(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.)
PARTIES
7. At all times herein mentioned, Defendant UNIVERSAL CLOTHING COMPANY, LLC. (hereinafter “UCC”) and Does 1 to 100, inclusive, was a corporation, sole proprietorship, partnership, limited partnership, and/or limited liability corporation, duly organized and existing under and by virtue of the laws of the State of California and doing business in the County of Sacramento, State of California, with its current principal place of business located at 1234 Main Street, West Sacramento, California and is an employer as defined in Government Code § 12926 (c).8. At all times mentioned, Defendant PAUL SMITH (hereinafter “Paul Smith”), is and has been a resident of the County of Sacramento, and was a manager, managing agent, supervisor, employee, officer, director, owner and/or partner of Defendant UCC.
9. At all times mentioned, Defendant DAVID SMITH (hereinafter “David Smith”), is and has been a resident of the county of Sacramento, and was a manager, managing agent, supervisor, employee, officer, director, owner and/or partner of Defendant UCC.
10. At all times mentioned, Plaintiff ROSA BROWN (hereinafter “Brown”), is and has been a resident of the County of Sacramento, State of California.
11. At all times mentioned, Plaintiff MANUEL WHITE (hereinafter “White”), is and has been a resident of the County of Los Angeles, state of California.
12. At all times mentioned, Plaintiff PATRICIA GREEN (hereinafter “Green”), is and has been a resident of the County of Los Angeles, state of California.
ADMINISTRATIVE EXHAUSTION/RIGHT TO SUE LETTER (BROWN)
13. On or about April 21, 2007, the California Department of Fair Employment and Housing (hereinafter “DFEH”) notified Brown of Plaintiff’s right to initiate legal proceedings on said charge of harassment, discrimination and retaliation on account of Plaintiff’s sex, race, national origin and association.14. Plaintiff was employed by Defendant UCC from 2004 until July 11, 2006 at which time Plaintiff’s employment was terminated by Defendant David Smith.
15. At all times herein mentioned, the acts and/or words constituting the discrimination, harassment and/or retaliation alleged herein occurred within one year prior to the filing of Plaintiffs administrative accusation and charges with the Department of Fair Employment and Housing. (See Part 3 of 18.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.