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Irene McCormack Lawsuit

Irene McCormack Lawsuit

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Published by Ken Williams

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Published by: Ken Williams on Jul 22, 2013
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.'
,
1
:2
3
4
S6
7
",
.
,
UI
NU~IH
8
Attorn.
for
1'I!jjnijl!.
IReNE
McCORMACK
JACKSON
By
Fa
1(1
II
12
IN
THE
SUPERIOR
COURt
OF
THE
StATe
OF
CALIFORNIA
FOR THE
COUNTY
OF
SAN DIEGO
13
IRENE
McCORMACK
JACKSON,
¢ABE
NO:
14
15
Plalntilf,
COMPlAINT
FOR
DAMAGES
16
1IS.
EMPLOYMENT
DISCRIMINATlON·
SEXUAl.
HARASSMENT
11
(VJOiation
or
Gov't
Code §12940
9/
seq.)
ITY
OF
SAt!
DIEGO; ROBERT
18
rsoB'!
F1LHER.
an
Individual;
and
OOE$
1 through 25,
inclusive,
19
20
1\
22
23
24
Defendants.
PRe
IMlNARY
FACTUAL
iTATeMENI
1,
Plaintiff IRENE McCORMACK
JACKSoN
(hnnaller
refaned
10
....
"P!ai!lllft'"
or
"MS.
McCormack
Jao:;1<aon")
is,
and
at
all
reiJWant
times
mentioned
herelll
25
was,
a
resident
or
the
County
of
San
DIego,
Slate
of
california.
26
Z.
PII'IlntiIf
Ms. McCormack Jackson
is
InIonned
ami
belie\'el!.,
and
based
27
thetaon alleges,
that
Oei&ndsnt
CITY
OF
SAN
DIEGO
Is,
and
at
aU
lImes
fIlIlevant
herein
28
760 476 8299
P.01
!
j
 
U I
,"Uri
I H
760 476 8299
1
was,
II municipality
organized
and
1Ix!$1ing
UI'lc:ler
lIle
Iiiws
of
!he
Slate
of
California
doing
2
$Ubstantiai
business
In
lilt
County
of
SanDiego,
State
of
California,
CiI¥
of
SanDiego
3
employs
more
than
five emplOj'lle$ ami
i$
engaged in
interstate
commerce
within
lhe4
maening
of
CaIlfQmIa
Ggyemmen! Code
§
121126.
5
S.
Plaintiff
Ms,
McCormack
Jackson
is
informed
and
believes,
and
based
6
lIleJeOn
Illleg~
that Defendant
~BERT
("BOB") F1LN!R, (hereinafter 'FILNER")
Is
an
7 individual
who
at
allrekMlnt limes
he
...
n
was
a resident
of
the
County
of San
Diego.
I
Plaintiff McCormack
JliICkson
is
informed
and
believes thel at all
relevant
timM
herein9 FILNeR
was
the
Mayor far Defendant City
ofSan
DIego
and
a$such,
a managing agent
10
of
Defendant
City
of
San
Diego,
11
4.
The true
names
and
capacilles,
whether Individual, associate or
otherwise,
12
of
Defendants
sued heNiin as
OOES
1l1lroYgh
25,
incluslve,
are
currently
unknown
to
13
Plaintiff McCormack Jackson,
who
lherarore
sues
said Defendants
by
SUM
fictitious
14
namE!$.
Plaintiff
is
informed
and
belielle$,
and
based
thereon
alle~,
that
eaeh
of the
15
Defendants designated herein
as
a
DOE
is
IegI.IIIy
responsible
in
SOmE!
mannar for
the
16
events
and
happeni~
referred
to
herein,
and
Cl'Iusad
InJury
and damage pfOl6mataly
17
thereby
10
Plaintlif
a$
hereinafl$r alleged, Plaintiff will seak
leave
of
Court to
amend
this
18
complaint
to
shOW
the
1Tu",
names
and
clfPaclties
of the
Defendants
dQ$ignated
hereinas
19
DOESwhen
the _
nave
been asoertaIned.
20
6.
Whenever in lhis complaint
referMlCe
is
made
to"Defendants.,
and
each
of
21
thern."
such
alleg9!1on
shaU
be
~d
to
mean
the
acts
of
Defendants
acting
7..2
individually, jointly, and/or
severally.
23
8.
Plaintiff McCormack
JaCkson is
informed
and
believes,
and
besed lhereon
24
alleges,
thai
at
all times mentioned
herein,
e8<lh
of
Ihe
Defendants
was
!he
agent,
25
____
and employee,
co-venturer
and
oo-conspirator
of
each
of
the
remaining
25
Defendants,
and
was
al
aU
times hereln mentionetl, actlnll wllhin lhe
course,
soope,
2.7
purpose.
consent,
knowledge,
ratifi<:atlon
and
authorization of
such
aQaney,
employment,
28
joint
-.tuIe
and conspiracy,
2
P.02
 
"
................:;;...:;;.
'::::'1!.I..l.....J
.'::'::::
U I
~,ORTH
COAST
~IEWS
07/22/2!1J.3
12:
31
3236531bb!!l
1
1.
On
November
8,
2012.
Defendant Robert
FHner
edgeo;l
out carl DeMaio
10
2.
become
\he
Mayor
of
san
Diego.
\he 8th
mC$!
populous City
in
the
UnitedStates.
In
his
3
first
press
conference
following
the election the
Mayor~lact
promil;ed
it:>
bring a divided
4
oily
togelher.
He
said
hI!
Wilnted
to
have
an
administratiDrJ
that
would
be
inClusive
of
) minorities
and
women.
Hepreaented
himself throughout
\he
mayoraloampaign
9$
a
6 8Upportar
of
women's
rights.
7
s.
N.
his
first
nlOWS
oonference
folloWing
his
election
Defendlilnt
Mayor-elect
8
Fllner
introduced
his
lieneee,
Bronwyn
Ingram,
lIS
his
flrsllady.
(However,
on
July 8.
9 2013,
she
announ<:Qd
via
email
10
a
group
of her
$Upportel:s
that the Mgagement
had
10
been
called
off and "the rel!ltionship
was
over,,,)
11
9.
On
January
7,
2013, Defendant Mayor Riner held a
press
oonference
to
12
announre
the
appointment
of
his
staff
WhIchOOI'Il!isted
of
Z4individuals,
more
\hen
half
13
of
hem
female.
one
third
of
whom
we¥$
Latino
and
twenty-flve
peroent
of
Whom
were
14
African
Americans. He
described the
two
demn appointeliS
!!landing
behind
DefenDant
15
Mayor
Filner
III
the
presa
conference
as his
'OO!'ll
feam.'
He aaid
that
the
flrsI
16
requirements
were
competence,
effectlveness
anC!
experience.
17
10.
Standing
right
behind
Defendsnt Mayor Filner
thal
day
was
a
prOud
Irene
1
g
McCormack
Jackson,
the
aYO~$
newly appoinfed communications
direc:lor.
Other
19
appointaes
inclUded
Donna
Fry<!'
(since
I'l!<ligned),
who
would
be
in
charge
of
open
2fJ
government
and
transparency,
Vince Hal,
Filner'$
new
Chief
of
Sfelr
(since
resigned)
21
and
Allen
Jones, Peputy Chief of
Staff
(since resigned).
22
11.
In
Introducing
Plaintiff McCormack
Jacbon, the
Defendant
Mayor
Fdr>er23
pointOO
out that she
had
n:lCenliy
II!!ft
a g-year
earaer
as
the
Vice
President
of
Public;
24
Policy for the Port
of
San Diego. He
stated
thlll
her
valli
axpenenca
at
the
Port
and
her
25
prior
""",,""nee
as a
working
news
person
would be
invaluable in
making
the
Cily
III
760 476 8299
26
driving economic
engine
in
\he
future. What
Defendsnt
Mayor Fllner
diel
not
mention
was
27
that Plaintiff McCormack
Jaokson had
taken
iii
$50,000
pay
cut
in ordGr
to
tak"this
job
28
with
his
administration.
She
believedln what the Mayor
had
pubncly
pllt forth
as
his
3
P.03

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