Racially Offensive Environment Leads To Lawsuit By West Sacramento Workers, Part 12 of 18

(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.
g) During the course of Green’s employment at UCC, Defendant Paul Smith persistently demanded a romantic and sexual relationship with Plaintiff Patricia Green. Green repeatedly rejected Paul Smith’s demands.
h) Thereafter, Defendant David Smith spoke with Brown and demanded that Brown provide to David Smith private details and private information concerning the personal and intimate life of Plaintiff Patricia Green.
i) Brown only informed David Smith that Plaintiff Patricia Green was dating Plaintiff White, but otherwise refused to divulge any information concerning Plaintiff Patricia Green.
j) After daily sexual harassment from Defendant Paul Smith, Plaintiff Green refused to continue to work in such an abusive environment and considered herself constructively discharged and quit her employment.
72. 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, including Plaintiff, consisting of racial insults and racially offensive remarks, including:
– Mother fucking Mexican
– Ignorant Mexicans
– Hurry up motherfucker
– Lazy Mexican
– Fucking Mexican
– Wet back
– Fucking wet backs
– Stupid Mexican
– Mexicans are ignorant

73. Within one year prior to the filing of the administrative complaint, Plaintiff complained to her superiors, supervisors, managers, and officers about the above described discrimination, harassment and abusive treatment. (See Part 13 of 18.)

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