(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.)
GENERAL STATEMENT OF BACKGROUND FACTS
22. At all times herein mentioned, Defendant UCC is a family owned company, operated by and owned by Paul Smith. Defendant UCC operates as merchant wholesaler with a garment factory manufacturing clothing for men, and manufacturing women’s, children’s, and infant’s clothing. The family also operates two factories in China.
23. At all times herein mentioned, Plaintiffs are informed and believe that: Defendant Paul Smith is of Iranian nationality, and of Muslim culture and heritage; Defendant Paul Smith is the principle owner and operator of Defendant UCC; Defendant Paul Smith is the father of Defendant David Smith.
24. At all times herein mentioned, Defendant David Smith is the son of Defendant Paul Smith and is an agent, supervisor, manager and/or managing agent of Defendant UCC at the subject premises.
25. At all times herein mentioned, Plaintiffs worked on the manufacturing plant floor area of UCC while the plant was then located at 123 East Blvd., Sacramento, CA. Plaintiffs last worked at the subject location during 2006. During 2006, there were about 50 to 60 average number of workers per day on the manufacturing plant floor during peak months and approximately 10 to 20 average number of workers per day on the manufacturing plant floor during the slower months.
26. At all times herein mentioned, approximately 80 % of the workers on the manufacturing plant floor were men and approximately 20 % were women.
27. At all times herein mentioned, Defendant UCC hires manufacturing plant floor workers from both a temporary employment agency and hires direct walk-in’s, so-called permanent plant workers.
28. At all times herein mentioned, Defendants’ pattern and practice is and has been that it hires from and/or through the temporary employment agency only men, no women. (See Part 5 of 18.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.