KARUNA ANAND, Plaintiff, SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO Case No.: 34-2018-00226894

1 Lawrance A.
Bohm (SBN: 208716) FILED/ENDORSED

Michael D. McCoy (SBN: 317868)
2 BOHM L A W GROUP, INC. JUN 2 1 2018
3 4600 Northgate Boulevard, Suite 210
Sacramento, Califomia 95834 By:. R. San Miauei
4 Telephone: 916.927.5574 Deputy Clerk
Facsimile: 916.927.2046
5
6 Erik M. Roper (SBN: 259756)
LAW O F F I C E OF E R I K M. ROPER
7
2121 Natomas Crossing Drive, Suite 200-117
8 Sacramento, Califomia 95834
Telephone: 916.281.8249
9 Facsimile: 916.527.0118
10 Attomeys for Claimant,
KARUNA ANAND
11
12 SUPERIOR COURT OF CALIFORNIA
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i j tzi o 13 COUNTY OF SACRAMENTO
" I ^ 14 KARUNA ANAND, Case No.: 34-2018-00226894

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U Plaintiff, PLAINTIFF'S V E R I F I E D FIRST
^ oa AMENDED COMPLAINT FOR
w 16 DAMAGES AND DEMAND FOR JURY
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o CALIFORNIA DEPARTMENT OF
Z < 18 Action Filed: February 9, 2018
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o CO CORRECTIONS AND REHABILITATION;
19 and DOES 1 through 30, inclusive. Action Filed: February 9, 2018
20 Defendants. 1. CA Labor Code §§ 98.6 and 1102.5
21 2. CA Health and Safety Code §1278.5
3. CA Labor Code § 6310
22
4. FEHA Disability Discrimination
23 5. FEHA Failure to Engage
6. FEHA Failure to Accommodate
24 7. FEHA Retaliation
25 8. Failure to Prevent Discrimination
and Retaliation
26 9. CFRA Interference/Retaliation
10. CA Government Code § 8547
27
Plaintiff Karuna Anand respectfully submits this First Amended Complaint for Damages
28
and Demand for Jury Trial and alleges as follows:
1
PltTs Verified First Amended Complaint for Damages and Dmnd for Jury Trial Lawrance A. Bohm, Esq.
Anand v. California Department of Corrections and Rehabilitation, et al. Erik M. Roper, Esq.
Case No.: 34-2018-00226894 Michael D. McCoy, Esq.
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1 CASE OVERVIEW
2 The Califomia Department of Corrections and Rehabilitation provides medical care and
3 psychiatric services to incarcerated inmates who are some of Califomia's most vulnerable
4 patients. CDCR cares for those who have committed crimes, but who have such acute
5 psychological issues that they must be treated or hospitalized. The CDCR also employs
6 psychologists as theyfinishtheir doctoral programs and accumulate hours required to sit for their
7 licensing exams. These patients are powerless to leave, and the unlicensed CDCR psychologists
8 treating them are inexperienced, and have little power in the agency's hierarchy. Rather than care
9 for its patients, who rely solely on CDCR for their mental and physical well-being, CDCR
10 violated numerous state laws that require licensed professionals to supervise unlicensed,
11 inexperienced healthcare providers. Due to CDCR's intentional and repeated violations, two
12 patients committed suicide within a three-month period. Many CDCR mental health professionals
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Q 1/3 a\ 13 resigned due to lack of patient and staff safety. One medical doctor, the Chief of Psychiatry,
" ^" ~ 14 refiised to quit, and refused to follow CDCR's unlawful orders to break patient safety laws. CDCR
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15 insisted that this doctor ignore Califomia law, and when she refused, retaliated against her by
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16 demoting this Chief of Psychiatry to the mail room, and forcing her to sort mail and screen letters
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17 for pornography. CDCR then further retaliated by abruptly terminating her.
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PARTIES AND JURISDICTION
o 19 1. Plaintiff Karuna Anand, M.D. ("Dr. Anand" or "Plaintiff) was at all times
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20 relevant to this action, a recruit, employee, or wrongfully terminated employee of Defendant
21 Califomia Department of Corrections and Rehabilitation ("CDCR" or "Defendant"), located in
22 Sacramento, Califomia.
23 2. Venue and jurisdiction are proper because Defendant is a state agency,
24 headquartered in Sacramento County, its officers and directors are in Sacramento County, several
•25 witnesses are located in Sacramento County, and the alleged wrongful termination decisions were
26 made in Sacramento County.
27 3. Defendant CDCR was at all times relevant to this action a public agency in the
28 State of Califomia. Defendant was at all times relevant an employer as defined by Califomia law.
2
1 4. Plaintiff is ignorant of the true names and capacities of the defendants sued herein
2 as DOES 1 through 100. Defendants Does 1 through 100 are sued herein underfictitiousnames
3 pursuant to Califomia Code of Civil Procedure section 474. Plaintiff is informed and believes,
4 and on that basis alleges, that each defendant sued under suchfictitiousnames is in some manner
5 responsible for the wrongs and damages as alleged herein. Plaintiff does not at this time know
6 the tme names or capacities of said defendants, but prays that the same may be inserted herein
7 when ascertained.
8 5. At all times relevant, each and every defendant was an agent and/or employee of
9 each and every other defendant. In doing the things alleged in the causes of action stated herein,
10 each and every defendant was acting within the course and scope of this agency or employment,
11 and was acting with the consent, permission and authorization of each remaining defendant. All
CS 12 actions of each defendant as alleged herein were ratified and approved by every other defendant
c/3 o\ 13 or their officers or managing agents.
14 STATEMENT OF FACTS
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6. Dr. Karuna Anand ("Plaintiff or "Dr. Anand") began employment as a
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o 16 psychiatrist in March 2010 at the Califomia Department of Corrections and Rehabilitation
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17 ("CDCR") at the Califomia Medical Facility - Vacavillc as a Staff Psychiatrist.
o 00 18 7. On or about March 16, 2014, Dr. Anand was promoted to the position of Senior
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19 Psychiatrist Supervisor, and began to serve in that role at CDCR's Califomia Health Care Facility
20 - Stockton ("CHCF Stockton"). A Senior Psychiatrist's duties include, but are not limited to:
21 recruiting and retention, directing and supervising medical staff, planning and directing
22 psychiatry and mental health services in both an inpatient and outpatient setting, and ensuring
23 compliance with rules and regulations. Senior Psychiatrists are also expected to work with the
24 Chief Psychiatrist ("CP") and Chief of Mental Health ("CMH").
25 8. In or around June 2015, Dr. Anand volunteered to transfer to the Califomia State
26 Prison, Sacramento ("CSP Sacramento") location as an Acting Chief Psychiatrist to review the
27 institution functioning and provide a review of findings and plan of correction to CDCR
28 Headquarters and its CEO at CSP Sacramento.
1 9. On or about August 17,2015, Dr. Anand retumed to CHCF Stockton at the request
2 of the CHCF CEO, Jackie Clark ("Ms. Clark"), to assume the position of Acting Chief
3 Psychiatrist. Dr. Anand performed "out of class" in this position fi-om August 17, 2015 until
4 January 15, 2016.
5 10. On or about August 18, 2015, Dr. Anand noticed serious staffing shortages which
6 directly impacted patient care at CHCF Stockton. Dr. Anand addressed this issue in meetings with
7 the Mental Health Leadership Team, which included Dr. Anand as the Acting Chief Psychiatrist,
8 Dr. Tani Shaffer ("Dr. Shaffer"), the Chief Psychologist, and Dr. Bret McLaughlin ("Dr.
9 McLaughlin"), the Chief of Mental Health.
10 11. In or around October 2015, Dr. Shelly Minor ("Dr. Minor"), the Clinical Director
11 of the Mental Health Crisis Unit, informed Dr. Anand of Dr. Minor's concems that staffing was
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12 critically low, negatively impacting patient care. Dr. Anand also complained of this issue to Dr.
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oT ^ § 14 a "misconception" and that they were "on top of things." Dr. Anand escalated this concern to Ms.
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16 12. In an effort to address these issues. Dr. Anand designed a plan to address the staff
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o ^ ? 17 shortages. Dr. Anand wanted approval to add a 0.25 psychiatry position which could be filled by
Z ^ 18 a psychiatrist who already worked full time for the state and wanted an additional day of work.
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19 Dr. Anand submitted this plan to Dr. McLaughlin and Ms. Clark. Dr. Anand emphasized that
20 CHCF Stockton was not currently operating in accordance with the standards required by the
21 federal Supreme Court in its Brown v. Plata decision (563 U.S. 493 (2011)) (often referred to as
22 mandating the "Coleman Standards" due to the Court's analysis of the related case of Coleman
23 V. Brown). Dr. Anand complained that CHCF Stockton's staffing was critically low, below the
24 standards set forth in Coleman, and that her plan would be a step towards remedying this. Dr.
25 McLaughlin was not supportive, telling Dr. Anand that she would "never get the additional
26 positions approved." Dr. Anand was ultimately successful in getting additional positions
27 approved.
28 ///
Anand v. California Department of Corrections and Rehabilitation, et al Erik M. Roper, Esq.
CaseNo.: 34-2018-00226894 Michael D. McCoy, Esq.
1 13. On or about January 14, 2016, Dr. Anand was promoted to the Chief Psychiatrist
2 position at CHCF Stockton. This promotion required a one-year probationary period. Dr.
3 McLaughlin armounced Dr. Anand's promotion in a memorandum, stating, "It is with great
4 pleasure that I armounce the promotion of Dr. Karuna Anand to the promotion of Chief
5 Psychiatrist. She had previously served as a Senior Psychiatrist here at CHCF since March 2014
6 and has been the acting Chief Psychiatrist since August 2015. She has excelled in her leadership
7 role and constantly found the means and energy to rectify system deficiencies and improve
8 processes. Her most recent success has been getting the 0.25 positions approved through
9 headquarters granting us an additional 20 psychiatry quarter-time slots, all while carrying a full
10 caseload."
11 14. Dr. Anand's duties in the capacity of a Chief Psychiatrist at CHCF Stockton
12 included providing supervision to psychiatry staff, including Staff Psychiatrists and Senior
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14 and ensuring psychiatrists complied with controlling laws and regulations. Additionally, Dr.
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15 Anand was responsible for assisting the Chief of Mental Health in developing, implementing, and
16 managing the mental health clinical activities and delivering effective, efficient care to patients.
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19 technical advice to advisory committees and health professionals engaged in the delivery of
20 mental health services both in the outpatient and inpatient setting. Dr. Anand also directed and
21 evaluated institutional and outpatient treatment programs to ensure compliance with appropriate
22 standards of care on a continuous basis.
23 ///
24 ///
25 ///
26 ///
27 ///
28 ///
1 15. In or around late February or early March 2016, Dr. Anand noticed that Dr. Shaffer
2 and Dr. McLaughlin were assigning a large number of unlicensed staff psychologists to the area
3 called the Mental Health Crisis Bed ("MHCB") widiout the required Department of Public Health
4 approval and Board of Psychology-mandated supervision. Dr. Anand approached Dr. Shaffer and
5 Dr. McLaughlin about this issue and complained that it negatively impacted patient safety. Dr.
6 McLaughlin and Dr. Shaffer responded to Dr. Anand's complaint by telling her, "We have it
7 under control."
8 16. Later in or around mid-March 2016, Dr. McLaughlin and Dr. Shaffer started
9 moving licensed staff psychologists from the MHCB, where a license is required, to the
10 unlicensed Enhanced Outpatient Program. This left the MHCB improperly staffed, without
11 enough licensed psychologists to supervise unlicensed psychologists.
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13 committed suicide approximately 27 hours after discharge. The clinician on the case was an
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14 unlicensed psychologist who was not allowed to work in the MHCB without approval or
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15 unsupervised. However, this unlicensed clinician was in fact working in the MHCB without a
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16 license, and with minimal to no supervision.
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17 18. In or around early-to-mid April 2016, multiple unlicensed psychologists in the
Z < 18 MHCB eamed their licenses. CDCR management pressured these newly-licensed psychologists tc
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19 sign off on unlicensed psychologists' work. Normally, newly-licensed psychologists will work
20 with more senior psychologists while they continue to gain experience, and senior psychologist:
21 sign off on unlicensed psychologists' work. The newly-licensed psychologists felt that they were
22 not qualified to immediately work in a supervisory position, and that doing so would present a
23 patient safety risk and put their licenses at risk. They verbalized their concems to the Clinica
24 Director of MHCB, Dr. Minor. Several newly-licensed psychologists who did not want tc
25 jeopardize patient care or their license status quit as a result.
26 ///
27 ///
28 ///
Anand v. California Department of Corrections and Rehabilitation, et al Erik M. Roper, Esq.
1 19. In or around mid-to-late April 2016, Dr. Anand again brought the issue oi'
2 inexperienced and untrained staff being assigned to the mental health crisis beds to Dr. Shaffer anc
3 Dr. McLaughlin. Psychiatry staff complained to Dr. Anand that unlicensed psychologists were noi
4 getting the supervision required by law, threatening patient safety and psychiatrists' licenses.
5 20. In or around June 2016, Dr. Anand complained to Dr. Minor, Senior Psychologisi
6 Supervisor and Clinical Director, MHCB, about unlicensed psychologists working in in a licensee
7 unit. . Dr. Anand reported Defendant's policies that required non-assigned psychologists anc
8 psychiatrists to sign off on unlicensed pre-doctoral interns' psychology orders and notes. Dr. Minoi
9 responded that she had already sent a written complaint to CDCR Headquarters ("HQ") and CDCP
10 Regional describing about the number of unlicensed clinicians in the MHCB, and her concern foi
11 patient safety due to their practices.
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12 21. In or around June 2016, Dr. Anand objected to Dr. Shaffer when Dr. Shaffer orderec
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13 psychiatrists to co-sign unlicensed psychologists' orders and documentation. Dr. Shaffer insistec
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14 it was acceptable. Believing it was unacceptable, unlawful, and a risk to patient safety. Dr. Ananc
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O HS 17 ("MBC") oversees psychiatrists, while the Board of Psychology ("BOP") oversees psychologists
Z ^ 18 Unlicensed psychologists must be supervised by an assigned licensed psychologist. This licensee
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19 psychologist has to be identified and sign a written agreement with the BOP to supervise the
20 unlicensed psychologist. Psychiatrists are not allowed to oversee unlicensed psychologists' work
21 The psychiatrists and licensed psychologists not appointed to this role were unwilling to take or
22 that patient care and professional liability, and such supervision was outside the scope of theii
23 duties. Dr. Anand told Dr. Shaffer and Dr. McLaughlin that unlicensed psychologists needed to be
24 properly supervised and assigned to the outpatient program, where a license was not required. Dr
25 Anand complained that allowing unlicensed psychologists to work in a licensed facility was illegal,
26 and endangered patient safety.
27 ///
28 ///
1 22. On or about June 21, 2016, Dr. Anand reached out to her counterpart at the
2 Califomia Medical Facility, Dr. Joan Gerbasi ("Dr. Gerbasi"), to confirm that staff psychiatrists
3 should not be made to co-sign orders from unlicensed psychologists. Dr. Gerbasi confirmed that
4 psychiatrists are not allowed to co-sign the work of unlicensed psychologists, but that unlicensed
5 psychologists should not be writing orders in the first place. Furthermore, Dr. Gerbasi stated that
6 each unlicensed psychologist has a designated, identified and assigned licensed psychologist who
7 is the only person authorized to sign off on their documentation.
8 23. In or around June 2016, the Coleman Special Master conducted a site visit at
9 CHCF Stockton. The Coleman Special Master is responsible for ensuring CDCR facilities meet
10 the standards set forth in the Coleman and Plata cases. The Special Master's report noted
11 deficiencies in categories that Dr. Anand complained about, and the Special Master ordered
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12 CHCF Stockton to create a Corrective Action Plan.
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19 team, and that psychiatrists have to sign off on the documentation created by the unlicensed
20 psychologists.
21 25. On or about August 4, 2016, there was another completed suicide in the licensed
22 facility at CHCF Stockton. The victim's assigned clinician was an unlicensed psychologist who
23 failed to notice waming signs which caused the clinician to improperly diagnose the patient and
24 identify that the patient's behaviors were linked to his deteriorating mental health. A proper
25 diagnosis would have increased in the patient's level of care, and sent him to a higher level of
26 mental health crisis bed.
27 ///
28 ///
1 26. In or around August 2016, Dr. Anand complained to Deputy Director of the Mental
2 Health Program, Katherine Tebrock ("Ms. Tebrock") about unsupervised, unlicensed
3 psychologists working in the MHCB. Ms. Tebrock assured Dr. Anand that she had already
4 scheduled the Chief of Mental Health, Dr. Corin Kottraba ("Dr. Kottraba"), for a site visit to
5 evaluate the situation.
6 27. In or around early August 2016, Dr. Kottraba inspected CHCF Stockton over the
7 course of a week. Shortly afterward. Dr. McLaughlin was demoted from the Chief of Mental
8 Health, and Dr. Shaffer was demoted from Chief Psychologist to Senior Psychologist. Dr.
9 Yashobra Rao ("Dr. Rao") took over as Acting Chief of Mental Health.
10 28. On or about August 24, 2016, Dr. Anand met with Dr. Rao, Dr. Kottraba, Dr.
11 Shaffer, and Senior Psychology Specialist Dr. Heather Pearson ("Dr. Pearson"). Dr. Rao and Dr.
12 Kottraba directed Dr. Anand to order staff psychiatrists to sign off on orders written by unlicensed
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14 unlicensed psychologists without a required written waiver in a licensed facility put patient safety
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15 at risk, is outside of psychiatrists' scope of practice, and is unlawful. Dr. Rao and Dr. Kottraba
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16 told Dr. Anand that as the Chief Psychiatrist, Dr. Anand could direct the psychiatrists to sign
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^5 17 under the "5% clause" in their duty statement. The "5% Clause" covers miscellaneous tasks not
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19 orders, and Dr. Rao and Dr. Kottraba then left her office.
20 29. On or about August 24, 2016, immediately after her meeting with Dr. Rao and Dr.
21 Kottraba, Dr. Anand complained by email to Dr. Golding about the directive to force psychiatrists
22 to supervise and sign off on unlicensed psychologists' work. Dr. Anand explained this order
23 would negatively impact patient safety, staff safety, and risk staff licenses.
24 30. On or about August 26, 2016 Dr. Anand met with Dr. Rao and CEO Raul Recarey
25 ("Mr. Recarey") to discuss psychiatrists signing off on unlicensed psychologists' work. Dr. Rao
26 said that Chief Psychologist Dr. Golding stated psychiatrists could co-sign work orders written
27 by unlicensed psychologists on patients they carried together, implying that Dr. Rao had not given
28 an illegal or unlawful order. Mr. Recarey stated that he would consult the CDCR legal department
Anand v. California Department of Corrections and Rehabililalion, et al Erik M. Roper, Esq.
1 about the matter, but that until given clear guidance to do otherwise, he had no intention of
2 changing the organizational plan and reporting structure in the department. Mr. Recarey told Dr.
3 Anand to work with Dr. Rao, which Dr. Anand understood as an order to continue to follow Dr.
4 Rao's unlawfiil orders.
5 31. Mr. Recarey never followed up with Dr. Anand regarding whether he spoke to
6 CDCR's legal department about the legality of Dr. Rao's orders.
7 32. On or around August 26, 2016, Dr. Golding emailed Dr. Anand and clarified that
8 psychiatrists cannot be ordered to sign off on unlicensed psychologist's orders. Dr. Golding
9 stated, "so giving a psychiatrist 15 to 30 orders on a series of patients that he or she would not
10 normally know, as apparently happened, and expecting him/her to sign (without fiilly presenting
11 the cases) is quite problematic. Ordering a psychiatrist to sign under those circumstances is
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13 33. On or around August 28, 2016, Dr. Anand requested Dr. Rao provide the
14 "supervision agreement for unlicensed psychologists" with staff psychiatrists to discuss in their
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psychiatrists.
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Z ^ 18 that numerous unlicensed pre-doctoral psychologists were working in the mental health crisis bed
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19 without DPH knowledge or written approval.
20 35. In or around September 2016, Dr. Anand complained to the BOP that unlicensed
21 psychologists employed in CDCH-Stockton were writing orders in the physician section of
22 patients' medical chart. In response, the BOP commimicated to Dr. Anand that "psychologists
23 have no knowledge, training, or experience in writing orders as this was not a part of psychology
24 curriculum." The BOP further informed Dr. Anand that the MBC regulates physician practices,
25 including writing orders, and directed her to contact the MBC. The MBC responded that it does
26 not regulate psychologists, and asked Dr. Anand to send copies of patient medical charts where
27 psychologists had written orders.
28 ///
10
1 36. On or around September 12, 2016, Dr. Rao withdrew licensed psychologists'
2 support to the unlicensed psychologists in the MHCB. This forced psychiatrists to directly
3 supervise the unlicensed psychologists.
4 37. On or around September 13, 2016, Dr. Anand leamed that Dr. Rao told Mr.
5 Recarey that Dr. Anand was handling employee work visas. In fact. Dr. Anand had no
6 involvement with employees' work visas. Mr. Recarey sent Dr. Anand an email that stated,
7 "employee work visas will be directed to Chief of Mental Health for authorization and approval
8 regardless of the employee's line of supervisors."
9 38. On or around September 14, 2016, Dr. Anand emailed Mr. Recarey for
10 clarification on the previous day's email and told him that she had not authorized anyone's work
11 visas. She received a reply from Mr. Recarey, which stated that, "Visa process was being handled
12 by you and I don't see the need for you to manage this task...." In response. Dr. Anand again
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14 39. On or around September 19, 2016, subordinate staff psychiatrists told Dr. Anand
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19 40. On or around September 21, 2016, Dr. Rao transferred Dr. Anand's support staff
20 office technician to another department, and left Dr. Anand to handle all administrative duties in
21 the Psychiatry Department. The Chief of Psychiatry position previously had the help of at least
22 one support staff office technician. Dr. Anand had to take over all administrative duties, in
23 addition to her work as a psychiatrist and managing the department.
24 41. On or around September 25, 2016, Dr. Minor called Dr. Anand and warned her,
25 "Watch your" back. Rao is out to get you. Don't tmst her."
26 42. On or around October 11, 2016, Dr. Rao gave Dr. Anand a probation report titled
27 "1^' and 2"*^ probation report," where Dr. Anand was rated as "Needs Improvement" in , most
28 categories. Dr. Anand received no verbal or written counseling prior to this report, and all of her
11
1 previous performance evaluations in the previous six years at CDCR had been between
2 "Standard" and "Outstanding." Dr. Anand's most recent 2015 report rated her as "Outstanding"
3 overall. Dr. Rao ordered Dr. Anand not to discuss her probation report with anyone.
4 43. On or around October 21, 2016, Dr. Anand and her union representative,
5 Lt. Avalos, met with Dr. Rao to dispute the probation report. Dr. Anand protested that the poor
6 marks were not supported by facts, then asked that Dr. Rao give examples of the critiques in the
7 probation report.
8 44. Later that day on or about October 21, 2016, Dr. Anand and her union
9 representative met with Mr. Recarey. Dr. Anand told Mr. Recarey that she found multiple
10 statements in the report to be false, derogatory, and unsubstantiated by facts. Dr. Anand further
11 shared that she had seen evidence of being "set up" by Dr. Rao, after Dr. Rao accidentally sent
Ol 12 emails intended for other people to Dr. Anand. Dr. Anand explained to Mr. Recarey that these
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ss sI i& 14 Dr. Rao's illegal orders. Mr. Recarey replied, "If there is something illegal going on here, then
15 go call the police."
16 45. On or around October 24, 2016, Dr. Anand went on an FMLA/CFRA medical
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20 Rao and Mr. Recarey on Dr. Anand's behalf, and Dr. Rao assured them that she would amend the
21 October 11, 2016 probation report to include only what she could substantiate with facts. Dr. Rao
22 never amended the probation report.
23 48. On or around January 5, 2017, Dr. Rao ordered Human Resources personnel to
24 deny Dr. Anand a merit salary increase.
25 49. On or about January 12, 2017, while out on FMLA/CFRA leave. Dr. Anand
26 received a letter in the mail that she was rejected on probation and would no longer serve as Chief
27 Psychiatrist.
28 ///
12
Anand v. California Depariment of Corrections and Rehabilitation, et al. Erik M. Roper, Esq.
1 50. On or around February 14, 2017, Dr. Anand retumed from FMLA/CFRA leave
2 and was reinstated at her last permanent position: Senior Psychiatrist Supervisor. Although Dr.
3 Anand was given her old title of Senior Psychiatrist Supervisor, she was given duties of a more
4 junior staff psychiatrist. Further, Dr. Anand was given the case load of two staff psychiatrists and
5 was asked to cover for a third who was on vacation for two weeks. At one point. Dr. Anand had
6 three times the case load of other psychiatrists.
7 51. On or around February 14, 2017, Dr. Anand requested a motorized cart as ar
8 accommodation for her broken foot. Dr. Anand received an inoperable cart. Dr. Anand complainec
9 and requested a new cart, but no replacement cart was made available to her. Dr. Anand informec
10 Dr. Rao of her foot fracture, which had not completely healed, and said she needed a cart as ar
11 accommodation. Dr. Rao responded that the carts had been assigned to other senior psychologists,
ts 12 and Dr. Anand should ask them if she needed one.
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13 52. On or about February 15, 2017, Dr. Anand leamed that Dr. Rao instructed
14 personnel specialists not to help Dr. Anand with personnel issues, but rather to forward all Dr.
15 Anand's issues or Dr. Anand's persormel requests to them to Dr. Rao.
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19 Dr. Anand noted that the psychology program supervisors were ordered to direct the unlicensed
20 psychologist in their program to not complete the mandated, referral chronology for the
21 psychiatrists, but mn a separate list. This gave the appearance that patients were given daily,
22 weekly, and monthly follow-up appointments mandated by Coleman, when in fact some patients
23 were only seen every 3-4 months.
24 54. Onorabout April 6, 2017, Dr. Anand informed the Coleman Special Master ofthe
25 myriad patient care practices at CHCF Stockton which she thought violated the Coleman
26 standards.
27
28 // •
///
, 13
1 55. Later on or about April 6,2017, Dr. Rao sent an email informing the mental health
2 staff that effective immediately. Dr. Anand was no longer employed at CHCF Stockton. In fact,
3 Dr. Anand was still employed there.
4 56. On or around April 10, 2017, Mr. Recarey and Dr. Rao disabled Dr. Anand's state
5 computer log-in and disconnected her CDCR-issued mobile phone.
6 57. On or about April 13, 2017, management for CDCR threatened to bring action against
7 Dr. Anand if she did not immediately resign.
8 58. On or around April 19, 2017, after Dr. Anand retumed from stress leave. Mr.
9 Recarey directed Dr. Anand to work in the mail room. Her duties included sorting letters and
10 searching prisoners' incoming mail for pornographic pictures. Due to her religion and personal
11 values. Dr. Anand found these images offensive and emotionally traumatizing.
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19 Rao and Mr. Recarey told the Coleman Special Master and other regulatory boards that Dr. Anand
20 alleged Coleman violations due to personal issues, and because she was rejected on probation.
21 62. Between June 2017 and October 2017, Dr. Rao and Mr. Recarey sent Dr. Anand
22 an investigation report alleging that Dr. Anand had been dishonest and had mistreated staff. Dr.
23 Anand disputed this report, and asked Dr. Rao and Mr. Recarey to provide evidence to support
24 their claims.
25 63. On or around October 6, 2017, CDCR provided Dr. Anand with notice that it was
26 terminating her from her position as Senior Psychiatrist Supervisor effective October 20, 2017.
27 64. On or around October 20, 2017, Dr. Anand was terminated.
28 ///
14
65. On February 10, 2017, Plaintiff filed a complaint of discrimination, harassment,
2 and retaliation with DFEH, alleging, inter alia, that Defendant discriminated, harassed, and
3 retaliated against Plaintiff because of her age, disability, engagement in protected activity, and
4 taking of protected medical leave. On that same date, DFEH issued to Plaintiff a Notice of Case
5 Closure and Right-To-Sue Notice with respect to her February 10, 2017 DFEH Complaint.
6 66. On January 5, 2018, Plaintiff filed an additional complaint of discrimination, and
7 retaliation with DFEH, alleging, inter alia, that Defendant discriminated against Plaintiff by inter
8 alia terminating, reprimanding, and denying her accommodations, because of her taking of
9 protected medical leave. Additionally, Plaintiff alleged that Defendant subjected her to retaliation
10 because inter alia Plaintiff reported patient abuse, reported/resisted discrimination, took protected
11 medical leave. On January 5, 2018, DFEH issued to Plaintiff a Notice of Case Closure and Right-
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19 69. Plaintiff incorporates the allegations contained in the above paragraphs as though
20 fully set forth herein.
21 70. At all relevant times. Plaintiff was an employee ofDefendant.
22 71. Labor Code section 98.6 states that an employer may not "discharge an employee
23 or in any manner discriminate against any employee . . . because the employee . . . has filed a
24 bona fide complaint or claim or instituted or caused to be instituted any proceeding under or
25 relating to his or her rights, which are under the jurisdiction of the Labor Commissioner." Labor
26 Code section 1102.5, subdivision (b), states that "[a]n employer, or any person acting on behalf
27 of the employer, shall not retaliate against an employee for disclosing information, or because the
28 employer believes that the employee disclosed or may disclose information, to a govemment or
15
1 law enforcement agency, to a person with authority over the employee or another employee who
2 has the authority to investigate, discover, or correct the violation or noncompliance, or for
3 providing information to, or testifying before, any public body conducting an investigation,
4 hearing, or inquiry, if the employee has reasonable cause to believe that the information discloses
5 a violation of state or federal statute, or a violation of or noncompliance with a local, state, or
6 federal rule or regulation, regardless of whether disclosing the information is part of the
7 employee's job duties." Labor Code section 1102.5, subdivision (c), states that an "employer may
8 not retaliate against an employee for refusing to participate in an activity that would result in a
9 violation of state or federal statute, or a violation or noncompliance with a state or federal rule or
10 regulation."
11 72. Plaintiff made numerous protected complaints to persons with authority over her
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16 as: Labor Code sections 232.5, 512, 6310, 6311, 6400, 6401, 6402, 6403, and 6404.
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19 not limited to making unfavorable changes to her work schedule and duties, denying her
20 reasonable accommodation, and wrongfully terminating her employment.
21 74. Defendant's unfavorable changes to Plaintiffs schedule and duties, denial of
22 reasonable accommodation, termination, and creation of the overall hostile terms and conditions
23 of employment, were substantial factors in causing Plaintiffs harm.
24 75. The conduct of Defendant and its managing agents and employees was a
25 substantial factor in causing Plaintiffs harm.
26 76. As an actual and proximate result of the aforementioned violations, Plaintiff has
27 been harmed in an amount according to proof, but in an amount in excess of the jurisdiction of
28 this Court.
16
1 77. As an actual and proximate result of Defendant's retaliation. Plaintiff has lost
2 wages, benefits, and other out-of-pocket expenses.
3 78. As an actual and proximate result of Defendant's aforementioned acts, Plaintiff
4 suffered physical injury. Plaintiff experienced insomnia, tension headaches, social isolation, an
5 increase in blood pressure, nausea, upset stomach, vomiting, acid refluxflare-ups,aches, pains,
6 increased heart rate, low energy, and fatigue and continues to suffer these symptoms along with
7 having intrusive memories, nightmares, flash backs, upsetting dreams of being set-up, framed,
8 directed to work in the mail room, re-living traumatic events, and continues to have disturbing
9 thoughts and feelings regarding made to work in the mail room and view pomographic contraband
10 material. Plaintiff avoids interacting with anyone from work, not answering phone calls, isolating
11 herself, has memory impairment, feels emotionally numb, feels detached from family and friends,
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22 81. The Califomia Legislature has determined that, in order to protect patients, "it is
23 the public policy of the State of Califomia to encourage patients, nurses, members of the medical
24 staff, and other health care workers to notify govemment entities of suspected unsafe patient care
25 and conditions CDCR Califomia Healthcare Facility Stockton is a "hospital facility" pursuant to
26 Health and Safety Code section 1250, subdivision (a).
27 82. Therefore, pursuant to Health and Safety Code section 1278.5, subdivision (b),
28 "[n]o health facility shall discriminate or retaliate, in any manner, against any patient, employee,
17
1 member of the medical staff, or any other health care worker of the health facility because that
2 person...[p]resented a grievance, complaint, or report to the facility, to an entity or agency
3 responsible for accrediting or evaluating the facility, or the medical staff of the facility, or to any
4 other govemmental entity." Pursuant to section 1278.5, subdivision (i), "'health facility', means
5 any facility defined under this chapter, including, but not limited to, the facility's administrative
6 personnel, employees, boards, and committees of the board, and medical staff."
7 83. Plaintiff was a member of the medical staff ofDefendant.
8 84. Defendant discriminated and retaliated against Plaintiff because she reported
9 concems about patient care, services, and hospital conditions. Furthermore, according to The
10 Joint Commission, "[ijntimidating and dismptive behaviors can foster medical errors... All
11 intimidating and dismptive behaviors are unprofessional and should not be tolerated."
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14 operates that health facility, or that owns or operates any other health facility, in retaliation against
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19 of the grievance or complaint by the employee, member of the medical staff or any other health
20 care worker ofthe facility."
21 86. Discriminatory and retaliatory actions were taken against Plaintiff within 120 days
22 of presenting complaints regarding patient care, services, and/or hospital conditions.
23 87. Health and Safety Code section 1278.5 has no administrative or judicial
24 exhaustion requirement.
25 88. As an actual and proximate result of the aforementioned violations. Plaintiff has
28 /•
26 been damaged in an amount according to proof, but in an amount in excess of the jurisdiction of
27 this Court.
18
1 89. As an actual and proximate result of Defendant's willful and intentional
2 retaliation. Plaintiff has lost wages, benefits and other out of pocket expenses.
3 90. As a proximate result of the aforementioned actions ofDefendant, Plaintiff sufferec
4 physical injury. Plaintiff experienced insomnia, tension headaches, social isolation, an increase ir
5 blood pressure, nausea, upset stomach, vomiting, acid refluxflare-ups,aches, pains, increasec
6 heart rate, low energy, and fatigue and continues to suffer these symptoms along with having
7 intmsive memories, nightmares,flashbacks, upsetting dreams of being set-up, framed, directed tc
8 work in the mail room, re-living traumatic events, and continues to have disturbing thoughts anc
9 feelings regarding made to work in the mail room and view pomographic contraband material
10 Plaintiff avoids interacting with anyone from work, not answering phone calls, isolating herself
11 has memory impairment, feels emotionally numb, feels detached from family and friends, negative
12 irritable, easily frightened, and has difficulty experiencing positive emotions. Plaintiff claims
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"^s i 14 91. As an actual and proximate result of Defendant's aforementioned acts. Plaintiff alsc
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22 93. Califomia Labor Code section 6310 states, "[a]ny employee who is discharged,
23 threatened with discharge, demoted, suspended, or in any other manner discriminated against in
24 the terms and conditions of employment by his or her employer because the employee has made
25 a bonafideoral or written complaint to the division, other govemmental agencies having statutory
26 responsibility for or assisting the division with reference to employee safety or health, his or her
27 employer, or his or her representative, of unsafe working conditions, or work practices, in his or
28 her employment or place of employment.. .shall be entitled to reinstatement and reimbursement
19
1 for lost wages and work benefits caused by the acts of the employer."
2 94. Califomia Labor Code section 6400, subdivision (a) states that "[ejvery employer
3 shall fumish employment and a place of employment that is safe and healthful for the employees
4 therein."
5 95. Califomia Labor Code section 6404 states that "[n]o employer shall occupy or
6 maintain any place of employment that is not safe and healthful."
7 96. Plaintiff made numerous protected complaints to persons with authority over her
8 at CDCR including, but not limited to, reports and complaints about patient safety issues, patient
9 care issues, incorrect medical procedures, incorrect psychological supervision, presence of
10 unlicensed personnel in a licensed facility without DPH written approval, unlicensed personnel
11 writing psychological orders without proper supervision. Defendant's demands that MDs perform
12 licensed psychologists' duties, retaliation, and violations of statutes and regulations.
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20 lost wages, benefits, and has incurred other out-of-pocket expenses.
21 99. As a proximate result of the aforementioned violations. Plaintiff has been damaged
22 in an amount according to proof, but in an amount in excess of the jurisdiction of this Court.
23 100. As an actual and proximate result of the aforementioned acts of Defendant, Plaintifl'
24 suffered physical injury. Plaintiff experienced insomnia, tension headaches, social isolation, ar
25 increase in blood pressure, nausea, upset stomach, vomiting, acid refluxflare-ups,aches, pains
27 having intrusive memories, nightmares, flash backs, upsetting dreams of being set-up, framed
20
1 thoughts and feelings regarding made to work in the mail room and view pomographic contrabanc
3 herself, has memory impairment, feels emotionally numb, feels detached from family and friends
4 negative, irritable, easily frightened, and has difficulty experiencing positive emotions. Plaintifl
5 claims general damages for mental distress in an amount according to proof at time of trial.
8 severe mental and emotional distress in an amount according to proof at'time of trial.
9 WHEREFORE, Plaintiff prays for judgment as hereinafter set forth.
10 FOURTH CAUSE OF ACTION
11 (Disability Discrimination: Gov. Code § 12940, subd. (a))
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19 disability,... of any person, to refiise to hire or employ the person or to refuse to select the person
20 for a training program leading to employment, or to bar or to discharge the person from
21 employment or from a training program leading to employment, or to discriminate against the
22 person in compensation or in terms, conditions, or privileges of employment."
23 105. At all times relevant to this matter, Plaintiff sufferedfi'oma "mental disability" as
24 defined by Govemment Code section 12926, subdivision (j), and Califomia Code of Regulations,
25 title 2, section 11065, subdivision (d)(1), and/or a "perceived disability" as defmed by
26 Govemment Code section 12926, subdivision (j), and Califomia Code of Regulations, title 2,
27 section 11065, subdivision (d)(5), and/or a "perceived potential disability" as defined by
28 Govemment Code section 12926, subdivision (j), and Califomia Code of Regulations, title 2,
21
1 section 11065, subdivision (d)(6), and/or a "physical disability" as defined by Govemment Code
2 section 12926, subdivision (m), and Califomia Code of Regulations, title 2, section 11065,
3 subdivision (d)(2). In spite of her disability. Plaintiff was able to perform the essential functions
4 of her position as defined by Govemment Code section 12926, subdivision (f), and Califomia
5 Code of Regulations, title 2, section 11065, subdivision (e), and was otherwise able to perform
6 her job had Defendant provided the reasonable accommodation required by Govemment Code
7 section 12926, subdivision (p), and Califomia Code of Regulations, title 2, section 11068,
8 subdivision (a).
9 106. Defendant's conduct violated Govemment Code section 12940, subdivision (a),
10 consistent with Califomia Code of Regulations, title 2, section 11066. Specifically, Defendant
11 knew of Plaintiff s physical and/or mental disabiUties that limited major life activities. In spite of
CN 12 her disabilities. Plaintiff was able to perform the essential functions of her position with
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19 employment. Defendant's statements and conduct complained of herein violated Govemment
20 Code section 12940, subdivision (a), and the Califomia Code of Regulations, title 2, sections
21 11019 and 11020.
22 108. Plaintiffs disabilities were a substantial motivating reason for Defendant's
23 decisions to deny Plaintiff reasonable accommodation, make unfavorable changes to Plaintiffs
24 work schedule and duties, terminate Plaintiffs employment, and create overall hostile terms and
25 conditions of employment.
26 109. Defendant's conduct was a substantial factor in causing Plaintiffs harm.
27 ///
28 ///
22
3 this Court. Plaintiff also seeks "affirmative relief or "prospective relief as defined by
4 Govemment Code section 12926, subdivision (a), including back pay, reimbursement of out of
5 pocket expenses and any such other relief that this Court deems proper.
6 111. As an actual and proximate result of Defendant's willfiil and intentional
7 discrimination. Plaintiff has lost wages, benefits, and other out-of-pocket expenses.
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21 severe mental and emotional distress in an amount according to proof at time of trial.
23 FIFTH CAUSE OF ACTION
24 (FEHA Failure to Engage in Interactive Process: Gov. Code § 12940(n))
27 115. At all relevant times, Plaintiff was an employee of Defendant.
28 ///
23
Anand v. California Department of Corrections and Rehabililalion, et al. Erik M. Roper, Esq.
1 116. At all times relevant to this matter, the Fair Employment and Housing Act,
2 Govemment Code section 12940, was/were in full force and effect and binding on Defendant.
3 Govemment Code section 12940, subdivision (n), reads: "It is an unlawfiil employment practice
4 . . . [f]or an employer or other entity covered by this part to fail to engage in a timely, good faith,
5 interactive process with the employee or applicant to determine effective reaspnable
6 accommodations, if any, in response to a request for reasonable accommodation by an employee
7 or applicant with a known physical or mental disability or known medical condition."
8 117. At all times relevant to this matter. Plaintiff suffered from a "mental disability" as
9 defined by Govemment Code section 12926, subdivision (j), and the Califomia Code of
10 Regulations, title 2, section 11065, subdivision (d)(1), and/or a "perceived disability" as defined
11 by Govemment Code section 12926, subdivision (j), and the Califomia Code of Regulations, title
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15 section 12926, subdivision (m), and the Califomia Code of Regulations, title 2, section 11065,
J S2 16 subdivision (d)(2). In spite of her disability. Plaintiff was able to perform the essential functions
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"g2 18 Code of Regulations, title 2, section 11065, subdivision (e), and was otherwise able to perform
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20 section 12926, subdivision (p), and the Califomia Code of Regulations, title 2, section 11068,
21 subdivision (a).
22 118. Although Plaintiff provided notice to Defendant regarding her mental disability
23 and/or physical disability. Defendant failed to accommodate Plaintiffs disabilities as set forth
24 above. Plaintiff was willing to participate in an interactive process to determine whether
25 reasonable accommodation could be made so that she would be able to perform the essential job
26 requirements. Defendant failed to approach Plaintiff to discuss the possible accommodation of
27 her mental disabilities and/or physical disabilities with her or her health care providers in good
28 faith. Defendant did not discuss the nature and extent of Plaintiffs mental health condition or
24
1 mental disabilities and/or physical disabilities, the advice and recommendation of her health care
2 providers, the extent of the necessary accommodation, and the need for future accommodation as
3 well as other areas of inquiry recognized in the Unites States Equal Employment Opportunity
4 Commission's "Enforcement Guidance: Reasonable Accommodation and Undue Hardship Under
5 the Americans With Disabilities Act", noted by the Califomia Legislature in Govemment Code
6 section 12926.1, subdivision (e). Defendant's obligation to engage in the interactive process of
7 accommodation was not excused or waived by Plaintiff. Because Defendant failed to engage in
8 the important interactive process between employee and employer in determining reasonable
9 accommodation. Defendant conduct violated Govemment Code section 12940, subdivision (n).
10 119. Defendant's failure to engage in a good-faith interactive process was a substantial
11 factor in causing Plaintiffs harm.
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20 122. As an actual and proximate result of Defendant's aforementioned acts, Plaintifl

23 increased heart rate, low energy, and fatigue and continues to suffer these symptoms along wit!
24 having intmsive memories, nightmares, flash backs, upsetting dreams of being set-up, framed
25
1 negative, irritable, easily frightened, and has difficulty experiencing positive emotions. Plaintifl'
7 SIXTH CAUSE OF ACTION
8 (FEHA Failure to Accommodate: Gov. Code § 12940, subd. (m))
11 125. At all relevant times. Plaintiff was an employee ofDefendant.
12 126. At all times relevant to this matter, the Fair Employment and Housing Act,
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? Su 16 or mental disability of an applicant or employee. Nothing in this subdivision or in paragraph (1)
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20 127. At all times relevant to this matter. Plaintiff suffered from a "mental disability" as
21 defined by Govemment Cocle section 12926, subdivision (j), and the Califomia Code of
22 Regulations, title 2, section 11065, subdivision (d)(1), and/or a "perceived disability" as defined
23 by Govemment Code section 12926, subdivision (j), and the Califomia Code of Regulations, title
24 2, section 11065, subdivision (d)(5), and/or a "perceived potential disability" as defmed by
25 Govemment Code section 12926, subdivision (j), and the Califomia Code of Regulations, title 2,
27 section 12926, subdivision (m), and the Califomia Code of Regulations, title 2, section 11065,
28 subdivision (d)(2). In spite of her disability, Plaintiff was able to perform the essential functions
26
1 of her position as defined by Govemment Code section 12926, subdivision (f), and the Califomia
2 Code of Regulations, title 2, section 11065, subdivision (e), and was otherwise able to perform
3 her job had Defendant provided the reasonable accommodation required by Govemment Code
4 section 12926, subdivision (p), and the Califomia Code of Regulations, title 2, section 11068,
5 subdivision (a).
6 128. Plaintiff provided notice to Defendant relating to her disabilities and requested
7 potential accommodations. Despite Plaintiffs disabilities, she was able to perform the essential
8 duties of her position with reasonable accommodations. However, Defendant refused to
9 accommodate Plaintiff Shortly after requesting accommodations, Defendant made the
10 appearance of providing an accommodation by providing Plaintiff a cart. However, the cart was
11 not functional, and Defendant subsequently failed to provide a functional cart or other
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> So 16 by Govemment Code section 12926, subdivision (t), and the Califomia Code of Regulations, title
^" i 17 2, section 11068. Accordingly, Defendant's conduct violated Govemment Code section 12940,
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20 in causing Plaintiffs harm.

22 been harmed in an amount according to proof, but in an amount in excess pf the jurisdiction of
24 Govemment Code section 12926, subdivision (a), including back pay, reimbursement of out-of-
25 pocket expenses, and any such other relief that this Court deems proper.
26 131; As an actual and proximate result of Defendant's willfiil and intentional failure to
27 reasonably accommodate. Plaintiff has lost wages, benefits, and other out-of-pocket expenses.
27
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15 SEVENTH CAUSE OF ACTION
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19 135. At all relevant times, Plaintiff was an employee ofDefendant.
20 136. At all times relevant to this action, it was unlawful under Govemment Code section
21 12940, subdivision (h), and Califomia Code of Regulations, title 2, section 11021 for Defendant
22 to retaliate against Plaintiff for complaining about illegal discrimination, harassment, and/or for
23 exercising her right to request reasonable accommodations. Defendant violated Govemment Code
24 section 12940, subdivision (h), and Califomia Code of Regulations, title 2, section 11021 by
25 retaliating against Plaintiff for her complaining about illegal discrimination, harassment, and/or
26 for exercising her right to request reasonable accommodations, and, for her complaints about
27 unsafe working conditions and Defendant's failure to follow the law in assigning medical and
28 psychological supervisory duties. Defendant engaged in disability-based discrimination and/or
28
Anand V. California Department of Corrections and Rehabilitation, et al. Erik M. Roper, Esq.
1 harassment by, among other things, rejecting Plaintiff on probation, terminating Plaintiffs
2 employment, placing Plaintiff on probation, failing to accommodate Plaintiffs disability, and/or
3 creating the overall hostile terms and conditions of employment.
4 137. Plaintiffs requests for accommodation and complaints regarding illegal
5 discrimination, retaliation, and/or harassment were substantial motivating reasons for Defendant
6 to, among other things, reject Plaintiff on probation, terminate Plaintiffs employment, place
7 Plaintiff on probation, fail to accommodate Plaintiffs disability, and/or create the overall hostile
8 terms and conditions of employment.
10 139. As an actual and proximate result of Defendant's aforementioned violations.
11 Plaintiff has been damaged in an amount according to proof, but in an amount in excess of the
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14 of-pocket expenses and any such other relief that this Court deems proper.
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< wo 16 retaliation. Plaintiff has lost wages, benefits, and other out-of-pocket expenses.
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21 having intmsive memories, nightmares, flash backs, upsetting dreams of being set-up, framed
28 ///
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5 EIGHTH CAUSE OF ACTION
6 (Failure to Prevent Harassment and Discrimination: Government Code § 12940(k))
9 144. At all times relevant. Plaintiff was an employee ofDefendant.
10 145. At all times relevant, the Fair Employment and Housing Act and Govemment
11 Code section 12940 was in full force and effect and binding on Defendant. Govemment Code
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12 section 12940, subdivision (k), reads, "It is an unlawfiil employment practice... [f|or an employer,
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14 leading to employment, to fail to take all reasonable steps necessary to prevent discrimination and
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20 Defendant has a duty to prevent unlawful discrimination and retaliation. Defendant knew or
21 should have known about the discrimination and retaliation based on disability as set forth above.
22 Defendant failed to implement adequate training, policies, or instructions that would have
23 prevented the aforementioned discrimination and retaliation of Plaintiff. Defendant breached its
24 duty to prevent the discrimination and retaliation of Plaintiff. Accordingly, Defendant violated
25 Govemment Cpde section 12940, subdivision (k), and The Califomia Code of Regulations, title
26 2, section 11019, subdivision (b)(3).
27 ///
28 ///
30
Anand v. California Department of Corrections and Rehabililalion, et al. Erik M. Roper, Esq.
1 148. Plaintiff was subjected to discrimination and/or retaliation in the course of her
2 employment with Defendant as described above.
3 149. Defendant failed to take all reasonable steps to prevent the discrimination and/or
4 retaliation.
5 150. Defendant's conduct was a substantial factor in causing Plaintiff harm.
6 151. As an actual and proximate result of Defendant's unlawfiil conduct, Plaintiff has
7 lost wages, benefits, and other out-of-pocket expenses.
8 152. As an actual and proximate result of the aforementioned acts. Plaintiff has been
9 harmed in an amount according to proof, but in an amount in excess of the jurisdiction pf this
10 Court. Plaintiff also seeks "affirmative relief or "prospective relief as defined by Govemment
11 Code section 12926, subdivision (a), including back pay, reimbursement of out-of-pocket
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12 expenses and any such other relief that this Court deems proper.
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26 severe mental and emotional distress.in an amount according to proof at time of trial.
28 ///
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1 NINTH CAUSE OF ACTION
2 (CFRA Interference/Retaliation: Gov., Code § 12945.2, subd. (1))
5 156. At all relevant times to this action, the Califomia Family Rights Act of 1993
6 ("CFRA"), Govemment Code sections 12945.1 and 12945.2, was in fiill force and effect and
7 binding on Defendant, requiring Defendant to provide Plaintiff with up to twelve (12) weeks of
8 qualifying leave and to refrain from retaliating or discriminating against Plaintiff for making such
9 a request.
10 157. Plaintiff was a full-time employee whom Defendant employed for over one year
11 and with over 1,250 hours in the twelve-month period immediately preceding her CFRA leave.
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io lwlE 14 159. Plaintiff took medical leave due to her own serious health condition that made her
J 15 unable to perform her job with Defendant.
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17 161. Defendant violated CFRA, Govemment Code section 12945.2, when it unlawfully
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19 taken protected medical leave to care for her serious health condition by, inter alia, rejecting
20 Plaintiff on Probation while Plaintiff was out on leave, demoting Plaintiff, and/or terminafing
21 Plaintiffs employment.
24 this Court. Plaintiff also seeks all remedies and penalties recoverable under CFRA, Govemment
25 Code section 12945.2 et seq.
26 163. As an actual and proximate result of Defendant's unlawfiil conduct. Plaintiff has
27 lost wages, benefits, and other out-of-pocket expenses.
28 ///
32
3 increase in blood pressure, nausea, upset stomach, vomifing, acid refluxflare-ups,aches, pains,
5 having intmsive memories, nightmares,flashbacks,upsetting dreams of being set-up, framed,
10 negative, irritable, easilyfrightened,and has difficulty experiencing positive emotions.. Plaintiff
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14 severe mental and emotional distress in an ampunt according to proof at time of trial.
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20 167. At all relevant times, Plaintiff was an employee ofDefendant.
21 ///
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1 168. At all relevant times, Govemment Code section 8547 et seq. was in full force and
2 effect protecting State employees from whistleblower retaliation. Section 8547 provides, in
3 relevant part, that, "The Legislature finds and declares that state employees should be free to
4 report waste, fraud, abuse of authority, violation of law, or threat to public health without fear of
5 retribution. The Legislature furtherfindsand declares that public servants best serve the citizenry
6 when they can be candid and honest without reservation in conducting the people's business." The
7 Act prohibits retaliation against state employees who "report waste, fraud, abuse of authority,
8 violation of law, or threat to public health" (Gov. Code, § 8547.1.) The Act authorizes "an action
9 for damages" to redress acts of retaliation. (Gov. Code, § 8547.8(c).)
10 169. During Plaintiffs employment with Defendant, Plaintiff complained verbally
11 and in writing to her supervisors and management about, inter alia, the lack of oversight for
12 unlicensed psychologists, how MDs were unlawfully ordered to approve actions outside the
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13 scope of their licensure, that these extra duties took time from MDs' official work duties, and of
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15 170. Plaintiffs protected disclosures were a substantial motivating reason for
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18 demote Plaintiff two levels, assign Plaintiff unskilled labor such as sorting mail, assign Plaintiff
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19 emotionally disturbing tasks, such as screening inmate mail for pornography, terminate Plaintiffs
20 employment, and create overall hostile terms and conditions of employment.
24 this Court.
25 173. As an actual and proximate result of Defendant's willfiil and intentional
26 discrimination. Plaintiff has lost wages, benefits, and other out-of-pocket expenses.
28 suffered physical injury. Plaintiff experienced insomnia, tension headaches, sociaHsolation, ar
34
2 increased heart rate, low energy, and fatigue and continues to suffer these symptoms along wit!
8 negative, irritable, easily frightened, and has difficulty experiencing positive emotions. Plaintifl"
10 175. Plaintiff has exhausted her administrative remedies, and timely filed her
11 whistleblower complaint with the State Personnel Board.
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12 176. As a proximate result of Defendant's unlawfiil conduct. Plaintiff has lost wages,
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13 benefits, and other out-of-pocket expenses.
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1^ 3 15 also suffered mental upset and other emotional distress. Plaintiff claims general damages for
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^^2 16 severe mental and emotional distress in an amount according to proof at time of trial.
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oS I 18 been harmed in an amount according to proof, but in an amount in excess of the jurisdiction of
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21 PRAYER FOR RELIEF
22 WHEREFORE, Plaintiff demands judgment against Defendant and any other defendants
23 who may be later added to this action as follows:
24 1. For compensatory damages, including, but not limited to lost wages and non-
25 economic damages in the amount according to proof;
26 2. For attorneys' fees and costs pursuant to all applicable statutes or legal principles;
27 3. For cost of suit incurred;
28 ///
35
1 4. For prejudgment interest on all amounts claimed pursuant to all applicable statutes
2 or legal principles; and

3 5. For such other and further relief as the Court may deem proper.
4
5 Date: June 20, 2018
6 ESQ.
7 MICHAEL D. MCCOY, ESQ.
8 Attomeys for Plaintiff,

KARUNA ANAND
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Plaintiff hereby demands trial by jury for this matter.
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s < z Date: June 20, 2018 By:
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•"3- Attomeys for Plaintiff,
20 KARUNA ANAND
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1 VERIFICATION OF FIRST AMENDED COMPLAINT FOR DAMAGES
2
3 I, , KARUNA ANAND,have read the attached First Amended Complaint for Damages
4 and hereby attest that the same is tme of my own knowledge, except as to those matters, which
5 are therein stated on my information or belief, and as to those matter that I believe it to be tme.
6 I declare under penalty of perjury under to the laws of the State of Califomia that the
7 foregoing is true and correct.
8 This Verification was executed on \)jvve " ^ ^ Z c i ^ , in Sacramento, CA 95834.
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KARUNA ANAND
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VERIFICATION OF FIRST AMENDED COMPLAINT FOR DAMAGES

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1 Anand v. California Department of Corrections and Rehabilitation, et al.
Superior Court of Califomia, County of Sacramento
2 CaseNo.: 34-2018-00226894
3
PROOF OF SERVICE BY MAIL
4
I, the undersigned declare that I am employed in the County of Sacramento, State of
5 Califomia. I am over the age of eighteen (18) years and not a party to the within action; my
6 business address is: 4600 Northgate Boulevard, Suite 210, Sacramento, Califomia 95834.
7 On June 21,2018,1 served the within:
8
PLAINTIFF'S V E R I F I E D F I R S T AMENDED COMPLAINT F O R DAMAGES
9 AND DEMAND FOR J U R Y T R I A L
10 XX By placing a tme copy thereof enclosed in a sealed envelope with prepaid postage
thereon fiilly prepaid for deposit in the United States Post Office mail box, at my
11 business address shown above, following Lawrance A. Bohm's ordinary business
practices for the collection and processing of correspondence for mailing, of which
12 I am readily familiar, to the individual(s) and address(s) as set forth below.
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13
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Krista J. Dunzweiler, Esq. Attorney for Defendant,
14 ATTORNEY GENERAL OF CALIFORNIA CALIFORNIA DEPARTMENT OF
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a: J 1300 I Street, Suite 125 CORRECTIONS AND
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O i Sacramento, California 95814 REHABILITATION
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< Erik M. Roper, Esq. Attorney for Plaintiff, (Co-Counsel)
S ^ 17 LAW OFFICE OF ERIK M. ROPER KARUNA ANAND
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18 2121 Natomas Crossing Drive, Suite 200-117
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Sacramento, California 95834
19
20 I declare under the penalty of perjury under the laws of the State of Califomia that the
foregoing is tme and correct, and that this declaration was executed on June 21, 2018, in
21 Sacramento, Califomia.
22
23
24
25 Anna Bates
26 Case Manager
27
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PROOF OF SERVICE

KARUNA ANAND, Plaintiff, SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO Case No.: 34-2018-00226894

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KARUNA ANAND, Plaintiff, SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO Case No.: 34-2018-00226894

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1 Lawrance A.

Bohm (SBN: 208716) FILED/ENDORSED

" I ^ 14 KARUNA ANAND, Case No.: 34-2018-00226894

19 (Violation of Labor Code § 6310)

20 122. As an actual and proximate result of Defendant's aforementioned acts, Plaintifl

20 in causing Plaintiffs harm.

2 or legal principles; and

8 Attomeys for Plaintiff,

VERIFICATION OF FIRST AMENDED COMPLAINT FOR DAMAGES

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