Professional Documents
Culture Documents
Steenhoek Vs Warner Bros BC681491
Steenhoek Vs Warner Bros BC681491
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1 ATEXANDER I(RAXOW+ GUCK TTP
LA Michael S. Morrison (State Bar No. 205320)
ocl30 201? I
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Jessica S. Choi (state Bar No. 312795)
3 401 wilshire Boulevard, Suite 1000
Santa Monlca, California 90401
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4 T: 310 394 0E88 | F: 310 394 0811
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E: [email protected] I [email protected]
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Atomeys for Plaintiff
BECKY STEENHOEK
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*$1 SUPERIOR COURT OF THE STATE OF CALIFORNIA
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!N AND FOR THE COUNTY OF LOS ANGELES - UNUMITED
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BECKY STEENHOEK, an individual, caseN8f, 6 S 1 4 91
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Plaintiff,
COMPLAINT FOR DAIIAGES
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14 I. SEXUAL HAMSSiIEI{T - HOSTILE
WARNER BROS. ENTERTAINMENT WORK ENVIRONIf,EiIT (Cal. Got/l
15 lNC., a Delaware Corporation doing coae S izglo(i)); I
23 WRONGFUL TERIIINATION IN
VIOLATION OF PUBLIC POLICY;
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1 Plaintiff Becky Steenhoek ('steenhoek" or "Plaintiff') complains and alleges on
2 information and belief the following against Defendants Warner Bros. Entertainment lnc.,
3 NZK Produc'tions, lnc. ("NZK'), Elan Gale, Peter Scalettar, Bennett Graebner, Jacqueline
5 INTRODUCTPN
I 'sEenhoeld'), who worked on the produclion and filming of 'The Bachelofl television
9 series as well as "Bachelo/' related spin-ofrs and specials, induding "The Bachelorette,"
't0 'Bachelor in Paradise," and "Jade & Tanner's Wedding'; (collectively, "The Bachelo/
11 Series'). Plaintiff worked for NZK Productions, lnc. and Wamer Bros. Entertainment lnc.
12 (collectively, 'Corporate Defendants") on'The Bachelo/' Series ftom October 2014 until
13 April 2016, when she was wrongfully terminated for complaining abor.rt the hostile work
14 environment that Defendants created by pervasive and persistent sexual inquiries and
15 language directed at her by the show's Executi\re Producers and Cast Producers.
t6 Despite Sleenhoek's making clear that she was not interested in discussing her sexual
17 life with her supervisors and co-workers, lhe Executive and Cast Producers of the shoitr,
18 including Elan Gale, Peter Scalettar, Bennett Graebner, Jacqueline Naz Perez, and
fi . "Has a man ever got your 'taco' [euphemism for vagina] talking?"
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1 2. The persistent serual inquiries directed at Steenhoek were not part of the
2 "creative' process of the shor but were instead intended to embarrass her because of
3 her sexual inexperience and conservative views about sex. Simply put, questioning
4 Steenhoek about her sex liE was entertainment for the Executive Prcducers. Afrer
5 Steenhoek protested against the unwanted sexual comments and personal inquirioS, lhe
7 work performance, tenninated her, and prevented her from being hired again on the
I serbs in her former position as a produclion assistant. Defendanb' conducf was exlrerne
9 and outrageous and caused Steenhoek significant economic and emotional harm. .
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14 California Code of CMI Procedure because Defendanb, or some of them, reside in.
15 andor are doing business ln Los Angeles County. Moreover, Defendants employed
16 Plaintifi in Los Angeles County and the harms occurred in Los Angelos County.
17 PARTIES
10 5. At all relevant times, Plaintiff Becky Steenhoek rrvas a resident of Los Angeles
19
20 6. Plaintifi is informed and believes and on this basis alleges that Defendant NZK
22 Galifomia.
23 7. Plaintifi is informed and believes and on this basis alleges that Defendant
26 8. Plaintiff is informed and belie\res and on this basis alhges that Defendant Elan
27 is a resident of Los Angeles County, Califomia.
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9. Plaintiff is informed and believes and on this basis alleges that Defendant
1'1. Plaintiff is infomed and believes and on this basis alleges that Defendant
12. Plaintiff is infomed and believes and on this basis alleges that Defendant
13. NZK and Warner Bros. Entertainment lnc. are joint employers of Plainffi. with
respect to NZK, it is the entity listed on Plaintiffs wage statements as her employer. NZK
1,' I is also the entity which issued the "Deal Memos" to Plaintiff which set forth some of the
nl terms and conditions of her employment on 'The Bachelor'' Series. NZK was also
,rl responsible for the payment of Plaintiffs wages and had the authority to discipline,
15 14. wamer Bros. Entedainment lnc. is the ioint employer of Plaintiff because it
16 also had the right to control the means and manner of Plaintiffs work performance' The
17 lndivirjual Ebfendants who har6sed and defamed Phintiff are also employees of Wamer
18 Bros. Enterlainment lnc. These individuals supervised Plaintiffs work and dictated her
job.
19 work assignments during her employment. They also discharged her from her
21 Series with its Poliry Prohibiting Discriminalion and Harassment, which contains the
23 and managers of D,efendants concerning the very condud at issue in this case. The
24 Policy Prohibiting Discrimination and Harassment also diects ernployees like Plainffi to
- if
25 contac{ Wamer Bros. Entertainment Corporate Legal - Employrnent Law Departnnl
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Compensation/Accident & Healtlr Coverage insurance as well as insurance wilh respect
4 15. Plair{iff further alleges that NZK and Wamer Bros. Entertainment lnc.
6 management, centralized control of labor relations, and common ownership and financial
7 conhol. Additional facts supporting the conclusion that NZK and Warner Bros.
12 Plaintiff sent notice under the Califomia Private Attomeys General Act of
13 2004 to sevenl entities, including NZK and Wamer Bros. Entertainment lnc.
16 Plaintiffs employer, and did not deny that it was Plaintiffs employer.
'17 b. On March 24,20'17 , Mce President & Senior Employment Counsel of
18 Warner 8ros. Enterlainment lnc. provided Plaintiffs personnel file to
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f. Wamer Bros. Entertainment lnc. and NZK share the same entity address
g, Warner Bros. Enterlainment lnc. and NZK share the same corporate
secretary.
0 '16. The true names and capacities of defendants named as Does 1-100, inclusive,
10 therefore sues hese defendants by such fictilious names. Plaintiff will amend this
1l Complaint to show the true names and capacities of these defendants when they are
12 ascertained .
13 17 . At all times mentioned, Defendants, and each of them, lvere the agents,
17 assigns, parents, substriaries and/or afiiliates. Ptaintiff also alleges that Defendants
IE were, at all tirnes relevant hereto, the alter egos of each other. \Mterever reference is
19 made to Defendants herein, it is intended to include all of the named Defendants as well
20 as the Doe defendants. Each of the fictitiously named Doe defiendants b responsible for
21 the occunenoes hetein alleged and pmximately caused Plaintiff damages (desoibed
22 belorv).
25 Series from Odober 2014 until Apdl 2016, when she was wrongfully teminated for
26 about the hostib worl environment created by the pelvasive and persistent
27 inquiries and language directed at her by the shou/s Executive Producers, Ehn
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1 Gale, Peter Scaletlar, and Bennett Graebner, as well as Cast Producers Jacqueline Na)
4 Bachelod' (Season 19) in the fall of 2014. Plaintiffs hard work and enthusiastic attitude.
5 made her a favorite of her co-workers and was noticed by the producers of the show.
6 20. Because of her excellent work performance, Steenhoek was asked to come
7 back to work as a PA. and promoted to Casting P.A. and Cast Handler for subsequent
8 seasorls ard series, including "The Bachelor" (Season 20), 'The Bachelorette" (Season
9 11), "Bachelor in Paradise" (Season 2), and "The Bachelo/'-related specials, such as
10 Jade and Tanne/s Wedding. Steenhoek grew accustomed to and relied on the
11 consistenl, year-round employment she had while working for MK.
12 2'1. ln her roles as a P.A. on the production side and Cast Handler, Steenhoek dir!
13 not witness or experience any offensive sexual comments or sexually explicit questions
14 directed at her, and she was allored to perform her job without inckJent. Phintifi
15 continued to thrive as a valued ernployee when she worked as a PA. on the production
't6 side and as a Cast Handler. ln March 2016, Gale and Scalettar asked Steenhoek to
17 interview for the Segment Producer position for lhe upcoming season of The
18 Bachelorette' (Season l2). Steenhoek was excited about the opportunity to join the
19 'inner circle' on the producing side of filming, and she accepted the position. As
20 Segment Producer, Steenhoek's main job responsibililies were as a lalent handler to the
2',1 lead, that season's Bachelorette Joelle ("JoJo") Fletcher. Steenhoek was paid a salary of
22 $1,400 a week, and her contract was for the 10-week length of the season. Steenhoek
23 worked anywhere ftom 15-18 hours per day, 7 days per week. Stapleton was
24 Steenhoek's dircc't supervisor in this role, and Stapleton reported direcUy to the Executive
25 Prcducels. While Steenhoek understood that sex was a theme on the shou\r, she was
n never iold that the job of segment producer wouH require her to share the intimate details
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27 & her own sexual life w'fih her supervisots or be forced to hear about her supervisors'
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1 personal serual experiences in intimate detail.
2 22. Soon into the filming of "The Bachelorette' (Season 12), Sleenhoek witnessed
3 and experienced daily and pervasive discussions about sex. None of the sexual talk was
4 related to the production of the show or assisting in the creative process. lnstead, the
5 production team bragged - in graphic detail - about their personal, sexual conduct and
6 directed sexually charged, deeply personal inquires to Steenhoek despite her clear
7 indications that she uras uncomfortable discussing her personal sex life.
I 23.- From March 22 through April 9, 2016, the Execulive and Cast Producers
I engaged on a daily basis in sexually explicit conversations about their personal sex lives
'10 and also directed highly inappropriab questions to Steenhoek. Questions dirccted at
11 Steenhoek included:
18 . Do you prefer oral or anal sex? Would you ever have anal sex?
following moming. The group began to discuss what they would have done with the extra
: time thal night. Graebner explained that he would have mashrrbated in bed with his wife,
5 describing in detail how he "jacked off' onto hb wife when they watched W at night.
6 Gale announced to th group that he would have 'trcked his gklfriend for two more
7 hours." The producerc.then continued to discuss masturbation and detailed how ofien
I each of them had sex.
I 25. Steenhoek was ofiended by the sexual inquiries directed al her and comments
10 about the Executive and Cast Producers' personal sex lives. She would not engage in
11 the conversations and was nevei told that the conversations were part Of the creative
12 proce6s. Steenhoek made clear that she was not interested in answering questions
13 about her private sexual life or hearing about the Sexual activities of her supervisors
11 which were unrelated b work or the shods creative pro@ss.
15 26. The more Steenhoek would get flustered and refuse to eng4e in the
16 conversation or answer these numerous sexually explicit questions, the more the
17 Executive Producers targeted her and pressured her to ansurcr the questions. The
18 Executive and Cast Producers enioyed teasing Steenhoek about her sexual life because
19 of her sexual inexperience and reluctance to discuss sex. When Steenhoek replied that
20 she did not want to answer the question or would remain silent in response to the
21 producers sexually exPlicit questions, the producers would comment, 'Becky is
22 blushing," "l'm sure we're making Becky uncornfortrable"' "l'm sure Beckys ears are
23 buming," and "Becky looks so honified." Steenhoek feh as if the visibb discornfort she
2 27 . The sexually explicit inquiries that wele aimed at Steenhoek because of her
3 gender did not and could not further the shovt's creative expression. steenhoek was
4 viewed as an ouEider, not a team player, and ridiculed as judgmental and too sensitive
5 for refusing to participate in the 'locker room' talk of sexual operiences and preferences.
D 28. Steenhoek was aware that as a dating and relationship shorv' the subiect of
I therefore there was no legitimate reason to constantly bombard her wiih sexual questions
I - especially when she had made clear that such questioning was offensive, unwelcomed,
10 and made her uncomforiable. Likewise, conversations about the Executive Producers'
11 and cast Producers, sex lives also were not show related. 'Ttp Bachelo/' has yet to
'12 have a shorv, for example, where anal sex was discussed as a topic. Ultimately, the fact
13 that the show touched on topics ]elated to dating and sex did not give the Executive and
14 Cast Producers free rein to harass Steenhoek in the name of the "creative process.'l
15 29. On April 9, 2016, Stapleton asked Steenhoek whether she "had ever bndled
't6 balls before.' At that point, Steenhoek put Stapleton on notice that such questions were
17 inappropriate and replierJ that she was over listening to and being constantly questioned
18 about her .private sex life. Steenhoek complained to Stapleton that the conversations
'19 made her feel uncomfortable and were causing her distress. Steenhoek's complaints to
20 her immediate supervisor ucre consistent with Defendants' sexral harassment policy for
22 30. The next day, Slapleton apologized about the conversation and toH
23 Steenhoek that she needed to understand that the Executive Producers \irere three
24 middle-aged men and that was what men talk about. Stapleton told Steenhoek, 'S!aQ
25 tre wav of the industrv and world that we wort in," so Steenhoek just had to accept it.
6 * 31. Onoe Sbenhoek cornphined to Staplelon, Steenhoek noticed a dramatic
27 ehange in the manner in which her supervisors interac,ted with her. Steenhoek was (1)
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1l shunned as an outsiier by the Executive Producers, (2) no longer allowed to sit in on
,l group meetings during which the producers would discuss the agenda or storylines they
,] wanted to push, (3) asked to step out of the room during show produdion and inteNieurs,
4 (4) uniusfly criticized by lhe producers, and (5) told she 'uould not be attending" the
5 filming of the shods elimination rose oeremony. This was humiliatirE and impac{ed her
6 ability to do her job. The producers also unfairly bhmed steenhoek for things completely
7 out of her control (e.g., room service taking too long to deliver food or dirty dishes being
8 hft by hotel staff in room). Each of these acts was discriminatory and retaliatory in nature
I and contributed to the hostile work environment experienced by Steenhoek'
10 32,onApdl17'2016'justoneweekafte]steenhoekcomplainedtostapleton,
11 Graebner informed Steenhoek that Steenhoek would not continue with the resl of the
12 filming of 'The Bachelorette." Graebner told steenhoek that she YUas not being enough
13 of a ',bitch,,, which was why she would not be continuing following the filming of the
11 hometown episodes. Graebner assured steenhoek that scalettar would be getting in
15 contac.t with sbenhoek about working as a P.A. in the office to preparc for "Badtelor in
16 Paradise" (Season 3) and Steenhoek would be paid the salary she received as a
17 segment Producer untit the end. of the season. steenhoek was shocked that she wouH
18 be terminated fuom her position merely because she protested against unwanted sexual
21 contact the prcducers, Steenhoek was told the executives were too busy to speak to her.
22 34. ln mid-May 2016, Steenhoek met with the shorrrirs Superuising Producer, Louis
23 Caric, and Stapbton. Stapleton and Caric toH Sieenhoek lhat 'her morals were getting
24 in the way of her work" and "her morals were a threat to the shortr.' Sieenhoek asked
25 why she was never spoken to about this purported issue before she complained and
26 she was terminabd. Steenhoek had asked mulliple times lhroughout the season
27 feedback from Stapleton and the Executive Producers regarding her job performane,
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bul at no point did they ever inform her that she was not doing a good job or fullilling her
job responsibilities. Caric told Steenhoek that the Executive Producers don't have time to
il sit down and talk about problems with employees, which is why they terminated
Steenhoek.
35. Previous to this meeting, on March 28, 20'16, Coordinator Lisa Propeck
contaded Steenhoek to ask her to wolk as Cast Handler for the upcoming season of
"Bacheloi in paradise" (season 3). Steenhoek was interested in retuming to this position
because it meant she did not have to work in the inner circle where she was subjected to
the unwanted harassment and ilbgal retaliation. Propeck told Steenhoek that she would
receive a confirmation email once the dates were confirmed for filming. Steenhoek
r:l emailed Propeck lhat she had not heard back yet ab61lt the travel dates for "Bachelor in
,',I paradise." Propeck replied to steenhoek that steenhoek would have to talk to caric
13 about it.
,,14 36. At the rneeting with caric and strapleton in mid-llay, caric infonned
15 Steenhoek that they were not going to bring Steenhoek along that season for 'Bachelor
16 in Paradise.', caric told steenhoek he dkl not think she was a good fit uorking on the
17 producing side, but if she was interesled in the production side, they might have a
18 coordinator position available for her. Caric suggested that Steenhoek take some time to
19 conskler if she had an interest in purcuing something on the production side. caric
20 instructed her to inform him whether she did, because he would be willing to conskler
21 Final Rose.,, Steenhoek accepted the ofbr, but then she received a phone call from
25 choudry on July 1, 2016, and Chodry informed her that she would no longer be able to
m as a P.A. on the production side for the specials per the Executives Producers'
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38. Chorvdry told Steenhoek that during a company meeting regarding the crew
br the specials, steenhoek's name carne up and the Executive Producerc cdticized
steenhoek. The Executive Producers stated that steenhoek was not to be hired under
any ciranmstances. chordry also shared that steenhoek was being discussed in a
negative light in.and around the 0ffrce. chowdry revealed to steenhoek that many of the
excelbn[ work performance; however, the Executive Producers made il knouln that
10 I 39. Within the time provided by law, Plaintiff caused to have filed a complaint of
Discrimination with the calilornia tlepartnent of Fair Employrnent and Housing CDFEH),
;l regarding all cf the facb alhjed in this Complaint for damages that eshblish a violation
13 | of the Fair Employment and Housing Ad (.'FEHA) on February 10,2017' The DFEH
,al issued a righLto-sue notice against the corporate Defendants on February ,0, 2017. On
,ui February '14,2017 and Marci 1,2017, Phintifi amended her DFEH charge to name and
16 include additional entities. on April 12, 2017, Plainffi amended her DFEH charge to
17 name and include the lndividual Defendants. The DFEH issued Plaintifi an amended
18 right to sue. Plaintiff and Defendants entered into. a tolling agreement, effective as of
24 40. Plaintifi realleges and incorporates by reference, as through fully set forth at
28 41. At all relevant times, Dehndants harassed Plaintifr on the basis of her sex
a hostile work environment for
27 ), in violation of the FEHA, and Defendants created
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Plaintiff. As described above, the Executive Producers anid Cast Producers engaged on
a daily basis in sexually explicit conversations about their personal sex lives and direc'ted
outsi{er; no longer allowed'her to sit in on group meetings during which lhe producers
would diicuss the agenda or storylines they wanted to push: ask6d her to step out of the
:I room during sho^, produdion and interviews; unjustv criticized heI; told her that she
"would not be attending" the filming of the sho#s etimination rose ceremony; terminated
her; prevented her hiring on other series and specials, and other conduct according to
proof.
42. The harassment \Jvas sevele and pervasive, and a reasonable person in
18 44. Defendants knew or should have known of the harassment and failed to take
't9 immediate and appropriate conective ac'tion.
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. Exemplary and punitive damages. Defendants have engaged in despicable
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conducl, exposing Plaintiff to cruel and unjust hadship, with the intent'ron to cause injury
to Plainliff, and with conscious disregard of her rights. Defendanls occupied a position of
kust which gave them power to damage Plaintiffs abili$ to earn a livelihood. Defendants
Plaintiff and discriminating against her under the circumstances described here.
:l Defendants' conduct was canied out by and ratifred by one or mole of Defendanb'
managing agents. Plaintiff is trerefore entiued to punitive damages in an amount to be
:l proven at trial. Defendants' conduct in discriminating against Plaintiff was willful and
48. Ratification. Plaintiff is informed and believes and on that basis alleges that
Defendants were at all relevant times aware of the conducl of each of the other
15 | sExDrscRmlNATlo}{
,.1 (Gal. Gov't Gode $ 129a0(a))
18 49. Plaintifi realleges and incorporates by refetence, as through fully set forth at
20 50. At all relevant times, Defendants discriminated against Plaintiff on the basis of
to
21 her sex (female), in violation of the FEI'IA, and Defendanb discharged and/or refused
Z2 hire Plaintifi on the basis of her sex (female). As described above, the Executi\re
23 Producers and cast Producers engaged on a daily basis in sexually e)Qlicit
questions
24 conversations about their personal sex lives and directed highly inappropriate
25 to Plaintiff, purposely escalating the intensity of their questioning and sexual discussions
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1 on group meetings during which the producers would discuss the agenda or storylines
2 they wanted to push; asked her to step out of the room dudng shour production and
3 interviews; unjustly criticized her; told her hat she '\rvould not be attending" the filming of
4 the shoit's eliminalion rose oeremony; terminated hr; prevented her hiring on other
5 series and specials, and other conduct according to proof.
7 Defendairts, Plaintifi sufiered and will sufier spechl damages for lost earnings and wages
8 in an amount not yet fully known, but in excess of the jurisdictional limits of this Court,
10 Defendants, Plaintiff suffercd general damages including, but not limited to, damage to
15 to Plainffi, and with conscious disregard of ler rights. Defendants occupied a position of
16 tust which gave them power to damage Plaintiffs ability to eam a livelihood. Defendants
17 abused that position of trust by maliciously, fraudulently, and oppressively discharging
18 Plainffi and discriminating against her under lhe circumstances described here.
19 Defendants' conduct was canied out by and ratified by one or more of Debndants'
21 proven at trial. Defendants' conduct in discriminating against Plaintiff was willful and
23 54.
Ratification. Plaintiff is informed and believes and on that basis alleges that
24 Defendants urere at all relevant times aware of the conduct of each of the other
26 t,u
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THIRD CAUSE OF ACT]ON
RETAUANON
(Cal. Govt Code S 12940(h))
.5 55. Plaintiff realleges and incorporales by reference, as through fully set forth at
I she has complained about or opposed any praclices that are unlaMul under FEHA,
10 through informal or formal complaints alleging such unlawful conduct.
'12 and opposing sexual harassrnent and discrimination io her supervisor and management.
15 longer allowed her to sit in on group meetings during which the producers would discuss
16 the agenda or storylines they wanted to push; asked her to step out of the room during
17 show produdion and interviews; unjustly criticized he6 told her that she 'lvould not be
1E attending" the filming of the shouy's elimination rose ceremony; terminated her; prevented
19 her hiring on other series and specials, and other conduct according to prmf'
21 Defendants, Plaintiff suffercd and will sufer special damages for lost eamings and wages
22 in an amount not yet fully known, but in excess of the jurisdictional limits of this Court
24 Defendants, Plaintiff suffered general damages including, but not limited to, damage to
;l to Plainffi, and with conscious disregard of her rights. Defendants occupied a position of
trust which gave them power to damage Plaintiffs ability to eam a livelihood. Defendants
Plaintifi and discriminating against her under the circumstances described here.
Defendants' conduc{ was canied out by and ratified by one or more of Defendants'
,.1 FAILUREToPREVENTHARASSmENT,DIscRII{l[ATlol{,ANDRETALIATIoN
15 (Cal. Gov't Code S r29'|(}(k))
17 63. Plaintifi realleges and incorporaEs by reference, as through fully set torth at
conduct, exposing Phintifi to cruel and unjust hardshh, with the intention to cause inlury
to Plaintiif, and with conscious disregard of her rights. Defendants occupied a position of
trust which gave them power to damage Plaintifrs abili$ to earn a livelihood. Defendants
Ptaintiff and discriminating against her under the circumstances described here.
Defendants' @nduct was carried out by ard ratified by one oI more of Defendants'
13 I proyen at trial. Defendants' conduct in discriminating against Plaintiff was willful and
21 70. Plainffi realleges and incorporates by reference, as through fully set forth at
23 71. Defendanls' conduct described in this comphint was e)dreme and outrageous
emotional
24 with the intention of causing, or reckless disregard of the probability of causing,
25 disbess to Plaintifi.
8 72. Plaintff is informed and believes and thereon alleges that Defendants'
pervasive
27 as described more fully above, including, but not limibd to, directing
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and persbtent sexual inquiries and language at her by the showts producers, was
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intended to cause PlainUff emotional distress. Alternatively, Defendants acted with
reckless disregard of the probabili$ that Plaintiff would suffer emotional distress, knowing
Defendants, Plaintiff suffered and will sufier special damages for lost eamings and wages
I
in an am6unt rmt yet fully known, but in excess of tre jurisdictional limits of this Court.
1
12 TS.Exemplaryandpunitivedamages.Defendantshaveengagedindespicable
13 conduc{, exposing Plaintiff to cruel and uniust hardship, with the intention to cause injury
'14 to Pfaintiff, and witr conscious disregard of her righb. Defendanb occupied a position of
15 trust whk$ gave them power'to damage Plaintiffs ability to eam a livelihood. Defendants
17 Plaintifi and discriminating against her under the circumstances described here.
18 Defendants' conduct was canied out by and ratilied by one or more of Defendants'
20 proven at tdal. Defendants' conduc.t in discriminating against Plaintiff was willful and
2 76.
Ratification. Plainffi is informed and believes and on lhat basis alleges that
23 Debndants were at all relevant times aware of the conduct of each of the other
24 Defendants and approred and ratified that conduct.
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S1XTH CAUSE OF ACTION
4 77. Plaintiff realleges and incorporates by reference, as through fully set forth at
7 public pilicies of the State of Califomia, including, but not limiled to, the FEI'IA and
8 federal fiUeVll.
11 in an amount not yet fully known, but in excess of the jurisdictional limits ol this court.
17 conduc,t, exposing Plaintiff to cruel and unjust hardship, with the intention to cause injury
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t8 to Phintiff, and with conscious disregard of her rights. Defendants occupied a position of
t9 trust wtrich gave them power to damage Plaintiffs ability to eam a livelihood. DeGndants
21 plaintiff and dbcriminating against her undbr the circumstances described here.
22 Defendants' conduct was canied out by and ratified by one or more of Debndants'
fr ut
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1 82. Ratification, Plaintiff is informed and believes and on that basis alleges that
2 Defendants were at all relevant limes aware of the conduct of each of the other
7 1. For general and special damages, according to proof' with inlerest thereon
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8 at the rnaximum legal rate;
9 2. For reasonable attomey's fees and costs, including expelt witness fees,
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Michael S. Morris6n
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Attorneys for Plaintiff
2. BECKY STEENHOEK
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Michael S. Morrison
Jessie S. Choi
Attorneys for Phinffi
:l BECKY STEENHOEK
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