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(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.)
STATEMENT OF FACTS RELATING TO GREEN
67. Plaintiff incorporates herein by reference each and every allegation contained in paragraphs1 through 28 with full force and effect as though fully set forth herein.
68. Green is a Latina female, born XX/XX/1962, and is of El Salvadoran descent and/or national origin. Green is presently 45 years of age.
69. On or about October 2003, Green was hired by Defendant UCC. Her last position with Defendant UCC was working as a floor manager, earning $9.00 per hour.
70. On or about August 15, 2006, Green was forced to quit her employment with Defendant UCC as a direct result of constructive discharge.
71. While Green was employed at UCC, she was subjected to a daily pattern and practice of sexual and racial discrimination, harassment and retaliation as a result of serious and pervasive sexual and racial discrimination and harassment against Latina workers resulting in a sexually and racially hostile work environment, including but not limited to:
a) Defendant Paul Smith vocally announced on many occasions on the work floor to the Latina workers that as the owner he had the right to demand and expect sexual favors from the Latina female workers.
b) Defendant Pal Smith did not make the same statement to the non-Latina female workers.
c) Defendant Paul Smith maintained inside the workplace areas open and notorious sexual relationship with two other women known as Marta and Justine.
d) Defendant Paul Smith made it clear to the Latina work force that things would be better for them at work is they went along with the sexual expectations. For example, Defendant Paul Smith extended more favorable treatment to the women romantically involved with him in the workplace with respect to terms and conditions of employment.
e) Defendant Paul Smith daily uttered sexually offensive remarks to non-compliant Latina women including labeling the Latina workers:
– bitch
– stupid cunts
– cunts
– panochas (derived from Spanish language derogatory term for vagina)
– pan (short for panochas)
– would form a triangle with his bilateral thumb and index fingers directing at Latina workers while sticking out his wiggling tongue. (See Part 12 of 18.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.