COLLINS v. TESLA MOTORS INC., et al. Document 1: Document

Superior Court of California, County of Alameda
Case No. 23CV031837
Filed April 25, 2023

Complaint Filed by: Lori Collins (Plaintiff) As to: Tesla Motors Inc. (Defendant); HIGHLAND SIENG (Defendant); MICHAEL SIMON (Defendant)

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Lawrence A. Organ (SBN 175503)
Julianne K. Stanford (SBN 290001)
Cimone A. Nunley (SBN 326915)
CALIFORNIA CIVIL RIGHTS LAW GROUP
332 San Anselmo Avenue
San Anselmo, CA Telephone: (415) 453-Facsimile: (415) 785-Email: larry@civilrightsca.com
julianne@civilrightsca.com
cimone@civilrightsca.com
Attorneys for Plaintiff
LORI COLLINS

CALIFORNIA SUPERIOR COURT

COUNTY OF ALAMEDA

Plaintiff,

Case No.:
LORI COLLINS,
v.
TESLA MOTORS, INC.; HIGHLAND
SIENG; MICHAEL SIMON; and DOES
1 through 10, inclusive,

Defendants.
COMPLAINT FOR DAMAGES
(1) Sexual Harassment (FEHA);
(2) Failure to Accommodate (FEHA);
(3) Failure to Engage in the Interactive Process
(FEHA);
(4) Failure to Prevent Harassment (FEHA);
(5) Acts of Violence (Ralph Act); and
(6) Constructive Termination in Violation of
Public Policy.
DEMAND FOR JURY TRIAL

COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
Page 2 INTRODUCTION

1.

Plaintiff Lori Collins began working on Defendant Tesla Motors, Inc.’s

manufacturing line in July of 2021. From the beginning of her employment, coworker Highland

“Panda” Sieng subjected Ms. Collins and her female colleagues to an endless barrage of sexual

harassment, including verbal comments and unwelcome physical assaults.
2.

Tesla Production Supervisor Jasmine Saucedo witnessed Sieng’s harassing

conduct, and received numerous complaints from her female subordinates, but took no action to

protect them. She sent a clear message to Sieng and other employees that sexual harassment

would be tolerated at Tesla.
3.

After witnessing Sieng’s harassment for months and management’s failure to

respond to Sieng’s conduct, Ms. Collins’ coworker Michael Simon sexually assaulted Ms.

Collins while trying to force her to drink alcohol at work.
4.

Ms. Collins promptly reported the assault to Tesla’s Human Resources

department and asked for medical leave. During her leave, Tesla continued to pressure Ms.

Collins to return to work. Ms. Collins repeatedly explained that she did not feel safe returning to

work with her harassers. During her leave, Tesla had informed Mr. Sieng that Ms. Collins had

lodged a harassment complaint. Mr. Sieng shared this information with Mr. Simon and Mr.

Simon sent Ms. Collins multiple text messages regarding the complaint. Ms. Collins asked HR

whether they had been fired and requested a shift change to avoid retaliation and further contact

with Mr. Simon and Mr. Sieng. Tesla ignored her requests and continued to keep Ms. Collins on

unpaid leave, while allowing Mr. Sieng to remain at work and Mr. Simon to remain on paid

leave.
5.

After Ms. Collins’ pleas for assistance and accommodation were ignored for

nearly a month, Ms. Collins felt that she had no choice but to resign from her employment with

Tesla.
PARTIES

6.
Defendant Tesla Motors, Inc. (“Tesla”) is a Delaware corporation headquartered
in Austin, Texas. Tesla is in the business of manufacturing and selling electronic vehicles and

COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
Page 3
conducts some of its manufacturing at its plant in Fremont, California. At all relevant times

herein, Tesla conducted business in Fremont, California. Tesla regularly employs five or more

individuals and regularly receives the services of five or more individuals pursuant to a contract.

Thus, Tesla is an employer within the meaning of California’s Fair Employment and Housing

Act (“FEHA”). At all relevant times herein, Tesla employed Plaintiff in Fremont, California.

7.
Defendant Highland Sieng is and at all relevant times herein was an adult

resident of California. He worked at Tesla’s Fremont plant during Ms. Collins’ tenure there,

from at least July 2021 through February of 2022.

8.
Defendant Michael Simon is and at all relevant times herein was an adult

resident of California. He worked at Tesla’s Fremont plant during Ms. Collins’ tenure there,

from at least July 2021 through February of 2022.

9.
Plaintiff Lori Collins is and at all relevant times herein was an adult resident of
California. She began working at Tesla’s Fremont plant in July of 2021.
10.
In addition to the Defendants named above, Plaintiff sues fictitiously named

Defendants Does 1 through 10, inclusive, pursuant to California Code of Civil Procedure

Section 474, because their names, capacities, status, or facts showing them to be liable to

Plaintiff are not presently known. Plaintiff is informed and believes, and based thereon alleges,

that each of the fictitiously named Defendants is responsible in some manner for the

occurrences herein alleged, and such Defendants caused Plaintiff’s damages as herein alleged.

Plaintiff will amend this complaint to show these Defendants’ true names and capacities,

together with appropriate charging language, when such information has been ascertained.

11.
Each Defendant is sued individually and as the agent or employee of every other

Defendant acting within the course and scope of said agency or employment, with the

knowledge or consent of the other co-Defendants.
JURISDICTION AND VENUE

12.
Jurisdiction and venue are proper in this court pursuant to Civil Code Section
and Code of Civil Procedure Section 395(a). The amount in controversy exceeds the

jurisdictional minimum of this Court.

COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
Page 4 13.

because during all relevant times Defendant employed Plaintiff in Alameda County.
ADMINISTRATIVE EXHAUSTION

14.

Venue is proper in this county pursuant to Government Code Section 12965(a),
On April 17, 2023, Ms. Collins filed a complaint with the California Civil Rights
Department (“CRD”). She received a right-to-sue notice the same day.
FACTUAL ALLEGATIONS

15.

Plaintiff incorporates the allegations set forth in the preceding paragraphs by
reference.
16.

Tesla hired Ms. Collins as a Production Associate on its night shift in July of

2021. She began working for Tesla on July 19, 2021, and Production Supervisor Jasmine

Saucedo became Ms. Collins’s supervisor three days later.
17.

From the beginning of Ms. Collins’s employment with Tesla, her coworker Mr.

Sieng subjected her and other female employees to a barrage of highly offensive sexual

comments, including asking Ms. Collins how much she would charge for “some pussy,” asking

Ms. Collins to participate in a threesome, asking if Ms. Collins would show him how she eats,

stating that Ms. Collins must “know how to fuck” because she has two children, stating he knew

how well Ms. Collins or other female workers knew how to “ride dick” based on how they

performed pre-shift stretches, calling Ms. Collins and other women “babe”, or calling Ms.

Collins and other women “beautiful.”
18.

Mr. Sieng also made comments like “Damn, look at that ass,” “Look at that

body,” or “looking good” to the women he worked with. Ms. Collins personally witnessed Mr.

Sieng harassing at least three other female workers. Mr. Sieng even physically assaulted other

female employee as Ms. Collins and other women watched, grabbing one woman’s breasts

while slapping another’s rear.
19.

Mr. Sieng did not try to hide his conduct. He made these comments in front of

Production Supervisor Saucedo. When Ms. Collins and others complained to Production

Supervisor Saucedo and their lead, Johnny (last name unknown), the Tesla supervisors took no

action.

COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
Page 5
20.
Mr. Sieng’s friend, Mr. Simon, observed Mr. Sieng’s conduct and management’s

indifference to complaints for months. Once Mr. Simon realized that sexual harassment would

not carry any consequences at Tesla, he turned his attention to Ms. Collins.

21.
On January 14, 2022, Ms. Collins was working in a secluded part of the factory

with few other employees nearby. Mr. Simon approached Ms. Collins with two cups of alcohol

and demanded Ms. Collins take one of the drinks.

22.
Ms. Collins refused, but Mr. Simon cornered Ms. Collins against a cart and

pushed his body into hers. Ms. Collins begged Mr. Simon to stop, but her arms were full of

materials and she could not push Mr. Simon away. Mr. Simon continued to push his body into

Ms. Collins, whispering into her ear, “Quit playing and drink this. I took the time to make this

for you, and I’m not taking no for an answer.” Ms. Collins tried to get Mr. Simon to stop by

saying a lead was nearby and security cameras were trained on the area, but Mr. Simon told her

no one was watching and tried to force her to drink.

23.
Shortly after, Mr. Sieng walked by. Instead of helping Ms. Collins, Mr. Sieng
called out, “Babe, you’re cheating on me,” and walked away.
24.
After Mr. Sieng left, Mr. Simon pushed Ms. Collins into a table and kissed her

neck. At that moment, another employee walked past. She immediately rushed to find an older

male employee, who got between Mr. Simon and Ms. Collins and pushed Mr. Simon away.

25.
Ms. Collins immediately reported the assault to Tesla Leads Davis (last name

unknown) and Johnny. When Ms. Collins asked if they would do anything in response, Lead

Davis promised to tell Production Supervisor Saucedo the following Monday and Johnny said,

“Don’t tell me, I’m no snitch!”

26.
Ms. Collins reported the assault to a third lead, Mikey (last name unknown), who

instructed Ms. Collins to go back to work and promised to move her to a different work area

than Mr. Simon at the next scheduled rotation. But after reporting the workplace assault to three

leads, no Tesla workers took steps to protect Ms. Collins, discipline Mr. Simon, or separate the

two in the workplace. After Ms. Collins went home for the weekend, no one from Tesla

contacted her.

COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
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27.
As soon as Ms. Collins arrived to work the following Monday, January 17, she

complained to Human Resources and requested leave from work. Instead, HR instructed Ms.

Collins to return to work.

28.
Ms. Collins was terrified for her safety. Mr. Simon had already assaulted her

once, and shortly before the assault, a Tesla employee murdered another worker in the factory’s

parking lot. Ms. Collins was afraid that Mr. Simon would seek similar retaliation. Over the

following weeks, Ms. Collins repeatedly asked Tesla Human Resources employee Daniel

Uchiyama about Mr. Sieng and Mr. Simon’s employment status, and expressed a fear of

retaliation. In response, Mr. Uchiyama only shared that Mr. Simon was on paid leave while

Tesla’s investigation was pending. Ms. Collins, meanwhile, was on unpaid leave. During this

leave, Mr. Simon learned about Ms. Collins’s complaints and called Ms. Collins twice in

addition to sending Ms. Collins two text messages. Meanwhile, Mr. Sieng told Ms. Collins he

laughed in HR’s faces when they informed him of her complaints, and stated he would not get

in trouble because he was friends with management. Mr. Sieng threatened that “something will

be done” when he learned which employee “snitched” on him, which Ms. Collins understood to

be a threat of retaliation.

29.
Instead of granting Ms. Collins leave or taking steps to protect her safety, Tesla

informed Ms. Collins that she had no sick leave available and was not eligible for leave under

the Family Medical Leave Act. Tesla continued to demand that Ms. Collins return to work. Ms.

Collins repeatedly expressed her discomfort at Mr. Sieng and Mr. Simon’s threats, and asked

Tesla to take steps to protect her safety. Tesla only offered a shift change—which would come

with a pay cut. Even after Ms. Collins was diagnosed with post-traumatic stress disorder and

informed Tesla of the same, Tesla failed to engage in discussions regarding accommodations

that might allow Ms. Collins to return to work.

30.
After three-plus weeks of silence from Tesla, Ms. Collins felt she had no choice

but to resign on February 8, 2022. In her resignation letter, Ms. Collins expressed that she was

resigning because Tesla had failed to protect her from harassment and failed to take steps to

accommodate her or protect her safety following the assault. Mr. Uchiyama ignored Ms.

COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
Page 7
Collins’s complaints and simply sent her exit paperwork.
31.
Since her resignation from Tesla, Ms. Collins suffers from post-traumatic stress

disorder, including symptoms of anxiety, intrusive thoughts, panic attacks, fluctuating moods,

and problems with concentration as a result of the assault and Tesla’s continual inaction in the

face of constant sexual harassment. Ms. Collins was out of work for two months as a result of

her forced resignation, had to accept a lower-paying position. Her new employment also has

less favorable hours that do not allow her to take her children to and from school. She struggles

to provide for her family and continues to suffer ongoing emotional distress and economic loss

as a result of Tesla’s actions.

FIRST CAUSE OF ACTION
SEXUAL HARASSMENT (FEHA)
Gov. Code § 12940(j)(1)
(Against All Defendants)

32.
Plaintiff incorporates by reference the allegations set forth in the preceding
paragraphs.
33.
Section 12940(j)(1) of the California Government Code renders it unlawful for
an employer to create or permit a work environment that is hostile, intimidating, offensive,
oppressive, or abusive to employees because of their sex.
34.
Defendant regularly employs five or more persons; therefore, it is a covered
employer within the meaning of FEHA.
35.
At all relevant times herein, Defendant employed Plaintiff. Plaintiff is a woman.
36.
Plaintiff was subjected to a hostile, intimidating, offensive, oppressive, and
abusive work environment because of her sex. Mr. Sieng harassed Plaintiff because of her sex,
by way of his constant comments about her body, remarks about the bodies of other female
employees, and graphic descriptions of sexual acts. The harassment was severe or pervasive,
because it occurred daily, creating a workplace that was intolerably harassing. Ms. Collins was
offended and distressed by his comments, as were her female colleagues.
37.
Mr. Simon likewise harassed Plaintiff because of her sex, as evidenced by the
fact that he grabbed her body and kissed her neck. Plaintiff was likewise offended by this

COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
Page 8
conduct.
38.
Defendant Tesla is liable for Mr. Simon and Mr. Sieng’s conduct. Ms. Collins

and other employees complained repeatedly about Mr. Sieng’s comments to Production

Supervisor Saucedo, but Defendant took no action. Additionally, Mr. Sieng harassed his female

colleagues in front of Production Supervisor Saucedo. Despite being placed on ample notice,

Defendant took no action to end the harassment, thereby ratifying the conduct. Likewise, after

Plaintiff complained to three leads, Defendant failed to take any action in response to Mr.

Simon’s assault, thereby ratifying the conduct.

39.
Defendants Simon and Sieng are personally liable for their own harassing acts.

40.
Plaintiff was harmed, and Defendants’ harassing conduct was a substantial factor

in causing her harm. She suffers mentally and emotionally from the trauma of being harassed

and assaulted because of her sex. Plaintiff has also suffered economic loss as a result of the

harassment.

41.
The above discriminatory conduct violates FEHA, as well as the public policy of

the state of California. Plaintiff is therefore entitled to all categories of damages, including, but

not limited to, economic and non-economic damages.

42.
As a result of the above harassing conduct, Plaintiff has retained attorneys to

prosecute this action. Plaintiff is therefore entitled to reasonable attorney’s fees and litigation

expenses, including expert witness fees and costs, incurred in bringing this action.

43.
Defendants Sieng and Simon and Defendant Tesla and/or its managing agents

engaged in the above discriminatory conduct maliciously, fraudulently, and oppressively, or in

conscious disregard of the rights and safety of Plaintiff and other disabled workers. Plaintiff is

thus entitled to recover punitive damages.
SECOND CAUSE OF ACTION
Failure to Accommodate (FEHA)
Gov. Code § 12940(m)
(Against Defendant Tesla)

44.
Plaintiff incorporates by reference the allegations set forth in the preceding
paragraphs.

COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
Page 9
45.
Government Code Section 12940(m) requires employers to provide reasonable
accommodations for their employees’ known disabilities.
46.
Defendant regularly employs five or more persons; therefore, it is a covered
employer within the meaning of FEHA.
47.
At all relevant times herein, Defendant employed Plaintiff. Plaintiff is disabled

suffers from post-traumatic stress disorder. Defendant was aware of this disability via reports

and doctors’ notes from Plaintiff.

48.
Plaintiff could have performed the essential functions of her position with
reasonable accommodations. Plaintiff could have also performed other available positions with
and without reasonable accommodations.
49.
Defendant refused to engage in a good-faith discussion with Plaintiff about

reasonable accommodations. Instead, Defendant offered Plaintiff only the option of returning to

work with her harassers or returning to work on a different shift with reduced pay. Faced with

these options, Plaintiff had no choice but to resign from her position.

50.
Plaintiff was harmed, and Defendants’ failure to provide reasonable

accommodations was a substantial factor in causing her harm. She suffers mentally,

emotionally, and financially as a result of Defendant’s conduct and her forced resignation.

51.
The above conduct violates FEHA, as well as the public policy of the state of

California. Plaintiff is therefore entitled to all categories of damages, including, but not limited

to, economic and non-economic damages.

52.
As a result of the above conduct, Plaintiff has retained attorneys to prosecute this

action. Plaintiff is therefore entitled to reasonable attorney’s fees and litigation expenses,

including expert witness fees and costs, incurred in bringing this action.

53.
Defendants and their managing agents engaged in the above conduct

maliciously, fraudulently, and oppressively, or in conscious disregard of the rights and safety of

Plaintiff and other disabled workers. Plaintiff is thus entitled to recover punitive damages.

THIRD CAUSE OF ACTION
Failure to Engage in the Interactive Process
Gov. Code § 12940(n)
COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
Page 10
(Against Defendant Tesla)
54.
Plaintiff incorporates by reference the allegations set forth in the preceding
paragraphs.
55.
Government Code Section 12940(n) requires employers to engage in a timely,
good-faith interactive process to accommodate disabled employees.
56.
Defendant regularly employs five or more persons; therefore, it is a covered
employer within the meaning of FEHA.
57.
At all relevant times herein, Defendant employed Plaintiff. Plaintiff is disabled
and suffered from post-traumatic stress disorder. Defendant was aware of this disability via
reports and doctors’ notes from Plaintiff.
58.
Plaintiff could have performed the essential functions of her position with
accommodations. Plaintiff could have also performed other available positions with and without
reasonable accommodations.
59.
Defendant failed to timely participate in the interactive process, instead
informing Plaintiff that her only options were to return to work with her harassers or a switch to
a different shift with reduced pay. Faced with these options, Plaintiff had no choice but to resign
from her position.
60.
Plaintiff was harmed, and Defendants’ failure to engage in the interactive process
was a substantial factor in causing her harm. She suffers mentally, emotionally, and financially
from Defendant’s conduct and her forced resignation.
61.
The above conduct violates FEHA, as well as the public policy of the state of
California. Plaintiff is therefore entitled to all categories of damages, including, but not limited
to, economic and non-economic damages.
62.
As a result of the above conduct, Plaintiff has retained attorneys to prosecute this
action. Plaintiff is therefore entitled to reasonable attorney’s fees and litigation expenses,
including expert witness fees and costs, incurred in bringing this action.
63.
Defendants and their managing agents engaged in the above conduct
maliciously, fraudulently, and oppressively, or in conscious disregard of the rights and safety of

COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
Page 11
Plaintiff and other disabled workers. Plaintiff is thus entitled to recover punitive damages.
FOURTH CAUSE OF ACTION
FAILURE TO PREVENT HARASSMENT
Gov. Code § 12940(k)
(Against Defendant Tesla)

64.
Plaintiff incorporates by reference the allegations set forth in the preceding
paragraphs.
65.
Government Code Section 12940(k) requires employers take all reasonable steps
to prevent harassment and discrimination in the workplace.
66.
Defendant regularly employs five or more persons; therefore, it is a covered
employer within the meaning of FEHA.

67.
At all relevant times herein, Defendant employed Plaintiff. Plaintiff is a woman.

68.
Defendant was unquestionably aware of the harassing conduct: in addition to

occurring in front of managers, both Ms. Collins and other women reported the conduct to

Defendant’s management.

69.
Instead of taking prompt, effective action reasonably calculated to end the

harassment against Plaintiff and other women, Defendant ignored the repeated complaints and

instead forced Plaintiff and other women to endure the increasingly worse harassment.

70.
Plaintiff was harmed and the failure to remediate the harassing conduct was a

substantial factor in causing her harm. She suffers mentally, emotionally, and financially

because of the harassment, the assault, and the forced resignation.

71.
The above conduct violates FEHA, as well as the public policy of the state of

California. Plaintiff is therefore entitled to all categories of damages, including, but not limited

to, economic and non-economic damages.

72.
As a result of the above conduct, Plaintiff has retained attorneys to prosecute this

action. Plaintiff is therefore entitled to reasonable attorney’s fees and litigation expenses,

including expert witness fees and costs, incurred in bringing this action.

73.
Defendant and its managing agents engaged in the above conduct maliciously,
fraudulently, and oppressively, or in conscious disregard of the rights and safety of Plaintiff and

COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
Page 12
other similarly situated workers. Plaintiff is entitled to recover punitive damages.
FIFTH CAUSE OF ACTION
ACTS OF VIOLENCE (RALPH ACT)
Cal. Civ. Code § 51.(Against Defendant Tesla and Defendant Simon)

74.
Plaintiff incorporates by reference the allegations set forth in the preceding
paragraphs.
75.
Section 51.7 of the California Civil Code makes it unlawful to commit an act of
violence against an individual on the basis of their membership in a protected class.
76.
Mr. Simon committed a violent act against Plaintiff by forcibly grabbing her,

pressing his body against hers, and kissing her. Given that it was a sexual assault, Plaintiff’s sex

was a substantial motivating reason for this conduct.

77.
Defendant Tesla is liable for this conduct. Defendant failed to take action against

prior sexually harassing conduct, thereby implicitly ratifying the conduct. Moreover, after the

assault, when Plaintiff complained to three separate leads and thereafter to Human Resources,

Defendant failed to take action. Defendant thereby implicitly ratified the assault.

78.
Plaintiff was harmed and the violent conduct was a substantial factor in causing

her harm. She suffers mentally, emotionally, and financially from the assault and her subsequent

forced resignation.

79.
The above conduct violates the laws and public policy of the state of California.

Plaintiff is therefore entitled to all categories of damages, including, but not limited to,

economic and non-economic damages.

80.
As a result of the above conduct, Plaintiff has retained attorneys to prosecute this

action. Plaintiff is therefore entitled to reasonable attorney’s fees and litigation expenses,

including expert witness fees and costs, incurred in bringing this action.

81.
Defendant Simon and Defendant Tesla and/or its managing agents engaged in

the above conduct maliciously, fraudulently, and oppressively, or in conscious disregard of the

rights and safety of Plaintiff and other similarly situated workers. Plaintiff is entitled to recover

punitive damages.

COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
Page 13 SIXTH CAUSE OF ACTION
CONSTRUCTIVE TERMINATION IN VIOLATION OF PUBLIC POLICY
(Against Defendant Tesla)

82.
Plaintiff incorporates by reference the allegations set forth in the preceding
paragraphs.
83.
It is a violation of the public policy of the State of California, including but not

limited to the policies expressed in FEHA, to force a qualified female employee to quit her

position.

84.
During her employment with Defendant, Plaintiff was subjected to an intolerably
hostile work environment based on first on her gender, where she was forced to work alongside

colleagues who made noxious, sexually harassing comments on a daily basis; and then when

based on her disability, when she was faced with the choice of returning to work with her

harassers in an environment that would trigger the symptoms of her post-traumatic stress

disorder, or returning to work on a different shift with reduced pay. When Plaintiff complained,

Defendant refused to engage in a good-faith interactive process.

85.
When faced with this choice, Plaintiff had no alternative but to quit her job. A
reasonable woman with post-traumatic stress disorder would have acted as Plaintiff did.
86.
The above conduct violates FEHA and the public policy of the state of

California, and entitles Plaintiff to all categories of damages, including, but not limited to,

economic and non-economic damages.

87.
As a result of the above conduct, Plaintiff has retained attorneys to prosecute this

action. Plaintiff is therefore entitled to reasonable attorney’s fees and litigation expenses,

including expert witness fees and costs, incurred in bringing this action.

88.
Defendant and its managing agents engaged in the above conduct maliciously,

fraudulently, and oppressively, or in conscious disregard of the rights and safety of Plaintiff and

other similarly situated workers. Plaintiff is entitled to recover punitive damages.

PRAYER FOR RELIEF
Wherefore, Plaintiff prays for relief as follows:
COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
Page 14
a. General damages according to proof, however, no less than the jurisdictional limit of
this court;

b. Special damages in amounts according to proof, together with prejudgment interest;

c. Exemplary and punitive damages in amounts according to proof;

d. Civil penalties of $25,000 pursuant to Civil Code Section 52(b)(2)

e. Reasonable attorneys’ fees and costs pursuant to Government Code Section
12965(c)(6), Civil Code Section 52(b)(3), and any other applicable statute;

f. Interest as provided by law;

g. Injunctive relief to require Defendant to develop and implement policies and

procedures to ensure that effective remedial measures are taken when discrimination

is reported; and

h.
For such other and further relief as this Court deems equitable and appropriate.

CALIFORNIA CIVIL RIGHTS LAW GROUP
Dated: April 19,
_________________________________
Cimone A. Nunley, Esq.

Attorney for Plaintiff
LORI COLLINS

DEMAND FOR JURY TRIAL

Plaintiff demands a trial by jury.

CALIFORNIA CIVIL RIGHTS LAW GROUP
Dated: April 19,
_________________________________
Cimone A. Nunley, Esq.

Attorney for Plaintiff
LORI COLLINS

COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
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