Free Certificate of Service - District Court of California - California

Case 3:08-cv-02845-WHA

Document 3

Filed 06/10/2008

Page 1 of 2

1 HANSON BRIDGETT LLP
DIANE MARIE O'MALLEY - 139166
2 domalley~hansonbridgett.com

JAHMAL T. DAVIS - 191504
3 jdavis~hansonbridgett.com

425 Market Street, 26th Floor
4 San Francisco, CA 94105
Telephone: (415) 777-3200

5 Facsimile: (415) 541-9366
6 Attorneys for Defendant

GOLDEN GATE BRIDGE HIGHWAY AND

7 TRANSPORTATION DISTRICT

8 UNITED STATES DISTRICT COURT
9 NORTHERN DISTRICT OF CALIFORNIA

10 SAN FRANCISCO DIVI510N
11 DOUGLAS ALARID,
12 13
v.

No. CV-08-2845-EMC

Plaintiff,

CERTIFICATE OF SERVICE RE DEFENDANT'S NOTICE OF FILING OF NOTICE OF REMOVAL OF ACTION TO FEDERAL COURT

14 GOLDEN GATE BRIDGE HIGHWAY
AND TRANSPORTATION DISTRICT; 15 MICHAEL LOCATI; DAVID RIVERA; KAY WITT, and DOES 1 through 50,

16 inclusive,

17 Defendants.
18
TO THE CLERK OF THE UNITED STATES

DISTRICT COURT FOR THE

19

NORTHERN DISTRICT OF CALIFORNIA:

20
21

PLEASE TAKE NOTICE THAT, pursuant to 28 U.S.C. § 1441(b), on June 9, 2008, Defendant GOLDEN GATE BRIDGE HIGHWAY AND TRANSPORTATION
DISTRICT ("Defendant"), by their undersigned attorneys, filed a Notice of Filing of Notice

22

23
24 25 26 27 28

of Removal of Action to Federal Court with the Clerk of the California Superior Court, in

and for the County of San Francisco, a copy of which is attached hereto. Defendant also

served Plaintiff with the Notice of Filng of Notice of Removal of Action to Federal Court
including the following attachments:
Exhibit 1: Notice of Removal of Action by Defendant Golden Gate Bridge

- 1 -

CERT. OF SERVICE RE DEF.'S NOT. OF FILING OF NOT. OF REMOVAL OF ACTION TO FEDERAL COURT

1486922.1

Case 3:08-cv-02845-WHA

Document 3

Filed 06/10/2008

Page 2 of 2

1 Highway and Transportation District with the following exhibits:
2
3

Exhibit A: Summons and Plaintiff's Complaint;

Exhibit B: Summons served on Defendant;
Exhibit C: Defendant's Answer to Plaintiff's Complaint

4
5

Exhibit D: Case No. CGC-08-473761 - Civil Case Cover Sheet, Notice
to Plaintiff of Case Management Conference; Alternative

6 7
8

Dispute Resolution (ADR) Program Information Package; (Blank Form) Stipulation to Alternative Dispute Resolution;

Notice regarding Judicial Mediation Program: San Francisco County Superior Court

9 Exhibit 2: Order Setting Initial Case Management Conference and ADR

10 Deadlines; Standing Order for Civil Practice in Cases Assigned for All Purposes to
11 Magistrate Judge Edward M. Chen; Standing Order for All Judges of the Northern

12 District of California - Contents of Joint Case Management Statement; Notice of
13 Assignment of Case to a United States Magistrate Judge for Trial; (Blank) Consent to
14 Proceed Before a Magistrate Judge; (Blank) Declination to Proceed Before a Magistrate

15 Judge and Request for Reassignment to a United States District Judge; U.S. District
16 Court, Northern California - ECF Registration Information Handout; U.S. District Court,
17 San Francisco, Guidelines Handout; Sheet with Judge's name and initials and location;

18 U.S. District Court, Northern California of California, Drop Box Filing Instructions;
19 Consenting to a Magistrate Judge's Jurisdiction in the Northern District of California.

20
21

DATED: June 9, 2008

HANSON BRIDGETT LLP

22 23 24 25 26 27

MARIE O'MALLEY a MAL T. DAVIS

~.

ttorneys for Defendant
GOLDEN GATE BRIDGE HIGHWAY AND TRANSPORTATION DISTRICT-

28
-2CERT. OF SERVICE RE DEF.'S NOT. OF FILING OF NOT. OF REMOVAL OF ACTION TO FEDERAL COURT

1486922.1

Case 3:08-cv-02845-WHA

Document 3-2

.-;:.:Filed 06/10/2008

Page 1 of 4

1 HANSON BRIDGETT LLP
DIANE MARiE O'MALLEY - 139166
2 domalley(§hansonbridgett.com

JAHMAL 1. DAVIS - 191504
3 jdavis(§hansonbridgett.com

ENDORSED FILED SUPERIOR COURT COUNTY OF SAN FRANCISCO
JUN 0 9 2008

425 Market Street, 26th Floor
4 San Francisco, CA 94105
Telephone: (415) 777-3200

5 Facsimile: (415) 541-9366
6 Attorneys for Defendant

GORDON PARK~L1t CLERK

6Y;.

. Deputy Clerk

GOLDEN GATE BRIDGE HIGHWAY AND

7 TRANSPORTATION DISTRICT

8 SUPERIOR COURT OF ,CALIFORNIA, COUNTY OF SAN FRANCISCO.

9 UNLIMITED JURISDICTION
10 DOUGLAS ALARID,
11

No. CGC-08-473761
DEFENDANT'S NOTICE OF FILING OF NOTICE OF REMOVAL OF ACTION TO FEDERAL COURT

Plaintiff,
v,

12
13 GOLDEN GATE BRIDGE

15 inclusive,

HIGHWAY AND TRANSPORTATION DISTRICT; 14 MICHAEL LOCATI; DAVID RIVERA; KAY WITT, and DOES 1 through 50,

16 Defendants.
17
18

19 TO PLAINTIFF DOUGLAS ALARID AND HIS ATTORNEYS OF RECORD AND
20 TO THE CLERK OF THE SUPERIOR COURT, IN AND FOR THE COUNTY OF SAN

21 FRANCISCO:
22 PLEASE TAKE NOTICE THAT Defendant has filed a Notice of Removal of the
23 above-captioned action from the Superior Court of the State of California, County of San

24 Francisco, on June 6, 2008. A true and correct copy of Defendant's Notice of Removal

25 is attached hereto and incorporated herein as Exhibit 1. The proceedings have been
26 removed from this Court to

the United States DistricíCourt for the Northern District of

27 California as Case No. CV-08-2845-EMC and shall be governed hereafter by the District

28 Court's orders, attached collectively hereto as Exhibit 2.
- 1 -

DEFENDANT'S NOTICE OF FILING OF NOTICE OF REMOVAL OF ACTION TO FEDERAL COURT

1485847.1

Case 3:08-cv-02845-WHA

Document 3-2

Filed 06/10/2008

Page 2 of 4

1

DATED: June 9,2008
2
3

. HANSON BRIDGETT LLP

4
5

ARIEO' AL 1. DAVIS

~orneys for Defendant
GOLDEN GATE BRIDGE HIGHWAY AND TRANSPORTATION DISTRICT

5 7 8
9

10
11

12

13 14
15

15 17 18 19

20
21

22 23
24 25 25 27 28
-2DEFENDANT'S NOTICE OF FILING OF NOTICE OF REMOVAL OF ACTION TO FEDERAL COURT
1485847.1

Case 3:08-cv-02845-WHA

Document 3-2

Filed 06/10/2008

Page 3 of 4

PROOF OF SERVICE
2 I, Joanne Leong, declare that I am a resident of the State of California. I am over the age

of 18 years and not a party to the action .entitled DoÚglas Alarid v. Golden Gate Bridge Highway 3 and Transportation District, et al., San Francisco Superior Court, Case No. CGC-08-473761; that my business address is 425 Market Street, 26th Floor, San Francisco, California 94105. On 4 June 9, 2008, I served a true and accurate copy of the document(s) entitled:

5 DEFENDANT'S NOTICE OF FILING OF NOTICE OF REMOVAL OF ACTION TO FEDERAL COURT
6 7
8

in this action by p~cing said copy(ies) in a sealed envelope, each addressed to the last address(es) given by theparty(ies) as follows:
David M. Poore, Esq.

Kahn Brown & Poore LLP

9

755 Baywood Drive, Suite 185
Petaluma, California 94954

10

11
12
13

IR

14 15 16

(By First Class Mail pursuant to Code of Civil Procedure section 1013.) I am readily familiar with Hanson Bridgett's practices for collecting and processing documents for mailing with United States Postal Service. Following these ordinary business practices, i placed the above referenced sealed envelope(s) for collection and mailing with the United States Postal Service on the date listed herein at 425 Market Street, 26th Floor., San Francisco, CA 94105. The above referenced sealed envelope(s) wilLbe deposited with the United States Postal Service on the date listed herein in the ordinary course of business.

o

17
18

(By Overnight Federal Express pursuant to Code of Civil Procedure section 1013.) I deposited each sealed envelope, with instructions to our Mailroom that the packages were to be picked up by Federal Express for overnight delivery.

19

o

20
21

(By Express Mail pursuant to Code of Civil Procedure section 1013.) i deposited each sealed envelope, with the postçige prepaid, to be delivered via UPS to the party(ies) so designated on the service list.
(By Telecopy Fax pursuant to Code of Civil Procedures section 1013.) I am readily familiar with Hanson Bridgett's practice for processing of documents via

o

22
23

Telefax. Following these ordinary business practices, I directed that the above
referenced documents(s) be placed in the Telefaxmachine, with àll costs of

24
25

Telefaxing prepaid, directed to each of the party(ies) listed on the attached service
list using the last Telefax nLimbers(s) given by the party(ies), and processed through the Telefax equipment, until a report is provided by that equipment

indicating that the Telefax operation was successfuL.

26 27
28
- 1 -

PROOF OF SERVICE

1485924. i

Case 3:08-cv-02845-WHA

Document 3-2

Filed 06/10/2008

Page 4 of 4

1

D

(BY E-MAIL) I am readily familiar with Hanson Bridgett's practice for processing of
documents via electronic mail (E-Mail). Following these ordinary business practices i personally e-mailed a copy of each document to each of the parties listed on the above-referenced service list by sending the documents directly to them at their email addresses listed above.

2
3

4
5

is true and correct and was executed on June 9, 2008

i declare under penalty of perjury under the laws of the State of California that the above in San Francisco, California.

6 7
8

9 10
11

rr~LY:r

12
13

14
15

16 17 18

19

20
21

22
23

24
25

26

27
28

-2PROOF OF SERVICE
1485924.1

Case 3:08-cv-02845-WHA

Document 3-3

Filed 06/10/2008

Page 1 of 48

Exhibit 1

Case 3:08-cv-02845-WHA

Document 3-3

Filed 06/10/2008

Page 2 of 48

/
.";..

1 HANSON BRIDGETT LLP
DIANE MARIE O'MALLEY - 139166
2 domalley§hansonbridgett.com

JAHMAL T. DAVIS - 191504
3 jdavis§hansonbridgett.com

6 2008 .
RIÇHARD w. WrEI''N
,~! r.. R:/ 110' r)i".i"'. ..

425 Market Street, 26th Floor 4 San Francisco, CA94105
Telephone: (415) 777-3200 5 Facsimile:. (415) 541-9366
6

NOnl HEHN DISTRiCT OF CAL/FO NIA

~:.;._;'" ,....). , ,,:) ¡,ieT COUR

Attorneys for Defendant GOLDEN GATE BRIDGE HIGHWAY AND
UNITED STATES DISTRICT COURT

7 TRANSPORTATION DISTRICT
8
9

. NORTHERN DISTRICT OF CALIFORNIA

E

c

10
11

SAN FRA~VCO r¡1~N

DOUGLAS ALARID, . No.. I:,J
Plaintiff,

2845

12

13. v.
14 GOLDEN GATE

NOTICE OF REMOVAL OF. ACTION TO FEDERAL COURT

BRIDGE HIGHWAY AND TRANSPORTATION DISTRICT;
KAY WITT, and DOES 1 through 50,

15 . MICHAEL LOCATI; DAVID RIVERA;

16 inclusive,
17

Defendants.

18

19 . TO THE CLERK OF THE UNITED STATES DISTRICT COURT FOR THE

20 NORTHERN DISTRICT OF CALIFORNIA:

21 PLEASE TAKE NOTICE THAT Defendant GOLDEN GATE BRIDGE HIGHWAY.
22 AND TRANSPORTATION DISTRICT (hereinafter "Defendant") hereby removes to this
23 Court, on the basis of federal question jurisdiction, the

state court action described

24 below:

25

1.

State Court Action: On March 28, 2008, Plaintiff DOUGLAS ALARID

26 (hereinafter "Plaintiff) commenced this action in the Superior Court for the State of
27 California, in and for the County of San Francisco, e.ntitled Douglas Alarid v. Golden

28 Gale Bridge Highway and TransportationDistrict, et al. , Case No. CGC-08-473761. A
- 1 -

NOTICE OF REMOVAL OF ACTION TO FEDERAL COURT

1468441.1

Case 3:08-cv-02845-WHA

Document 3-3

Filed 06/10/2008

Page 3 of 48

. 1. true and correct copy of the Summons and Complaint filed by Plaintiff is attached hereto
2 as Exhibit A;

3 2. Timelv Removal: Defendant was served with a copy of the Summons and
4 Complaint on May 9, 2U08. A true and correct copy of the Summons served upon

5 Dèfendant is attached hereto as Exhibit 8;
6 3. Answer: On June 6, 2008, Defendant filed an Answer to Plaintiffs

7 Complaint with the Superior Court of the State of California in and for the County of San

8 Francisco and served such Answer upon Plaintiff. A copy of the Answer and

9 accompanying proof of service is attached hereto as Exhibit C;

10 4. Jurisdiction: This is a civil action over which this Court has original
.11 jurisdiction under 28 U.S.C. §1331. In the Complaint, Plaintiff alleges violations of the
12. Family and Medical Leave.

Act 29 U.S.C. §2601 (Ex. A, 9:14 - 10:22) and federal civil

13 rights statutes 42 U.S.C. §§ 1983, 1985. (16:13 - 17:13.) Accordingly, this entire action
14 is removable to this Court pursuant to the provisions of 28 U.S.C. §1441 (b) and 28 ,
15 U:S.C. § 1367.
16 5. Venue: . Venue lies in the United States District Court for the Northern
. 17 District of California in that a substantial part of the alleged events or omissions on which

18 Plaintiffs claims are based occurred in San Francisco, California. 28 U.S.C. §1391 (b);
19 6. Intradistrict AssiQnment: Pursuant to Civil L.R. 3-2(d), this action is proper

20 in the San Francisco Division because the action arose in the County of San Francisco;
21 7. Pursuant to 28 V.S.C. §1446(d), a copy of this Notice of Removal is being
22 fied with the Clerk of the Superior Court of the State of California, County of San

. 23 . Francisco;

24 . 8. Pursuant to 28 U.S.C. §1446(d), Defendant is providing written notice to

25 Plaintiff;
26 9. State Court Documents: Pursuant to the provisions of 28 U.S.C. §1446(a),

27 Defendant attaches herewith, and incorporates by reference, the following documents,

28 which are all process, pleadings, and orders served on Defendant and filed in the
NOTICE OF REMOVAL OF ACTiON TO

FEDERAL COURT 1468441.1

-2-

Case 3:08-cv-02845-WHA

Document 3-3

Filed 06/10/2008

Page 4 of 48

1 Superior Court of the State of

California in and for the County of San Francisco prior to

2 the filng of this Notice of Removal:

3

a.

Summons and Plaintiffs Complaint: San Francisco County Superior

4 Court, Case No. CGC-08-473761 (Exhibit A);

5

b.

Civil Case Cover Sheet, Notice to Plaintiff of Case Management
..

. 6 Conference; Alternative Dispute Resolution (ADR) Program

Information Package; (Blank

7 Form) Stipulation to Alternative Dispute Resolution; Notice regarding Judicial Mediation
8 Program: San Francisco County Superior Court, Case No. CGC-08-473761 (Exhibit D);

.9 and;
10
c.

Defendant's Answer to Plaintiffs Complaint (Exhibit C).

11 .10. Service: Written Notice and Proof of Service of the filing of this Notice of

12 Removal by Defendant has been or wil be served upon all parties as required by law.

13 WHEREFORE, Defendant respectfully requests that this action now proceed
14 against DefendaJit in this Court as an action properly removed.
15

16 DATED: June 6,2008
17
18 19

. HANSON BRIDGETT LLP

ARIE O'MA EY
MAL T. DAVIS

20
21

Attorneys for Defendant
GOLDEN GATE BRIDGE HIGHWAY AND TRANSPORTATION DISTRICT

22 23
24

25
26 27
28
-3NOTICE OF REMOVAL OF ACTION TO FEDERAL COURT
1468441.1

Case 3:08-cv-02845-WHA

Document 3-3

Filed 06/10/2008

Page 5 of 48

Exhibit A

Case 3:08-cv-02845-WHA

Document 3-3

Filed 06/10/2008

Page 6 of 48

$~MMONS
.

(
_ COr~f 0N,.

SUM.100 .
(SOl'A/ usoii &A t'l'

HOTICE TO DEFENDAN:: . . .
and DOES. i through 50, inclusive

. .. (CITACION JUDICIAL)

GOLOBN GATE BRIDGE HIGHWAY1\ TR1SPORTATioi~ . DISTRICTi'MICHL LOCTtlDAVID RIVERA, KAY WITT,

(AV1S(J AL DEMANDADO): . . ....

I
i

!

,
i

\, .

i
i

.1

yOU ARE e~iNG SUED BY PlINTIFF: (LO ESTA DEMANDANOO EL DEMANDANTE): .

DO$LAS AIID'.

. Yoi ti.lve ~ CAlENDARD.lVS a!\ thl, au .iid i.l ~... l-ld OI

you tø IIn wr"M ...po.. i. thl, li.ltld Iiavi.

Cop Hf.d ~ lhe pblntll. A len.. 01 ~ An..1S rd.ptte you Yrx wrn fnpO mvit ~ In pn)p.~d.gal for If yo,"wa"lll.
ÇQl0...JI.yOU (;M. Thl11N ii. c; to"'at yo un Ul fOl).our rt'li.You UA nnd 1M.. cOrt to aDd mo

Inf()lon M lhe C,liromÏl COO OnIl :Jlflp C."" ~.~o.u.~..,"p). you couty l-llb.ry. Or tli eoOU

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Tli ... 0('*.1 ielr.tm YOU ma wa to can an lIOMJ rl li." you dG n'" tnmnn Ittor, rOI ma wim to un in .ttor~ ""~"lf~. If you i:nnii afd .1l'lllony; you NY be .ii1bl fa fr lel Mtcnftom ai'llol ''' ~t.. .

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..T~ name st iirt5 of the c;iUs: ~! HUA: .. (E;Irie ydrecde Ia ro6 fl$l: . . (H..dicrI'
San Francisco superior CQU~t, ofCalifornia 400 McAllister Street

San F:Cnçisco,Californ1.a.
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,BY FAX

David M" Poore, E:iq.,SDN.l!J2541 (70.7) 763-7100 '
Kahn BrOwn &. Poore LLP .

.. petalumahnCi)lif~ia 94954 OATE~ . 11 I. Ö Ll . .. -L\ See/&r

755 BaywOod Drive. suite. ias

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(P9f9 preba de &tlrog dl1 8sla cJÐ'i6 use eI 'o,"lUlab Prf of Serlçe of Summon, (POS-OID)).
. HOl1CE TO llE pERSON SERVED; Yoo Ðre se .

1. 0 8$ 8nlt'ol dofonan .
3. 0 onboalf of (spe): .

2.0 85 lh ~ wGc \lndeith fictitious nama of (spy):

\lnder 0 CCP 416.10 (çer&\io) 0 CCP -416.60 (mInor)
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o CcP.4 15.-40 (assoation Of pertner'N 0 CCP 416.90 (lllhr1iOO pon)

4. n by penal delIV on (date): .

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.----_.._.--- .

SVMMO.tlS

~&~ . Cl .

Case 3:08-cv-02845-WHA

Document 3-3

Filed 06/10/2008

Page 7 of 48

. ENP-0R~Q
si¡iriorCóUrl L.T'
COnl of San ri'-o

FL

. 1 David M. Poore, SBN .192541

. KAHN BROWN & POORE LLP . 2 755 BaywóodDnvè; Suite 185

MAR 2 8 2006

Petåluma, California 94954 3 Tel~hone:(701) 763-7100
. Facsimile: (707) 763-7) 80

R.v.. -- f) i (g I;
i;r. . . .. ..~?E!!:¥ ~ e:~

.eeRl3eNPAR~l:l elar.k

4 dpco-le~kahnbroWninw.com
5

CAMAOE (DSI
. AUG2 9 2008 ..9~p.

Attorneys for Plaintiff
ALARID.

, 6 DOUGLAS

7

8.
9
10
11

SuPERORCOUR'l OF ÇAUFORNJA- COUNT.OFSANFRCISCO

. .. DEP21~
UNTED JUnicrloN

".
DOUOLASALARro,

Cas~No. OGO..O B -47 37.~ 1

l2 Plaintiff:
.13
14

EQUITABLE, AND/OR lNJUCfIV .RELlEF

COMPLA FORDAMAGE,. ...

v.

VlOLATIONS OF GOVENM CODE

15

PREVENT AN INTIGATE HASSME; VIOLATIONS Ç)F THE
GOLDEN OÀ TE BRIDGE HIGHWAY AND ..

SECTON 12940, E~ S£Q.; FAILUR TÒ .

CALIFORNIAFAMILYRIOHT ACl,

16 .TRANSPORTA nON DlSTICT; MICHAL

LOCATI;.DAVIRIRA: KAYWT: and

GOVENT CODE SECTION 12945.1.
ET. SEQ.;VlOLATIONS OF 42.U$.C. §§ .. .

J7
)8

DOES 1 thrugh 50, inclusive, ..

..1981, 1983, 1985~ETSEQ_: VlOLAllÖNS . OF TH CAUFORN CONSTITUTION;

Defendants.
19

. .. VlOLATIQNSOF CALIFORN. LAOR TH pAIR CODE § 233; VIOLATIONS OF . LAOR STANDARS ACT, 29 V.S.C. §
. 2 i 5: VLOi: nONS OF THE. F AM Y MEDICAL LE Vg. ACf, 26U.S.C. §§2601, . ET SSQ.; VIOLATIONS OFCIlL CODE

20
21

SECTION 1708.8 . '~l' .. .

22
23

JUY TR ))EMAED

..' n

,:-j ,.

24 . PlaintiffDOUOUS ALÁRID complaini.an al1cges(1i follows:
.25
26

lARTlES AN JUTsmClON
1.

I.

27

P¡aintitTDOUGLAS .ALA is. and at-all re(ovant times hero,has bee B
Cali fomi

28 resdent ofthii State of

a. PluintiffAlnrd was an employee of defendimt GOLDEN

. -) - ..
COMPLAINT F:OR D)'M~OE, EQtJABtE AN lNJUcnv.s RELI

Case 3:08-cv-02845-WHA

Document 3-3

Filed 06/10/2008

Page 8 of 48

GATE BRIGE IDGHWA¥ AND TRASP,ORTATJON DISTRICT ("Golden Gate Bridge" or
i. "defe1ldant") within the meaing of California Fair Emp)oymeitand Housing. Act ("FERA"),.

3
4 meaning of

2..

. . .. .
_.
Defendant Golden Gate Bridge, inCluding

At aU relev~t times~ defendat Goldèn Gate Bridge w~ án employe; wiùiin the

the California Family R.ights Act C"CFRA"), and, as .sucp, was prôhibited from

5 harssing, discrminating and retaliating in employment

on the basis of disabilty/medical

6 cöndition association or asseIiiig fai:ily leave rights. Defendant was also an employer within thc
7 meaning of

the Family Medical Leave Act of 1993, 29 V.S.C. Sections 2601, ct. scq. ("FMLA"),
employed, at all relevant

8 in thatitís engageØ in industr affecting interstate commerce and has

9 times,

over 50 employees to quality as an employer urder the FMLA
. 3.

10

its deparents, units, and/or poHticai

i i subdivisio.ns, are and at nIl relevant times hereto. were employer operting.3s públicen~ities
12 within the State ofCalifomiii, County of

13persòIÌs.
.14
.IS

4.

Defendant Golden Gate Bridge is a COUDty muIicipality Iocate(lwithin the State

Califoriia ~d doing business as a govemtent entity

16 5.. Defendant MICHAEL LOCA TI ("Locati" or'~defendant") is an individual whose
i7 resid~nc.e is loctedïn the State.ofCatifomia. Defendant l.ocati is.

.i 8 employee of

the Golden

. . . . . .' .. . . . - .. .
under color of state authority and law.. .
Gate.Bridge. For puroses of the cause. of action the Golden Gate Bridge,

San Fracisco, who regUlady employed moretMri five

of
;

a suerisOr and(0rmanageral

under the Civil Rights

19 Act, defendant LOcflti is being sued in his individual capacity acting under color oJlaw.
20 6. .At all relevant times herein, defendat Loeati was.a supersor,.manager, and/or
21. managiIlgagent of

and as such was prohibited from harassing and
the .

22 i'ctaliatin~ against employees ori the basis ofniakng complaints -reg.iUdii.g violations of

23. . CiiifoIDa Fair Employment and Housing Act.

24 :

7.

Defendant DAVID RIVERA ("Rivera" or "defendant") is an individual whose

.25 . residence is located. in the State ofCalifomia. Defendant

Rivcra is a superisor and/or

26 manageral employee of the

Golden Gate Bridge. For puroses of the cause of action under the

27 . Civil RightS Act, defendant Rivera is being sued iillúsindividual capacitY acting under color of.

28 Jaw.
-2-

COMPLAT roR DÄMGE, EQUIABLE, AN INJUCTREf

Case 3:08-cv-02845-WHA

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Page 9 of 48

2 managing agent of

. 3 retaliating against employees on the basis of making complaints reg¡iding. violations of the

... .. . . ," . .
the G~lderi GateBrldge, and as such.was prohibited tìom harssing

4 Ciifonúa FaiiE,ployment and Housing Act. .

..5. 9. . .uetèndant KAY Wl1T("Witt" or "defendant") is an individual whose residence is.
6 located

7 the Golden Gatè Bridge; For pUfposesQfthe cause of action. under theCiviiRights Act,
8 defendant Witt is being .sued in her individual capacity acting under color ofIaw.
9 10. . At all relevant

. " . . . .. .. . . . ..
the n .. This Court has jurisdiction and

8. At aU .relevant times. herein, defendant Rivera was a supcrisor,managcr, and/or

and

in theBtate ofCaiifomi~. D~fe~dant Witt is a supervisor and/or manngeralemployee of

times herein, defenøant Witt was a supersor, manager, ard/or .

10 managing agent of

Golden Gate Bridge, and as such was prohibited frmhiissing ~d

11 rct.iatbig against employees on the basi.s of ~akng complaints regarding violatio~s of tht!

. 12 Ciiiforiiia Fair Employment .and l:oUsing Act.

13

14 . Gate Bridge .emp1oyed plaintiffwith.n the Couiity ~f San Francisco, SI~te of C.alifornia. ..
1512. . Plainiiffbasex~aUsted all ad~iJJJstri~e.remedies with the Deparent of

.16 EmpJoynent and Housing ("DFEH;'). Plaintiff

17 DFEH;DFEH investigated the charge foÚpproximately one year; an~ plaintiffhas fied tms
18 action withn one year of the

19

. 13.

20 corporate, parership, individual or ot11~ise, of defeIdant. sued her~in as DOES i through 50~
21 inclusive. and for this reaSon sues each

. .. . . . . .
filed ii tiIely administrtive. charge with the
issuance of tbe n8ht~to-sue letter.

venue over tls action in that defendant Goidei .

..

Fair

PlaintIfdoes not know the true names, capacities and identities, whether

defendant by such fictitious names in accrdance with

24 Section 474 of

the Code of Ci~j P~oced~re.. Plainiiffi~ informed and believeS. and on thiit basis

23 àlieges, that.each of

the. fictitiously-named defèndants is legally resonsible for the .events and

24 actions refered to in this Complaint and wrongfully caused injury and damageS to plaintiff as
25 alleged below. Plaintiff

will seek leave t~ amend this complaint to stte these dctèndants' tre

26. names and capacities

when they are ascertained.
Plaintiff is infonned ard believes, and thereby alleges that each of

27

14.

the defendants
and employees. of

28 herein were at all times relevant hereto, the agents, representatives, serants

the

-3COMPLA

FOR DAMAGE, EQUITABLE, ANOJNJÙCT RELIEF

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:-

.Temainin~ defendants, and Were acting at least in p~ within the Cour~e and scope of such
2 relationslnp., and that the

wrongfl acts alleged herem wereconuittea by such defendants, and

...

-.

3 each of

them. Furtherore, plaintiff

is infonned lId believes that defendants were; at allrelevant
purses otFEHA.

4 . times, one integrated enterprise and/or employer for

5

6
7

. 8 . r~levant times, piiûntiffwas Ii Hispanic male that asociat~ with. a family member who suffers.
9 fr~ a disabilty and/or medica1 condition, in~i~ding requesting medical leave .to cae fOT t;iit

10. .fumily member. As such, plaintiff was a member of a protected category for purses ofF:HA.
11

. .. . . . ..
FACTUAL BACKGROUND
15. 16.
On or abut November 7, 2002, plaintiff was

PlaintiffAlard.is a former employee of defendant Golden Gate Bridge. At all

hired as a Bridge Patiol Offcer,a

iilawenforcemenfposition, fOT the Golden Gate Bridge. . At the time that plaintiffbegnn his
13.cmployment and t!lrQughQ~t his employment

at the Goiden Gate Bndge, pl~ntiffwas:quiilified tó .

14 work in thsJaw enorcement position. Throughouthisemployment with the Golden Gate

15 Bridge, plaintiff dílgently and competently performed his duties, and received pay increases in

16 . aècordance with his pcrorm~ce. Plaintifffurter recived consistent praise regarding his
17 abilities ard skil level, and was provided

with excelleo;i evaluations for his peroimance.

18.

17.

.19 Bridg~ Sergeat, a supervsory title at the Golden Gate Bridgc Distrct. Plaintiff met the
20 quaifications for promotion, and was ~ventuàlly forwarded to the final oral board for a panel

. .
On or about January

20, 2005, plaintiff applied for a promotion to the position of

21 interiew.
22
18.
Once plaintiff arved at the panel interew for promotion, he noticed that

23 defendant Locati' s wife,. Lisa Locati, wßS a member of the oral board. Plaintiff believed that this . 24 . assignent may have been imprope becau.se plaintiff had previously been involved in an internal
25 . giev~ce and complaint

regarding defendant Locati. During the ora board, it Was obvious that.

26 defendant Locati's wife was not neutral and unbiased. Instead, thoughout the oral board,
27 defendant Locati's wife consistently made inappropri.ate and demeanng remarks and comments
28. towards plaintiff in an attempt to prevent him from obtamng a promotion. Plaintiff is informed

-4. CoMlLATFOR DAMAGE; EQUIABLE; AND IÑJUCTI RELIEF

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-and believes that .defend~is placed Mrs. Lociiti on the o~ board for ile puroses of

denying

2 plaintiffs promotion.
3
. .19.
In late-Februar and March 2005, plaintiff

fied an internal complaint with

4 defenda:~ts.requesting,that defendant Loeatl's wife b.e removed from the oral board, and that any
5. oral board results be inyaJidiit~~

6 . 20. Defendants ignored plaitiffs concerns. and: instead en~aged in repeated acts of
7 retaliation and haassment towards plaintitfbased upon.his complaints.and his race and/or
8 riationalorigin. Moi:eover, defendants failed to reasonably investigate plaintiffs complaint, iid,
9 instea, allowed the harassing conduct to continue. Asa.resul11 plaintiff

1o

promotion, and was not provided with a promoÙon board tJat was fair and impartal,

i1

21.

On or about April 15, 2005, aft.èr becoming a qualified employee under the FMLA .

12 and/or CFRA, plaintiff applied for the FMLA and/or CFRA leave on an intermittent basis to care
.13 for his elderly mother. PlainIiffprovided defendants with adequate and reasonable written

14 verbalnotIteofthe heed to

15 mother was sufferng from hei disea~ and kidney failure, and required hospitalization for hear .

16 sUrgery;.hear bypass, and. a kidiey.trplant, that required plaintifrs asistace on an

17 . .intermittentbiisis for basic car ánd tratment with daily life activities: Plairliffs mothe)' was
18 . under the continuous

. . . . . . . . .

was denied the

and .

take FMLA und/or CFRA léaveon anintenrittent basis.. PlaihtiWs .

.

19

mother had a chronic sçrous health condition that qualfied plaintiff as an eligible employee for

. . . '. ."
treatment or supervision of a health car~ provider. As a result, plaintl.tls .
medical conditon thaI

20 . purpses of

the FMA ami/or CFRA.

21 . 22. . Plaintiffs mother further suffered frm a di~abiiity and/or

22 substatially limited iierd~i1y life uctivities. Plaintiffs mother's disabiltya.nd medical condition
23 required reasonable accommodations for leave requests so that plaintiff could adequately care for

24 his elderly mother.
25

23.

Plamtifls mother's treating physician completed the necessa paperwork.

for

26 FMLA and/or CFRA leave, and placed plaintiff on interittent leave until March 31, 2006.
27 During this period öfJeave, pJaintiffwas authorized to take increments of

leave thughout the

28. work-week to car for his mother..

_... ~ -5-

. COMPLAT FOR DAMAGE, EQUITABLE, AND lNJUNCT RELIEF

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-.

~.

1 24. Once defendants becae awareotpiaintifls mother's disability .nnd medical
2. . condition, including.his request for iriterittentFMLA and/oi' CFRA leave,. defendants engaged

3 in a campaign. of harsm~nt; realiation, ìnterfe~eiice, imd discrlinatiori ~a direct result of
4 these

protected categories, :and d~:endants bega to iook for :iy.reason however slight to target
of supportng discipline lInd terination.

. . .
to discrmination,
on the basis that

5 plaintiff's employment witl) the goal

.6

.25.

From approximately April 2005, and conti~uing up until the" date of plaintiffs

7 tenn'nation (?DOr about March 30, 2006, defendant~ ~ubjected plaintiff

8. harassment, retliation, and unequal treatment in the workplace

9

mother

. .
other

. .

plaintiffs

had a serous medical conditionanddisabilty/medical condition and plaintíffrequ.ested

10 fàIily and medical leave in accordance with Üle federai and state laws. Defendants fuher ..

11 engaged in a patt~ and practice ?finter~ng with, restrnins, and arbitrarly denying plaintiff
12 . and: sirilarly situted employees farilymedicaJ leave

rights; including but not limited to;

13 (1) treating.employees thatasseied famly medic~l leave nghts differently ¡nthe workplace;

14 ' providing diffeient levels of discipline .for employe(l that asserted farly medical leave rights; .
is : (3)arbiIrarly changi~g the employees' work Schedule or amount of

.. . . .

(2)

hours worked i!l a week to.

16 adverely impact the calculati9n for mediçal leave; (4) falsely i!lfon:ing plaitiff that he had
17 exceeded his allowable fari~y rieØical leave or that he needed to "re-certfi' for leave; (5)
18 engagig in stereotypical cOIDents and atttudes towards

plaintiff and other similarly situatCd

19 employees who took medical and family leave; (6) refusing to provide or providing misleading

20. FMLA infonnation; (7) wrongfully denying medi~alleave despite Üle fact that plaintiff and other
21 simi.1arly situated employees Were qualified and eligìble for continued leave; (8) wrongfully
22 . ¡nfonn pl~intiff of

his sttus regarding his recerfication reuir~ent8 under theFM~Aandior
and other similarly

23. CFRA; (9) treating plaintiff

'situated employee in a hostie and TUd~ maner

24 for takng medical

leave; (10) mÍscharacterzing FMLA and/or CFRA leave; (II) makng

25 imprope and demeaning comments, sl~, and remarks conceing medicalleavc; and (12)
26 engaging in a pattern and practice ofinterferng with plaintiff and other similarly situated

27 employees' rights to FMAandior CFRA leave. Deferidant Golden Gate Bri~ge also changed its
28 FMLA policy without any potice to plaintiff and other similarly situated employees.
COMPLAINT FOR DAMGE, EQUITABLE, AND INJUCT REIEF.

-6-,

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J
2 plaintiff 3 based

26.

During this time, defendants furter diScriminated, haiássed~ and retaliated .against

based upon msnationalorigiand race, including creating a hostirework environment
upn the fact that plaintiff

was a Hispanic worker.
period of

4 27. . Morever, during this

time, plaintif! requested that defendants allow hir

5 to work an outside and

separate par-time job as .3 federal police offcer to supplement his íncòme

6. so that he could adequately care for lusmoth~r's financial and medical needs.
7 28. In

or about iate~December 2005 and Janti.2006. plaintiffsmother's medical

8 . condition began to signri'icatly detenor~te. Plaintiff

9 family medical

leave durg ths perod oftime to cae for his mother.

to 29. Plaintiffs need to take additional and legally permissible intennittent leave was

. ..

was require(lto take

more intermttent

11 .met with hostility ~y defendants.: In early.,Januil 2006, defendants immediately placed plaintiff.
12 . an

an irrproper "sick leave" disciplinar progra that directly affected his rights to FMLA and/or

13 CFRA leave.
. .14 30.. On or about Januaiy29, 2006, p1aintiffrequ~stcd the réàSoriable accommodation
15 of a "shif exchange" Wiil another påtrol offcer so that he could care

for his :mother. The other

16. offc~r.was agIeeable to the shift exchange; and engaging in shift exchanges was a i;ommo:g

17 custom and pr.actice at the Galden.CateBridge Distct.
18

31.

Plaihtiffs request for reasonable acconuodations was.aiso met wìth hostilty,

and

1 g waS ùnlatemlly.denjed without any reaonable e.xplanation. Defendants refued to reasonably

20 accommodate plaintiffs r~ues1, and furter fiÜled to engage in the go?d tàith interactive process .
21 to deìerineile reasonableness of the reauested accommodations, including what.

22 accommodntioJ1s were appropriate under the cicumstances. Insteid, defendants continued to

23 harass, discrminate, and re~1iate agaist plaiItiffbased upon his requests for leave and
24 accommodations.

.26

. 32.

During ths

period oftime, plaiDtiffcontínued to make interal complaints

26 .concemingdefendants' improper actions, but defendants refused to investigate thecòmplaints.
27 and, instead, engaged in adverse actions towards plaintiffbascd upon. his.

protected requests.

. 28
-7COMPLAINT FOR DAMGE, EQUIABLE, AND INJUCT RELIf

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33. Morever, when defend~ts becare aware ofplaiiitifPs internal complai~ts, the
2 . harassment, discriination, interlè1'ence, and1etaJiation intensified and necame worse, in~ludil1g
3 but

not limited io (1) ~ngfully diScplining plamtiff; 0) providing plaintiffwith negative work

. . . .
.'
basis;. (9)

..

4 evaluations; (3) providing plaiiitiffwith a veTbaladmonilion for p~ty and uiim:e allegations; (4)

5 interfering with plaintifPs. use of sick leave ard family-medical leave; (5) opely cnticizing
6 plaintiff

for using authoriied s.ick leave; (6) iiporingplaintiffs mother's doctor's

7 recommendations; (7) targeting plaintiffs employment for ~'discipÍinar action" and ..
8 "termination"; (8) harassing and critícizing plaintiff on a daily

9 .piiiintiffs employment in an attempt to Crte a record for termination; (l0) miiing comments,

10 siurs, and remarks; (1 J) treating plaintiff diffe~ntly thar similáJly siÌuated employees bas~
11 upo~ association~related disabilty, medical condition, and assering fanily-medicalleave rights; .
12 . and

(12) retaliating against plaii1tifffor using perissible and allotted sick leave compensation

.13. time, and requesting reasonable accoIIodations:

14

J5 Ci:RA ¡eave, defendanis.began lookig for any reas~n to taget and terminate plaintiffs
16 employment. In. Januar and Februar 2096, defendants .hired .severnl unkown I'rivate

. ..' . .. . .... .... .
34.
his par-time employment (in which plaintiff

. . .

targeting ~d monitoring

Furermore, after pIaiiitiff madê intemal.complaintSregllding his FMLAand/or.

/ 17 invesiga~ion firms to "ronow" plaintiff andcondu~t "sureilance activities" ?f plaintiff in an
18 atempt to

target his employment. Inparqular, even though plaiiltiffhad prcvíousiyadvised

19 defendant's of

was not eligible for FMLA anØlor

20 CFRA), defendants instnictediheir"privatc investigators" to monitor plaintiff ai.his outside
21 . employment in an attempt t.o support a case of FMLA ."abuse."

22

35.

Dung this time, defendants retained, directed,~olìcited. induce, and/or caused .

23. sev:eral unown private investigators to conduct sucillance of plaintiff and his mother Without
24 any probable cause, reaSonable or ariculabJe suspicion; or anY

25 course of

this investigation, defendants violated plaintifPs right ofpiivacy and captured visual
plaintiff

. .
privacy; DefeIidmts' invasion of

other reasonable basis. During the

26 ima~es of

inside his house, his mother's house, and other loctions in which hc had a
privacy was offensive to a reasonable
in engaging in

27 reasonable expectation of

28 person in light of

plaintiffs circumstances, and was intended to capture plaintiff

-8COMPI,AINTFOR DAMGE, EQÜITABL~, AND INJUCTVE RELIEF

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~.

...

. i. . personal or familal activity that had nothing whatsoever to do with pJaj~tifls employment with
.2 Golden Gate Bridge. .
3

36.

De.tèndarts' surcil~ee confirmed

what they already kne~: plainti1'Í'was
and plaintiff Spent a considerable amount of

4 working a par-time job to supplement

his income,

. ~. time carng for his mother. .

6

.37.

7 without any adequate or

8. categories identified abo~e. Defendants further temiinated plaintiffs émployment based upon

. . .. .
...
fully set fort hereín. .

qn or about MarcbJO, 2006, defendats terminated plwntitf's employment

reasonable due process hearing as a direct result of plaintiffs p~tected

9 false, inaccurte, and Ilisleading reaons, including FM~A "abusc" and. working in an "outside

10 employment" situationwitiout authorization. Plaintiffs terminaton was discrimiiÌatoryand also.
I I in direc reÚ1liation for her previous

complaints of discrminatio'n, harssment, retaliation; and.

i 2 unequal treatment ir the workplace. .

J3
14
15

'FIRST CAUSE OF ACTION

'~,~~;~~t;.r.;g:J~~¡~~~ All defendants) .
38.
Plaintifr¡'ealleg~ and incorpra~s by referenc~ Paragraphs 1 though 37 of

16

this

17 Complait as though

18

19 . Complait ~ though fully set fort herein'.
20
21

..
..39.

Plaintiff real

leges and incorprate by. reference Pargraphs J through 28 of this

40.
41. 42.

Plaintiffwas an .eligibJe employec for pUroses of the FMLA.
PJainiiffs mother s.ffered from a serious medical conditi~n..

22

PJai~tiffwas initially appTovet fOr family medicalleav.e'under tie FMLA by

23 defendants for plaintiff.s mother's serious medical condition.
24
43.

Family Medical Leave Act of 1993,29 V.S.C. Sections 2601, et. seq. prolúbits

25 defendants frminterfcrng, restraing, discrminating or retaliating against an 'employee for
26 exercising family medical leave

rights, or deIiyÌTig an eligible employee's family medica leave.

27 The FMLA furter prohibits an employer from changing its FMLA policies without providing
28rcaonab1e notice to tie affected employees. .
-9COMPLAIN FOR DAMGE, EQUIA.U, AN INJUCT RÉLlEf

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-44... In acting above, defendants violated theFMLA with regard to pi aintiff

when it.

2 discnininåted against plaintiff for assering nghts und~r the FMLA, retaliated against plaintiff in

. 3 takg advers employment actions for plaintiff's exercise of nghts under the FMLA, .interfered
4 . with plaintiffs family mediCal leave, resiriiined plaintiffs family mediCal leave, denied plainÙfls
5 legítimate family medical

leave, and uIfuately terminated plaintifls employment while plaintiff

6 was. on FMLAleaveand in direct Tctaiationfor plaintiff exercisingiis rights und~r the FMLA
7 and making

internal complaints ofFMLA:viola.tions.

8 . . 45. . Defendant Golden Gate 'ßndge further violated the FMLA when it changed its

9FMLA policies and procedures withouìproviding any reasonable notice to plaintiff and other
1o similarly

situated employee.
46,
In acting above, defendant Go1denGatc~ndge has a pattern and practiCê 6.f

11'

.12 violating the.FMLA. Defei1d~t maintainsa.patternand practice of: (1) r.eta1iating against
i:3 employe~ who ex~cise their ~ghts undcrthe FM.LA; (2) interfering with affected employees'
. 14 rights underthe.FMCA; (3) chaigíngthe

FMLA policies and procedur~s; iid (4) discriminating

15 agais(eiployees who hàvc asserted rì~ts under theFMLA.
16 47. As a direct and proximate result of defendants' conduct, plaintiff has suffered

loss

17 .of employment, lost wages and benefits, future wase I~ss, oiler compena~tioiì loss, and aitomey's
18 . feeS and costs.

19

48.

As a fuer direct and proximate result of defendants' .conduct,plaintifr seeks

. io. interes~ statutory damages, liquidated damages, equitable and/or injunctive relief, iid any other

21 . . relief that the Court deems fair and just.

22. ..

'SECONDCAlJSE OF ACTION
(Medical Condition/Disabilty Association Discrmination 7" FEHA ., Defendant Golden Gate
Bridge only) .

23.

24
25

. .
-10-

49.

Plai~tiffreaiieges and incorPorate by reference Paragraphs 1 thrugh 48 oftlus

. 26 Complaint as though fully set fort herein.
27

28
COMPLAINT FOR DAMAGE, EQUITABLE, "NO INJUNCT RELIE

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-I

50.

2 unlawfJ cmploym~t practice for ancmployer to discrminate in the 'ters and conditions of.
3 employment on tlebasis of II medical condition/disabilty associåtion or perceived association.
4 . 51. : Dtfendilt violatcQGoveicnt Code § 12940, et.seq~ with regard. to plaintiff
5 . whei it discrminated against llaintiff on the basis of

6 . . disailty andlor.medi~al condition, and terminated plalitifÍ s empl~yment, and/or took other

7 adverse ~ployment actions against Plaintiff as a resùlt of plaintiffs association or perceived
. 8 assocation with a person thai is a member ofa protècted categorY under FEHA, including .ihè .
9 failure to

.. . . ... . .
Calitomia Goverent Code §§U9Úi(m) and.

12940, ct. seq., provide

that it is an

his assoCiation with a peron thiit has a

-, . .

make rt~aSonabte accommodations.

10

52.

Defend~t's conduct toward plaintiff as aneg~ above, constitu.tesanunlawful
Cali fomi

11 ttp10ymentpTactice in violation of

a Goverent Code § 12940.

12 . 53; ,As a

direct ard

proximate r,esu1tofdefendant.'s co~duct~piaintiffha sutTe~èd loss

13 . Of emplóymênt, indignity, great humiliation and emotional dists miifesting in phys~cal

14. . symplóms.
1 S 54. Defendat's actions have. cauSed and

continue to cause plaintÜf substtiai losses

19 in earings, sIgnificantreputation andprofessiònal injury, .1088 ofptomotional opportuníties and

.17 other eiployrent benefits,.lostwag~s,atiomeys' tees, medical expenses, futlc eangs iid

18 benefits, cost of suit, hurrliation, embarassment an.danguisht all tö his damage in ll amount

19 . according to proof..

20 . Tlß CAUSE OF ACTON
21 (Medicil Co~dition/isabílty Association Harasment - FEHA '-All Defendants)
22 55... Pi£tintifrrealleges and incorporates by ~eference Pargra~hs.1 t.ro~gh 45 of

. .

this

23 Complait as though fully set fort herein.
24
56.
California Govcmment Code §§ 12926(m) and 129400) provide that it is

an .

25 unlawful employment practice fòr anemploy~, supersor; or any eml'loyee to haras any peron
26 on the basis

of association or perceived association 'with a person that is a member of a protected

27 category underl:EHA.

28

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1.

57.

Defendats violated Goverment êode ~ 12940(j) With regard to plaintiff when.

2 they

engaged in s~~ere and perasive conduct towards plaintiff, created a hostile

3 environment for plaintiff and harassed plaintiff

4 perceived asociation with .his spouse, a peron with a disabilty and medical condition as defined

. .

in the workplace on

the basis of

..
work .
substantial

his association or

5 under FEHA.
6

58.

. . . .
Detèndants' conduc~ toward plaintiff a.s all~gedabove, constitutes.

an unlawfl

7 employment practice ín violation of Californa Govenment Code § 12940..
8 . .59.. Asa direct ard proximate result of defendants' harassing conduct, plaintiffh~
9 . súffered loss of employment, indignity, great hmnilation iid emotioniii distress .manfesting in

10 physical symptoms.
11

. 12. . in eaiings, significanfreputatiori andprofessjonril inj~; Joss of promotiomii opportrú ties and. .

13. other employment benefits,lost wages, attorneys' fees, medical expenses, future earings and
.. 14 benefits, cost of

. .
60.
were furter committed by managing agents, risk of

Defendants' ac.tionshave caused and continue to.cnuse plaintiff

losses

suit, humílatíon~ embaraSsment and anguish, ull to their dåmage in an iiount

i 5 . according to proof. ..

I6 61..

The actg.oftle individual defendants only as alleged hérein, were jfiteiitionaJ,

17 18

outrgeous, despicabl~, oppressive; fraudulent, ard done with il wil and intent to injure plaintiff
and to cause plaintitfmentiil anguish,aiiety, and distress. The acts of

19

offcers, or directors of the defendant, or ratifi~ by
disregard of

. . .

the corpiáte defendant

20
21

the defendant at a c~rpràte leveL. The d.efendants' actsweIe done ~n conscious

the.

severe emotionid harm to Plaintiff and with the intent to injure Plaintiff, constituting

22
23 24

òppression, fraud; m~ice under California Civil Code §3294, entitling Plaint.iffto p~iiti~e
damages 8Sto all individuål defendants.
III
/11

.25
26 27

III III

28

II/

. COMPLAIN FOR DAMAGE, EQurrABLE, AND INJUCT RELIEF

- .....

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Case 3:08-cv-02845-WHA

Document 3-3

Filed 06/10/2008

Page 19 of 48

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Bridge

f
2

FOURTH

CAUSE .OFACTION

J. ..... ,.. . . Only). . . . . . . . .. '.
4 .5
62.

(Medic~l ConditionIisabiltyAssociation Retaiation - FEHA- Defendant Golden Gate

6 . Complaint as though fully set forth h~eii:. .

7 63. Californa Governent Code §§ 12926(m) and 12940(h) providés that it is an
8 unawful employment practice for an erployeÙr any other pèrson to

. ~ .' . " ." .
retaliate agaist an
and then \iJtimately terminated pIBi~tiff
then requesting that an

PlaintitlreaJIeges and incorporate by reference Paragraphs 1 through 61 ofthis

9 employee for opposirig anunJawfl employment practice or filing a complaint of discnmination

10 orharllsment.
11

64.

. . 12 involuntarly transfered; demoted, denied prómotionalopportunities, conducted inapproprite
13 discipline imd other iidverse employrent actions,

. .... . .. . . .. . ..
immediate Defendants' actions have caus.ed.and continue to caure plaintiff substantial

Defendants violated Gov~cnt Code § Ù940withregard to Piiltiffwhen they

14 employment as a res~lt.ofmaking complaints

to dCrcndantsof discriinatiÖn, retaliation. unequ¡ii .

. 15 treatent,

and harsmeIit in the workplace and

. .

investigation .

1 6 . and remedial

'meaSures be taken.

17

65..

Defendants' conduct toward plaintiff as alleged abrive, consti~tes an unl~wful.

18 . employment practice iri violation of California Governent Code § 12940. ..

.19

.66.

As å diret and proxilate result of defendants' retaliatory conduct, plâintiff has

20 suffered loss of employment, indignity, great humiiaiion and emotionaJ disn:ess manifesting in
21 physièal symptoms.

22

.. 67.

23 in eaings, significant reputation and professional Injury, loss ofpi-omotionalopportunities and
24 other employment benefits, lost wages,

. 2Sbenefits, cost

of

suit, humilation, embarrsment and anguish, all to theÌr damage in an amount

. .
-13-

losses

attorneys' fees,medical expenses,' futur earngs and .

26 accl'dingto proof
27
28
-cOMPLAlNT FOR DAMAGE: EQUITABLE. AND INJUCT RELIEF

Case 3:08-cv-02845-WHA

Document 3-3

Filed 06/10/2008

Page 20 of 48

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2.

(McdicaLeave Discriination - CRFA - Defendant Golden Gate Bridge only)

. . .' .

F1l'H CAUSE OF ACTION

3 . 68.. PJaintiílreaHeges ard incorprate

4

Complaint as though fully setforthefèin.

5. 69. CaIiforniäGoverIent Code § 1294.5.1, et. seq., provide th~t it is

.6 employment practice for

7 on the basis of

. .. . .
.71.

by reference Paragraplis'l through 67 ofthis .

an un~wful

an .~p1oyer to discriminate in the temis and conditions of emp1QYme'nt

assertng family mtXicaf leave rights under the CaIifomiaFamily .Righls Act.

8 70.' Defbndaht violated GoverentCöde § 12945.1,et. seq. with regard

to plaintiff
asseron of rights una~r the CFRA; and

9. . when it discriminated ~gaint plaintiff on the basis of his

10: term.inated plaintiffs employment, andior took other adverse employment actions ågaiiist

11 plaintiff, including reaonable accomodations.
12

Defendant's.coIiducttoward plaintiff as alleged above, constituteS~nuiùawful

13 . cmployrmmt practice in violation òf California tjovemment Code§ 129~5.2~
14. 72.. As à diret .and proximate result of defendat's conduct, plaintiff

has suffered loss.

15.of employment: indignity, great humliation and eIotion~1 distrcs.s maIfeStlng in physical
. 16 . symptoms, .
17 .

. 18 in earings, signiflcånt reputation and professional injury, Joss ofpromotionaI opportunities.and
19. .oùier,employmentbenefits,

. . .'
73.
75.

DefendaIt's .actions have caused and .continueto cause .plaintiff substantial losses

lost wages, attorneys' fees, medical expenses, future eaings.and

.20 . benepts, cost of suit. htmilation, embarassment and.anguisl1, all to his damage in.an aiount -

21 according to proof..

.22 SIXTH CAUSE OFA.CTioN
23 (Medica Leave Retulintion ~ CFRA ..Defendant Golden

Gate Bndge only) .

ths
24 : 74. PlaíntiffrealleEeS and incorpomte by reference Paragrphs i through 73 of

25 Complaint as thougl fully set fort herein.
26

Californa Goveilent COde § 12945.2 provides that it is an unlawfu
employee for oppsing an unlawfl

27 employÍent practice for an employer to retaliate against an

28 employment practice or fiing a complaint ofrc1ating to aserton of

rights under the CFRA.

-14CÖMPLATFOR DAMGE, EQUÍT'ÂBLE, AND lJiJUCfiVE RE.TEF

Case 3:08-cv-02845-WHA

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Page 21 of 48

76. Defendants violated Govenuent Code § 12945.2 with regard to

pi ainti

fl

when

2 they denied promotional opportties, conducteôinappropriate disCipline and other adverse
3 .

employment actions, and then ultimately terminated plaintiff employment as a resuJt of makng
an

:1. . complaintS to defendants öf violations of the CFRA in the woi:kplace and then i:equesiing that

5.. . immediate jnvestigation ~d remedial ~easures be tak~.
6 77.. .. Defendants' conduct t~w~d plaintiff as alleged above, constitutes an imawfl

7. . employmentpractic!; in vtolation öfCalifomia Government Code. § 1'2945.2. .
8
78.

As a direct and prpximate result of dèfendants' retl:liatory conduct¡ plairtiff has

9 suffered loss of employment, indignty, great humilation and emotioJlal distress

'10. phys.icar symptoms.
i 1

79.

Defendants' actions have caused and continue to cause plaintiff substantial

. .

manifesting in

losses
and

12 in earings, significat reputation and.professional injur, loss of

promotional opportities

.13 other employment benefits~ lost wages, attorneys' fees; medical expni;e~; future eangs and .

14benèfts, cost of s'utt, hunuliatión, embaiiasent. and anguish, aIl to their dam.age in an amount

1 saccrding to proof.

16 SEVENTH CAUSE OF ACTION
17 (Failure to:

Prevent Discrimîation - Defendant SCOE)
80.
Plaintiff

18

incorprates herein by reference all oftheatJegations contained in

. 19. paragraphsl through 79 oflhis complaint as fuIJy set forth

herein.

20

81.

California Governent Code § ~2940(~)et seq., provldethåt itis an unlawful

. .21 . employment praciice for an employer to fail to take all reasonable steps necessary to prevent
12 discrjminatíon, retaliation, ard harassme~t from occurng in the workplace. .
23 82.. Defi:ndant violated GoveITent Code § 12940 et seq., with regard to when

. . .' .
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24 defendants knowigly andreckJessly created a hostile work environment for plaintiff, failed to
25 conduct reaonable and imparial investigations when .pJaintiff complained ahout discriminatory

26 conduct on the part of superisors and management, and failed to take reaonable steps necessa
27 to investigate the misconduct and prevent it from occurrng and continuing: .
28
COMPLAT fOR. DAMAGE, EQUITABLE, AN INJUCTE-RELIEF

Case 3:08-cv-02845-WHA

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1.

-'

83.

Defendant's conduct to'ward plaintiff iid other.similarly situated employees as

2 . iùlegedabOve. constitut~s an. unlawful employment practice in violation of Càlifornia .. .
3. . Goverent Code § 12940.

4

84.

As a .direct and. proximate result

5' 9f employment, indignty, grea humiliation and emotional distress manifesng in physical

.. .
of defendanf s conduct, piaintiff

has suffered loss

6 symptoms.
7

85.

Derendant's actions hàve caused and continue to

cause plaitiffsubst~tiallosses

8 . in earings, significånt reputation and professional.injuI', loss of promotional opportnities and.
9 other employment benëfit~, lost wages, attorneys' tees, medical expenses: futu

.. .

earnings ~d

.10 benefits, cost of suit, humilation, embarrassment and anguish, all to her damage in ri nmount

11 accrding to proof.
12

.13
14
15

EIC'ATH CAUSE.OF ACTION

. .
reference all of

86.

Plaintiftïncorprates herein by

16 paragraph~ 1 tho~gh 85 of tlM Complaint as fully: set forth herein.

l7 87. Defendants actions and railure~ as alleged abov~ c.oiistltute a patter and practice

'". . ': ....'. ',:'. ':. - ":' ; ..":, ":~""'\ .... .. .
of the Civil Rights

. . . .
because of condition thus' treating plaintiff

(Violations of Civil Rights4tws - All Deftidants)

the allegationÙoritaned in .

18 of

violatiòns.

laws ofihe United. StateS¡:A2:tJi&;Ôt,~§'ênlS:3V'l~85';1)efendants

19 while aCting under color of state authority and law wrongflly and intentionally discriminated
20 against and retaliated against plaintiff

his protected categories, including race. national

21 origin, aSsociation disability and medical

in an iieaual manner
constitutes

:22 without any rationaI or ieg:iiin~te basis. Defendiits'.conduct, ~s set fort above,.

23 violations, und~ coloroi law, of plaintiffs rights, privileges, and. immunities guarteed to him
24 .by the FirSt Amendment ofUie United States Constituion rights offreesl'eech and to petition the

25 government for redress of grevances, the equal protection clauseofthe United StateS the Fourteenth Amtmdment ofuie United States 26 Constitution, and the due process clause of
27 Constitution~ Moreover, as set fort above, plaintiffwas denied both substantive and procural
. 28 due process prior to his termination as a public employee because'defendants failed to provide

. .16COMPLAiNT fOR DAMGE, EQUIABLE, AN INilJNCT RELIEF

Case 3:08-cv-02845-WHA

Document 3-3

Filed 06/10/2008

Page 23 of 48

plaintiff

with a heang and/or opportityto be heard pror t~ his teninati~n thus deprivig

. .

.--

2 plaitirr of1.iber and prope rights. '
3. 88.. Defendants' actonsliave caused and continue to cauSe plaintiff substantial losses
4 in eaings; signifi~treputation iid professional injury, loss ~rpromotionaI opportiiities and

. 5 ~ther emplo~eni benefits, lòst wages, ilttorn~~s' fees, medkal expenses, futue earings and
6. ..bencfits, costofsuii, humiliation, embarsment and anguish, all to his damage

. '. . .

in ii amount

7 according to proof.
.8 '89. . As to the individual defendants only, the acts of

. .

this defendant as a1lèged herein,.

9 was intentional, outrgeous, despícable, oppreiisive, frudulent, ard done \Vith il will and intent
io to injUre plalntiffand to cause pJaintiffrnental angui~h, anxiety, and distress.. .Qcfendant's acts

n were done inconsGÍ,?usdisregard .of,the risk ofscvere emotional har to piiüntiff and with the
12 . intent to injure

plaintiff constituting oppression, frudj malice under .califonùa CiVil Code

13§3i94, entitling Plaiiitiffto punitive damages against these defendant only.
)

14
15

NINTH CAUSE OF ACTION
(Violations of the Califonua Constitution,

'16

Ar. I - Defendant Golden G~te Only)

17

90.

PlaintiffincoiPorates herein by reference all the allegations contaiiiet in
set fort herein.

i 8 .paragraphs 1 thruSi 890f ths complaint as fully

19

91.

The Califbrnia Constitution, Article 1, Section 7, provides Ùlat a

public entity may

20 .oot deprive a person of a propery or liber interest

without due process oflaw. Thc.Califomia

21 Constitution :frth~r protects plaintiffs freeom of speech, equal protection, and right of privacy
22 92.. In acting herein, .defendant violated plaintiffs property and libertydue process.

2~ rights in failing to provide pJaiiititfwith adequate procedura and substantive due process prior to
24 engaging in adverse employment actions against plaintiff

and terminating plaintiffs employment,.
privacy, equal protection, and freè speech.

25 and violated plaintitJ's constutiona rights of

26

93.

As a result of defendant's actions, plail1tif seeks equitable and injunctive relief.

27 including but not limited to reistatement and back-pay, and any other damages accol'dingto

28 proof.
-17COMPLAI FOR DAMGE, EQUIA8T.E, AND INJUCT RELæ.i

Case 3:08-cv-02845-WHA

Document 3-3

Filed 06/10/2008

Page 24 of 48

1

.2
3
(Violations of

TENTH CAUSE. OF ActION
the California Labor Code § 233 - Defendant Golden Gate Only) .
allegations

4

94.

Plaintiffinoorprates h~~nby referénce all the

containcdin ..

. 5 pargrphs 1 thugh 93 of

this complaint as fully

set forthherein.

6. 95. . California Labor Code § 233 prohib.its an employer from using permissible sick.
. .7 leaÝeas a basis to discipline an employee, and discriminating or reta1iali~g ~gairist anenployee.
8 that assers rus or- her rights to use allotted

. ..

sick leave. .

9 . 96... .J!1 acting above, defendant violated Californa Labor Code § .233 when it

10 . discrmimitec, retaliated, disciplined, and took adverse employment actions agains plaintiff for
11 using rus aùthorized sick leave.
12

97.

13 in earnings, signific~t reputation and profes.sional injur' loss of

14 . . other empl¡'ynentbenefitS,lost wages, attorneys' fees, medical expenses, future earnings and
15 .. benefis,

. . . .
(Violations of

Dèrendants' actions have caused and coiitinu~ to cause plaintiff substantial losses

.

promotional opportunities and

cost of suit, humil iatiòn, embaiassinent ard anguish, all to his damage in an amoWlt

1 6acoording to proof.
17
18 19

ELEVENTH CAUSE OF ACTION
the Labor Code § ~15:: DefendaIt Golden Gate Bridge)

20

98.

Plaitiffincofporates heretn by rcferencea1lùie allegations contained in

21 pargraphs 1 tlough 970fthis complaint as ful1y set fort herein.
22
. 99.
The.

Fair Labor Standards Act,. LabOr C~de § 215 prohibits an eTplòyer frm .

23 discnminatigor: retaliating against an employee that files an interal complaint with thc
assertion of sick leave
24 employer regarding violations of the compenSation statues, including the

. 25 compensation.

.26 100. . In acting above, defendant violated Lalr Code § 215 when it discriminated,

27 retliated, disciplined, and took adverse employment actions against plaintiff

..

for filing an. internal

28 complaintregnrding defendants' intederence with her allotted sick leave compensation.
-18COMPLAJT FOR DAMAGE, EQUITABLE, AN INJUCTI RELIEf

Case 3:08-cv-02845-WHA

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Filed 06/10/2008

Page 25 of 48

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101. Defendants' actons have caused and continue to cause plaintiff suostiititiallosses
2 . ineamings, significantreputaIion and professional injtiry,lossofpromotiQnal oppoitnitiesand

3 oÙler employment beefits, lost wages, attorneys' fees, medical expenses, future earnings and
4 benefits,cost of suit,humilation, embaraSsment and anguish, all to her damage in an amount
5 according

to proof:

6 . TWELFfH'CAUSE OF ACTION
7 (Violations of ciVil Code Section .1708.8 .. All Defendants)
8
102. Plaintiff

incorporates herein by reference iil the aiiegations contained il .

9. pàragraphs 1 through 10 löfthis complai.Iifas fully set f~rth herein.
10 .103. Defendants violated Civil Code Secion 1708.8 when they impropely plaèCd
11 plaintiff under sureilance and yjoliit~ IDS right of

i 2.. 1 04.

13 105.

14. was intentional, outrageous, despicable, oppressive, fraudulent, and

15 to iiijure plaintiff and to cåuse plaintiff m.ental anguish, aiiety, and distress. Defendants .acts
16 . were dorie in conscious disregard ofthc riskof severe emotional ham to

17 inte~t to injure plaintiff constitutig oppression, frud, malice under CalifoIna Civil Code
18 §3294, entitling PJaintiffto puitiv.e.damages against these deíèndait only.
19

. . . . . .. .
privacy.
As to the individual defendantson.ly, thè aets of

Defendants caused plaintiff damages in accordan~with pro()f at tral.
this defendant

as ailegedherein,

done with il wil and .intent

. .
suit therein;

plaintiff and with the

20
21
Wherefore, plaintiff

PRAYER FORRELlEF
prays for judgment against Defendants, and each ofthcn as follows:

22
23

1. For general damages in an amount according to proÎ; .
2. For special damages in an amoUnt according to proof;
.3. For

24

prejudgment interest in an amount according to proof;

25 26
27

4: For injunctive relief or oiler equitable rdief .according to proof,
and cost of

5~ For reasonable attorney's fees

6. For punitive damàgcs. against individual defendilts only;

28

7. For statuory penalties and any other statutory relief;

-19. COMPLAT f-ÓR DAMAGE, EQUITABLE, AN INJUCTI RELIEf

Case 3:08-cv-02845-WHA

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Page 26 of 48

'1.
8. For such other and furter relief as the

-'cour mily deem proper.

2 9. PJalntiffherebvdemands a trial by jury.
3

4 Dated: March 28. 2098
5

KAHN BROWN & POORE LLP

6
7
8

9 10
.11

12
13

14
15 16 17

.18
19

20
21

22
23

t4
25

26 27
.28

-20U .'COMPLAINTFOR. DAMAGE, EQUITABLE, AND INJUCTE RELIEF

Case 3:08-cv-02845-WHA

Document 3-3

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Page 27 of 48

Exhibit B

Case 3:08-cv-02845-WHA

Document 3-3

Filed 06/10/2008

Page 28 of 48

Ð5/67/2008 12: 41

787753', , dEl

KBP SONOHA

PAGE 81.

Ell

SUMM _."'5.
(G/T AG/O.1~. JUQICIAL) NOTIt;e TO DEFENDANT: .

DiSTIçT~ MICHL LOCATI; DAVID :RIVER; KAY .WITT;

(AVISO At DEMANDADO):. . . . MLOFiNGATE BRIDGE HIGHAY AlTRSlOR'lJ.TION

.lOD8MAY-g rit4:io

and OOES.1 through SO , inclusive .

SEGRtTARY OF'

THE DISTRict,:. .

.fta.~ fl(, vvæ
YOU ARE BEING SUED BY PLANTIFF:

DOUGLA ALID .

(LO EST Á DEMANDANDO El. Df¡MANÐANrE):

You hlVl 3lCALENDAR oAviriÌor tbl& aunioiiii ond i-iii P"PI'n ørø IlNo on )'DI to f110,. \lii.. tøl\p(tiil allhlii i:ut and hiivoa . i:ripy ~iid on Uio plall1tllt... A laller or phoii Qln will not protect yo\l. YoowrlUen rnpQnH muat liIn proper '.gal form "you W3nllh. tOurt.to hoar your can. 'lh.re ma.bè II coul1 fOlm thaI you cininsii for yourrllllPoM... Vou c.n n..d thO" COIl rOJ/T..nd mòn . IflO'irlon III Ih. CaJifomii Coiirn Onllno S,If.Hlilp CBntlir (W\.cou.r1info.eagov/&BlfhoJp), your county law:llbary. or tho cPurthou&o . yOU c;/lot pay the f10ng 10., ask tho Obl. Crlltk~r 3 fH wslvllfol'. IfyOl do nQ\ tile )'out fGlip.nISG on time, you may : .""arlÎ:i you. If

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.. . ThlSrli are otør Ivyal ro~lf.8m8nll, YQ\I rny wantlaÇDlllIR ,,ore,. T1ghi.awy. if

you do not kIowan aUomiiy, you may WI 10 CllIlin.

~ltQrm'y I1ferr.l.iiorJlc.lf you cirimit.urford an alt8y. you misy ~...Illbl. fo frll kil ,Priii$ ftprn a npnprofl 1&g .ervc~"

.prora. Y 011 çan IQCR thlH' noriPl ¡ioupi at lhii ClJlcrla Lagl Servicg, Wvb $lIG ('N.l3whelPÇllfotnlaQlll, tho c.lifømia
. ColU Online ~"ir-H.ip Caritor (ww.ooulnfo.c.govflniAlp).orby coctlng yoiir i~i t:llrf or tollnlybiir ..QCliilon. .

TlVntl.30 D/AS DE CALENDARw r!~ da qi Ie ImirglXn On ~r;ón Y pilu kiuJi pàfi pnnntar !Jn' tNpii.. po ei. .

eofffmiii to.coU1/nfo.OIf1vllnH/1~titpiloJ, .n Iii. blbllftl d-IIJJ!$ du $V ooni:do.O en Il 00 aU 'II .awj øi..ii sJ nO . Jlrx/l su'" II/ cuotii f/I1 Pfac1n, pl/J øi :illtllrIo iH l/l bO..4l /q ~ un fomiuf,rl d. AXQlklón de pa~ f1 curu Sl no pi_rr

IJcrri flønG qll.f1$f.t &/ fom~lo.¡ ectN " rI~ qu ~n $U c# 1m Ja co. Espolbfe .aii hayt.un foimul". qi 1Ø&d PuW& rJ!larplff iiU ~;". Pu~ ollntr 0l~ touJrltJ dø 1R aarl.. y ",;5$ ln~rbn ." ",T ç,;ri .ii" Ayud_. di