(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) f) Defendant Paul Smith did not utter any similar sexually and/or racially offensive words at the non-Latina workers and did not perform any same or similar acts to the non-Latina workers.…
(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…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) 60. Defendant UCC also discriminated against Plaintiff because of his vocal opposition to the sexual favoritism at his workplace. 61. The effect of Defendant UCC’s unlawful employment practices has been to…
(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.…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) STATEMENT OF FACTS RELATING TO PLAINTIFF WHITE 49. Plaintiff incorporates herein by reference each and every allegation contained in paragraphs1 through 28 with full force and effect as though fully set…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) 41. Defendant UCC also discriminated against Plaintiff because of her vocal opposition to the harassment at their workplace. 42. The effect of Defendant UCC’s unlawful employment practices has been to limit,…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) 33. All times herein mentioned, Defendants Paul Smith and David Smith daily maintained a pattern and practice of unlawful workplace racial discrimination and harassment against Latino and Latina plant floor workers,…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) STATEMENT OF FACTS RELATING TO BROWN 29. Plaintiff incorporates herein by reference each and every allegation contained in paragraphs 1 through 28 with full force and effect as though fully set…
(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…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) ADMINISTRATIVE EXHAUSTION/RIGHT TO SUE LETTER (WHITE) 16. On or about April 15, 2007, the California Department of Fair Employment and Housing (hereinafter “DFEH”) notified Mendoza of Plaintiff’s right to initiate legal…