Complaint,Petition: TAPIA -v- AMAZON.COM, INC. et al Print

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                                ELECTRONICALLY FILED
                                                                                          SUPERIOR COURT OF CALIFORNIA
                                                                                          COUNTY OF SAN BERNARDINO
                                                                                          SAN BERNARDINO DISTRICT

     Peter Lazarus   (SBN 128055)                                                         2/14/2024 5:31   PM
     Brian Angelini   (SBN 234072)                                                              Gaspar Ambriz Medina,   DEPUTY
                                                                                          By:
     PACIFIC     ATTORNEY GROUP
     856 South Robertson Boulevard
     Los Angeles, CA 90035
     Tel: (310) 659-6000
     Fax: (310) 659-4000
     Attorneys for Plaintiff,   CRISTINA TAPIA


                         SUPERIOR COURT OF THE STATE OF CALIFORNIA

                                    COUNTY OF SAN BERNARDINO
                                                                                                    CIVSBZ405575
     CRISTINA TAPIA,                                                                 Case No.

lO                                  Plaintiff,                                       UNLIMITED COMPLAINT FOR
                                                                                     DAMAGES AND INJUNCTIVE RELIEF:
ll          V.
                                                                                     1.   SEXUAL HARASSMENT (HOSTILE
12   AMAZON.COM,INC., AKA AMAZON;
                                                                                          WORK ENVIRONMENT) UNDER CAL.
     AMAZON.COM SERVICES, LLC; and                                                        FAIR EMPLOYMENT AND HOUSING
l3   DOES   1   t0 20, inclusive,
                                                                                          ACT (“FEHA”);
                                                                                      .   SEXUAL HARASSMENT (QUID PRO
l4                                                                                        QUO) UNDER FEHA;
                                    Defendants.                                       .   SEXUAL HARASSMENT DIRECTED
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                                                                                          AT OTHERS (HOSTILE WORK
                                                                                          ENVIRONMENT)
l6                                                                                    .   FAILURE TO PREVENT HARASSMENT
                                                                                          AND DISCRIMINATION;
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                                                  VvvvvvvvVVVVVVVVVVVVVVVVVVVVVVVV




                                                                                      .   UNFAIR, UNLAWFUL, FRAUDULENT
                                                                                          BUSINESS PRACTICES (CAL. BUS. &
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                                                                                          PROF. CODE § 17200 ET SEQ); AND
                                                                                      .   RETALIATION;
l9                                                                                    .   WRONGFUL TERMINATION IN
                                                                                          VIOLATION OF FEHA; and
20                                                                                    .   WRONGFUL TERMINATION IN
                                                                                          VIOLATION OF PUBLIC POLICY.
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                                                                                           DEMAND FOR A JURY TRIAL
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                                         COMPLAINT FOR DAMAGES
                COMES NOW PLAINTIFF, CRISTINA TAPIA, and for causes of action against the

     defendants and each of them, alleges as follows:


                                                               JURISDICTION

           1.   This Court      is   the proper court, and this action     is   properly filed in San Bernardino County,


     because defendants’ obligations and              liability arise therein,       because Plaintiff and defendants


     reside in    San Bernardino, because defendants maintain offices and transact business within San

     Bernardino County, and because the work that                is    the subj ect 0f this action      was performed by

     Plaintiff in      San Bernardino County.
lO
                                                                      PARTIES
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           2.   Plaintiff,   CRISTINA TAPIA           (hereinafter referred t0 as “Plaintiff” 0r           “TAPIA”)   is   and
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     was     at all   times relevant hereto a resident 0f San Bernardino County, State 0f California.


l4         3.   Plaintiff is    informed and believes, and thereon alleges, that              at all   times herein, Defendant

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     AMAZON.COM,                INC.    AKA AMAZON (hereinafter referred t0 as “AMAZON”), is an
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     unknown business           entity   doing and transacting business Within San Bemardino County, State of
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     California.
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l9         4.    Plaintiff is   informed and believes, and thereon alleges, that              at all   times herein, Defendant

20   AMAZON.COM SERVICES, LLC (hereinafter referred t0 as “LLC”), is a corporation doing
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     and transacting business within San Bernardino County, State 0f California.
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           5.   A11    named    defendants in paragraphs 3 through 4, inclusive, are collectively referred t0
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     herein as “Defendants.”
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25         6.   Defendants are Plaintiffs employer within the meaning 0f Cal. Government Code

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     Sections 12926, subdivision            (d),   12940, and 12950, and California Labor Code Sects. 200 et

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     seq.,   and regularly employ five           (5) or   more persons and       is   therefore subj ect t0 the jurisdiction of
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     this Court.


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                                                    COMPLAINT FOR DAMAGES