSE CLAIMS AND WHISTLEBLOWER PROTECTIONS THE COUNTY OF MONTGOMERY POLICIES AND PROCEDURES POLICY It is the obligation of the County of Montgomery (the County ) to prevent and detect any fraud, waste and abuse in its organization related to Federal

More information

Title: Preventing and Reporting Fraud, Waste and Abuse in Federal Health Care Programs. Area Manual: Corporate Compliance Page: Page 1 of 10

Title: Preventing and Reporting Fraud, Waste and Abuse in Federal Health Care Programs. Area Manual: Corporate Compliance Page: Page 1 of 10 Title: Preventing and Reporting Fraud, Waste and Abuse in Federal Health Care Programs Area Manual: Corporate Compliance Page: Page 1 of 10 Reference Number: I-70 Effective Date: 10/02 Contact Person:

More information

IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION : : : : : : : : : : : : : : : : : :

IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION : : : : : : : : : : : : : : : : : : IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION JOAN FREDERICKS c/o Alphonse A. Gerhardstein 617 Vine Street #14009 Cincinnati, OH 45251, vs. Plaintiff, JOHN E. POTTER, et.

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA NATURE OF THE ACTION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA NATURE OF THE ACTION IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, DEC 28 Pi i 3", 15 OA~LOREITA G. WtlYTE CLERK Vo Plaintiff, PARAGON SYSTEMS, INC. CWIL

More information

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff, BLUE MAX TRUCKING, INC., Defendant. CIVIL ACTION NO. 3:02CV COMPLAINT

More information

CALIFORNIA FALSE CLAIMS ACT GOVERNMENT CODE SECTION 12650-12656

CALIFORNIA FALSE CLAIMS ACT GOVERNMENT CODE SECTION 12650-12656 CALIFORNIA FALSE CLAIMS ACT GOVERNMENT CODE SECTION 12650-12656 12650. (a) This article shall be known and may be cited as the False Claims Act. (b) For purposes of this article: (1) "Claim" includes any

More information

Case 1:14-cv-00050-WBS Document 1 Filed 02/14/14 Page 1 of 14

Case 1:14-cv-00050-WBS Document 1 Filed 02/14/14 Page 1 of 14 Case 1:14-cv-00050-WBS Document 1 Filed 02/14/14 Page 1 of 14 RENEE KAREL renee@karel-law.com ISB #9050 KAREL LAW OFFICE, PLLC 787 E. STATE ST., #150 EAGLE, ID 83616 TEL: 208-854-3640 FAX: 208-854-3704

More information

Policy and Procedure: Corporate Compliance Topic: False Claims Act and Whistleblower Provisions, Deficit Reduction Act

Policy and Procedure: Corporate Compliance Topic: False Claims Act and Whistleblower Provisions, Deficit Reduction Act Policy and Procedure: Corporate Compliance Topic: False Claims Act and Whistleblower Provisions, Deficit Reduction Act SCOPE OF POLICY This policy applies to all CFS employees, including trainees, volunteers,

More information

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK KELVIN BLEDSOE, Plaintiff, v. SAAQIN, INC., No. COMPLAINT FOR VIOLATION OF FAIR LABOR STANDARDS ACT JURY TRIAL DEMANDED Defendant. Plaintiff Kelvin

More information