(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) 25. At all times during the employment relationship, PLAINTIFFS performed their duties in a highly satisfactory, competent and diligent manner. 26. PLAINTIFFS have filed Charges of Discrimination with the California Department…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) FIRST CAUSE OF ACTION (Sexual Harassment in Violation of Gov’t. Code §12900 et seq., by All PLAINTIFFS and Against All DEFENDANTS) 21. PLAINTIFFS repeat and reallege the allegations contained in paragraphs…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) FACTUAL ALLEGATIONS 10. PLAINTIFF JANE DOE 1 commenced employment with DEFENDANT STARS in or about April 1998 as a waitress. At no time was PLAINTIFF DOE 1 employed as a stripper.…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) First Amended Complaint for Damages for Sexual Harassment THE PARTIES 1. PLAINTIFF JANE DOE 1 ( PLAINTIFF DOE 1 ) was at all relevant times herein an individual female residing in…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) FOURTH CAUSE OF ACTION BY ALL PLAINTIFFS AGAINST ALL DEFENDANTS BASED UPON INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 104. Plaintiffs incorporate herein by reference each and every allegation contained in paragraphs1 through…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) THIRD CAUSE OF ACTION BY ALL PLAINTIFFS AGAINST DEFENDANT UCC BASED UPON RETALIATION 99. Plaintiffs incorporate herein by reference each and every allegation contained in paragraphs1 through 87 with full force…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) SECOND CAUSE OF ACTION BY ALL PLAINTIFFS AGAINST ALL DEFENDANTS BASED UPON HOSTILE WORK ENVIRONMENT HARASSMENT 93. Plaintiffs incorporate herein by reference each and every allegation contained in paragraphs1 through 87…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) FIRST CAUSE OF ACTION BY ALL PLAINTIFFS AGAINST DEFENDANT UCC BASED UPON EMPLOYMENT DISCRIMINATION 88. Plaintiffs incorporate herein by reference each and every allegation contained in paragraphs1 through 87 with full…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) 82. Defendant UCC and/or its agents and employees, supervisors, managers, officers and/or directors knew or should have known of the harassing actions on the basis of verbal and/or written reports of…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) 74. Defendant UCC maintained and/or allowed a pattern and practice of unlawful sexual and racial discrimination, harassment and retaliation against female workers, including Plaintiff herein. 75. Defendant UCC directly and/or through…