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

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1 \\.. I' 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 A. Vlomcer/C\erk C\liIW,;... Facsimile: () -0 DepUtY Website: BY. LEY Carney R. Shegerian, Esq. #01 SHEGERIAN & ASSOCIATES, INC. Arizona Avenue, Suite 00 Santa Monica, California 001 Telephone: () 0-00 Facsimile: () 0-01 Website: Attorneys for Plaintiff, FRANCINE GODOY SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES, UNLIMITED JURISDICTION FRANCINE GODOY, ) Case No. ) Plaintiff, ) Demand for Jury Trial vs. ) ) 1. Sexual Harassment CITY OF LOS ANGELES; JOSE HUIZAR; ). Retaliation in Violation of the Fair and DOES 1-0, inclusive, ) Enlployment and Housing Act ) Defendants. ) Over $, ~) Plaintiff complains and alleges as follows: ) Verified c-o-m-p-la-in-t- --;o~~&"-a~a~e~ad 0 ) 1. At all times herein mentioned, Plaintiff was a resident of the County of Los Angeles, State of California.. At all times herein mentioned, Defendant, CITY OF LOS ANGELES (hereinafter "CITY") is a public entity and was Plaintiffs employer.. At all times herein mentioned, Defendant, JOSE HUIZAR (hereinafter "HUIZAR") was and is a resident living in the County of Los Angeles in the State of California and at all times herein mentioned was plaintiffs supervisor. 1.

2 . Plaintiff is ignorant ofthe true names and capacities, whether individual, corporate, or associate, ofthose Defendants fictitiously sued as DOES 1 through 0 inclusive and so the Plaintiff sues them by these fictitious names. The Plaintiff is informed and believes that each ofthe DOE Defendants reside in the State of California and are in some manner responsible for the conduct alleged herein. Upon discovering the true names and capacities of these fictitiously named Defendants, the Plaintiff will amend this complaint to show the true names and capacities ofthese fictitiously named Defendants.. Plaintiff was hired by CITY in 0. During the course of her employment, she attained the title ofdeputy Chief of Staff. During the course ofher employnlent, Plaintiff worked under HUIZAR in the offices next to HUIZAR's office.. During the course of her employment under HUIZAR, Plaintiff was subjected to regular 1 physical and verbal sexual harassment, including propositions for sexual favors. 1.. HUIZAR's sexual harassment was severe and pervasive in Plaintiffs working environment.. As detailed in the example below, HUIZAR explicitly conditioned Plaintiffs enlploynlent benefits on sexual favors and when Plaintiff refused HUIZAR's sexual advances and opposed 1 HUIZAR's sexual harassnlent, HUIZAR began a campaign ofretaliation against Plaintiff.. The instances ofhuizar's sexual harassment and retaliation against Plaintiff are too numerous to articulate, however the following paragraphs describe only one series of events in his campaign of sexu~l harassment and retaliation.. In or about October 1, HUIZAR suggested that Plaintiff run for a position on the Commmlity College Board oftrustees (hereinafter "CCBT"). 1l. In October 1, Plaintiff worked full time in HUIZAR's City Hall office. 1. At some point in 1, HUIZAR told influential people to support Plaintiff in her campaign for the CCBT. 1. On or about October, 1 (Columbus Day), HUIZAR called Plaintiff after hours and told her to come to his office at City HalL. On or about October, 1, Plaintiff arrived at HUIZAR's office after :00 p.nl.. Verified COlnplaint for Damages and Demand for Jury Trial

3 On or about October, 1, after Plaintiff arrived at I-IUIZAR's office at City Hall, HUIZAR told Plaintiff that if she wanted his continued support in her campaign for the CCBT, she would have to have sex with him. 1. On or about October, 1, after HUIZl\R conditioned his support on her having sex with him, Plaintiff refused his sexual advances.. On or about October, 1, after Plaintiff refused HUIZAR's sexual advances, HUIZAR got angry and started yelling and cursing at Plaintiff.. On or about October, 1, after Plaintiff refused HUIZAR's sexual advances, HUIZAR went into Plaintiffs office and started opening her drawers, taking her belongings, grabbing her files and taking her things into his office.. On or about October, 1, while HUIZAR was taking things out of Plaintiff s office, Plaintiff left the office at City Hall.. On November, 1, Plaintiff was scheduled to have her endorsement meeting with the Faculty Guild.. At some point prior to October, 1, HUIZAR indicated to Plaintiff that with his endorsement, Plaintiff would be the Faculty Guild's candidate.. Once Plaintiff would be the Faculty Guild's candidate; she could then run for t~e position on the CCBT.. On November 1,1, after :00 p.m., HUIZAR contacted Plaintiff by cell phone.. On November 1,1, after :00 p.m., HUIZAR told Plaintiff that his car was parked down the street from her home and she should come meet him. On November 1,1, after being contacted by HUIZAR, Plaintiff left her home and went into HUIZAR's car.. On November 1,1 after :00 p.m., while Plaintiff was in HlTIZAR's car, HUIZAR told Plaintiff that he doesn't feel "close" to her.. On November 1,1 after :00 p.m., while Plaintiff was in HUIZAR's car, HUIZAR told Plaintiff that the campaign process was "difficult.". V erified Complaint for Damages and Demand for Jury Trial

4 . On November 1,1 after :00 p.m., while Plaintiffwas in HUIZAR's car, HUIZAR told Plaintiff that they needed to be "closer" for him to support Plaintiff through the campaign process.. On November 1,1, while Plaintiff was in HUIZAR's car, Plaintiff understood that these were sexual advances. 0. On November 1,1, while Plaintiff was in HUIZAR's car, she refused HUIZAR's sexual advances. l. On November 1,1, while Plaintiff was in HUIZAR's car and after she refused his sexual advances, HUIZAR told Plaintiff that he was going to "cancel" Plaintiffs endorsement meeting scheduled for the next morning. On November 1, 1, after HUIZAR said he would cancel the endorsement meeting, 1 Plaintiff left HUIZAR's car and returned home. 1. HUIZAR called Plaintiff many times between the evening ofnovember 1,1 and the morning ofnovember, 1.. Plaintiff did not respond to HlJIZAR's calls between the evening ofnovember 1,1 and 1 the morning ofnovember 1.. HUIZAR even called Plaintiffs mother and asked ifshe knew where he could find Plaintiff.. On November,1, at approximately :0 a.m., Plaintiff showed up to the endorsement meeting with the Faculty Guild.. When Plaintiff entered the meeting with the Faculty Guild, the members ofthe Faculty Guild looked surprised to see Plaintiff. Plaintiff was asked to leave the room and she did.. Shortly thereafter, Plaintiffwas told that the Faculty Guild was surprised that Plaintiff showed up because HUIZAR had contacted them indicating that he was pulling his support of Plaintiff since, as HUIZAR claimed, Ms. Godoy has an ill brother that needed her care and that Ms. Godoy was not capable of running for the position on the CCBT. :

5 . Plaintiff is informed, believes and thereupon alleges that at some point prior to the November,1 Faculty Guild meeting, HUIZAR communicated to at least one person that he was pulling his support ofms. Godoy running for a position on the CCBT. 0. Plaintiff is informed, believes and thereupon alleges that at some point prior to the November,1 Faculty Guild meeting, HUIZAR communicated to at least one person that Ms. Godoy has an ill brother that needed her care and that Ms. Godoy was not capable ofrum1ing for a position on the CCBT. 1. After the November, 1 Faculty Guild meeting, HUIZAR removed some ofplaintiffs job duties. 0. In late December 1 and/or early January 1, Plaintiff was told that she should no longer show up at the office and should instead work from home. 1. After Plaintiff was told to work from home, her assignments and duties were cut significantly 1 but she was still receiving her full salary.. Plaintiff would sit at home much ofher time with no work to perform since she was being retaliated against by HUIZAR due to her refusal to have sex with him. 1. As a result ofhuizar's sexual harassment and retaliation, ignoring, removing duties and assignments, and being banned from entry into the office, Plaintiff was forced to quit her position of Deputy Chiefof Staff and took a position with the Department of Sanitation.. All ofthe foregoing and following actions taken towards the Plaintiff that are alleged in this complaint were carried out by HUIZAR, who was acting in a deliberate, cold, callous, malicious, oppressive, and intentional manner in order to injure and damage Plaintiff.. As a result of being subjected to sexual harassment and retaliation, Plaintiff suffered emotional injuries. Further, as a result ofall ofthe foregoing and following actions taken towards Plaintiff as alleged herein, Plaintiff has incurred loss ofearnings and benefits in an amount not yet ascertained..

6 1 1 1 First Cause of Action SEXUAL HARASSMENT (As against all Defendants). Plaintiff realleges the information set forth in Paragraphs 1- and incorporates these paragraphs into this cause of action as ifthey were fully alleged herein.. This cause ofaction is based upon California statutes prohibiting sexual harassment in the workplace including, but not limited to California Government Code 0, et seq. 0. The Plaintiff has exhausted her administrative remedies under the California Fair Employment and Housing Act and was issued a Notice of Case Closure - Right to Sue against defendants. l. Plaintiff is informed, believes, and alleges that at all times Plaintiff was employed by CITY, HUIZAR did the affirmative acts as described in the general allegations herein that constituted sexual harassment. Defendants kn')wingly and intentionally engaged in said unwelcome discrinlinatory and sexually harassing conduct towards Plaintiff.. As a direct, foreseeable, and proximate result of the conduct of defendants, Plaintiff has suffered, and continues to suffer emotional distress, losses in salary, bonuses, job benefits, and other employment benefits which she would have received from Defendants, plus expenses incurred in obtaining substitute employment and not being regularly employed all to her danlage in a sunl within the jurisdiction ofthis court, to be ascertained according to proof.. The grossly outrageous, reckless, oppressive, intentional, malicious and bad faith manner in which HUIZAR engaged in those acts as described in this cause ofaction entitled Plaintiff to an award of punitive dalnages against HUIZAR, in an amount within the jurisdiction of this court, to be ascertained by the fact finder, that is sufficiently high to punish HUIZAR, deter him from engaging in such conduct again, and to make an example of him to others.. The Plaintiff also requests costs and attorney f~es, as allowed by FEHA for the Plaintiffs prosecution of this action in reference to the FEHA code violations described herein..

7 1 1 1 Second Cause of Action RETALIATION IN VIOLATION OF THE FAIR EMPLOYMENT AND HOUSING ACT (As against CITY and DOES 1-0). Plaintiff realleges the information set forth in Paragraphs 1- as though fully set forth and alleged herein.. This cause of action is based upon California Government Code Section 0, et seq. which prohibits retaliation against an employee for opposing any practice forbidden by the Fair Employment and Housing Act or for complaining about or protesting sexual harassment.. Plaintiff exhausted her administrative Temedies under the California Fair Employment and Housing Act and the Department of Fair Housing and Employment has issued the Notice of Case Closure/Right-to-Sue Letter with respect to said defendants.. Defendants violated Calif. Gov. Code 0, et seq. by retaliating against Plaintiff because she opposed, complained about and protested Defendant's sexual harassment.. As a direct, foreseeable, and proximate result of the conduct of Defendants, Plaintiff has suffered, and continues to suffer emotional distress, losses in salary, bonuses, job benefits, and other en1ployn1ent benefits which she would have received from Defendant, plus expenses incurred in obtaining substitute employment and not being regularly employed all to her damage in a sum within the jurisdiction ofthis court, to be ascertained according to proof. 0. The grossly outrageous, reckless, oppressive, intentional, malicious and bad faith manner in which HlJIZAR engaged in those acts as described in this cause of action entitled Plaintiff to an award of punitive damages against HUIZAR, in an amount within the jurisdiction ofthis court, to be ascertained by the fact finder, that is sufficiently high to punish HUIZAR, deter him from engaging in such conduct again, and to make an example ofhim to others. 1. The Plaintiff also requests costs and attorney fees, as allowed by FEHA forthe Plaintiffs prosecution of this action in reference to the FEHA code violations described herein.. Plaintiff demands a jury trial and the amount in controversy exceeds $,000..

8 1 1 Plaintiff respectfully requests the following relief: 1. For special damages in an amount according to proof for Plaintiffs loss ofpast and future earnings, loss ofjob security and all damages flowing therefrom;. For all general and special damages to compensate Plaintiff for any injuries, medical expenses, suffering and related damages;. As only against Defendant Jose Huizar and DOES 0-0, for punitive damages, as allowed by law, that will punish, make an example of, and deter future conduct by HUIZAR;. F or all interest as allowed by law;. For all costs and disbursements incurred in this suit;. For attorneys' fees;. For such other and further relief as the Court deems just and proper. DATED: October,1 1.

9 VERlFICA TION I, the undersigned, declare: I am a Plaintiff in the above-captioned matter and I am familiar with the contents ofthe foregoing document entitled. The information supplied therein is based on my own personal knowledge and/or has been supplied by my attorneys or other agents. The information contained in the foregoing document is true, except as to the matters which are therein st~ted on information or belief, and, as to those matters, I am informed and believe that they are true. I declare under penalty of perjury, pursuant to the laws of the State of California, that the foregoing is true and correct. Executed on October,1, at Los Angeles, California

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