Page 1 DAVID A. LOWE (SBN 178811)
dal@rezlaw.com
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sex-motivated negative treatment.
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Asadirect, foreseeable, and proximate result of Defendants’ unlawful actions,
Ms. Brooks has suffered economic loss, pain and suffering and severe emotional distress,
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including shame, anxiety, embarrassment, stress, and indignity, all to her damage in an amount to
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upon her sex. Plaintiff was denied terms and privileges granted to men — i.e., a workplace free of
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to which men were not subjected — including the above-described unlawful treatment — based
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Defendant discriminated against Plaintiff by subjecting her to working conditions
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Ms. Brooks is thus entitled to recover punitive
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to malice, and in conscious disregard of her rights and safety. Tesla managing agents were on
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with the wrongful intention of injuring Ms. Brooks, from an improper and evil motive amounting
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Ms. Brooks has suffered physical injury, pain, and suffering and continues to suffer severe
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| Asadirect, foreseeable, and proximate result of Tesla’s unlawful actions,
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be proven at the time of trial.
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to malice, and in conscious disregard of her rights and safety. Tesla managing agents were on
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with the sovenefut intention of injuring Ms. Brooks, from an improper and evil motive amounting
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Tesla committed the aforementioned acts despicably, maliciously, and willfully,
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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEFPage 12 =
notice of and ratified the offending conduct. Ms. Brooks is thus entitled to recover punitive
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damages from Tesla in an amount according to proof.
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1.
emotional distress;
2.
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For a temporary, preliminary, and permanent injunction enjoining Tesla from
continuing to engage in the violations of California Government Code § 12940 described herein,
including by requiring Tesla to adopt training, monitoring, reporting, and enforcement policies
3.
For punitive damages as allowed by law;
4.
For an award to Ms. Brooks of costs of suit incurred herein and reasonable
ew
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For prejudgment interest and post-judgment interest permitted by law;
6.
For an injunction to prevent future violations of Government Code § 12940; and
7.
For an award of such other and further reliefas the Court deems just and proper.
DATED:
December
14,
Respectfully submitted,
RUDY, EXELROD, ZIEFF & LOWE, LLP
By:
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reasonably calculated to immediately end such unlawful practices;
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For compensatory damages, including but not limited to, lost back pay (including,
but not limited to, salary and bonus wages), equity, fringe benefits, future lost earnings, and
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WHEREFORE, Ms. Brooks prays for judgment against Tesla as follows:
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PRAYER FOR RELIEF
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MEGHAN F. LOISEL
FIRM
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THE JHAVERI-WEEKS
Attorneys for Plaintiff Jessica Brooks
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WILLIAM C. JHAVERI-WEEKS
ALLY N. GIROUARD
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COMPLAINT FOR DAMAGES
AND INJUNCTIVE RELIEFPage 13 Plaintiff hereby demands a trial by jury on all causes of action and/or issues so triable.
DATED:
December 14,
Respectfully submitted,
RUDY, EXELROD, ZIEFF & LOWE, LLP
By
" DAVID.ALOWE
MEGHAN F. LOISEL
THE JHAVERI-WEEKS FIRM
WILLIAM C. JHAVERI-WEEKS
ALLY N. GIROUARD
Attorneys for Plaintiff Jessica Brooks
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DEMAND FOR JURY TRIAL
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
PDF Page 1
PlainSite Cover Page
PDF Page 2
DAVID A. LOWE (SBN 178811)
dal@rezlaw.com
351 California Street, Suite 700
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Telephone: (415) 434-9800
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WILLIAM C. JHAVERI-WEEKS (SBN 289984)
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ALLY N. GIROUARD (SBN 336625)
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THE JHAVERI-WEEKS FIRM
351 California Street, Suite 700
San Francisco, CA 94104
Telephone: (415) 463-8097
Facsimile: (415) 367-1439
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Jessica Brooks
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
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Attorneys for Plaintiff
BROOKS,
Case No.
Plaintiff,
Dycy 904015
COMPLAINT FOR DAMAGES
INJUCTIVE RELIEF
VS.
TESLA, INC. WHICH WILL DO BUSINESS
IN CALIFORNIA AS TESLA MOTORS,
INC., a Delaware Corporation; and DOES 1
DEMAND
FOR JURY TRIAL
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through 20, inclusive,
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Defendants.
COMPLAINT
FOR DAMAGES
AND
INJUNCTIVE
RELIEF
AND
PDF Page 3
NATURE OF THE CASE
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factory facilities to nightmarish conditions of rampant sexual harassment. Tesla’s facilities more
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resemble a crude, archaic construction site or frat house than a cutting-edge company in the heart
of the progressive San Francisco Bay Area. The pervasive culture of sexual harassment, which
includes a daily barrage of sexist language and behavior, is known to supervisors and managers
and often perpetrated by them.
2s
Jessica Brooks was harassed starting from the first day of orientation, spurring her
to state in her feedback to the orientation that the company needed to place more importance on
sexual harassment training.
Once she began the job at Tesla’s seat-making factory, Ms. Brooks
was harassed so constantly that she began stacking boxes around her work station to discourage
men from coming and whistling at and ogling her.
She made a special trip to a thrift store to buy
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persistent harasser, Human Resources was already aware that she had been stacking boxes around
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her station to protect herself but had done nothing; as a result of the complaint, as far as
Ms. Brooks was aware, the on/y repercussion was that H.R. moved her to a new workstation
where she was forced to learn a new role and the harassment continued.
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your tattoos — you got em all-over your body? | think it’s really sexy.”
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subjected to whistles, sexual noises (“Mm-mm”), sexual hand gestures, and men brushing up
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Ms. Brooks received comments at work like “Look at all that ass!” and “I like
against her.
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3.
When she complained to Human Resources about a particularly
to H.R. nearly every single day that she worked at Tesla — there was no sense in complaining
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her to stare at her figure.
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flannels to tie around her waist so men would stop commenting on her back-side and approaching
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for its workers,' the truth is that for years Tesla has subjected women working in its Fremont
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Although Tesla publicly claims that it fosters a safe and respectful environment
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1.
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Jessica Brooks complains and alleges as follows:
She was regularly
again about something that everyone knew about.
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She did not report every incident to H.R.-because she would have been complaining
- ' Tesla, Inc. 2020 10-K Report to the Securities and Exchange Commission at pp. 12-13,
https://www.sec.gov/Archives/edgar/data/1 3 18605/000156459021004599/tsla-
10k_20201231.htm
.
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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
PDF Page 4
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Tesla’s Managers and Leads participate in and tolerate the harassment, and the
culture is that this kind of behavior is so normal that nothing will happen to those who engage in
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4.
it.
Ms. Brooks often cries in the morning before work because she dreads having to
deal with this harassing behavior.
She feels embarrassed, humiliated, uncomfortable,
disrespected, and unsafe at work.
She is a hard worker and a fast learner.
She wanted to have a long career
at Tesla and grow professionally within the Company, but is now suffering anxiety because of the
harassment.
She brings this case to stop to the systemic sexual harassment that plagues her and
the other women at Tesla.
PARTIES
6.
Ms. Brooks has been employed by Tesla since June 26, 2021
California factory.
7.
at its Fremont,
She resides in Antioch, California.
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Defendant Tesla, Inc. Which Will Do Business In California As Tesla Motors, Inc.
(“Tesla” or “Defendant”), is a Delaware Corporation with its principal place of business in
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herself to doing her work well at Tesla, and she needs the job.
She has devoted
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California.
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inclusive, whether individual, corporate, associate or otherwise are unknown to Plaintiff, who
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| through 20,
therefore sues said Defendants by fictitious names pursuant to California Code of Civil Procedure
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The true names and capacities of Defendants named herein as Does
section 474.
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8.
Does | through 20, inclusive, when they have been determined.
Plaintiff will amend this Complaint to show such true names and capacities of
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VENUE AND JURISDICTION -
because Plaintiff's employment was performed in this county and because the legal violations
alleged herein took place in this county.
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Venue is proper in this Court under California Code of Civil Procedure § 395.5
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Venue is also proper in this Court under California Government Code § 12965(b)
because Defendant committed the unlawful practices alleged herein in this county.
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10.
///
2
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
PDF Page 5
4
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This Court has general jurisdiction to adjudicate this unlimited civil case, in which
the total amount in controversy, exclusive of interest and costs, exceeds $75,000.
12.
This Court has jurisdiction to adjudicate Plaintiffs claims under the Fair
Employment and Housing Act pursuant to California Government Code § 12965(b).
13.
This Court has personal jurisdiction over Defendant because Defendant employed
Plaintiff at Defendant’s place of business located in this county, and because Defendant’s acts
allegedly giving rise to liability occurred in this county.
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NO
11.
PROCEDURAL ALLEGATIONS
14,
Prior to filing this Complaint, Plaintiff filed a complaint with the Department of
Fair Employment and Housing against Defendant for discrimination, harassment, and retaliation
on December 13, 2021. Plaintiff obtained a notice of Right-to-Sue on the same date prior to
filing this lawsuit.
FACTS COMMON
TO ALL CAUSES
OF ACTION
A.
Throughout Ms. Brooks’s Time at Tesla, She Has Experienced Near Daily
Sexually Harassing Comments and Behavior.
15.
Tesla hired Ms. Brooks in June 2021 as a Production Associate working on the
factory floor of its seat-making facility in Fremont, California.
16.
Ms. Brooks was harassed at her orientation as a new employee at Tesla.
She and
other new employees were asked to participate in warm-up exercises, and when she was doing
Squats, a man in the back grunted and called out “woohoo — yeah!” ina sexually suggestive way.
When Tesla requested feedback on the orientation, Ms. Brooks told them that she had felt
uncomfortable due to the comment during stretching, and that Tesla should stress the importance
of sexual harassment training.
17.
As soon as Ms. Brooks began working on the line, male co-workers would make it
a point to walk past her station and whistle or look at her body and make comments.
She later
heard from a colleague and a Lead on another line, Pierre [last name unknown], that her very first
day on the line, her Manager, George Knott, was going around making comments about her such
as “Check out the new girl” and “Have you seen the new girl? She’s mad thick.”
3
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
This helped
PDF Page 6
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against her on purpose, make sexual comments like “Damn, that’s a lot of ass,” make sexual hand
gestures, and whistle or make sexual noises at her, like “mmm-mmm.”
on forklifts and stare at her or stop and try to get her attention and flirt with her.
18.
Drivers would drive past
Within her first couple of months of starting, she became so exasperated that she
stacked up boxes behind her to block men from staring at her figure.
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station, gawking at her, and ogling her. As the weeks went on, men would stare at her, brush up
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explain why starting from her first day, so many male co-workers were hanging around her
19.
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store and bought flannels to wear around her waist. She started wearing baggy clothes along with
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Men were staring at her back-side so noticeably that Ms. Brooks went to a thrift
her Tesla uniform, but men continued to shower her with unwanted attention.
20.
One of the Leads in Ms. Brooks’s area told her he could tell she felt
uncomfortable, and he said she was not alone, mentioning another female employee who had
been barraged with similar attention and saying that “all the guys are like that as soon as they see
“fresh meat.’”
21.
On one occasion, Ms. Brooks’ co-worker, [D.J.], told her that he overheard a
male-coworker making comments about Ms. Brooks, along the lines of “Damn, who is that?” and
“Look at her over there,” while smiling and laughing with other male employees like it was a
Joke.
A Lead, Ian [last name unknown], replied “That’s all [D.J.] right there” — joking that
Ms. Brooks was a conquest who “belonged” to [D.J.]. Managers demonstrate that there will be
no consequences for treating female employees like this.
22.
One co-worker, Roberto [last name unknown], emerged as particularly aggressive
and bothersome toward Ms. Brooks.
bothered her.
He constantly made little jokes, whistled at her, and
On one occasion, he came and leaned inappropriately close to her body.
When she
recoiled, he said he was trying to smell what kind of perfume she had on, flirtatiously explaining
“Pm a man, and, you know....”
to flirt with her.
On this same day, he ran a cart into her, apparently as an excuse
She had had enough of the harassment by this point and said to him, “excuse
me, what are you doing?” and “you’re being very unprofessional with the staring and comments
and you need to grow up.”
Roberto grew visibly upset and angry, turning red in the face, and he
4
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
PDF Page 7
=
responded threateningly “Do you know where I’m from?” as if he were in a gang. Leads and
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managers overheard this exchange.
of Roberto’s, huddled together staring at her, and one of the men made a sexual hand-motion of
slapping a woman’s ass. Around the same time, another man who had been part of the same
group was teaching her how to put a bolt inside a seat frame, and told her “I like your tattoos —
you got ‘em all over your body?
24.
I think it’s really sexy.”
Ms. Brooks told her supervisor that Roberto was bothering her, and her supervisor
told her to report it to H.R., which she did. She was surprised that the H.R. representative (Ellen
[last name unknown)) already knew that Ms. Brooks had set up boxes around her to block men
from staring at her — Ms. Brooks did not understand why H.R. had not done anything if the
Company was already aware of the lengths to which she had gone to stop the harassment.
It was
clear to Ms. Brooks that her managers also were aware that her stacking the boxes was a reaction
to the constant harassment.
25.
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work area. She said to her manager, “why am I being moved when I’m the one being harassed?”
There was no direct response to this question, and the manager proceeded to move Ms. Brooks to
a new area. A couple weeks later, H.R. told Ms. Brooks that they had completed the
investigation but that they were not allowed to disclose any details about it.
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manager, Louis [spelling unknown], informed Ms. Brooks that she would be moving to a new
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H.R. informed Ms. Brooks that the investigation was ongoing.
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stream of certain male employees lingering around her prior work station miraculously
disappeared. ‘In her new location on the Manual line, Ms. Brooks noticed that men would come
all the way across the factory to stare at her and flirt with her. One man, a Lead, stared at her
persistently that she felt as ff'she were being stalked, and she finally asked him “what is your
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learning the position.
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line, where she had to start from scratch
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26.
A witness will testify that once Ms. Brooks had been moved, the steady
problem?”
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5
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
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her performance, and discipline her.
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Ms. Brooks, both through her complaints, and because the behavior was committed and/or
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Tesla knew or should have known of the rampant sexual harassment directed at
witnessed by Supervisors and Leads.
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40.
corrective action.
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Tesla’s Supervisors and Leads, who had authority to direct Ms. Brooks’s work activities, evaluate
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Tesla is strictly liable for the sexual harassment because it was conducted by
4].
Yet Tesla failed to take immediate and appropriate
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emotional distress, including shame, anxiety, embarrassment, stress, and indignity, all to her
damage in an amount to be proven at the time of trial. Asa result of the conduct she has missed
work and lost wages.
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with the wrongful intention of injuring Ms. Brooks, from an improper and evil motive amounting
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Tesla committed the aforementioned acts despicably, maliciously, and willfully,
to malice, and in conscious disregard of her rights and safety.
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notice of and ratified the offending conduct..
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Ms. Brooks has suffered physical injury, pain, and suffering and continues to suffer severe
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damages from Tesla in an amount according to proof.
Tesla managing agents were on
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(Failure to Prevent Sexual Harassment in Violation of FEHA, Gov. Code § 12940(k))
43.
44.
.
Tesla failed to take immediate preventative and corrective steps reasonably
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calculated to prevent the sexual harassment of Ms. Brooks.
45.
workplace.
47.
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Plaintiff hereby incorporates by reference the previous paragraphs as if fully set
forth herein and alleges as follows:
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SECOND CAUSE OF ACTION
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Ms. Brooks is thus entitled to recover punitive
Tesla failed to act on Ms. Brooks’s reports of sexual harassment.
Tesla knew or should have known of the rampant sexual harassment
in its
As a direct, foreseeable, and proximate result of Tesla’s unlawful actions,
Ms. Brooks has suffered physical injury, pain, and suffering and continues to suffer severe
8
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
PDF Page 11
damage in an amount to be proven at the time of trial.
48.
—_
with the wrongful intention of injuring Ms. Brooks, from an improper and evil motive amounting
to malice, and in conscious disregard of her rights and safety. Tesla managing agents were on
notice of and ratified the offending conduct.
Ms. Brooks is thus entitled to recover punitive
Aa
damages from Tesla in an amount according to proof.
THIRD CAUSE OF ACTION
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Tesla committed the aforementioned acts despicably, maliciously, and willfully,
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emotional distress, including shame, anxiety, embarrassment, stress, and indignity, all to her
(Retaliation in Violation of FEHA, Gov. Code § 12940(h))
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49.
Plaintiff hereby incorporates by reference the previous paragraphs as if fully set
forth herein and alleges as follows:
50.
FEHA makes it unlawful for an employer to discriminate against a person because
she has opposed practices that are unlawful under the FEHA.
SI.
As set forth above, Ms. Brooks engaged in protected activity by opposing and
reporting complaints of sexual harassment and discrimination to HR and to her Supervisors and
Leads.
Ms. Brooks also repeatedly rebuffed the sexual advances or invitations and made it clear
that she objected to this inappropriate conduct.
52.
The conduct that Ms. Brooks reported, complained of, and objected to constituted
unlawful sexual harassment and discrimination under the FEHA.
53.
After making these complaints and objecting to the above inappropriate conduct,
Ms. Brooks was retaliated against in various ways.
She was denied certain privileges and
benefits that were afforded to women who did not object to Supervisors’ sexual advances and
flirtations.
54.
When Ms. Brooks complained about being harassed, H.R. moved Ms. Brooks to a
new location at the factory, rather than moving the male coworker or otherwise addressing his
inappropriate conduct.
The subject of the complaint and his friends created a hostile work
environment for Ms. Brooks in retaliation for her complaint.
This negatively affected her
conditions of employment, ability to succeed in her job, and prospects for career advancement.
9
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
PDF Page 12
=|
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emotional distress, including shame, anxiety, embarrassment, stress, and indignity, all to her
damage in an amount to be proven at the time of trial.
56.
Tesla committed the aforementioned acts despicably, maliciously, and willfully,
NO
notice of and ratified the offending conduct.
damages from Tesla in an amount according to proof.
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(Discrimination in Violation of
57.
FEHA, Gov. Code §§ 12940 et seq.)
Plaintiff hereby incorporates by reference the previous paragraphs as if fully set
forth herein and alleges as follows:
58.
Under California Government Code § 12940, it is an unlawful employment
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FOURTH CAUSE OF ACTION
practice for an employer to discriminate against an employee in terms, conditions, or privileges
of employment, because of her sex.
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sex-motivated negative treatment.
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Asadirect, foreseeable, and proximate result of Defendants’ unlawful actions,
Ms. Brooks has suffered economic loss, pain and suffering and severe emotional distress,
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60.
including shame, anxiety, embarrassment, stress, and indignity, all to her damage in an amount to
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upon her sex. Plaintiff was denied terms and privileges granted to men — i.e., a workplace free of
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to which men were not subjected — including the above-described unlawful treatment — based
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Defendant discriminated against Plaintiff by subjecting her to working conditions
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Ms. Brooks is thus entitled to recover punitive
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to malice, and in conscious disregard of her rights and safety. Tesla managing agents were on
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with the wrongful intention of injuring Ms. Brooks, from an improper and evil motive amounting
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Ms. Brooks has suffered physical injury, pain, and suffering and continues to suffer severe
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be proven at the time of trial.
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to malice, and in conscious disregard of her rights and safety. Tesla managing agents were on
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with the sovenefut intention of injuring Ms. Brooks, from an improper and evil motive amounting
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Tesla committed the aforementioned acts despicably, maliciously, and willfully,
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61.
10
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
PDF Page 13
=
notice of and ratified the offending conduct. Ms. Brooks is thus entitled to recover punitive
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damages from Tesla in an amount according to proof.
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1.
emotional distress;
2.
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For a temporary, preliminary, and permanent injunction enjoining Tesla from
continuing to engage in the violations of California Government Code § 12940 described herein,
including by requiring Tesla to adopt training, monitoring, reporting, and enforcement policies
3.
For punitive damages as allowed by law;
4.
For an award to Ms. Brooks of costs of suit incurred herein and reasonable
ew
OT
For prejudgment interest and post-judgment interest permitted by law;
6.
For an injunction to prevent future violations of Government Code § 12940; and
7.
For an award of such other and further reliefas the Court deems just and proper.
DATED:
December
14, 2021
Respectfully submitted,
RUDY, EXELROD, ZIEFF & LOWE, LLP
By:
Kh.
LQ rrr
PR
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DAVIDALOWE
P
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attorneys’ fees;
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reasonably calculated to immediately end such unlawful practices;
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For compensatory damages, including but not limited to, lost back pay (including,
but not limited to, salary and bonus wages), equity, fringe benefits, future lost earnings, and
Aa
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WHEREFORE, Ms. Brooks prays for judgment against Tesla as follows:
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PRAYER FOR RELIEF
RN
FPF
MEGHAN F. LOISEL
FIRM
PR
OT
THE JHAVERI-WEEKS
Attorneys for Plaintiff Jessica Brooks
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PR
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WILLIAM C. JHAVERI-WEEKS
ALLY N. GIROUARD
1]
COMPLAINT FOR DAMAGES
AND INJUNCTIVE RELIEF
PDF Page 14
Plaintiff hereby demands a trial by jury on all causes of action and/or issues so triable.
DATED:
December 14, 2021
Respectfully submitted,
RUDY, EXELROD, ZIEFF & LOWE, LLP
By
" DAVID.ALOWE
MEGHAN F. LOISEL
THE JHAVERI-WEEKS FIRM
WILLIAM C. JHAVERI-WEEKS
ALLY N. GIROUARD
Attorneys for Plaintiff Jessica Brooks
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DEMAND FOR JURY TRIAL
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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF