(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.)
PURSUANT TO GOVERNMENT CODE SECTION 12940 ET SEQ.
PLAINTIFFS, ROSA BROWN, MANUEL WHITE and PATRICIA GREEN, jointly and/or severally allege as follows:
GENERAL ALLEGATIONS BY PLAINTIFFS AGAINST DEFENDANTS FOR VIOLATION OF EMPLOYMENT CIVIL RIGHTS
1. This is an action for damages to redress the deprivation of rights secured to Plaintiffs by the California Fair Employment and Housing Act (hereinafter “FEHA”), Government Code § 12940, et seq.
2. Plaintiffs seek to obtain relief against their former employer, the Defendants named herein and its agents and employees for subjecting Plaintiffs to discrimination, harassment and/or retaliation on account of Plaintiffs’ sex, race, national origin and association. Additionally, Plaintiffs seek compensatory and exemplary damages for discrimination, harassment and/or retaliation.
3. This action is brought pursuant to the California FEHA, California Government Code § 12940 et seq. Pursuant to said Act, Plaintiffs filed timely charges of discrimination regarding the acts and practices of Defendants alleged herein.
4. The true names and capacities, whether individual, associate, corporate or otherwise of Defendants Does 1 to 100 inclusive and each of them are unknown to Plaintiffs at this time who, therefore, sues said Defendants by such fictitious names. Plaintiffs will amend this complaint to state their true names and capacities when same have been ascertained. Plaintiffs are informed and believe and thereon allege, that each of the defendants designated herein as a Doe is responsible in some manner for the events and occurrences herein described and is liable to Plaintiffs for the damages as herein alleged.
5. Plaintiffs are informed and believe and thereon allege, that in connection with the actions and omissions alleged herein, Defendants, entered into a partnership, employment, conspiracy, joint venture and/or principal-agent relationship to carry out all the acts and omissions herein alleged. At all times material such Defendants have been and continue to be the employees, agents, co-conspirators, partners, employers principals and/or joint venturers, acting within the purpose and scope of and pursuant to their employment, agency, conspiracy, joint venture and/or partnership and with the authorization, direction, consent, ratification and adoption of their employers, agents and/or co-conspirators. At all time herein mentioned, each Defendant was, and is, the duly authorized agent and employee of each of the other Defendants and, in doing the things hereinafter mentioned, was acting within the course and scope of that agency and employment.
6. Plaintiffs are informed and believe and thereon allege, that each of the Defendants, named and unnamed, are, and at all times relevant hereto were, the agents, servants and/or employees of each and every other named Defendant and Does 1 to 100 and that each of the individual Defendants were acting at all times within the scope of their agency and/or employment and with the knowledge of their principal and/or employer and/or co-defendant. (See Part 2 of 18.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.