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10 rt 12 3 14 15 16 17 18 19 20 24 22 23 24 25 26 27 Russell A. Robinson, SBN 163937 _ Law Office of Russell A. Robinson PPPREEB 345 Grove Street, 1* Floor Lod ean San Francisco, CA 94102 ASSES Phone: 418.861.4416 . , Fax: 415.431.4526 NAY 29 2019 Nawa4e@omallcom CLERK OF THE COURT Counsel for Plaintiff BY ae BOWED LS YULANDA WILLIAMS SUPERIOR COURT OF THE STATE OF CALIFORNIA CITY & COUNTY OF SAN FRANCISCO, YULANDA WILLIAMS, caseNo. — CG0-19-576 323 Plaintiff, COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF v. [Employment] CITY & COUNTY OF SAN FRANCISCO, ~ [Jury Trial Demanded] MARTIN HALLORAN, DENISE FLAHERTY, and DOES 1-40, Defendants. J COMES NOW PLAINTIFF YULANDA WILLIAMS AND STATES AS FOLLOWS: JURISDICTION AND VENUE 1. This action arises in part under California Government Code §12940, et seq. This Court thus has jurisdiction this matter, and Plaintiff therefore files this action in this Court, 2. Plaintiff's claims arose in and around the City & County of San Francisco. Thus, venue is proper herein at the time this action is commenced. PARTIES 3. Plaintiff Yulanda Williams is an adult female citizen of the United States residing in the State of Califomia. She is of African ancestry (she is black; that is, African-American). At all relevant times, Plaintiff has been over 40 years of age. At all times, Defendants were aware of these facts. Williams has been employed by the City & County of San Francisco, and began working as a peace officer in about 1990. At the present time, Williams is an acting captain Williams v. City & County oF San Francisco, et af POOT COMPLAINT FOR DAMAGES. AND INJUNCTIVE RELIEF es 10 u 12 14 15 16 7 18 19 20 2 2 23 24 23 26 27 28 Ve VY having attained the rank of lieutenant through advances based on merit. 4. On information and belief, Defendant CITY & COUNTY OF SAN FRANCISCO is a municipal entity organized and existing under the laws of the State of California. One of its subdivisions, or agencies, is the San Francisco Police Nepartment (SFPD). On information and belief, the SFPD may not sue and be sued. Thus, together these two entities ere referred to as San Francisco or C&CSF unless otherwise noted 5. Oninformation and belief, Defendant MARTIN HALLORAN is (or was) an employee of San Francisco at the SFPD. He was until recently the president of the SFPOA (more fully described below). 6. Oninformation and belief, Defendant DENISE FLAHERTY is an employee of San Francisco at the SFPD. At times relevant to this complaint, Flaherty was a police captain 7. Plaintiff is ignorant of the identities of Defendants DOES 1 though 40, and therefore sues such defendants as fictiiously named persons/entities, whose true identities and roles in the events which are the subject matter of this complaint are presently unknown Piaintiff will amend this complaint to identify fictiiously named Defendants and to set forth facts relating to each when same become known to Plaintiff. Plaintiff is informed anc believes and thereon alleges that each DOE Defendant is legally responsible for events alleged herein which caused injury and damage to Plaintiff 8. __Indoing acts or omissions alleged, Defendants and each of them were acting in the course and scope of their employment with their respective agencies. In doing the acts or omissions alleged, Defendants acted under color of authority andlor under color of law. 9. Indoing acts or omissions alleged, each Defendant acted as the agent, servant, ‘employee, and/or in concert with each of the other Defendants herein. SPECIFIC FACTS 10. Plaintiff sets forth a series of acts and failures to act spanning more than four years, continuing through April 2019. 11. On March 15, 2015, at a meeting as President of Officers For Justice Peace Officers Association, Plaintiff was notified that her name was in several Wiiams v. City & County of San Francisco, etal. POOT COMPLAINT FOR DAMAGES. ‘AUD INJUNCTIVE RELIEF 23 26 27 28 rewspapers. Plaintiff had been singled out by active SFPD members engaged in racist and homophobic texting. 12. On March 16, 2015, Commander Ann Mannix and Deputy Chief Garrett Tom alone of all command staff members called ta apologize and to express concern for Plaintiff as being named by those members involved in what became known as “Text-Gate |." On March 17, 2015, Plaintiff filed a complaint with the EEO office and spoke to Insp. Lloyd Lew; she also complained to then-Chief Greg Suhr. 13. On April 30,'2018, Plaintiff met Chief Suhr and the SFPOA to tell them about Plaintiff's new PSA Message “Not On My Watch.” Her idea met with resistance and delays, but on the day the website launched the Press Release falsely indicated the idea and inception came from Harry Soulette. 14. On August 18, 2015, Plaintiff met with Chief Suhr and Marion Jackson in the Chief's Office. They discussed Recruitment, Academy, FTO Program, and the need for further diversity. Plaintiff indicated a desire to work in 1A Criminal Unit, but Suhr stated that would be difficult with Plaintiff serving as the OF J President; she had previously put herself through the Internal Affairs Class offered by POST. Plaintiff was denied the position. 15. On September 11, 2015, Plaintiff again met with Chief Suhr and Marion Jackson in the Chief's Office. The scope of conversation regarded Textgate, ‘Not On My Watch," and the need for a Racial Harmony symposium to discuss the racial divide in a non-threatening environment with mental health professionals, respected ‘community leaders, and members of the SFPD with every member allowed to patticipate. Chief Suhr stopped the meeting and called Plaintiff out of the meeting to advise her of a pending IA investigation. Plaintiff was told that she ‘just a witness.” Plaintiff then shared a conversation with Lt. Valerie Matthews from long before and that itwas her opinion Matthews was attempting to gossip. The Chief downplayed the situation, therefore Plaintiff thought nothing further about the matter. 16. On December 10, 2015, Plaintiff met with Malia Cohen regerding the Willams v_ City & County oF San Francisco, et al POOT COMPLAINT FOR DAMAGES ‘AUD INJUNCTIVE RELIEF se