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Plaintiff, began working for the corporate Defendant on or about March of 2003. In August of 2003 she was hired on directly by said Defendant as an administrative assistant earning $13.00 an hour.
In approximately February of 2004 Defendant, SITE MANAGER engaging in a continuous, severe, and pervasive campaign of sexually harassing Plaintiff, M, as follows, without many interruptions, or any long interruptions, in doing something harassing or retaliatory to Plaintiff. In fact, by June or July of 2004, Site Manager was harassing M on a daily basis. The harassing conduct included:
a. talking about Plaintiff’s buttocks, while in her presence including saying “are you working out your buttocks looks smaller;”
b. telling Plaintiff she looked good in certain jeans, indicating she looked good in a sexual way, and the jeans got him excited enough about her anatomy to discuss it with her;
c. standing behind Plaintiff and looking down her blouse. This occurred in July of 2004 and he said “nice mole” referring to a mole that would only be visible if he were staring down her neck line in the area of her cleavage;
d. calling Plaintiff into his office and telling her that she excited him;
e. telling Plaintiff to look down and showing Plaintiff that his penis was erect when telling Plaintiff she excited him;
f. in June of 2004 telling Plaintiff she excited him so much he had “precum;”
g. asking Plaintiff if he could touch her buttocks;
h. telling Plaintiff that if she divorced they could start dating. This was said multiple times; I. in July of 2004 coming up from behind Plaintiff and touching her shoulder;
j. poking Plaintiff’s buttocks;
k. during July of 2004 putting his hands on Plaintiff’s hips;
l. in May or June of 2004, asking Plaintiff if she wanted to look at his apartment;
m. at least two to three times, referring to Plaintiff as “his bitch” meaning that she was his sex slave;
n. making comments about taking women upstairs meaning he would take them upstairs and have sex with them;
o. calling Plaintiff his hot bitch.
On or about August 3, 2004, site manager’s boss from Memphis, came to the Ontario facility. M told Caffeine Junkie she wanted to talk to him because she had a few complaints. Site Manager became suspicious and asked why M had to speak to Caffeine Junkie.
On or about August 3, 2004, M told Caffeine Junkie she wanted to make a sexual harassment complaint.
On or about August 4, 2004, a woman from the corporate Defendant’s Cerritos human resource department came to speak to M. Plaintiff told her she had been touched and sexually harassed by Site Manager. M told Site Manager she felt like she was walking on egg shells and Site Manager was acting rude.
On or about August 6, 2004 M told Caffeine Junkie that Site Manager was now being rude to her. She said he was retaliating against her and mentioned an incident where he hung up the phone on her. Additionally, Site Manager wrote Plaintiff up on August 3, 2004 for missing work due to her daughter’s illness.
On August 9, 2004 M wrote the letter that is attached as Exhibit 1 to this complaint. The letter was sent to the Human Resources Director in Memphis as well as Useless HR person. The letter she states that M had not heard when if ever Site Manager will be removed from having to work with her. She also mentioned Site Manager was harassing and retaliating against her and she did not feel comfortable working with him. She states that if remedial measures were not taken to prevent further harassment she would be resigning. She also reiterated some of the harassment she had been exposed to.
On August 13, 2004, the corporate Defendant sent M a letter stating that they concluded that Site Manager had engaged in inappropriate conduct, but not sexual harassment and that he would remain working in Ontario. On August 16, 2004, M responded by sending Exhibit 2. The letter indicates that there were at least two witnesses to the fact that Site Manager was a harasser, and specifies what those other witnesses knew. Those witnesses are Plaintiffs C and MM who at that time had not yet decided to take legal action. The letter states that M resigned due to the intolerability of having to go back to work with Site Manager. The letter also included DFEH charges against the corporate Defendant, and Site Manager, that M had filed.
Plaintiff, C began working for the corporate Defendant on or about October 2003 as a warehouse worker.
Defendant, SITE MANAGER, engaged in a continuous, severe, and pervasive campaign of sexually harassing Plaintiff, C, as follows, without many interruptions, or any long interruptions, in doing something harassing or retaliatory to Plaintiff. The harassing conduct included:
a. asking what color C’s underwear was;
b. telling C to sit on his lap;
c. saying something about spanking C;
d. touching C’s thigh;
e. saying he would make a woman out of C thereby meaning he would devirginize her on her birthday;
f. asking a worker if they had sex with C in the warehouse in order to harass C and make her feel uncomfortable and as if she was being sexually harassed.
On or about August 5, 2004 C spoke to Useless HR person asked what C had seen the harasser doing to M and what M was doing to defend herself. C said she saw Site Manager touch M on her shoulder, and she overheard Site Manager talk to M in a sexual way. C also stated that Site Manager would call women “his bitches.” C also mentioned that she thought a lot of people in the warehouse were “talking dirty.” C said that she thought because Site Manager was setting a bad example this was happening.
On or about August 11, 2004 C spoke to Caffeine Junkie. During this conversation, C said she wanted to put in a sexual harassment complaint about the Site Manager. C mentioned that Site Manager had called C big butt Sally. She also stated that Site Manager said he could see C’s bra and stared at her through a white shirt.
In an August 13, 2004 letter Caffeine Junkie told C to return to work by August 17, 2004, or consider her employment terminated.
On August 18, 2004, C wrote a letter to the Director of Human Resources, in another state. That letter is attached as Exhibit 3. The letter states that C resigned because she was being told to come back to work when there was more than adequate information Site Manager was a sexual harasser, and C did not want to work with him for that reason.
On or about October of 2003 MM began working for the corporate Defendant.
Beginning in approximately May of 2004, Defendant, SITE MANAGER, began engaging in a continuous, severe, and pervasive campaign of sexually harassing Plaintiff, MM, as follows, without many interruptions, or any long interruptions, in doing something harassing or retaliatory to Plaintiff, also during 2004. The harassing conduct included:
a. massaging MM at least 3-5 times;
b. joking and talking dirty to MM;
c. touching MM’s arms, shoulder, and other parts of her body at least 3 times;
d. making 2-3 comments a week about Plaintiff’s big breasts, and blouses she wore;
e. talking about various sexual relations he had with women he allegedly met at bars, and how he touched them in sexual ways. Plaintiff responded to some of these comments by telling Site Manager she thought he was a “sicko;”
f. starring at Plaintiff’s buttocks and breasts;
g. looking at Plaintiff’s breasts when he spoke to her;
h. calling Plaintiff up to his office for no apparent reason and then telling him to sit down and talk to him at least twice a week as an attempt to flirt with Plaintiff;
I. telling Plaintiff she doesn’t have a sufficient buttocks;
j. telling Plaintiff there will soon be company uniforms and M and MM’s uniform will be plaid mini-skirts like school girls wear;
k. listening to Site Manager talk about the other women’s breasts who worked in the company;
l. telling Plaintiff she needed a man;
m. if Plaintiff’s boy-friend called Site Manager would tell him MM was busy and often times make comments about MM needing a man and not a little boy;
n. doing wrestling moves on Plaintiff and other female co-workers where he would throw himself on them and touch them.
Defendant, SERIAL HARASSER, AN INDIVIDUAL, engaged in a continuous, severe, and pervasive campaign of sexually harassing Plaintiff, MM, as follows, without many interruptions, or any long interruptions, in doing something harassing or retaliatory to Plaintiff as follows, despite the fact that another female complained of his sexual harassment in approximately April of 2004:
a. calling Plaintiff his girl-friend;
b. telling male co-workers that he and Plaintiff had a secret place in the warehouse where they had sex;
c. calling Plaintiff my love;
d. making vulgar sexual comments to Plaintiff
On or about May of 2004, Plaintiff told Site Manager that SERIAL HARASSER was giving her the creeps and scaring her. She said that SERIAL HARASSER was telling everybody that MM was his girl-friend, there was a secret hiding place in the warehouse where they had sex, and he was talking dirty to her. Additionally, this conduct occurred in front of Site Manager. By June of 2004, MM was crying in front of Site Manager saying she could not put up with SERIAL HARASSER.
On or about August 4, 2004 Useless HR person interviewed MM. MM told Useless HR person that Site Manager had touched MM. MM also provided other information about Site Manager’s sexual harassment at work. Useless HR person left her notes in Site Manager’s office, and Site Manager found them.
After MM spoke to Useless HR person, Site Manager became very hostile towards MM. His behavior included slamming doors, making ugly faces, throwing papers, looking through the window at MM, driving a forklift in circles in view of MM, and almost locking her out of the facility. Site Manager also refused to respond when MM spoke to him. He also asked MM to do work he never had her do before.
On August 5, 2004, Useless HR person asked how Site Manager was behaving. MM said “rude and mean.”
On August 18, 2004, MM wrote Caffeine Junkie. The letter described physical and mental problems MM suffered as a result of Site Manager. It also states that she was uncomfortable with Site Manager still being there.
On August 20, 2004, MM wrote a letter to Useless HR person and John Travolta. The letter states that unless Site Manager and SERIAL HARASSER are removed from the workplace, MM will not come back. The letter mentions the various forms of harassment MM and others were exposed to. MM enclosed DFEH charges against the corporate Defendant, Site Manager, and SERIAL HARASSER. She gave the corporate Defendant until August 27, 2004 to remove Site Manager from the workplace, or she would quit. The company never responded so MM considered her employment to have ended.