ANNE B~RFIELD WEILLS, SBN 139845
DAN SIEGEL, SBN 564oo
SIEGEL YEE BRUNNER gz MEHTA 14th Street, Suite 5oo
Oakland, California 94612
Telephone: (5to) 839-s2oo
Facsimile: (5to) 444-6698
Email: abweills@gmail.corn
Email: danmsiegel@gmaikcom
Attorneys for Plaintiff
TESSA BATCHELDER-HOSSFELD
SUPERIOR COURT OF CALIFORNIA
COUNTY OF ALAMEDA
TESSA BATCHELDER-HOSSFELD,
Plaintiff,
)
TESLA MOTORS, and Does t through t5,
Defendants.
)
)
)
)
)
)
)
FOR DAMAGES
Demand for Jury Trial
)
)
) Case No.
)
) COMPLAINT
)
Plaintiff TESSA BATCHELDER-HOSSFELD complains against defendant TESLA
MOTORS, and Does t-t5 as follows:
PRELIMINARY STATEMENT
L TESLA MOTORS and discriminated against plaintiff TESSA BATCHHELDER-
HOSSFELD based on her gender and her sexual orientation. Defendant TESLA
MOTORS created a discriminatory hostile work environment for Batchelder-Hossfeld,
and defendant retaliated against her for complaining about her hostile work
environment and discrimination.
BATCHELDFR-HOSSFELD o. TESLA
Complaint for Damages
Case No.Page 2 I
JURISDICTION
The actions giving rise to this lawsuit occurred in County of Alameda.
VENUE
Venue is proper in the Superior Court of California, County of Alameda
because the acts complained of herein occurred in Fremont, Alameda County.
PARTIES
. Plaintiff was employed by defendant TESLA MOTORS as a Quality
Inspection Production Associate on the first shift at the TESLA Fremont facility.
At all relevant times, defendant was and is a Corporation.
. The true names and capacities of the defendants named herein as Does
i
through i5, inclusive, whether individual, corporate, associate, or otherwise are
unknown to plaintiff, who therefore sues such defendants by fictitious names pursuant
to Code of Civil Procedure 5 474. Plaintiff is informed and believes, and thereon alleges,
that each of the fictitiously named defendants is responsible in the manner set forth
herein, or in some other manner for the occurrences alleged herein and that the
damages as alleged herein were proximately caused by their conduct. Plaintiff is
informed and believes, and thereon alleges, that each of the fictitiously named
defendants is a California resident. Plaintiff will amend this complaint to show the true
names and capacities of each of the fictitiously named defendants when such names and
capacities have been determined.
STATEMENT OF FACTS
. Tessa Batchelder-Hossfeld was
BATCHEI.DER-HOSSFEED o. TESLA
Complaint for Damages
hired on December 4, 2oi7. Approximately
Case No.Page 3 twenty workers, including Batchelder-Hossfeld, were initially picked to be on a quality
inspection team. Tessa Batchelder-Hossfeld soon became a lead. Batchelder-Hossfeld
was then promoted to be an in-line technician in January 2019.. As Tessa Batchelder-Hossfeld became more skilled in computer diagnostics
over her three years working at Tesla, she solved many technical and mechanical
problems with her keen mind and strong work ethic. Just before her termination,
Batchelder-Hossfeld was working at thc end of the assembly line, as a lead in-line
technician where she diagnosed and fixed all the outstanding problems so that cars
passed all relevant tests.. Soon after being assigned to work for Supervisor Cristian Altamirano,
Batchelder-Hossfeld received five-star performance reviews from him. Altamirano had
Batchelder-Hossfeld perform many of his management taslm: 1l she ran his morning
meetings; 2) she completed his daily upper-management power point presentations; 3)
she presented all such power point presentations to tier 3, 4 and 5 for management for
Altamirano; and 4) Altamirano asked Batchelder-Hossfeld for personal favors, for
example, buying and bringing an English Bulldog back from her vacation in England.
Right before Altamirano fired her, he wanted Batchelder-Hossfcld to create caps and T-
shirts for him.
. Most all of the tasks required of Batchelder-Hossfeld were Cristian
Altamirano's management tasks and did not fall under Batchelder-Hossfeld's lead
responsibilities. Supervisor Almamirano often came to Batchelder-Hossfeld and asked
her to review and edit emails for him. Altamirano often told her that she had the best
communication and literary skills of his team.
.
Although Batchelder-Hossfeld had great reviews from a number of cross
BATCHELDFR-HOSSFFI D o. TESL4
Complaint for Damages
Case No.Page 4 1
functional team supervisors and upper management, she was never offered a promotion
from Supervisor Altamirano, even though she had requested a promotion on at least five
occasions. When Batchelder-Hossfeld would ask about promotions, Alamirano would
tell her that she "was not ready," but he refused to give her reasons as to why, or any
advice as to hovv she could improve.
i2. In spite of Batchhelder-Hossfeld's successful career at Tesla, up to the day she
was fired, there were a number of incidents that contributed to the sexist and hostile
work environment she experienced, before she was fired. One of the early
discriminatory incidents was when Batchelder-Hossfeld was reported to Human
Resources (HR) by older male co-workers on false allegations that she was "sleeping
with Cristian for her lead promotion." This was completely untrue and she was already
a lead when her team was officially combined with Altamirano's in January 2019.
] 3.
The stress level was extremely high for Batchelder-Hossfeld at Tesla. After
working for Tesla for an intense three years, before she was fired, she was diagnosed
with Endometriosis, a very painful and serious disorder. Batchelder-Hossfeld also lost a
significant amount of her hair working at Tesla, which is also triggered by stress.. An example of Altamirano's discriminatory animus towards
her was evident in
that he never offered or informed Batchelder-Hossfeld of the existence of the two open
supervisor positions before he promoted her two other male co-leads to supervisor.
Altamirano secretly coached the men for the management positions. Batchhelder-
Hossfeld was kept in the dark about their promotions until Altamirano announced to
the unit that Batchelder-Hossfeld's co-leads had been secretly promoted. Altamirano
became especially defensive and angry when Batchelder-Hossfeld directly complained tc
BATCH''.J.DEA-HOSSFFIrD o. TFSIA
Complaint for Damages
Case No.Page 5 him about being passed over for a promotion by someone less qualified that her.
Altamirano fired her shortly after..
Not long before she was fired, Supervisor Altamirano became aware of
Batchelder-Hossfeld's romantic and intimate relationship with another woman. After
he understood that she had a same sex relationship, Altamirano's behavior towards
Batchelder-Hossfeld became more misogynist and hostile. Batchelder-Hossfeld was
fired on December 11, 2020.
EXHAUSTION OF ADMINISTRATIVE REMEDIES
Complaint — DFEH No. 202202-1619'7722
Date Filed: February 23 2022
. On
February 7, 2o22, Batchelder-Hossfeld filed a Complaint alleging
discrimination with the Department of Fair Employment and Housing ("DFEH"),
.
On February 23, 2o22, the DFEH issued a Notice of Case Closure and Right to
Sue.
FIRST CIA.IM FOR RELIEF
FAIR EMPLOYMENT AND HOUSING ACT DISCRIMINATION
(Government Code 0 12940)
. Batchelder-Hossfeld refers to and incorporates by reference paragraphs
through 17 above as though fully set forth herein.. By virtue
of the foregoing, defendants Tesla Motors discriminated against
Batchelder-Hossfeld based on her female gender and sexual orientation by refusing to
promote her and firing her. She was subject to a hostile work environment based on her
BATCHELDER-HOSSFELD u. TESLA
Compiaintfor Damages
Case No.Page 6 female gender and sexual orientation.
SECOND CLAIM FOR RELIEF
FAIR EMPLOYMENT AND HOUSING ACT RETALIATION
(Government Code 0 12940)
2o. Batchelder-Hossfeld refers to and incorporates by reference paragraphs I
through t9 above as though fully set forth herein.
2L By virtue of the foregoing, defendant Tesla Motors retaliated against
Batchelder-Hossfeld after she complained about discrimination.
THIRD CLAIM FOR RELIEF
FAIR EMPLOYMENT AND HOUSING FAILURE TO PREVENT THE ACT OF
DISCRIMINATION
Government Code 5 12940)
. Plaintiff refers to and incorporates by reference paragraphs I through
2t above
as though fully set forth herein.
. Defendant Tesla failed to prevent discrimination and retaliated against
Batchelder-Hossfeld.. Batchelder-Hossfeld was discriminated against as a woman and was denied
promotions by defendant Tesla Motors because of her female gender and sexual
orientation.
. Batchelder-Hossfeld prays for judgment against defendant Tesla Motors as
follows:
BATCHELDER-HOSSJ'FLD v. TESLA
Complaintfor Damages
Case No.Page 7 (1)
Compensatory damages for past and future lost wages and benefits, in an
amount to be determined;
(2)
General damages for pain, suffering, emotional distress, and damage to
her reputation, in an amount to be determined;
(3)
Interest at the legal rate;
(4)
Attorneys'ees;
(5)
Costs of the suit; and
(6)
Such other and further relief as the Court may deem proper.
BATCHFI.DFR-IIOSSFELD v. TESLA
Complaint for Damages
Case No.
PDF Page 1
PlainSite Cover Page
PDF Page 2
1
2
3
4
5
ANNE B~RFIELD WEILLS, SBN 139845
DAN SIEGEL, SBN 564oo
SIEGEL YEE BRUNNER gz MEHTA
475 14th Street, Suite 5oo
Oakland, California 94612
Telephone: (5to) 839-s2oo
Facsimile: (5to) 444-6698
Email: abweills@gmail.corn
Email: danmsiegel@gmaikcom
7
Attorneys for Plaintiff
TESSA BATCHELDER-HOSSFELD
10
SUPERIOR COURT OF CALIFORNIA
COUNTY OF ALAMEDA
12
13
14
TESSA BATCHELDER-HOSSFELD,
Plaintiff,
15
)
16
17
18
TESLA MOTORS, and Does t through t5,
Defendants.
)
)
)
)
)
)
)
FOR DAMAGES
Demand for Jury Trial
)
)
20
21
) Case No.
)
) COMPLAINT
)
Plaintiff TESSA BATCHELDER-HOSSFELD complains against defendant TESLA
MOTORS, and Does t-t5 as follows:
23
24
PRELIMINARY STATEMENT
L TESLA MOTORS and discriminated against plaintiff TESSA BATCHHELDER-
25
HOSSFELD based on her gender and her sexual orientation. Defendant TESLA
27
MOTORS created a discriminatory hostile work environment for Batchelder-Hossfeld,
and defendant retaliated against her for complaining about her hostile work
environment and discrimination.
BATCHELDFR-HOSSFELD o. TESLA
Complaint for Damages
Case No.
PDF Page 3
I
JURISDICTION
2
The actions giving rise to this lawsuit occurred in County of Alameda.
VENUE
Venue is proper in the Superior Court of California, County of Alameda
because the acts complained of herein occurred in Fremont, Alameda County.
PARTIES
8
4. Plaintiff was employed by defendant TESLA MOTORS as a Quality
Inspection Production Associate on the first shift at the TESLA Fremont facility.
10
At all relevant times, defendant was and is a Corporation.
11
6. The true names and capacities of the defendants named herein as Does
13
i
through i5, inclusive, whether individual, corporate, associate, or otherwise are
14
15
unknown to plaintiff, who therefore sues such defendants by fictitious names pursuant
to Code of Civil Procedure 5 474. Plaintiff is informed and believes, and thereon alleges,
17
that each of the fictitiously named defendants is responsible in the manner set forth
herein, or in some other manner for the occurrences alleged herein and that the
19
20
damages as alleged herein were proximately caused by their conduct. Plaintiff is
informed and believes, and thereon alleges, that each of the fictitiously named
21
defendants is a California resident. Plaintiff will amend this complaint to show the true
23
names and capacities of each of the fictitiously named defendants when such names and
24
capacities have been determined.
25
STATEMENT OF FACTS
26
27
28
7. Tessa Batchelder-Hossfeld was
BATCHEI.DER-HOSSFEED o. TESLA
Complaint for Damages
hired on December 4, 2oi7. Approximately
Case No.
PDF Page 4
twenty workers, including Batchelder-Hossfeld, were initially picked to be on a quality
inspection team. Tessa Batchelder-Hossfeld soon became a lead. Batchelder-Hossfeld
was then promoted to be an in-line technician in January 2019.
8. As Tessa Batchelder-Hossfeld became more skilled in computer diagnostics
over her three years working at Tesla, she solved many technical and mechanical
problems with her keen mind and strong work ethic. Just before her termination,
Batchelder-Hossfeld was working at thc end of the assembly line, as a lead in-line
technician where she diagnosed and fixed all the outstanding problems so that cars
10
passed all relevant tests.
9. Soon after being assigned to work for Supervisor Cristian Altamirano,
12
13
14
Batchelder-Hossfeld received five-star performance reviews from him. Altamirano had
Batchelder-Hossfeld perform many of his management taslm: 1l she ran his morning
meetings; 2) she completed his daily upper-management power point presentations; 3)
16
she presented all such power point presentations to tier 3, 4 and 5 for management for
17
18
19
Altamirano; and 4) Altamirano asked Batchelder-Hossfeld for personal favors, for
example, buying and bringing an English Bulldog back from her vacation in England.
20
Right before Altamirano fired her, he wanted Batchelder-Hossfcld to create caps and T-
21
shirts for him.
22
10. Most all of the tasks required of Batchelder-Hossfeld were Cristian
23
24
Altamirano's management tasks and did not fall under Batchelder-Hossfeld's lead
25
responsibilities. Supervisor Almamirano often came to Batchelder-Hossfeld and asked
26
her to review and edit emails for him. Altamirano often told her that she had the best
27
communication and literary skills of his team.
28
11.
Although Batchelder-Hossfeld had great reviews from a number of cross
BATCHELDFR-HOSSFFI D o. TESL4
Complaint for Damages
Case No.
PDF Page 5
1
functional team supervisors and upper management, she was never offered a promotion
from Supervisor Altamirano, even though she had requested a promotion on at least five
3
occasions. When Batchelder-Hossfeld would ask about promotions, Alamirano would
4
5
tell her that she "was not ready," but he refused to give her reasons as to why, or any
advice as to hovv she could improve.
7
i2. In spite of Batchhelder-Hossfeld's successful career at Tesla, up to the day she
was fired, there were a number of incidents that contributed to the sexist and hostile
9
work environment she experienced, before she was fired. One of the early
10
discriminatory incidents was when Batchelder-Hossfeld was reported to Human
11
Resources (HR) by older male co-workers on false allegations that she was "sleeping
13
with Cristian for her lead promotion." This was completely untrue and she was already
a lead when her team was officially combined with Altamirano's in January 2019.
15
] 3.
The stress level was extremely high for Batchelder-Hossfeld at Tesla. After
16
working for Tesla for an intense three years, before she was fired, she was diagnosed
with Endometriosis, a very painful and serious disorder. Batchelder-Hossfeld also lost a
19
20
significant amount of her hair working at Tesla, which is also triggered by stress.
14. An example of Altamirano's discriminatory animus towards
her was evident in
21
22
that he never offered or informed Batchelder-Hossfeld of the existence of the two open
23
supervisor positions before he promoted her two other male co-leads to supervisor.
24
Altamirano secretly coached the men for the management positions. Batchhelder-
25
Hossfeld was kept in the dark about their promotions until Altamirano announced to
26
the unit that Batchelder-Hossfeld's co-leads had been secretly promoted. Altamirano
27
became especially defensive and angry when Batchelder-Hossfeld directly complained tc
28
BATCH''.J.DEA-HOSSFFIrD o. TFSIA
Complaint for Damages
Case No.
PDF Page 6
him about being passed over for a promotion by someone less qualified that her.
Altamirano fired her shortly after.
16.
Not long before she was fired, Supervisor Altamirano became aware of
Batchelder-Hossfeld's romantic and intimate relationship with another woman. After
he understood that she had a same sex relationship, Altamirano's behavior towards
Batchelder-Hossfeld became more misogynist and hostile. Batchelder-Hossfeld was
fired on December 11, 2020.
10
EXHAUSTION OF ADMINISTRATIVE REMEDIES
Complaint — DFEH No. 202202-1619'7722
12
Date Filed: February 23 2022
13
16. On
14
15
February 7, 2o22, Batchelder-Hossfeld filed a Complaint alleging
discrimination with the Department of Fair Employment and Housing ("DFEH"),
16
17.
On February 23, 2o22, the DFEH issued a Notice of Case Closure and Right to
17
Sue.
18
FIRST CIA.IM FOR RELIEF
19
20
FAIR EMPLOYMENT AND HOUSING ACT DISCRIMINATION
21
(Government Code 0 12940)
22
18. Batchelder-Hossfeld refers to and incorporates by reference paragraphs
1
23
24
25
through 17 above as though fully set forth herein.
19. By virtue
of the foregoing, defendants Tesla Motors discriminated against
26
27
Batchelder-Hossfeld based on her female gender and sexual orientation by refusing to
28
promote her and firing her. She was subject to a hostile work environment based on her
BATCHELDER-HOSSFELD u. TESLA
Compiaintfor Damages
Case No.
PDF Page 7
female gender and sexual orientation.
SECOND CLAIM FOR RELIEF
FAIR EMPLOYMENT AND HOUSING ACT RETALIATION
(Government Code 0 12940)
2o. Batchelder-Hossfeld refers to and incorporates by reference paragraphs I
through t9 above as though fully set forth herein.
2L By virtue of the foregoing, defendant Tesla Motors retaliated against
10
Batchelder-Hossfeld after she complained about discrimination.
12
THIRD CLAIM FOR RELIEF
13
FAIR EMPLOYMENT AND HOUSING FAILURE TO PREVENT THE ACT OF
14
DISCRIMINATION
Government Code 5 12940)
16
22. Plaintiff refers to and incorporates by reference paragraphs I through
2t above
17
18
as though fully set forth herein.
19
20
21
22
23. Defendant Tesla failed to prevent discrimination and retaliated against
Batchelder-Hossfeld.
24. Batchelder-Hossfeld was discriminated against as a woman and was denied
23
24
promotions by defendant Tesla Motors because of her female gender and sexual
25
orientation.
26
27
28
25. Batchelder-Hossfeld prays for judgment against defendant Tesla Motors as
follows:
BATCHELDER-HOSSJ'FLD v. TESLA
Complaintfor Damages
Case No.
PDF Page 8
(1)
Compensatory damages for past and future lost wages and benefits, in an
amount to be determined;
(2)
General damages for pain, suffering, emotional distress, and damage to
her reputation, in an amount to be determined;
10
(3)
Interest at the legal rate;
(4)
Attorneys'ees;
(5)
Costs of the suit; and
(6)
Such other and further relief as the Court may deem proper.
12
13
14
Dated: February 17, 2023
~
SIEGEL, YEE, BRUNNER 8z MEHTA
16
Byg
17
~ ~&'i!~if.)
,i(
4
ANNE BUITEQIELI) WEILLS
18
Attorneys for Plaintiff
TESSA BATCHELDER-HOSSFELD
19
20
21
22
23
24
25
26
27
28
BATCHFI.DFR-IIOSSFELD v. TESLA
Complaint for Damages
Case No.
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