West Sacramento Clothing Company Workers Sexually Harassed, Part 9 of 18

(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.)

55. Within one year prior to the filing of the administrative complaint, Plaintiff complained to his superiors, supervisors, managers, and officers about the above described discrimination, harassment and abusive treatment.
56. Defendant UCC maintained and/or allowed a pattern and practice of unlawful sexual and racial discrimination, harassment and retaliation against female workers.
57. Such discrimination and harassment also created a hostile and/or offensive working environment for Plaintiff.
58. Plaintiff was obliged to work in an atmosphere which was hostile to females by virtue of severe and pervasive favoritism granted to Latina females plant floor workers who would go along with Defendant Paul Smith, including unsolicited and unwelcome sexual remarks and/or innuendos, advances, requests for sexual favors and other verbal and physical conduct of a sexual nature. The sexual harassment was sufficiently serious and pervasive to alter the conditions of Plaintiffs employment and create a working environment which was intimidating, insulting, and abusive.
59. Defendant UCC discriminated against Plaintiff in violation of Government Code Section 12940 et seq. by constructively discharging and/or firing and otherwise discriminating against Plaintiff by engaging in, tolerating and/or failing to prevent the favoritism alleged above and by failing to take any action, or make any reasonable and/or adequate investigation of plaintiff’s reports of favoritism and failed to take any steps reasonably calculated to end the discrimination, harassment and retaliation and/or correct or redress the unlawful employment practices. (See Part 10 of 18.)


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