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UI N U ~ I H CORST NEWS
8 Attorn. for 1'I!jjnijl!. IReNE McCORMACK JACKSON
By Fa
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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.)
CITY OF SAt! DIEGO; ROBERT
18 rsoB'! F1LHER. an Individual; and
OOE$ 1 through 25, inclusive,
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1\
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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
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1 was, II municipality organized and 1Ix!$1ing UI'lc:ler lIle Iiiws of !he Slate of California doing
2 $Ubstantiai business In lilt County of San Diego, State of California, CiI¥ of San Diego
3 employs more than five emplOj'lle$ ami i$ engaged in interstate commerce within lhe
4 maening of CaIlfQmIa Ggyemmen! Code § 121126.
5 S. Plaintiff Ms, McCormack Jackson is informed and believes, and based
6 lIleJeOn that Defendant ("BOB") F1LN!R, (hereinafter 'FILNER") Is an
7 individual who at allrekMlnt limes he .... ln was a resident of the County of San Diego.
I Plaintiff McCormack JliICkson is informed and believes thel at all relevant timM herein
9 FILNeR was the Mayor far Defendant City of San 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 that eaeh of the
15 Defendants designated herein as a DOE is IegI.IIIy responsible in SOmE! mannar for the
16 events and 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 herein as
19 DOES when 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 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,
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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$! populous City in the United States. In his
3 first press conference following the election the promil;ed it:> bring a divided
4 oily togelher. He said hI! Wilnted to have an administratiDrJ that would be inClusive of
) minorities and women. He preaented himself throughout \he mayoral oampaign 9$ 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 $Upportel:s that the Mgagement had
10 been called off and "the rel!ltionship was over,,,)
11 9. On January 7, 2013, Defendant Mayor Riner held a press oonference to
12 announre the appointment of his staff WhIch OOI'Il!isted of Z4 individuals, more \hen half
13 of them female. one third of whom we¥$ 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 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>er
23 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
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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
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1 vision for san Diego's future. Ms. McCormaok Jackson believed in Defendant Filner,
2 pllllin and simple.
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:> 12. That day Defendant Finer said in referring to his core team, "They all know
4 what they're getting into.' Plaintiff McCormaCk JaeklSon thought that was a true
5 statement. She thought that whal she was getting into was an administration !hat would
6 be dedlca.ted to irnprtlving the livH of San DIego residents. She !hough! that the Finer
7 administration would be doing greetthlngs for the people of the City of San Diego and
8 thai she would play a pert in that h(ataric affort.
9 13. Instead, in the short time thst Defendant Fllner hall been Mayor, Robert
10 Fllner has disgraced him"!!lf and !he office he holds, by engaging in numerous insianoas
11 of sexual harassment If Plaintiff McCormack JaekISon had known what she was "really
12 getiIn!ll into' she never would have left her position at the Port of San Diego.
l>
14 BRST CAUSE OF ACTION
15 (SomJa/ Harassment In Violation of Caljfcmla God Cq4, 512940 et $Qq.
1 Q Against All Dst'endllntl and DOES 1-25)
! 7 14 Plairrtllf McCormack Jaokson repeats and reaUeges by reference each and
I Severy <dlegetion contained In paragraph'" 1 throUlih 13 and incorporates !he saml!! herein
19 as though fully set furth.
20 15. Plaintiff McCormac!< J!ICk&>n was previously employed as ths Ville
21 Pre<!>iden! of Public Polley for the Port of San Diego. In that capacity, she eamed
22 $ 1 7 ~ , O O O a year. JI.Irer Defendant FHnerwas eIooted Mayor for Oe!endant City of San
2:; Diego, Plalnlllf resigned her position .. !he Vice President of PI.lbfic Policy for thG Port of
24 San Diego and accepted !he posltion of Cornmunicatioll$ DII'Gc\or fur Defendants, at a
2S salely reduction of $50,000 a year, beca\l1Se iIIe is an ideal",,! and felt tim !he n$W
26 administration would be dcing good things and shoo wanted to be a part of it. Plaintiff
27 McCormaCk Jackson believes in public sarvioa. Plainlllf McCormack Jaekson bellan
28 employment With Defendants on January 3, 2013.
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I 16. On Jenuary 25, 2013. Defendant Mayor Filner_ giving iii "Slate of !he
2 City" address. The speech was IUpposed to begin at 6:00 p.m. However, they were
3 running late. As the Communications Director, Plaintiff McConnacK Jaclc:son was
4 bacl<8lage wfth Defendant Alner. Plaillliff said 10 lJefendant Mayor Fllner. "Don' WOfrIJ
5 Mayor, you will do a great jab: Defendant Mayor Filner replied in 111m or IUbstance. "I
6 would do a batter Job if you gave n1@ a kisa.·
1 17. The foUOWing month, February 2013. Defendant Mayor Filnerdecided 10
8 crash the Cily Attornev's Press oonterence. Plaillliff McConnack Jackson was in en
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<;I eleIIa10r with [)e{$ndan! Mayor Filner along with the police offtoer asaigned to Oefe<1dant
1 () Mayor Filnar. The pollee officer was fixing his han"c;uffs. The MaYQr put a headlock on
11 Plaintiff and said. 'you know what I would like to dO with those handouffar Plaintiff
12 e.ldricatad hel'tlelf and Immediately chal'\ged the IUbjec:t.
13 18. In or about lilts FebruarylUrly MarcJ'l 2013, Plaintiff McCormack Jackson,
14 Def$ndant Mayor Fllnar and his assigned pcrn:e offiOi!lr got 1010 an a1ave1or. As they were
1 S getting Inlo the eleva10r De{$ndant Mayor F"ner that he had forgotten his jacket
16 The police officer offered to go back and get it. Plaintiff McCormack Jackson got into the
17 elevator with Defendant Mayor Filner.
1S 19. As soon as the elevator doors closed, Defendant MaYQrFilner pulled
19 Plaintiff McCormack Jackson toward him while placing his arms around her without her
20 consent. He !>aid in s\.Im or substance, 'you know you are beautiful. I have always loved
21 you. Somedey I know thet you are golng 10 marry me. 1 am so in love with you.
22 WOUldn't it be great ff you 100k off your panties and WOI'ked without !hem onr Plaintiff
23 was aghast and pu$hed him awlllY. Defendant Filner!hen stated "Come Ort. Give me a
24 kiss." When Plaintifflumad away, witnout her oonsent, he kissed her on the cheek.
25 Mayor RIner only ceased lrying to kiss her v;t., the elevator stopped and a staffer got in
26 with them.
27 2Q. Tha fi",t Saturday in April 2013, Defendant Mayor Fliner opened the lobby
28 of City Hal to meet with anyone who wante<l to "peak with him for a iilIw minutes ",acn.
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As the Communications Oirector, Plaintiff McCormack Jackson was lQqUired to be at this
2 event Defendant FUne, had been meeting wilh for a While and decided \0
3 take a bnlak. Defendant Mayor Filner ill known to love chocolate. dOUghnw. Plainliff
4 pOinted out to Oefendant Mayor Filner that thefli! were some choeolam doughnw
5 a\l'llilable.
6 21. Wrthout her eont.ent Defendant /oAaVor Filnar put Pleintiff McCormack
7 Jackson into a headlock and pUlled her lliong with him as he made his way toward the
g doughnuts. Pialnlilf McCormack Jackson could not get :xway. His grip was too strong. As
9 Mayor FHner puDed her along. he told her that she was 'so beQutifUl' and that he had
10 loved her for a long time. Plaintiff could not move. He a$ked her 'when are we going to
11 get married. Wouldn't it be great if we oonsummaled the marriage?" All Pialnlilf
12 McCormac:!< Jack$Ol\ could lhlnk of to say was, 'Slr, you have people out thera.' He
13 finally released her.
14 22. In lata Apnllaarly May 2013, Plainlilf McCormack Jackson and Oefendar\t
15 Mayor Riner were going 10 the "Monthly lalkwith Ih .. Mayor" at the Fox Studies in San
16 DI&9O when Defendant Mayor Filner came up behind Pleintiff Meconnaek Jackson, aod
17 without her consent. put hi!> arm around her shoulder. Deftlndant Mayor Filner said In
18 sum or substance, "you are so beautiful. 110\I¥.1 you. One day we are going to get
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19 married.' Defendant Mayor Filne, said he was infatuated with Plaintiff and that thay \'.Ie,a
2Q going to be togethe,. "Let's make It happen,' he said.
21 23. In June :!013, Defendam Mayor Filner _ silting in a chair _ding a
:22 proposed press relesoe. He said to Plaintifl McCOrmack Jackson,. Utfs just put some
2:l ex<;:Iamation points at the end," A$ Defendant Mayor FllnQl' got up to leave, wUh Ihe door
24 to har offiCe open, he $Sid in sum or substance, "you are so beautiful. I am infatuated
25 with you, When a .... you going to gel naked? Come on, give me a kiss.' As Plaintiff
26 McConnack Jackson attamp\ed to gat Defendant Mayor Finer to Ie""", !let offioe, he
27 kissed her on the cheek, Plaintiff sl«nty told him that he needed to leave her office.
28 Defendant Mayor F'JIne, replied, 'you Qal'u'lalldck me out. 1 am the Mayor. I O\!In go
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l " ' ~ E l r e I want, any time I want. a
2 .24. In June 2013. Defendant Mayor Fllner went to Saoramento wiIIl hi$ Chief of
3 Staff. Plaintiff McCormack Jackson i$ informed and beJMwes that whHe Defendant Mayor
4 Filner was gone. female staffef$ approached his Deputy Chief of steff. Allen Jones about
5 the hostile worl< environment that the Mayor had orealed for female Mlployees.
6 25. Plaintiff McCormack Jack$on is infOl'Tl'led and believes that in the short time
7 tha1 Defendant Mayor Filner had been in offICe. three women had m be driven home
8 bec:aus.e of his abusive treatment. Plaintiff McCormack Jackson is fUrther informed and
9 believes that fiIIe schedulers resigned bocau$S of Defendant Mayor Filner's behavior.
10 Plaintiff had also confided in Mr. Jones that she too had been thinking about ge\fing
11 lInOIher job.
12 26. The day altar Defendant Mayor FUner relumed from Sacramento, the!9
13 was a policy meeting at City Hall. Defendant Mayor Filner walked into the conference
14 ; room along With hl& Chief of Sll!lff. /Is the Communications Director, Plaintiff McCormack
15 Jackson was in atWndance as WIllI the Deputy Chief of Staff, Mr. Jones.
16 27. Mr. Jones began to address Defend<ilnt Mayor Fnner and said In sum or
17 substance. "before we start there Ie something r need to say. I have Known you
18 {Defendant Mayor Fllner] longer than anyone hef1i,. We have been lrienda for 35 years.
19 You need to listen to me. You are running a terrible offiQe. You are treating women in ~ !
20 horrible manner. What you are doing may even be illegal. You need to change your
21 ways. You need extreme therapy. In fila meantime, 1st us (referring to his core staff) run
21 the aflice: Osf9ndant Mayer Anar intem!pted him saying, "Allen. you are full of shit.
23 Give me one example.' Mr. Jones replied, "Bob. I know your modus operandi. This i$
24 Ilowyou get people offtllelr point. You iIllemJI)t tham. I am nat playing your game. You
25 need to lislen to me.' Defendant Mayor Fllner then SlIt back and said In sum or
26 substance. "maybe you [Allen Jones] just do not want to be here.' Mr. Jones replied,
27 "You are right. I do not want to be here. I resign.'
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28. AI that moment Plainiif! MeCorma<:k Jackson that notfling would
2 change. If Defendant Mayor Filner would not listen II) hia fri<lnd and oonfidanw of 35
:3 yeallI, then thera was no Chance tIlaI Defendant Filner was going to SlOp his sexual
4 harassment of her or slop creating II hostile and intimidating wor1<; elwln::mment for the
5 othE>r women who WQrked at Cily Hall.
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Q 29. Plaintiff McCormack had been suffering degradation and humiliatioo at the
7 hands of Defendant Mayor Filner. At iIlat IOOment Plaintiff realized that Defendant Filner
8 would not ceaslt his behavior and that she could no longer allowl!Dlerate his behavior.
9 Plaintiff MGCormack Jadleon SlI)od up and said in sum or subatance. 'I agree with Allen.
lC You are horrible" and ehe began WBlking out.
11 30. As Plaintiff MGCormack Jackson was leaving Defendant Mayor Filner sald
12 in sum Of substance, "Really Irene, give me just one exampla, I dare you." Plaintiff
13 turned arOlJnd lind said in sum or SlJbstance, 'Really Mayor - you want me to do that?
14 How abOut when you said IhlIt I sholJld take my psntles off and woll< without them.'
15 Plail"\tlff McCormack Jackson Slamonlld the door and walked out.
16 31. After Plaintiff McConnack Jackson lei! that day Defendant Mayor Filner
17 sent an emissary to her which Ih$n led to a meeting on June 25,2013. M.lhat mealing,
18 Defendant Mayor Filner agreed that he had been despicabla toward women. He said thai
19 he needed help and that he would apologize publicly for what he had Defendant
20 Mayor Filner al90 said iIlat he would get _ual harassment training.
21 32, Defendant Mayor Filner Offered Plaintiff MoCorma<:k Jackson Ihe
22 opponunilylO work for the COO in charge of opetational communlea1ions for the
23 City. Plaintiff had no other employment opporl:lJnlty and Ihus ac¢epl:ed Ille position.
24 33. There 'IIeIli! several other ooeasions where Defendant Mayor "'ill1$/' placed
2S Plairltilf MeComnaok Jackson In a headlock without her consent. PJail'lliff is informed and
25 believes iIlat Defandant Mayor Fllner has done the .......... to other women.
27 III
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1 M. Plaintiff McCormack Jackson is informed and beDews tnat Defendant
2 Mayor Fllner has al$o engaged In sexually Offensive behavior With ottler female
3
4 35. Pleiniiff McCormack JQCkson repeats and realleges by reference each and
5 every allegation conlained in paTagfliPhs 1 tOrough 34 and incorporale$ tOe same herein
6 as though fully set forth and ful'lher alleges thm: (1) Plail11il'f McCormack Jackson was an
7 employee of Defendant City of SSn Diego; (2) Plaintift' McCormack Jackson was
S subjected to unwanted harassing conduct because she is II woman; (3) tOe harassing
9 conduct was severe or parvaslve; (4) II reasonable woman in Plaintiff McCQrn'liiIck
10 Jackson's cltcumstance& would have considered the wor!( environment to be hostile or
11 abuslva; (5) Plail11il'f McCormack JaCkson <;oniidered tOe work environment to be
12 . hostile or abusive; (6) Defendanl Fllner parlioipatad in the harassing conouc!; (1) P\alntlff
13 McCormack Jackson was harmed; and (8) the conduct was a substantial factor in
14 cau,,;ng Plalniiff McConTliilok Jack$O!1's harm.
15 36, hl a result of 'IIle aforementioned conduct, Plaintiff McCormack Jackson
16 has suflena<l and wiD continue to suffer pain and suffering, and extreme and severe
17 mental anguish and emotional cfl&tress resullins from Defendant Mayor Fllner's conduct,
18 37, Deiendanls are <IITlployel1lln the Stale of Canfomi!1, as defined In the
19 California Fair employment II!ld Housing At't rFEHA"), Callfllm;a Government Code
20 §12S2!;.
21 38. Defendants' hara!l$ment of Plaintiff on the basis of her gander constitule$ a
:tl violation of the California Fair Employment and HoIJsing NJt. CaUfomill
22 §12940 e/ seq.
24 39. Plaintiff McCormack Jackson is infomled and believes, and based thereon
25 alleges, !hat in addition to tOe prac:tlces enumeraled aboVe, Defendants may have
26 engaged in other dlscrlrninatory praellCS$ against ner wIliah are not yet ful!y known. At
27 such lim!! 3$ such discriminatory practices become known to her, Plalfltiff will seek leave
28 of Court to amend thl$ Complall'll in that regard.
9
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40. On July 1 S, 2013, Plaintiff McCormack Jackson flied timely chargee against
Z Defendants with the California Department of Fair Employment and Housing ("DPEH")
3 against Defendants Mayor Alner and CIty of San Diego. Wifhin one year of '!he filing of
4 this Complaint. the California D9plIrtmant of Fair Employment and Housing issued right
5 to sue notlces to Plaintiff McCormack JaCkson lhl. lawsuit. True and correct
6 copies of the administrmive cha:llIes and right to sUe lell:er are attached hereto as
7 Exhilits 'A" and "8.' Plaintiff McCormaek Jaokaorl has Iherefore e:xnlllusted her
8 admilllstratlve remed ies
9 41. As II direct and proximate of Defendants' willful, knowing and
If) intentional discrimination against her, Plaini'll'! McCormack Jackson has l!IUffared and will
11 continue to sulfar extIeme and severe mental anguish and emotiooal dislTess. Plaintiff
12 McCormack Jackson is thereby entilled to general and compensatory damages In
13 amounts to be proven at trial.
14 42. As iii direct and proximate result of Defendants' willful. knowing and
15 intentional discrimination against her, Plaintiff McCormaek Jaekson has further suffered
16 and will oontinue to I!uffar a loss of earnings andlor other employment benefi1:s and jQb
17 opportunities.. Plaintiff McCormack Jackson is thereby entitled 10 general and
U compensatory damages In Ql'l'lounts to be p!'O\I9Il at trial.
19 43. As a further, dll'<!ICI and proximate _ult of DefOndants· violation of
20 California !?Iovamman! Code §12900, el. seq., as herelofore described, Plaintiff
21 MoCormaCk Jackson has been compelled to retain the services of counsel in an effort to
22. enforce the IEI!ms and conditiOns of her employment relationship with Defendants, and
Z3 hes Il\erQby InCurred. and wi!1 continue to incur, Ie,,"" fees and costs, the filII nature and
l4 extent Of which are presanl!y unknown 10 her. Plaintiff McCormack JaCkson will therefore
25 seek leave of Court to amand this Complaint in that regard ""hen \he same shaH be flllly
26 and finally asoertail'lQlj, Plaintiff McCormack Jackson requests that allomeys fees b<>
27 . awarded purauant to Califomja Government Code § 12985.
2S III
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44. Plaintiff McCormack Jackson ill informed aM believes, and based
2 alleges., that the outrageous COI'lduct of Defendal'll$ described above was done with
3 malice, fraud and oppression and wlIh conscious disregard for her rights and with the
4 intent design snd purpose of injuring her. Defendanls participated, authorized,
S condoned and/or ratified t"'e unlawful CQIIdU1:'t of Defendant Mayor Filner. By reason
6 !h9teof, Plaintiff McCormack Jackson is entitled to or exemplety damages from
7 Defendant Fllner in a sum aCCOrding to proof at trial.
8 WHEREFORE, Plaintiff MoCormack Jac:lllson prays that judgment be entered in
9 her flM>r and against Defendants as follows:
10 1. That Plaintiff be awar:lad general and compensatory damages,
11 including prejudgment Inter'l'sl, in an amount aooording to proof at trial:
12 2. That Plaintiff Q'l! awal'd'l!d reasonable attorneys' feas and costs of suit and
13 knerestinourred;
14 3. That Plaintill be awBl'd'l!d punitivec or exemplary damage!. against
15 Defendant Filner in an amount according 10 pltlaf at trial; and
16 4. That this Court award suoh other and further relief as the Court deems just
17 and pmpel'.
18
19 DATED: 2013 ALLRED, MAAOKO & GOlDBERG
2Q
21

, ORI ALL
22
:l.3
, :o.ttomeys for Plaintiff
IRENE McCORMACK JACKSON
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25
26
27
28
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EXBlBr.t A
JUL-22-2013
UT NORTH CORST NEIJS

!\IIPI(MOI!Ift
RE$IO'OND1H'IT
CIty 01 San Diego,
f\0lJ8I! il9ao, fll"'"
AGeNTfOR5ERVICE
Jan Golds""n, CiIj' of
_Diego
NO, OF
105110
Robert reol>1 fllnor
ClA'7EFUDJu118.201l
M¢PlF:e.o JI.JI1a,2t13,
COI\I!'I.AINT 01' DIsCRIMINATION UNDER Tile Plt01ll9l0"" OF THE
CALIFORNIA FAUt EIIIPLQYMIiNT AND HOUSllle ACT
:>F;;H i\4A TIf;R
141691""053$

,.\DORES::'
202 C 5!Joot San Diego CA 9210-,

202 C S""," S8n D''''9'>CA 921i)1

(B'9) 23e.B220

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p,tQST :;lISCRI\ilf.1A naN TOOl<
J\I:'l2O,2013
i'fPE OF EMPLOYeR
EIeC1!!d OffiolallStat ...
Locai
?02 C street San :nego CA
.. - .. - ."'---""-,_._----,.-"'-,
REVISSD JULY ZC{;.'l
PAGE 113
750 4' Ib 8,,:<:<
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O,j LtJ LOJ..;) .;;L.,J..)..J-.J ...... u ..
,...., IV< ,- .......... ,

AJSA f\ESU .. T. I WAS
COI\ll'1AI1IIT 01' D!sCIIIMfjATION UNDER THe PRO\IISIONS OF TI'Il
CAWfORNIA FAIR 1EMPtoYYI!MT AND HOUSING ACT
Jun 20.2013

DFfri ",MAnER hlUMBE;;':
1411!91-60538
Oenied a W'Oti: f1'QQ of ttisc"'il"r.tM!bn andiQr retalffilti!)r'l, Fon::ed to
quit, other sC'IlJ_d \I> $Oxusl h ..... M\\!N
I wes by Ihe City of Dl(tgQ e-s tile Oirectnr 01 fot Mayor Bob FJ1l"1er froM Jafluary
3, ,2<;)13 until Jur'Ia ZO, 201 a. Dl.trlng the eotlrlile of my employment. ! W\ilS $Ubj:$Cted tc·se)(uii har<":lssm&ln; 'f1!j MI'.
Fitner. Be<;ause af the intolerable woddng I had no choice bu! to resign my Director :1f
Comrnunka&:u'''s, Thereafter, I '\!\ISS oF.eIed am:'.lther pOSifion In .enoftler I wr.urtiy hoid.
ClATEF1...Et:..IUI 2012;
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JUL-22-2013 14:57
UT NORTH NEWS
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I 'Msh to ptnU1it thls matter 1:'1 r;ourt I hereby feql..'e5t '!hat the Departrn!i:'lI Fair Empfoyrnent aM HtJu!1l1n;
provide 8 rigrrt to 9Ue. I um:ierstand if I want a fede:-al to we 1 "liS!! L"le U.S. Equal
EmpI_ Cppoo1lJnlty Comml •• "," (SEOC) '" fi'e • """",alnt _In 30 "")'1> 01 """"pt of "" DFEH "Noace of
Case c::JosUI'6 al'ld to Sue, n or wBbin 300 days of the alleged ;,ct. earlielt-.
! hine been coerced into maklng requast, nor do I make It based on tear of retaUiatiorr if! d() not de>?Q, !
understand it is trnJ Oepartti'.ent Of Fair El'I1p10!lt:'!Mt and Housll''Ets parley to not prQOess or I"aOp.ElA a compialn(
once the complaint has been closed an (he oMit of "Complairtant Elected Court .b,ctiol'\'."
By $.lhmftii:1S thjs oomplaint. I am declaring under penally rI under fue laws of the .state of ca:'iftrmla that,
to !hill b¢St of roy knowledge, alllnf01TT'etiOIl coni:BIneo )1'1' this tnJe and correct, except matters ste.ted
on my infOrmaaor, BOd belief, and I de:date that tI'Io$e maltli!n; I believe to be t"llQ"
VOrt1led by [,en. McCormack Jacl<SOn, Complaillom. and dalec 00 July 18, 20'3 at EI Cajon, CA.
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UT NORTH COAST NEWS
07/22/2013 12:.31
760 476 8299 P.16
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