Viviane Ghaderi v. Amazon.com Services LLC, et al. Document 1: Complaint

Superior Court of California, County of Los Angeles
Case No. 24STCV09529
Filed April 16, 2024

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Julian Burns King (Bar No. 298617)
julian@kingsiegel.com
Robert J. King (Bar No. 302454)
robert@kingsiegel.com
Andrea Obando (Bar No. 312640)
andrea@kingsiegel.com
KING & SIEGEL LLP
555 University Avenue, Ste. Sacramento, California tel: (213) 465-fax: (213) 465-
8 Attorneys for Plaintiff
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
11 Viviane Ghaderi, an individual,
Plaintiff,
vs.
CASE NO.
VERIFIED COMPLAINT FOR:
1)
15 Amazon.com Services LLC, a
Delaware limited liability company;
16 Andrey Styskin, an individual;
Mahesh Krishnakumar, an
17 individual; and Does 1-10, inclusive,
Defendants.
2)
3)
4)
5)

6)

7)

Discrimination in Violation
of FEHA;
Retaliation in Violation of
FEHA;
Harassment in Violation of
FEHA;
Retaliation in Violation of
CFRA and the PDLL;
Failure to Prevent
Discrimination, Harassment,
and Retaliation in Violation
of FEHA;
Retaliation in Violation of
Labor Code § 1102.5; and
Wrongful Termination in
Violation of Public Policy
Demand for Jury Trial
Verified Complaint
Page 2 Plaintiff Viviane Ghaderi, by and through her attorneys, complains and al-

2 leges as follows:
INTRODUCTION
1.

Originally a retail company, Defendant Amazon.com Services LLC
5 (“Amazon”) has increasingly tried to stake out its place in the tech world. News re6 ports throughout 2022 and 2023 alleged that Amazon was playing “catch up” in its
7 AI capabilities. 1 Amazon reportedly scrapped the launch of an AI model in 8 due to “technical issues and the launch of ChatGPT, which executives felt was far
9 superior to Amazon’s offering.” 2 After falling behind throughout 2023, Amazon in10 vested up to $4 billion in another generative AI startup, Anthropic, to “try[] to
11 keep pace with rivals such as Microsoft and Google,” in a deal that “underscore[d]
12 the frenzy to be at the forefront of AI.” 3 Amazon CEO Andrew Jassy reassured in13 vestors in a February 1, 2024 earnings call that generative AI “is and will continue
14 to be an area of pervasive focus and investment across Amazon.” 2.

Against this background, Amazon employees’ legal rights came second
16 to the Company’s high-stakes game of catch-up in the AI race. Even legally pro17 tected leaves of absence were discouraged; employees who exercised their rights
18 were retaliated against, their careers collateral damage in the battle for the future
19 of the technology industry.
3.

That is what happened to Plaintiff Viviane Ghaderi, an accomplished

Caroline O’Donovan, “Amazon tells employees it isn’t falling behind on AI,” Washington
Post (Apr. 8, 2023), available at https://www.washingtonpost.com/technology/
2023/04/08/amazon-ai-chatgpt-falling-behind/ (last visited February 16, 2024).
2 Id.
3 Adam Satariano and Cade Metz, “Amazon Takes a Big Stake in the AI Start-Up Anthropic,” New York Times (Sept. 25, 2023), available at https://www.nytimes.com/
2023/09/25/technology/amazon-anthropic-ai-deal.html (last visited February 16, 2024).
4 Ryan Deffenbaugh, “Amazon Is The Cloud King. AI Could Change That,” Investor’s
Business Daily (Feb. 9, 2024), available at https://www.investors.com/news/
technology/amazon-stock-aws-ai-cloud-microsoft-google/ (last visited February 16,
2024).
Verified Complaint
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Page 3 1 AI researcher who holds a Ph.D. from the University of Southern California and
2 worked on AI for Amazon from May 2018 to December 2021 and March 2022 to
3 November 2023. Ms. Ghaderi was a highly sought-after manager and researcher
4 during her first tenure at Amazon and was heavily recruited to return to the com5 pany to contribute to its AI efforts in early 2022, with promises of leading a sci6 ence-focused team and a strong future growth trajectory.
4.

Initially, Ms. Ghaderi thrived upon her return to Amazon. She was
8 given increasingly important projects with additional team members assigned un9 der her supervision.
5.

This immediately changed when Ms. Ghaderi shared that she was
11 pregnant and would take maternity leave. Frustrated with the timing of her preg12 nancy—rival OpenAI’s GPT-4 model launched during her disability leave—and
13 convinced that she would not be a sufficiently reliable employee after becoming a
14 mother, her supervisor immediately handed her off to a subordinate.
6.

Upon her return from leave, Ms. Ghaderi conveyed to the Legal De-
16 partment that her leaders had directed her to violate internal copyright policies
17 and applicable law. Her concern was later proven reasonable when the Times sued
18 OpenAI, Inc., Microsoft Corporation, and OpenAI’s affiliate corporations for copy19 right infringement. 5 Separately, Ms. Ghaderi complained to Human Resources
20 about her maternity leave negatively impacting her job duties and annual review.
7.

Less than a week after Ms. Ghaderi made these protected complaints,
22 she was stripped of her job duties and her team members were reassigned to other
23 supervisors. When she complained that her reassignment was retaliatory, Human
24 Resources conducted a cursory investigation with predetermined results, finding
25 no evidence of pregnancy discrimination. This finding was notwithstanding multi
The New York Times Company v. Microsoft Corporation, et al., Case No. 1:23-cv-11195,
27 Dkt. 1 (S.D.N.Y. Dec. 27, 2023), available at https://s3.documentcloud.org/documents/
24241000/2023-12-27-nyt-dkt-1-complaint.pdf (last visited April 16, 2024).
Verified Complaint
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Page 4 1 ple comments by her direct supervisor about how she should “spend time with
2 [her] daughter” and “just enjoy being a new mother” when she expressed con3 cerns about her career trajectory.
8.
Ms. Ghaderi took her job-protected baby bonding leave under CFRA
5 from May 15, 2023, to August 2, 2023. When she returned, she immediately was
6 placed on a covert performance improvement plan, called a “Focus” plan, despite
7 receiving a “Meets High Bar” performance review before her baby bonding leave
8 and protected complaints. She was then placed on a formal performance im9 provement plan, called a “Pivot” plan, that required her to meet impossible
10 benchmarks within a short period. On October 23, 2023, Ms. Ghaderi reached out
11 to Human Resources again to raise concerns that she was being forced out due to
12 the timing of her pregnancy and baby bonding leaves.
9.
On November 17, 2023, while Ms. Ghaderi’s discrimination complaint
14 was pending, Ms. Ghaderi was fired. At least one other member of Ms. Ghaderi’s
15 prior team who had taken leave was also terminated.
PARTIES

10.
Plaintiff Viviane Ghaderi is a woman who at all times relevant to
18 this Complaint was a resident of Los Angeles County, State of California, where she
19 was employed by Defendants. At all times relevant to this Complaint, Ms. Ghaderi
20 was an “employee” of Defendants as that term is defined by California Government
21 Code § 12926(c).
11.
Defendant Amazon.com Services LLC (“Amazon”) is a Delaware
23 corporation licensed to do business within the County of Los Angeles. Plaintiff is
24 informed and believes that at all times relevant to the Complaint, Amazon has em25 ployed more than five people and has been an “employer” within the meaning of
26 the FEHA. Amazon has a principal place of business of 410 Terry Ave. N., Seattle,
27 Washington, 98109-5210.
12.
Defendant Andrey Styskin is an individual and, on information and
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Page 5 1 belief, a resident of the County of Los Angeles. From 2023 through the present,
2 Styskin has been a managing agent of Defendant Amazon.
13.
Defendant Mahesh Krishnakumar is an individual and, on infor-
4 mation and belief, a resident of the State of California. From 2021 through the pre5 sent, Krishnakumar has been a managing agent of Defendant Amazon.
14.
Ms. Ghaderi does not currently know the names and true identities of
7 defendants Does 1-10 (hereinafter “Defendants,” collectively with Amazon.com
8 Services LLC). Ms. Ghaderi reserves the right to amend this complaint to allege
9 their true names and capacities when this information is available. Each Doe de10 fendant is responsible for the damages alleged pursuant to each of the causes of
11 action asserted, either through its own conduct, or vicariously through the conduct
12 of others. All further references in this complaint to any of the named Defendants
13 includes the fictitiously named defendants.
15.
At all times alleged in the complaint, each Defendant was an agent,
15 servant, joint employer, employee, partner, and/or joint venture of every other De16 fendant and was acting within the scope of the Defendants’ relationship. Moreo17 ver, the conduct of every Defendant was ratified by each other Defendant.
VENUE AND JURISDICTION

16.
This Court has jurisdiction over all causes of action in this complaint
20 pursuant to Article VI, § 4 of the California Constitution and California Code of
21 Civil Procedure §§ 88 and 410.10 by virtue of the fact that this is a civil action in
22 which the matter in controversy, not including attorneys’ fees, interests, and costs,
23 exceeds $25,000, and because each cause of action asserted arises under the laws
24 of the State of California or is subject to adjudication in the courts of the State of
25 California.
17.
This Court has personal jurisdiction over Defendants because each
27 Defendant is either a resident of or has caused injuries in Los Angeles County
28 through its violation of the California Fair Employment and Housing Act and other
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Page 6 1 statutes specified herein.
18.
Venue is proper in Los Angeles County because Defendants do busi-
3 ness in Los Angeles County and because Plaintiff worked and earned wages in Los
4 Angeles County as described herein.
FACTUAL ALLEGATIONS

Defendants Recruit and Hire Ms. Ghaderi

19.
Plaintiff Viviane Ghaderi is a German-born scientist focusing on arti-
8 ficial intelligence who holds a Ph.D. in Electrical Engineering, a M.S. in Biomedical
9 Engineering, and a B.S. in Electrical Engineering from the University of Southern
10 California’s Viterbi School of Engineering. She completed a postdoctoral fellow11 ship at the Technische Universität München in Munich, Germany, where she
12 helped develop an AI system to guide the blind. This research resulted in an assis13 tive device called Neuroglasses that enables blind people to perceive the world
14 through a natural audio landscape. She then worked as an AI product and software
15 manager for companies in Germany, including BMW. She has published over a
16 dozen pieces of scientific research and holds five patents. She received numerous
17 research grants for her academic work.
20.
Ms. Ghaderi worked for Amazon as a Technical Program Manager,
19 Software Development Manager, and Science Manager from May 2018 through
20 February 2021. Ms. Ghaderi received positive reviews in each of these roles as well
21 as positive upward feedback from her teams of engineers and scientists. Her annu22 al “Forte” reviews included feedback commending her for “show[ing] a great deal
23 of ownership, bias for action and attention to details”; for her “excellent” commu24 nication skills, ability to “synthesize complex data, requirements and results in
25 tangible action items”; and for being a “constructive bridge builder between
26 teams, even when touching on potentially contentious topics.” Her direct reports
27 recounted that she “is super powerful in both innovating and leadership . . . . She
28 discovers strength in everyone and leads large teams towards accomplishments.”
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Page 7
21.
When Ms. Ghaderi voluntarily left Amazon to join a start-up, Amazon
2 soon began recruiting her to return to the organization based on her strong per3 formance and relationships with colleagues. Ms. Ghaderi’s prior supervisor offered
4 her a new role with the promise of a future opportunity to become an Applied Sci5 ence Manager, the highest-paying technical role in the department. This role was
6 unique because most Science positions are on an independent contributor track,
7 while the Applied Science Manager role would allow Ms. Ghaderi to manage a
8 team. Moreover, Science roles permit those holding them to publish original re9 search and make ongoing contributions to their scientific fields—a unique role of10 fered to elite researchers by only the most sophisticated organizations.
22.
On or about March 28, 2022, Ms. Ghaderi began working as a Soft-
12 ware Engineering Manager for Defendants. She was hired at the top of her salary
13 band because of her strong performance during her prior tenure and the high es14 teem in which her managers held her. Ms. Ghaderi initially led a team of three em15 ployees: one scientist and two engineers. Consistent with her history at Amazon,
16 she performed well and received positive feedback from supervisors and direct re17 ports alike during her first five-plus months back at Amazon.
Ms. Ghaderi is Promoted and Given an Expanded Role Immediately

Before Sharing News of Her Pregnancy

23.
In or around September 2022, Amazon decided to create a new, Sci-
21 ence-focused team concentrating on data quality and compliance in the Alexa or22 ganization. Ms. Ghaderi was moved up on the organization chart to lead this team.
23 It was announced that she would report to the Director of the department, Daniel
24 Marcu, an L8 employee. (Ms. Ghaderi had previously reported to an L6 employee.)
25 Marcu shared this news with the team on September 19, 2022, writing, “[W]e are
26 excited to share that Viviane will lead the charter to improve web data extraction
27 and data quality,” further stating that an additional three team members—one sen28 ior engineer and two Applied Scientists—would report to Ms. Ghaderi.
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Page 8 24.

In this role, Ms. Ghaderi was also granted the ability to build and lead
2 an applied science team, supporting her career goal of becoming an Applied Sci3 ence Manager. She supervised a total of six employees, comprised of five scientists
4 and one senior engineer. This team, called Zelda, presented significant opportuni5 ties to Ms. Ghaderi: it would allow her and her team to publish novel scientific re6 search addressing critical issues in society.
25.

In the short time Ms. Ghaderi led Zelda, her team undertook numer-
8 ous research papers and presentations, including research on modeling for the de9 tection of sexism in language models. 26.

Ironically, Amazon was unable or unwilling to detect sexism in its own
11 organization: just a week after Ms. Ghaderi’s promotion was announced, Defend12 ants began the process of sidelining her because she disclosed her pregnancy.
Defendants Strip Ms. Ghaderi of Her Promotion Immediately after

Learning of Her Pregnancy
27.

The following week, Ms. Ghaderi had her first meeting with Marcu,
16 her new supervisor, to discuss her new role and responsibilities. During this meet17 ing, Ms. Ghaderi informed Marcu that she was pregnant. (She had previously
18 shared the news with her former manager, who apparently had not communicated
19 it to Marcu.)
28.

Marcu, taken aback, responded by informing Ms. Ghaderi that she
21 would be “temporarily” transferred to report to a different employee, Mahesh
22 Krishnakumar. Marcu admitted to Ms. Ghaderi that he was changing her reporting
23 structure “temporar[ily]” so he would not have to “worry” about managing her
Weston Feely, Prabhakar Gupta, Manas Mohanty, Timothy Chon, Tuhin Kundu, Vijit
Singh,
Sandeept Atluri, Tanya Roosta, Viviane Ghaderi, Peter Schulam, Heba Elfardy,
QCon at SemEval-2023 Task 10: Data Augmentation and Model Ensembling for Detec26 tion of Online Sexism (2023), Proceedings of the 17th Workshop on Semantic Evaluation,
available at https://www.amazon.science/publications/qcon-at-semeval-2023-task-1027 data-augmentation-and-model-ensembling-for-detection-of-online-sexism (last visited
April 16, 2024).

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Page 9 1 team during her leave.
29.

This transfer became effective on or about October 14, 2022, and Ms.
3 Ghaderi began reporting to Krishnakumar. By mid-October, this change was for4 malized in the organization chart.
30.

Although Ms. Ghaderi had been planning to take her pregnancy leave
6 starting on or about November 7, 2022, Krishnakumar pressured her to delay tak7 ing leave so that she could complete more work. Ms. Ghaderi complied and, as a
8 result, she worked until November 15, 2022, the day she was forced to undergo an
9 emergency C-section.
31.

Two weeks into Ms. Ghaderi’s pregnancy disability leave, OpenAI
11 launched GPT-4 (“ChatGPT”), causing panic within the organization. A Scientist
12 was assigned to lead Zelda during Ms. Ghaderi’s absence and continued to lead the
13 project upon Ms. Ghaderi’s return.
Defendants Further Retaliate Against Ms. Ghaderi Upon Her Return

from Pregnancy Leave

32.
In or around January 2023, Ms. Ghaderi returned to work after ap-
17 proximately 10 weeks of pregnancy disability leave. She began participating in
18 team calls approximately two weeks before her formal return to facilitate a smooth
19 return to work.
33.
When Ms. Ghaderi returned to work, her team informed her that Ma-
21 hesh had been absent for four of the ten weeks of her leave, and when he was not
22 absent, he rarely met with the team and provided them with little to no direction
23 or input. As a result, the work that needed to be completed during Ms. Ghaderi’s
24 10-week leave was not completed.
34.
Nonetheless, Ms. Ghaderi immediately began working on Zelda’s
26 charter and implementing its goals, including working on various research pro27 jects.
35.
Krishnakumar made numerous discriminatory and harassing comVerified Complaint
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Page 10 1 ments to Ms. Ghaderi upon her return from leave, repeatedly stating things along
2 the lines of, “take it easy, I have young daughters, so I know it’s hard to be a
3 woman with a newborn,” or “you should spend time with your daughter,” or
4 “you should just enjoy being a new mother.” These comments stood out in part
5 because Ms. Ghaderi was one of the only mothers in the Alexa organization.
36.
Because of these comments and because she was derailed from her
7 previous career track, Ms. Ghaderi asked Mahesh if she could be transferred back
8 to report to Marcu, as she had been before she informed the Defendants of her
9 pregnancy. Mahesh responded that he did not know and directed her to ask Marcu
10 directly.
37.
On or about February 15, 2023, Ms. Ghaderi messaged Marcu and re-
12 quested to be reinstated to her former position. Marcu denied this request and
13 stated that Ms. Ghaderi should continue reporting to Krishnakumar, without
14 providing any explanation as to why. When Andrey Styskin joined the organization
15 as a Director later that month, Ms. Ghaderi again asked Marcu whether she would
16 be restored to her previous place in the reporting structure. Marcu disclaimed re17 sponsibility, stating that it was “for Andrey to decide, not me.” Styskin never rein18 stated Ms. Ghaderi to her prior place in the reporting structure.
38.
By March 2023, Ms. Ghaderi’s ratings from her direct reports were
20 within the top 5% of leaders at Amazon, based on employees’ engagement and per21 ception of their managers’ performance.
39.
While Ms. Ghaderi’s direct reports identified “earn[ing] trust” as a
23 strength of hers—with one stating that “Viviane does a great job at earning trust
24 through listening . . . , following up, and taking action” and another stating that
25 she “earns trust easily”—her manager, Mahesh Krishnakumar, identified “earn[s]
26 trust” as an area where Ms. Ghaderi needed to grow, along with “deliver[ing] re27 sults.”
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Ms. Ghaderi Complains about Defendants’ Violation

of Its Internal Copyright Policies and Copyright Law

40.
Around the same time, Ms. Ghaderi inherited a project relating to De-
4 fendants’ large language models. Ms. Ghaderi was in charge of flagging violations
5 of Amazon’s internal copyright policies and escalating these concerns to Amazon’s
6 in-house Legal Department.
41.
In March 2023, Styskin met with Ms. Ghaderi to understand why De-
8 fendants were not meeting goals on a project relating to search quality on the
9 Alexa team. Ms. Ghaderi outlined the challenges she had faced because of Ama10 zon’s internal copyright-related policies—which she had fully complied with—and
11 that she had met with a representative from the Legal Department to explain her
12 concerns and the tension they posed with the direction she had received from up13 per management, which advised her to violate the direction from Legal.
42.
Styskin rejected Ms. Ghaderi’s concerns about Amazon’s internal poli-
15 cies and instructed her to ignore those policies in pursuit of better results because
16 “everyone else”—i.e., other AI companies—“is doing it.”
Defendants Continue to Retaliate against Ms. Ghaderi,

Causing Her to Complain of Pregnancy Discrimination

43.
On or about March 28, 2023, Ms. Ghaderi had a performance review
20 for 2022. The review failed to follow the Defendants’ normal process. Specifically,
21 it did not consider input from her prior manager for most of 2022 or positive up22 ward feedback provided by her team. The manager’s feedback portion of the re23 view was largely negative and contradicted the positive feedback her team mem24 bers, despite the fact that Krishnakumar only supervised Ms. Ghaderi for a little
25 over a month in 2022. Specifically, although the review overall stated that Ms.
26 Ghaderi “Meets [the] High Bar” imposed by Amazon, the review noted that Ms.
27 Ghaderi needed to improve at “earn[ing] trust” and “delivering results.”
44.
When Ms. Ghaderi asked her manager, Krishnakumar, about this conVerified Complaint
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Page 12 1 tradiction, he could not give her a response backed up by any data. Ms. Ghaderi
2 followed up with an email to Krishnakumar asking for clarification. Krishnakumar
3 ignored this email.
45.
On or about March 31, 2023, Ms. Ghaderi complained to Human Re-
5 sources about this review, her “temporary” transfer from Marcu to Krishnakumar
6 immediately after informing Marcu of her pregnancy, and the fact that she had
7 never been reinstated to her former position as promised. Human Resources stat8 ed that they would investigate and respond to Ms. Ghaderi by April 7, 2023.
46.
On or about April 5, 2023, Krishnakumar scheduled a one-on-one
10 with Ms. Ghaderi regarding her 2022 compensation statement. During this meet11 ing, Ms. Ghaderi mentioned the email she had sent to Krishnakumar that had gone
12 unanswered, again requesting an explanation for his contradictory review and vio13 lation of Defendants’ formal review process. Krishnakumar refused to answer or
14 share any data points she requested, became defensive, and said he would take this
15 up with Styskin.
47.
Approximately one hour later, Ms. Ghaderi received a request to meet
17 in person with Styskin and Krishnakumar. Ms. Ghaderi wrote to Human Re18 sources the following day, indicating that she was concerned about the meeting
19 because, among other things, her “work context/dynamic ha[d] complete shifted
20 from just 4.5 months ago when I had been moved (excitingly) to work under
21 [Marcu] before my maternity leave.”
48.
On or about April 6, 2023, Ms. Ghaderi met with Styskin and Krish-
23 nakumar. Styskin announced that Defendants had decided to strip Ms. Ghaderi’s
24 team from her and demote her to a position reporting to a peer, Sanket Nayak,
25 who reported to Krishnakumar. Styskin asked Ms. Ghaderi how she felt about the
26 changes, and when she asked for clarification on what he meant, he responded,
27 “You know, feelings, or are you saying, ‘oh, I’m from Germany so I don’t have feel28 ings’?”
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On or about April 10, 2023, Ms. Ghaderi made a formal complaint to
2 Human Resources, stating her good faith belief that she had been demoted due to
3 discrimination and retaliation relating to her pregnancy, and relaying Styskin’s
4 comment about her not having feelings because she is German.
50.

On or about April 21, 2023, Ms. Ghaderi reiterated her complaint in a
6 meeting with Human Resources. Although Ms. Ghaderi explained that she felt that
7 much of Defendants’ conduct related to her pregnancy and leave, Defendants’ fo8 cus was on Styskin’s comment, rather than pregnancy discrimination or retalia9 tion.
Defendants Retaliate against Ms. Ghaderi Further

after She Takes Baby Bonding Leave
51.

In or around May 2023, Ms. Ghaderi took the remainder of her job-
13 protected baby bonding leave. She returned to work in early August 2023.
52.

On May 24, while Ms. Ghaderi was on baby bonding leave, Amazon’s
15 HR representative, Tia Bailey, informed her that Amazon had “spoke[n] with rele16 vant parties and reviewed relevant documentation . . . and found a violation of
17 Amazon policy or standard of conduct” concerning Styskin’s comment that Ms.
18 Ghaderi did not have feelings because she was German. Bailey specifically told Ms.
19 Ghaderi that they did not find evidence of pregnancy discrimination or retaliation
20 for taking pregnancy disability leave. Instead, Bailey informed Ms. Ghaderi that
21 “org changes can happen at any time” and that, because her pay wasn’t reduced,
22 any modifications to the reporting structure were “not a demotion” and were not
23 discriminatory. 7 Bailey refused to modify Ms. Ghaderi’s 2022 annual review.
The law does not agree with Amazon HR. See, e.g., Ray v. Henderson, 217 F.3d 1234,
(9th Cir. 2000) (holding that lateral transfers can be adverse employment actions);
Wyatt v. City of Boston, 35 F.3d 13, 15-16 (1st Cir. 1994) (holding that adverse employ26 ment actions include “disadvantageous transfers or assignments”); Knox v. Indiana, F.3d 1327, 1334 (7th Cir. 1996) (holding that adverse employment actions include “de27 priving the person of previously available support services . . . or cutting off challenging
assignments”); Yartzoff v. Thomas, 809 F.2d 1371, 1376 (9th Cir. 1987) (“Transfers of job

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53.
Upon her return to work, Ms. Ghaderi was on the Defendants’ “Ramp
2 Back” program, which, under Defendants’ policy, gives new parents “eight consec3 utive weeks of flexibility and partial work hours after the birth or adoption of a
4 child to readjust to work schedules as new parents.” 8 The Ramp Back program is
5 billed as a flexible program demonstrating Amazon’s commitment to allowing
6 working parents to return to the workplace so they can “succeed and thrive.”
54.
Immediately upon her return from leave, Ms. Ghaderi was placed on
8 an informal performance improvement plan, called a “Focus” plan. 10 The Focus
9 plan is a secret performance improvement plan in which employees are not in10 formed that they are placed into “Focus” unless they explicitly ask.
55.
Shortly after Ms. Ghaderi returned to work, Defendants further di-
12 minished her role, including reducing her charter and removing direct reports
13 from her team.
56.
On August 14, 2023, Ms. Ghaderi met with Nayak to discuss her goals
15 upon returning to work from job-protected CFRA leave for baby bonding. This
16 conversation focused on Ms. Ghaderi’s numerous purported weaknesses—
17 notwithstanding her overall “Meets High Bar” rating just two months before her
18 baby bonding leave—and deficiencies in her team and leadership.
57.
During this meeting, Ms. Ghaderi again raised her concern that the
20 Applied Science Manager career track was no longer available to her. Nayak reiter
duties and undeserved performance ratings, if proven, would constitute ‘adverse employment decisions.’”); St. John v. Employment Devel. Dep’t, 642 F.2d 273, 274 (9th Cir.
1981) (holding that a lateral transfer to a job with the same pay may constitute an adverse
employment action).
8 See “Amazon FamilyFlex helps bring more parents back to the workplace,” Nov. 3, 2021,
available at https://www.aboutamazon.com/news/operations/amazon-familyflex-helpsbring-more-parents-back-to-the-workplace (last visited Mar. 6, 2024).
9 Id.
10 See “Amazon reportedly doesn’t want employees to know when they’re on performance
plans / The ‘Focus’ program is the Fight Club of management tactics,” Jul. 9, 2021, available at https://www.theverge.com/2021/7/9/22570579/amazon-performance-focusplans-hidden-employees (last visited Mar. 6, 2024).
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Page 15 1 ated that “leadership” expected her to continue to work as a Software Development
2 Manager for the AmazonBot feature team and confirmed that a promotion to Sci3 ence Leader was off the table for the foreseeable future.
58.
Because she had been sidelined from future growth opportunities, Ms.
5 Ghaderi requested permission to switch teams on September 29, 2023. On Octo6 ber 2, 2023, Nayak confirmed that Ms. Ghaderi was on a Focus plan and thus
7 would not be allowed to transfer.
Defendants Pressure Ms. Ghaderi to Resign and Ultimately Fire Her
59.
Defendants placed Ms. Ghaderi on an explicit performance improve-
10 ment plan, called a “Pivot” plan, on October 13, 2023. The Pivot plan purported to
11 give Ms. Ghaderi the “choice” of either complying with the plan or resigning and
12 releasing all claims against Amazon in exchange for a small severance.
60.
The Pivot plan was pretextual and intentionally concocted to guaran-
14 tee Ms. Ghaderi’s failure. For example, the first goal required her to create a plan
15 to reduce data storage costs across the entire AmazonBot web crawling organiza16 tion by 75% in just 8 workdays. Ms. Ghaderi asked several senior, high-performing
17 engineers about this goal, and they confirmed that they did not believe it was pos18 sible within the given timeframe. Even if it were possible, Ms. Ghaderi had not
19 been responsible for data storage until the week she was placed on the Pivot plan,
20 meaning that she had no time to understand the existing storage architecture. Nor
21 did Ms. Ghaderi have the engineering support to finalize such a plan in only 22 workdays given the changes to her team over the past months.
61.
When Ms. Ghaderi asked Nayak for guidance on how to implement
24 this plan within the given timeframe, he provided almost no feedback, retorting
25 that she “should be able to do this with no help.”
62.
On or about October 23, 2023, Ms. Ghaderi made another complaint
27 to Human Resources, outlining the impossible situation Defendants placed her in
28 with the Pivot plan and once again complaining of pregnancy discrimination. HuVerified Complaint
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Page 16 1 man Resources did not assist, encouraging her to speak with her manager, alt2 hough she explained she had already done so. When Ms. Ghaderi followed up,
3 Human Resources opened an investigation into her allegations of pregnancy dis4 crimination.
63.
On November 17, 2023, while Ms. Ghaderi’s discrimination complaint
6 was pending, Ms. Ghaderi was fired. At least one other member of her prior team
7 who had taken leave was also terminated.
64.
Under Defendants’ policies, because Ms. Ghaderi was still subject to
9 the performance improvement plan, she was ineligible for hire by any other Ama10 zon teams. This prevented her from continuing to work in a different Amazon or11 ganization, even though other leaders expressly contacted her to encourage her to
12 transfer into their teams.
65.
Human Resources contacted Ms. Ghaderi in early January to discuss
14 the findings of their purported investigation into Ms. Ghaderi’s allegations of
15 pregnancy discrimination and retaliation. Again, Amazon absolved itself of mis16 conduct, finding that no discrimination occurred.
EXHAUSTION OF ADMINISTRATIVE REMEDIES

66.
Plaintiff has met all administration exhaustion requirements by ob-
19 taining a right-to-sue letter from the California Department of Fair Employment
20 and Housing (“DFEH”). See Exhibit A.
CAUSES OF ACTION

FIRST CAUSE OF ACTION

Discrimination in Violation of FEHA

Gov. Code §§ 12940, et seq.

(Plaintiff Against Defendant Amazon)

67.
Plaintiff repeats and incorporates by reference all allegations con-
27 tained in the preceding paragraphs as if fully set forth herein.
68.
The California Fair Employment and Housing Act provides that it is
Verified Complaint
Doc ID: c4c950480e75f4ca55aa729e707a53604d38cc30
Page 17 1 unlawful for “an employer, because of the . . . sex . . . of any person, to . . . dis2 charge the person from employment, . . . or to discriminate against the person in
3 compensation or in terms, conditions, or privileges of employment.” Gov. Code
4 § 12940(a). “Sex” is defined to include pregnancy, childbirth, breastfeeding, and
5 related medical conditions. Gov. Code § 12926(r)(1).
69.
Amazon discriminated against Ms. Ghaderi because of her sex and her
7 pregnancy by reassigning her to a lower level within the organization structure,
8 removing direct reports from her supervision, reassigning her to supervise a dif9 ferent team, and terminating her.
70.
Ms. Ghaderi’s pregnancy and pregnancy-related disabilities were the
11 sole or motivating factors in Amazon’s decision to take these adverse employment
12 actions.
71.
As a direct and proximate result of Amazon’s conduct, Ms. Ghaderi
14 has suffered special damages in the form of lost earnings, benefits, and/or out-of15 pocket expenses in an amount subject to proof at trial. As further direct and prox16 imate result of Amazon’s conduct, Ms. Ghaderi continues to suffer damages in the
17 form of lost future earnings, benefits, and/or other prospective damages in an
18 amount to be proven at trial.
72.
Amazon’s conduct has further caused Ms. Ghaderi to lose financial
20 stability, peace of mind, and future security. Amazon’s conduct has caused her se21 vere embarrassment, humiliation, and mental and emotional distress and discom22 fort in an amount not fully ascertained but subject to proof at trial.
73.
Because of the conduct alleged herein, Ms. Ghaderi hired attorneys to
24 prosecute her claims under FEHA. Accordingly, Ms. Ghaderi is entitled to recover
25 attorneys’ fees and costs pursuant to Government Code § 12965(b), in addition to
26 other damages as provided by law.
74.
Moreover, Amazon’s conduct has been intentional, deliberate, willful,
28 malicious, reckless, and conducted in callous disregard for Ms. Ghaderi’s rights,
Verified Complaint
Doc ID: c4c950480e75f4ca55aa729e707a53604d38cc30
Page 18 1 entitling her to punitive damages.
SECOND CAUSE OF ACTION

Retaliation in Violation of the FEHA

Gov. Code § 12940, et seq.

(Plaintiff Against Defendants)

75.
Plaintiff repeats and incorporates by reference all allegations con-
7 tained in the preceding paragraphs as if fully set forth herein.
76.
The California Fair Employment and Housing Act provides that it is
9 unlawful for an employer to retaliate against an person “because the person has
10 opposed any practices forbidden under [FEHA] or because the person has filed a
11 complaint, testified, or assisted in any proceeding under [FEHA].” Gov. Code
12 § 12940(h).
77.
Ms. Ghaderi engaged in protected activity by stating her intent to take
14 leave under the PDLL, making protected complaints of pregnancy discrimination,
15 retaliation for taking leave under the PDLL/CFRA, and harassing comments based
16 on her pregnancy, gender, and ethnicity.
78.
Amazon retaliated against Ms. Ghaderi because of these protected ac-
18 tivities, removing direct reports from her supervision, reassigning her to supervise
19 a different team, and terminating her.
79.
Ms. Ghaderi’s protected activities were the sole or motivating factors
21 in Amazon’s decision to take these adverse employment actions.
80.
As a direct and proximate result of Amazon’s conduct, Ms. Ghaderi
23 has suffered special damages in the form of lost earnings, benefits, and/or out-of24 pocket expenses in an amount subject to proof at trial. As further direct and prox25 imate result of Amazon’s conduct, Ms. Ghaderi continues to suffer damages in the
26 form of lost future earnings, benefits, and/or other prospective damages in an
27 amount to be proven at trial.
81.
Amazon’s conduct has further caused Ms. Ghaderi to lose financial
Verified Complaint
Doc ID: c4c950480e75f4ca55aa729e707a53604d38cc30
Page 19 1 stability, peace of mind, and future security. Amazon’s conduct has caused her se2 vere embarrassment, humiliation, and mental and emotional distress and discom3 fort in an amount not fully ascertained but subject to proof at trial.
82.
Because of the conduct alleged herein, Ms. Ghaderi hired attorneys to
5 prosecute her claims under FEHA. Accordingly, Ms. Ghaderi is entitled to recover
6 attorneys’ fees and costs pursuant to Government Code § 12965(b), in addition to
7 other damages as provided by law.
83.
Moreover, Amazon’s conduct has been intentional, deliberate, willful,
9 malicious, reckless, and conducted in callous disregard for Ms. Ghaderi’s rights,
10 entitling her to punitive damages.
THIRD CAUSE OF ACTION

Harassment in Violation of FEHA

Gov. Code §§ 12940, et seq.

(Plaintiff Against Defendant Amazon, Styskin, and Krishnakumar)

84.
Plaintiff repeats and incorporates by reference all allegations con-
16 tained in the preceding paragraphs as if fully set forth herein.
85.
The California Fair Employment and Housing Act provides that it is
18 unlawful for unlawful for employer to discriminate against or harass an employee
19 on the basis of sex, gender, race, or ethnicity. Gov. Code § 12940(j). “Sex” is de20 fined to include pregnancy, childbirth, breastfeeding, and related medical condi21 tions. Gov. Code § 12926(r)(1). Employers are strictly liable for harassment by su22 pervisory-level employees. State Dept. of Health Servs. v. Superior Court, 23 Cal.4th 1026, 1041-1042 (2003).
86.
Ms. Ghaderi was subjected to a hostile and pervasive atmosphere of
25 harassment, including repeated comments about her status as a new mother,
26 spending more time with her baby, and her national origin, including the sugges27 tion that she did not have feelings because she is of German descent. This harass28 ment was so severe and pervasive that it altered the terms and conditions of Ms.
Verified Complaint
Doc ID: c4c950480e75f4ca55aa729e707a53604d38cc30
Page 20 1 Ghaderi’s employment and created a hostile and abusive work environment. A rea2 sonable person in Ms. Ghaderi’s circumstances would have considered the work
3 environment to be hostile and/or abusive, and Plaintiff considered her work envi4 ronment to be hostile and/or abusive.
87.
As a direct and proximate result of Defendants’ conduct, Ms. Ghaderi
6 has suffered special damages in the form of lost earnings, benefits, and/or out-of7 pocket expenses in an amount subject to proof at trial. As further direct and prox8 imate result of Defendants’ conduct, Ms. Ghaderi continues to suffer damages in
9 the form of lost future earnings, benefits, and/or other prospective damages in an
10 amount to be proven at trial.
88.
Defendants’ conduct has further caused Ms. Ghaderi to lose financial
12 stability, peace of mind, and future security. Amazon’s conduct has caused her se13 vere embarrassment, humiliation, and mental and emotional distress and discom14 fort in an amount not fully ascertained but subject to proof at trial.
89.
Because of the conduct alleged herein, Ms. Ghaderi hired attorneys to
16 prosecute her claims under FEHA. Accordingly, Ms. Ghaderi is entitled to recover
17 attorneys’ fees and costs pursuant to Government Code § 12965(b), in addition to
18 other damages as provided by law.
90.
Moreover, Defendants’ conduct has been intentional, deliberate, will-
20 ful, malicious, reckless, and conducted in callous disregard for Ms. Ghaderi’s
21 rights, entitling her to punitive damages.
FOURTH CAUSE OF ACTION

Retaliation in Violation of CFRA and the PDLL

Gov. Code § 12940, et seq.

(Plaintiff Against Defendant Amazon)

91.
Plaintiff repeats and incorporates by reference every allegation in this
27 complaint as if fully set forth herein.
92.
The California Family Rights Act and the California Pregnancy DisaVerified Complaint
Doc ID: c4c950480e75f4ca55aa729e707a53604d38cc30
Page 21 1 bility Leave Law both prohibit retaliation against an employee who exercises their
2 rights under each respective law. Gov. Code §§ 12940(h), 12945.2(k).
93.
Ms. Ghaderi engaged in protected activity by stating her intent to take
4 leave under the PDLL and taking leave under the PDLL and CFRA.
94.
Amazon retaliated against Ms. Ghaderi because of these protected ac-
6 tivities, removing direct reports from her supervision, reassigning her to supervise
7 a different team, and terminating her.
95.
Ms. Ghaderi’s protected activities were the sole or motivating factors
9 in Amazon’s decision to take these adverse employment actions.
96.
As a direct and proximate result of Defendants’ conduct, Ms. Ghaderi
11 has suffered special damages in the form of lost earnings, benefits, and/or out-of12 pocket expenses in an amount subject to proof at trial. As further direct and prox13 imate result of Defendants’ conduct, Ms. Ghaderi continues to suffer damages in
14 the form of lost future earnings, benefits, and/or other prospective damages in an
15 amount to be proven at trial.
97.
Defendants’ conduct has further caused Ms. Ghaderi to lose financial
17 stability, peace of mind, and future security. Amazon’s conduct has caused her se18 vere embarrassment, humiliation, and mental and emotional distress and discom19 fort in an amount not fully ascertained but subject to proof at trial.
98.
Because of the conduct alleged herein, Ms. Ghaderi hired attorneys to
21 prosecute her claims under FEHA. Accordingly, Ms. Ghaderi is entitled to recover
22 attorneys’ fees and costs pursuant to Government Code § 12965(b), in addition to
23 other damages as provided by law.
99.
Moreover, Defendants’ conduct has been intentional, deliberate, will-
25 ful, malicious, reckless, and conducted in callous disregard for Ms. Ghaderi’s
26 rights, entitling her to punitive damages.
Verified Complaint
Doc ID: c4c950480e75f4ca55aa729e707a53604d38cc30
Page 22
FIFTH CAUSE OF ACTION

Failure to Prevent Discrimination, Harassment, and Retaliation

in Violation of the FEHA

Gov. Code § 12940, et seq.

(Plaintiff Against Defendant Amazon)

100. Plaintiff repeats and incorporates by reference every allegation in this
7 complaint as if fully set forth herein.
101.
Section 12940(k) of the FEHA separately provides for liability against
9 an employer if it “fail[s] to take all reasonable steps necessary to prevent discrimi10 nation and harassment from occurring.”
102. Amazon, through its managing agents and supervisors, should have
12 but did not take all reasonable steps to prevent discrimination. Ms. Ghaderi made
13 numerous protected complaints to Human Resources, yet, to Ms. Ghaderi’s
14 knowledge, no specific remedial measures were taken. Ms. Ghaderi’s team and
15 scope of work were not restored to her. And even after Ms. Ghaderi’s multiple
16 complaints of discrimination, harassing comments, and retaliation, no one at Am17 azon prevented her from being fired.
103. As a direct and proximate result of Defendants’ conduct, Ms. Ghaderi
19 has suffered special damages in the form of lost earnings, benefits, and/or out-of20 pocket expenses in an amount subject to proof at trial. As further direct and prox21 imate result of Defendants’ conduct, Ms. Ghaderi continues to suffer damages in
22 the form of lost future earnings, benefits, and/or other prospective damages in an
23 amount to be proven at trial.
104. Defendants’ conduct has further caused Ms. Ghaderi to lose financial
25 stability, peace of mind, and future security. Amazon’s conduct has caused her se26 vere embarrassment, humiliation, and mental and emotional distress and discom27 fort in an amount not fully ascertained but subject to proof at trial.
105. Because of the conduct alleged herein, Ms. Ghaderi hired attorneys to
Verified Complaint
Doc ID: c4c950480e75f4ca55aa729e707a53604d38cc30
Page 23 1 prosecute her claims under FEHA. Accordingly, Ms. Ghaderi is entitled to recover
2 attorneys’ fees and costs pursuant to Government Code § 12965(b), in addition to
3 other damages as provided by law.
106. Moreover, Defendants’ conduct has been intentional, deliberate, will-
5 ful, malicious, reckless, and conducted in callous disregard for Ms. Ghaderi’s
6 rights, entitling her to punitive damages.
SIXTH CAUSE OF ACTION

Whistleblower Retaliation

Lab. Code § 1102.5, et seq.

(Plaintiff Against Defendants)

107. Plaintiff repeats and incorporates by reference every allegation in this
12 complaint as if fully set forth herein.
108. Labor Code section 1102.5(b) makes it unlawful for an employer to re-
14 taliate against an employee because the employer believes that the employee dis15 closed or will disclose information “to a government or law enforcement agency, to
16 a person with authority over the employee or another employee who has the au17 thority to investigate, discovery, or correct the violation or noncompliance […] if
18 the employee has reasonable cause to believe that the information discloses [a vio19 lation of law].”
109. Section 1102.5 also makes it unlawful for an employer to “retaliate
21 against an employee for refusing to participate in an activity that would result in a
22 [violation of law].” Lab. Code § 1102.5(c).
110.
As alleged above, Plaintiff complained to Amazon’s Legal Department
24 and her supervisors about violations of Amazon’s internal copyright policies and
25 copyright law.
111.
Amazon retaliated against Ms. Ghaderi because of these protected ac-
27 tivities, removing direct reports from her supervision, reassigning her to supervise
28 a different team, and terminating her.
Verified Complaint
Doc ID: c4c950480e75f4ca55aa729e707a53604d38cc30
Page 24
112.
Plaintiff is entitled to lost wages, back pay, front pay, and reasonable
2 attorney’s fees. Moreover, Defendants are subject to a civil penalty of $10,000 pur3 suant to Labor Code § 1102.5.
SEVENTH CAUSE OF ACTION

Wrongful Termination in Violation of Public Policy

(Plaintiff Against Defendant Amazon)

113.
Plaintiff repeats and incorporates by reference all allegations con-
8 tained in the preceding paragraphs as if fully set forth herein.
114.
It is against public policy in California to discriminate in the terms
10 and conditions of employment based on pregnancy, gender, disability, and sex.
11 See, e.g., Cal. Const., Art. 1, § 8. It is further illegal to retaliate against employees
12 for complaining in good faith about violations of law or violations of the FEHA.
13 Lab. Code § 1102.5; Gov. Code § 12940(h).
115.
Defendants discriminated against Ms. Ghaderi because of her preg-
15 nancy and her use of PDLL/CFRA leave, and retaliated against her based on her
16 complaints of violations of copyright law and policy and FEHA.
116.
Amazon retaliated against Ms. Ghaderi because of these protected ac-
18 tivities, removing direct reports from her supervision, reassigning her to supervise
19 a different team, and terminating her.
117.
Ms. Ghaderi’s protected activities were the sole or motivating factors
21 in Amazon’s decision to take these adverse employment actions.
118.
This discriminatory conduct constitutes an unlawful employment
23 practice in violation of California’s well-established public policy.
119.
As a direct and proximate result Amazon’s conduct, Ms. Ghaderi has
25 suffered special damages in the form of lost earnings, benefits, and/or out-of26 pocket expenses in an amount subject to proof at trial. As further direct and prox27 imate result of Defendants’ conduct, Ms. Ghaderi continues to suffer damages in
28 the form of lost future earnings, benefits, and/or other prospective damages in an
Verified Complaint
Doc ID: c4c950480e75f4ca55aa729e707a53604d38cc30
Page 25 1 amount to be proven at trial.
120. Amazon’s conduct has further caused Ms. Ghaderi to lose financial
3 stability, peace of mind, and future security. Amazon’s conduct has caused her se4 vere embarrassment, humiliation, and mental and emotional distress and discom5 fort in an amount not fully ascertained but subject to proof at trial.
121.
Moreover, Amazon’s conduct has been intentional, deliberate, willful,
7 malicious, reckless, and conducted in callous disregard for Ms. Ghaderi’s rights,
8 entitling her to punitive damages.
DEMAND FOR JURY TRIAL

Pursuant to California Code of Civil Procedure § 631, Plaintiff demands a
11 trial by jury on all issues so triable.
PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully prays judgment as follows:

A.
For actual and liquidated damages according to proof at trial;

B.
For statutory and civil penalties and special damages, according to
16 proof at trial;
C.
For punitive and exemplary damages according to proof;

D.
For pre- and post-judgment interest on monetary damages;

E.
For reasonable attorney’s fees and costs and expert fees and costs as
20 allowed by law; and
F.
For such other relief as this Court deems just and proper.
Dated: April 16,
Respectfully submitted,
KING & SIEGEL LLP

By: _______________________
Julian Burns King
Robert J. King
Andrea Obando
Attorneys for Plaintiff
Verified Complaint
Doc ID: c4c950480e75f4ca55aa729e707a53604d38cc30
Page 26 VERIFICATION

I, Viviane Ghaderi, am Plaintiff in the above-entitled action. I have read the
3 foregoing complaint and know the contents. Based on my own knowledge, except as
4 to those matters which are therein stated on information and belief, and, as to
5 those matters, the allegations in the complaint are true to the best of my
6 knowledge.
I declare under penalty of perjury under the laws of the State of California
8 that the foregoing is true and correct.
April Executed on _________,
2024, at Los Angeles, California.

__________________________
Viviane Ghaderi
VERIFICATION
Doc ID: c4c950480e75f4ca55aa729e707a53604d38cc30
Page 27 Exhibit A
Page 28 S T A T E O F C A L I F O R N I A | Business, Consumer Services and Housing Agency
Civil Rights Department
GAVIN NEWSOM, GOVERNOR
KEVIN KISH, DIRECTOR
2218 Kausen Drive, Suite 100 | Elk Grove | CA | 800-884-1684 (voice) | 800-700-2320 (TTY) | California’s Relay Service at calcivilrights.ca.gov | contact.center@calcivilrights.ca.gov
April 16,
Julian Burns King
724 S Spring Street, Suite Los Angeles, CA 90014-RE:
Notice to Complainant’s Attorney
CRD Matter Number: 202404-Right to Sue: Ghaderi / Amazon.com Services LLC et al.
Dear Julian Burns King:
Attached is a copy of your complaint of discrimination filed with the Civil Rights
Department (CRD) pursuant to the California Fair Employment and Housing Act,
Government Code section 12900 et seq. Also attached is a copy of your Notice of Case
Closure and Right to Sue.
Pursuant to Government Code section 12962, CRD will not serve these
documents on the employer. You must serve the complaint separately, to all named
respondents. Please refer to the attached Notice of Case Closure and Right to Sue for
information regarding filing a private lawsuit in the State of California. A courtesy "Notice
of Filing of Discrimination Complaint" is attached for your convenience.
Be advised that the CRD does not review or edit the complaint form to ensure that it
meets procedural or statutory requirements.
Sincerely,
Civil Rights Department
CRD - ENF 80 RS (Revised 02/23)
Page 29 S T A T E O F C A L I F O R N I A | Business, Consumer Services and Housing Agency
GAVIN NEWSOM, GOVERNOR
KEVIN KISH, DIRECTOR
Civil Rights Department
2218 Kausen Drive, Suite 100 | Elk Grove | CA | 800-884-1684 (voice) | 800-700-2320 (TTY) | California’s Relay Service at calcivilrights.ca.gov | contact.center@calcivilrights.ca.gov
April 16, RE:
Notice of Filing of Discrimination Complaint
CRD Matter Number: 202404-Right to Sue: Ghaderi / Amazon.com Services LLC et al.
To All Respondent(s):
Enclosed is a copy of a complaint of discrimination that has been filed with the Civil
Rights Department (CRD) in accordance with Government Code section 12960. This
constitutes service of the complaint pursuant to Government Code section 12962. The
complainant has requested an authorization to file a lawsuit. A copy of the Notice of
Case Closure and Right to Sue is enclosed for your records.
Please refer to the attached complaint for a list of all respondent(s) and their
contact information.
No response to CRD is requested or required.
Sincerely,
Civil Rights Department
CRD - ENF 80 RS (Revised 02/23)
Page 30 S T A T E O F C A L I F O R N I A | Business, Consumer Services and Housing Agency
GAVIN NEWSOM, GOVERNOR
KEVIN KISH, DIRECTOR
Civil Rights Department
2218 Kausen Drive, Suite 100 | Elk Grove | CA | 800-884-1684 (voice) | 800-700-2320 (TTY) | California’s Relay Service at calcivilrights.ca.gov | contact.center@calcivilrights.ca.gov
April 16, Viviane Ghaderi
,
RE:
Notice of Case Closure and Right to Sue
CRD Matter Number: 202404-Right to Sue: Ghaderi / Amazon.com Services LLC et al.
Dear Viviane Ghaderi:
This letter informs you that the above-referenced complaint filed with the Civil Rights
Department (CRD) has been closed effective April 16, 2024 because an immediate
Right to Sue notice was requested.
This letter is also your Right to Sue notice. According to Government Code section
12965, subdivision (b), a civil action may be brought under the provisions of the Fair
Employment and Housing Act against the person, employer, labor organization or
employment agency named in the above-referenced complaint. The civil action must be
filed within one year from the date of this letter.
To obtain a federal Right to Sue notice, you must contact the U.S. Equal
Employment Opportunity Commission (EEOC) to file a complaint within 30 days
of receipt of this CRD Notice of Case Closure or within 300 days of the alleged
discriminatory act, whichever is earlier.
Sincerely,
Civil Rights Department
CRD - ENF 80 RS (Revised 02/23)
Page 31
COMPLAINT OF EMPLOYMENT DISCRIMINATION
BEFORE THE STATE OF CALIFORNIA

Civil Rights Department
Under the California Fair Employment and Housing Act
(Gov. Code, § 12900 et seq.)

In the Matter of the Complaint of

CRD No. 202404-
Viviane Ghaderi
Complainant,
vs.
Amazon.com Services LLC
,
Andrey Styskin
,
Mahesh Krishnakumar
,
Respondents

1. Respondent Amazon.com Services LLC is an employer subject to suit under the California
Fair Employment and Housing Act (FEHA) (Gov. Code, § 12900 et seq.).

2.Complainant is naming Andrey Styskin individual as Co-Respondent(s).
Complainant is naming Mahesh Krishnakumar individual as Co-Respondent(s).

3. Complainant Viviane Ghaderi, resides in the City of , State of .
4. Complainant alleges that on or about November 17, 2023, respondent took the
20 following adverse actions:
21 Complainant was harassed because of complainant's national origin (includes language
22 restrictions), sex/gender, pregnancy, childbirth, breast feeding, and/or related medical
conditions, pregnancy disability leave (pdl).

Complainant was discriminated against because of complainant's sex/gender,
pregnancy, childbirth, breast feeding, and/or related medical conditions, family care and
medical leave (cfra) related to serious health condition of employee or family member, child
bonding, or military exigencies, pregnancy disability leave (pdl) and as a result of the

-1Complaint – CRD No. 202404-
Date Filed: April 16,
CRD-ENF 80 RS (Revised 12/22)
Page 32 1 discrimination was terminated, laid off, demoted, asked impermissible non-job-related
questions, denied any employment benefit or privilege, denied work opportunities or
2 assignments.
3 Complainant experienced retaliation because complainant reported or resisted any form
of discrimination or harassment, requested or used family care and medical leave (cfra)
4 related to serious health condition of employee or family member, child bonding, or military
exigencies, requested or used pregnancy disability leave (pdl) and as a result was
5 terminated, laid off, demoted, asked impermissible non-job-related questions, denied any
employment benefit or privilege, denied work opportunities or assignments.
Additional Complaint Details:

-2Complaint – CRD No. 202404-
Date Filed: April 16,
CRD-ENF 80 RS (Revised 12/22)
Page 33 1 VERIFICATION
2 I, Julian Burns King, am the Attorney in the above-entitled complaint. I have read
the foregoing complaint and know the contents thereof. The matters alleged are
based on information and belief, which I believe to be true.
On April 16, 2024, I declare under penalty of perjury under the laws of the State of
5 California that the foregoing is true and correct.
Sacramento, CA

-3Complaint – CRD No. 202404-
Date Filed: April 16,
CRD-ENF 80 RS (Revised 12/22)
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