25550 HAWTHORNE, SUITE 310
TORRANCE. CALIFORNIA 90505
P 310-322-7500 EFAX 844-721-5217
[email protected] https://shegerianconniff.com (310) 322-7500 June 5, 2024
SENT BY ELECTRONIC MAIL
ATTN: Abigail Zermeno, Human Resources Department
City of Anaheim
201 South Anaheim Boulevard, Suite 501
Anaheim, California 92805
[email protected]
Re: Harassment, Discrimination, and Wrongful Termination of
PRIVILEGED AND CONFIDENTIAL SETTLEMENT
COMMUNICATION BASED ON CALIFORNIA EVIDENCE
CODE §§ 1152 AND 1154 AND FEDERAL RULES OF EVIDENCE 408 Dear Ms. Zermeno:
Please let this correspondence serve as formal notice that our office represents regarding claims she has against her former employer, defendant City of Anaheim (“the City”), and individual defendants and .
The purpose of this letter is to explore the possibility of reaching an amicable resolution of our client’s claims before fully committing our firm’s (and your) resources to lengthy and costly litigation, and trial work. Further, we ask that you immediatel y furnish personnel file as outlined in Section E and preserve all evidence relevant to this action as further described on in Section F. We have instructed our client not to discuss this letter with anyone while we are attempting to resolve this matter in good faith.
ITEM # CS 01
City of Anaheim
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A. CONFIDENTIAL SETTLEMENT DISCUSSION
This correspondence is sent as a settlement proposal regarding my client’s claims and, as such, is submitted in confidence and is inadmissible for any purpose. (See California Evidence Code § 1152 and 1154.)
B. ALLEGATIONS OF HARASSMENT, DISCRIMINATION, AND
RETALIATION BASED ON DISABILITY AND/OR MEDICAL
CONDITION.
If you do not wish to resolve claims through fair and quick resolution, she will be forced to file h er lawsuit in Orange County Superior Court on or before June 25, 2024. If a lawsuit is filed, all defendants will be served during business hours at their places of business. will allege the following claims against Defendants:
1. Discrimination, harassment, and retaliation on the basis of disability and/or medical condition in violation of FEHA;
2. Failure to accommodate disability and/or medical condition in violation of FEHA;
3. Discrimination, harassment, and retaliation on the basis of age in violation of FEHA;
4. Failure to prevent discrimination, harassment, and retaliation;
5. Wrongful termination in violation of public policy;
6. Violation of California Labor Code § 1102.5;
7. Intentional infliction of emotional distress.
This is not meant to be an exhaustive list, and we reserve the right to amend allegations as additional facts are acquired throughout the course of litigation and discovery process.
1. Begins Her Employment with The City of Anaheim
on or About November 1, 2019, as a Collections Specialist.
On or about November 1, 2019, was hired by The City of Anaheim (“the City”) as a Collections Specialist working in the Finance Department. provided assistance with deposit procedures and practices of payment acceptance from customers at the publi c service counter. received and verified payment by mail and over the
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counter for various city services. She also collected, sorted, and processed the depository boxes that were received overnight by counting currency and verifying dollar amounts to ensure balance sheets for collections were accurate. Additionally, she maint ained a balanced cash drawer for daily cash receipts activities, ran report listing, and ensured that all credit card receipts for payments taken at each cashier stations were accounted for prior to auto settlement.
reported directly to
.
Throughout her employment, was an exemplary employee. was an enthusiastic employee who was eager to do well and help the City as much as possible.
Yet, despite contributions and strong work ethic, the City discriminated against her and wrongfully terminated her employment after she suffered a .
2. In October 2020,
.
In or about October 2020,
.
On May 10, 2021,
.
A week-long recovery time turned into a year. was initially placed on short - term disability leave shortly in May 2021, which extended into long term disability from November 6, 2021, to June 30, 2022.
, she was determined to return to normal
everyday life.
was eager to return to work and had a meeting with Human Resources (“HR”) on June 17, 2022. She underestimated but
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informed HR that she could resume her duties without accommodations. feared she would provide the City of Anaheim a reason to terminate her if she requested accommodations after a long medical leave of absence. She knew the negative stigma around disabled workers and the discrimination they face. was driven to keep her job and believed she would excel as she did before .
3. Returns to Work and Immediately Notifies HR Her Difficulty in Completing Tasks Timely and Making Typographical Errors Due to Her ; However, The City Fails to
Properly Accommodate and Places Her on a Three-Day Suspension Without Pay And A Performance Improvement Plan.
Upon her return in June 2022, quickly realized her
her to make typos and take more time than usual to
complete tasks. promptly emailed HR to arrange a meeting.
On June 26, 2022, met with HR, expressing her deep concerns about the mistakes and explaining that she needed more time to complete her tasks accurately. She also disclosed her
, which also slowed her down. requested a simple accommodation: moving the monitor a few inches to the right to mitigate the issue.
Despite this adjustment, found it ineffective. She immediately informed of the ongoing difficulties. Unfortunately, and HR failed to take further action to provide the necessary accommodations. As a result, continued to have a difficult time adjusting to her working conditions with her disability , highlighting the urgent need for appropriate and effective adjustments to her work environment.
In August 2022, the City placed on a baseless performance improvement plan (PIP) specifically because of the “errors” she was making—even though they knew the errors were a result of her disability and the failure for her to have additional time to complete her tasks.
The City determined did not meet the expectations in the PIP and placed her on a three -day suspension without pay, and she was required to undergo a medical assessment for clearance before HR allowed her to return to work.
On September 30, 2022, under the instruction of the City of Anaheim, underwent a physical examination conducted by Concentra. The examination results informed HR that she was fit for duty but required work restrictions .
Promptly, received a
City of Anaheim
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, consistent with the difficulties she
faced at work.
Once her medical disability was known by HR and other staff, the mistreatment and discrimination she feared she would face when returning to work began.
4. Shortly After Her Return, Is Subjected to Harassment from Supervisors and Coworkers Who Pressure And Rush Her To Complete Work, Despite Knowing About Her Disability, Which Causes When Completing Her Tasks.
After receiving clearance, returned to work and tried her best to keep up and perform well without any accommodations. Despite her determined efforts, her fellow collection specialists and supervisors began to harass her about her disability , pressuring and rushing her to complete her work to set her up for failure given her disability. repeatedly expressed she needed more time given , but was ignored, Below are just a few examples of instances when was rushed to complete her duties, inevitably set up for failure:
• “We are not going to babysit you. ” , another Collection Specialist, stated this to with an attitude before the lunch hour. This made feel degraded and pressured to finish her tasks quickly to avoid being blamed for taking a late lunch.
• “You’re not going to finish it?” criticized again, an hour later when was preparing to take her lunch break. Flustered and under pressure, felt compelled to stay and rush to complete her task. She knew that if she didn't take her lunch on time, it would delay others' breaks, and she would be blamed. • On or about May 1, 2023, , another collections
specialist with no authority over employment, rolled her eyes and rudely told , “Street Citations are first.” chose police citations because she was confident in completing them on time . This comment frustrated , as her coworkers were not patient with her and made her feel inadequate when she did her best to help.
• “You should not be doing credit card slips!” stated this to when she began doing credit card slips earlier in the day because of her medical disability to provide herself with more time to complete this task efficiently and accurately.
However, continued to give her a hard time for her disability and added more stress on .
City of Anaheim
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• On or around May 10, 2023, stated, “Yes, because we like to work,” after asked if the afternoon mail had been picked up for the day. insinuated that was not working because she was too slow given her disability. was belittled for her medical disability when simply trying to help. felt as if she was in a high school locker room isolated by bullies who mistreated her and discriminated against her for having a medical disability leaving her to feel unsafe at work. This behavior caused her to make additional errors because she wa s constantly judged, pressured, and rushed. The severe stress she was under further compounded her inability to focus. The pressure to finish quickly before the lunch hour made a stressful situation even more stressful because felt like she would be terminated if she did not complete the tasks demanded by her supervisors. reported the harsh treatment she received from and the others to her supervisor, , and how it affected her ability to work. However, responded by stating, “ Well it’s because does not understand why you need to work.” Evidently, was complaining to others that she did not want at work given how slow she worked and processed information. felt isolated from this comment as her supervisor justified discrimination against her. would reassure her that she would speak to the others regarding their treatment towards . However, no action was taken, and the treatment became worse and further exacerbated the effect her medical disability had on her work. felt hopeless. She had nowhere to express the issues she had with her medical disability as , her supervisor, did not support her. Since her supervisor did not help her after she complained and even condoned the discriminatory behavior, n o longer felt safe. felt like a burden because of her medical disability and the disregard the City had for her. She continued to try her best despite the hostile work environment and kept her head down to avoid further harassment.
5. On or about October 12, 2023, Disability Is Deemed “Likely Permanent” and She Again Requests Accommodations For More Time To Complete Tasks, But the City Fails To Accommodate Her, Subjects Her More Harassment, Places Her On Another Suspension, and U ltimately Terminates Her Employment.
The continuous mistreatment towards created a hostile work environment leaving her feeling unsupported in a job she was dedicated to performing well. finally obtained an additional doctor’s note requesting accommodations. She provided the doctor’s note hoping that her work environment would become better in order to perform well. However, that was not the case.
City of Anaheim
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On or about October 12, 2023, provided a Doctor’s note confirming her chronic condition .
Additionally, on or around October 17, 2023, provided HR with a doctor’s note from
requested that the City of Anaheim provide with accommodations of more time, grace, understanding and patience to complete her job duties. He explained that is capable of completing her tasks well but will require more time than others. (Exhibit 2 & 3). It also noted disability is “likely permanent.” Despite multiple doctors’ notes and request for more time to complete tasks, the City completely failed to engage in the interactive process and failed to provide a simple accommodation. Not only did the City fail to provide the reasonable acc ommodations requested, they also subjected her to even more discriminatory treatment that exacerbated the already hostile work environment. Additionally, was constantly blamed and made her feel guilty for supposedly causing more work on her cowor kers due to her . became a target and was subjected to discriminatory
comments from her supervisors and coworkers, such as:
• “You’re not even helping them!” shouted this to while waiting for a customer to organize their items to approach the counter for her assistance.
• “I was trying to make sure that this person was doing her job right! ” shouted this in front of a customer after she intervened with assistance with the customer although her calculations were correct. • “You have four minutes to balance.” made this comment to with a raised eyebrow and attitude, rushing her to take her lunch while she was trying to complete a tasks, again adding pressure for to work faster. • “You’re always here but you can’t do the job, but is never here but she does it well.” stated this to when called out of work when she was feeling ill. received multiple write ups despite being on time every day while called out more than the amount allowed and never received a write up.
• “That’s all you did this morning?” made this comment to in reference to the 150 plus transactions she had completed – a normal amount of work that any other employee would complete. had confided in another employee, , who works in another department
City of Anaheim
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about this unfair treatment via Teams, discussing the discrimination because she had completed more than enough work.
• “Are you doing these mistakes on purpose?” This comment was made to on several occasions by despite knowing about her disability and work restrictions.
After the repeated harassment and unfair treatment due to her disability, complained verbally several times to and explained to her that she needed more time and patience in order to effectively complete her tasks in accordance to the provide d doctor’s note. However, failed to address complaints and failed to provide her with the extra time she needed to avoid making mistakes. Instead, warned , “We are not going to give you more time. If you want to work here, you must complete your work at the same time as the other girls here.” Rather than engage in the interactive process and provide with a reasonable accommodation, the City placed on another suspension – this time a 15 -day suspension – in January 2024.
During the months of February and March 2024, continuously emailed and verbally pressured to finish her tasks quickly and blamed her for causing delays for the others. were well aware of need for more time but continued to make her feel pressured and rushed. They suggested that she needed more training, however, knew how to do the task at hand and did not need more training.
She simply needed more time because of her medical disabil ity.
Despite their failure to provide with the requested accommodation, HR placed her on a baseless 90-day performance plan in April 2024.
Before the 90 -day performance plan could even run its full course, the Orange County Employees Association reached out to in late April 2024 and terminated her.
The City offered a lump sum severance payment in exchange for waiver of her rights to sue the City. This was an apparent attempt made by the City to avoid litigation for their clear intention to wrongfully terminate based on her disability and failure to provide necessary accommodations.
On May 2, 2024, declined the City’s offer because she requested for continued health insurance coverage for the rest of the year due to her disability. However, they failed to meet this request and thus proceeded with her discharge. employment officially ended with a letter of termination received on May 8, 2024.
City of Anaheim
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6. As a Result of the City’s Wrongful Actions And Termination, Does Not Have Medical Insurance, Cannot Find New Employment, and Suffers from Severe Anxiety.
The City stripped of her personal autonomy, livelihood, and self -esteem. thought was the worst thing to ever happen to her, but the way The City discriminated against her was far worse. dedicated hard work, effort, and time to help the City and the overall public through her job just to be disregarded. The City left with no medical insurance, no income, and no hope.
The treatment endured during her employment due to her medical disability
. was
determined to reclaim normalcy and live a productive lifestyle. However, her co -workers and supervisors cruelly discriminated against her, lack of patience, and treating her just like the stereotype that she feared she would face if she requested accommodations . They never gave her a chance to prove herself, immediately belittling her for medical disability.
This relentless mistreatment exacerbated her struggles, despite her unwavering resilience and determination to do well.
Further, considered applying for new jobs. However, after being treated as a burden and discriminated against by the City of Anaheim due to her medical disability, she is now afraid of facing the same treatment from other employers. She believes that no one will want to hire someone with her medical history, especially after experiencing how the City of Anaheim treated her
life changed dramatically after but the City of Anaheim made everything worse for her . is a professional with years of experience in the industry and a University of California, Riverside graduate in Business Administration.
She should not have had her job terminated because
. It is abundantl y clear The City of Anaheim acted unlawfully when it terminated . Should this case proceed without settlement, any jury will see The City of Anaheim’s unlawful actions destroyed .
C. RECENT PREVALENCE OF DISABILITY AND/OR MEDICAL
CONDITION RELATED LAWSUITS AND VERDICTS
As you are aware, exposure in employment cases is quite substantial. Even more notable is that FEHA’s lack of a cap on compensatory and punitive damages has allowed for record breaking verdicts in these types of cases. In the past five years, there have been
City of Anaheim
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numerous seven-figure verdicts and settlements for workplace disability /age harassment and disability/age discrimination cases, including:
• McCray v WestRock Servs. LLC (2024): Plaintiff accused the Defendant of terminating him because he has a mental disability that caused his unfair treatment in the workplace. Further, Defendant refused to investigate the unfair treatment that could have helped Plaintiff - $9.4 million verdict • Callahan v Marriott Intl, Inc., et al (2023): Long-time hotel concierge claimed insufficient accommodation for his physical limitations - $20 million verdict • Martinez v. Pharmavite LLC (2023): Maria Martinez was a lead at Pharmavite, LLC's packaging department. She became disabled with physical conditions and was provided work restrictions from her doctor. The jury found in favor of Maria Martinez for Failure to Engage in the Interactive Process and Failure to Reasonably Accommodate - $7.4 million verdict
• Whithorn v. City of West Covina (2023): Larry Whithorn worked for the City of West Covina for nearly 30 years. He joined the department in 2019 as a firefighter and was promoted to fire chief in 2014. He began experiencing harassment after he spent roughly eight months on medical leave in 2017. He was wrongfully terminated in April of 2019 - $4.1 million verdict • Spillane v. Partners in Leadership LLC (2023): Stryder Spillane was subjected to discriminatory and harassing comments following his diagnosis with Multiple Sclerosis and his developing difficulties speaking. Plaintiff complained about mistreatment by co -workers and was then demoted and forced to resign - $2.7 million verdict
• Flores v. Office Depot (2017): Supply chain supervisor was placed on a performance improvement plan just four days after returning from medical leave and was terminated two months later - $10 million verdict • Astorga v. Snap -On Logistics (2017): Jury award to manufacturing plant supervisor who suffers multiple on the job injuries and is later fired - $15 million verdict
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City of Anaheim
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• Barrie v. California Dept. Transportation (2017): Jury awards Caltrans employee in disability harassment case for ignoring his complaints about allergies to perfume and certain cleaning products - 3 million verdict • Navarro v. DHL Global Forwarding (2017): Diabetic driver fired after unauthorized stop to treat low blood sugar gets $1.5 jury verdict - $1.5 million verdict
• Vasquez v. Los Angeles County Metropolitan Transportation Authority (2013): bus driver with chronic health conditions is fired for repeated absences, but he claims that he is disabled and L.A. Metro failed to make reasonable accommodations - $1.9 million verdict
D. DEFENDANT’S EXPOSURE TO MULTIPLE LEVELS OF LIABILITY As you are also aware, defendants face significant risks of cost and attorneys’ fees as a result of litigation, not only on your end, but to compensate plaintiff. All of the aforementioned actions were brought under provisions of FEHA that allow awards of attorneys’ fees which can reach above $1,000,000 alone without a multiplier. Our client here has raised several claims under FEHA and we will, of course, be entitled to attorneys’ fees in a similar range upon prevailing at trial.
The public, media, judges, and jurors have increased their sensitivities toward rectifying the devastating impacts that discrimination, harassment, and retaliation have on their victims, particularly in the case of individuals who suffer from sexual harass ment.
Highly publicized incidents, high profile cases, and routine verdicts all have contributed to the public’s increased awareness, outrage, and corresponding need for effective remedies for discrimination, harassment, and retaliation in the workplace.
If this case is resolved through litigation and is made public, we will be forced undertake extensive discovery. In our belief, there are sufficient disputed issues of material fact to defeat a motion for summary judgment, and this ensures that this matte r will be heard in front of a jury.
E. FORMAL DEMAND FOR PERSONNEL FILE
Additionally, please let this correspondence serve as a formal written request, made pursuant to California law, for:
(1) complete personnel file,
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(2) complete payroll records, and
(3) a true and correct copy of any instrument has ever signed relating to h is obtaining or holding employment with The City of Anaheim.
California Labor Code section 226(b) requires all California employers to provide current and former employees copies of their payroll records upon request.
Pursuant to Labor Code section 226(a), request is hereby made for name entire payroll and wage history with The City of Anaheim, including all payroll and wage records and paycheck copies.
Please note that all itemized statements that reflect this history must include the following items, per California law:
• Gross and net wages earned;
• Total hours worked;
• Number of piece-rate units earned and any applicable piece rate if the employee is paid on a piece-rate basis;
• All deductions;
• Inclusive dates of the period for which the employee is paid; • Last four digits of the employee’s Social Security number (“SSN”) (an employee identification number other than a SSN may be shown on the itemized statement); • Name and address of the legal entity that is the employer; and • All applicable hourly rates in effect during the pay period and the corresponding number of hours the employee worked at each hourly rate.
See California Labor Code § 226(a).1
Further, California Labor Code section 1198.5 states that every California employee has a right to inspect the personnel file an employer maintains for him or her. See California Labor Code § 1198.5. This requirement applies to records related to an em - ployee’s performance and to any grievance concerning the employee, including any personal reason an employee’s employment has been terminated. Labor Code § 1198.5(a).
Last, California Labor Code section 432 states: “If an employee or applicant signs any instrument relating to the obtaining or holding of employment, he shall be given a copy of the instrument upon request.”
1 Please note that, should our office not receive the documents requested pursuant to California Labor Code section 226(b) within twenty-one (21) days of the date of this correspondence, The City will be subject to civil penalties under California law and will also be responsible for our client’s attorneys’ fees and costs related to this firm’s efforts to enforce section 226 of the Labor Code.
City of Anaheim
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Accordingly, demand is hereby made that defendants forward to our office true and correct copies of the documents requested above immediately.
F. DEMAND FOR PRESERVATION OF EVIDENCE
You have a duty to preserve evidence relevant to this action, even without a court order. Because electronic data may be an untraceable source of discovery in this matter, it is your client’s duty to preserve all potentially relevant electronic data. Consistent with that duty, we request that your data be preserved and maintained in a readily accessible format and in accordance with the following safeguards.
By this letter, demands that you preserve any and all evidence concerning h is anticipated lawsuit for harassment, discrimination, retaliation and related claims. This evidence specifically includes all e -mails sent by The City (including all employees and agents), witness statements, investigative reports, etc. Once litigation commences, we will be demanding production of all of these items, as well as others to which you have access.
Please make sure that this is done promptly.
1. Electronic Data To Be Preserved.
The following types of electronic data and/or the electronic data of your client’s subsidiaries, divisions, agents, and employees should be preserved in native format with metadata intact, in accordance with the steps set forth below:
• All electronic mail and information about electronic mail (including message contents, headers and logs of e mail system usage) sent or received by anyone relating to the subject of the impending litigation;
• All databases, including field and structural information, as well as records, containing any information relating to the subject of the impending litigation; • All logs of activity on any computer system that has been used to process or store data containing information relating to the subject of the impending litigation; • All other electronic data containing information about or relating to the subject of the potential litigation, including:
• All word processing files and file fragments;
• Electronic data created by applications that process financial, accounting, and billing information;
• All electronic calendar and scheduling program files and file fragments;
City of Anaheim
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2. Online Data Storage.
With regard to online storage and direct access storage devices attached to your computers, we request that your client not modify or delete any existing electronic data file that meets the criteria set forth above, unless an exact mirror copy has been made and will be preserved and kept accessible for purposes of this potential litigation.
3. Offline Data Storage, Back Ups and Archives.
With regard to all electronic media used for offline storage, such as magnetic tapes and cartridges, CDs, DVDs, and the like, used with any computer, that contain any electronic information relating to the subject of this litigation, we request that your c lient stop any activity that may result in the loss of such data. This request is intended to cover all removable electronic media used for data storage in any device containing back -up or archive data sets.
4. Preservation of Replaced Data Storage Devices.
We request that your client preserve all electronic data storage devices and media that may contain data relating to the subject of the potential litigation and that your client replaces for any reason.
5. Fixed Drives on Stand Alone Personal Computers and Network Stations.
We request that your client not alter or erase relevant electronic data that existed on fixed drives attached to stand-alone microcomputers or network work stations at the time of filing of this action or perform other procedures, such as data compression, disk defragmentation, and optimization routines that may affect such data, unless an exact copy has been made each such active file and of directory listings (including hidden files) for all directories containing any such file and that your client comple tely restore all deleted electronic files and file fragments and arrange to preserve all such data during the pendency of this litigation.
6. Applications and Utilities.
We request that your client preserve copies of all applications and utilities that may be used to process electronic data discussed in this letter.
7. Log of System Modifications.
We request that your client maintain an activity log of document modifications made to any electronic data processing system that may affect any system’s capability to process electronic data relating to the subject of the litigation.
City of Anaheim
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8. Personnel Computers Used By Employees, Contractors, and Others Under Your Control.
Please immediately take the following steps with regard to all of the fixed drives attached to each personnel computer used by anyone under your control:
• Exact copies should be made of all electronic data relating to the subject of the litigation;
• Full directory listings (including hidden files) for all directories and subdirectories should be written;
• All removable electronic media, such as floppy diskettes, magnetic tapes and cartridges, CDs, DVDs, and the like, that existed before the delivery of this letter and that contain relevant data should be collected, maintained intact, and kept available du ring the pendency of this litigation.
9. Evidence Created After Receipt of This Letter.
All relevant electronic data created after receipt of this letter should be preserved in a manner consistent with the directions in this letter.
Please note that nothing herein is intended to be, or shall be deemed, a full or final statement of claims or a waiver of any of h is rights, title, or interests, all of which are expressly reserved. Going forward, any further communication in this matter must be directed to our office and not to . You may reach us at (310) 322 -7500. If you have questions, please do not hesitate to contact us. It is our sincere hope that an informal process can be conducted in good faith and thus my client’s cl aims can be resolved fairly and quickly. We look forward to hearing from you.
Thank you for your attention to this matter.
Very truly yours,
Cortney Shegerian, Esq. Heather Conniff, Esq.