Complaint,Petition: KEVIN PATTERSON VS THORNTON AIRCRAFT COMPANY, LLC

On April 30, 2024 a Complaint,Petition was filed involving a dispute between Patterson Kevin, and Thornton Aircraft Company Llc, for Wrongful Termination (General Jurisdiction) in the District Court of Los Angeles County.

Preview
HANNEMANN LAW FIRM, A PRQPFssIoNALcoRPoRAIIQN
Brian G. Hannemann, Esq.. State Bar No. — 166109
1042 N. Mountain Ave., Suite B-222
Upland, California 91786
Tel: (909) 980-7878
Fax: (909) 912-8999
ba&hesa&r.a&mail.corn

Kathleen Doherty, Esq. SBN: 310608
katevdohertv entail.corn
1042 N. MouIitain Ave., B-596
Upland, CA 91786
&z T: (909) 522-0228
0 F:(909) 912-8084
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Attorneys for Plaintiff,
0 KEVIN PATTERSON
P SUPERIOR COURT OF CALIFORNIA
10
0 COUNTY OF LOS ANGELES - STANLEY MOSK COURTHOUSE
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KEVIN PATTERSON, an individual, ) CASE NO:
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Plaintiff, COMPLAINT FOR DAMAGES AND
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5 I. UNLAWFUL RACE
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14 ) DISCRIMINATION VIOLATION OF FEHA
vs. ) (Gov'6 Code ('I 12940(a));
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0 15 ) 2. DISABILITY DISCRIMINATION IN
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&o ) VIOLATION OF FEHA (Gov 7 Code II
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16 THORNTON AIRCRAFT COMPANY ) 12940(a));
Z D LLC, a California Limited Liability 3. FAILURE TO PREVENT
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z0 17 Company; and DOES 1-50, ) DISCRIMINATION (Gov'6 Code ss 12940(k));
) 4. VIOLATION OF LABOR CODE )
18 ) 6311;
) 5. WRONGFUL TERMINATION IN
19 Defendants. ) VIOLATION OF PUBLIC POLICY
)
20 ) DEMAND FOR JURY TRIAL
z 21

22 Plaintiff KEVIN PATTERSON alleges as follows:
23 VENUE AND PARTIES
24 I. Plaintiff KEVIN PATTERSON (hereinafter "Plaintilf") is an African American
25 male over the age of eighteen, and a resident of San Bernardino County, California.

26 Defendant THORNTON AIRCRAFT COMPANY. LLC (dba Thornton Aviation) is

27 a California Limited Liability Company, principal executive oflice located at 7520 Hayvenhurst

28 Ave., Van Nuys, California 91406& qualified to and actually doing business in the County of Los

- I-
CQSIPLAINT FoR DAiIIAGEs Aivo IixJuixcTIVE RELIEF
Angeles, State of California and is subject to suit under the California Fair Employment and
Housing Act, California Government Code II 1 2900, et seq., in that THORNTON AIRCRAFT

COMPANY, LLC regularly employs five or more persons.
3. Defendant DOES 1-25 and each of them, are entities, form unknown, qualified to

and actually doing business in the County of Los Angeles, State of California at and are subject to

suit under the California Fair Employment and Housing Act, California Government Code II12900,

z et seq., in that DOES regularly employ five or more persons.
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4. Defendants THORNTON AIRCRAFT COMPANY, LLC; and Does 1-25 shall

0 hereinafter be collectively referred to as "Employer" or "Employers."
CE 10 5. Employers respectively exercised joint control over Plaintiff s and other
0 a employees'mployment,
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co 'I having divided traditional rights and responsibilities of the employer between them
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zH 12 such that each is an employer of Plaintiff.

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13 6. Employers entered into a co-employment relationship wherein they jointly
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15 employees'mployment.
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16 7. Defendants THORNTON AIRCRAFT COMPANY, LLC; and Does 1-50 shall
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17 hereinafter be collectively referred to as "Defendants."

18 8. The true names and capacities, whether corporate, individual, associate or
z 19 otherwise, of Defendants designated herein as Does I through 50, inclusive, are unknown to
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20 Plaintiff, who therefore sues such Defendants by such fictitious names. Plaintiff will amend this
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z 21 Complaint to allege their true names and capacities when the same have been ascertained.
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22 9. Plaintiff is informed and believes and thereon alleges that each of said Defendants is
23 in some manner intentionally, negligently, or otherwise responsible for the acts, occurrences and

transactions alleged herein.
25 10. Plaintiff is informed and believes and thereon alleges that in performing the
26 unlawful acts alleged herein, each Defendant was the agent, employee and representative of each of
27 the remaining Defendants, and in doing the unlawful things alleged was acting within the course,

purpose, scope and authority of such agency, employment or representation.

-2-
CoMPLAINT FoR DAMAGEs AND INJUNcTIVE RELIEF
1 11. Plaintiff is informed and believes and thereon alleges that each Defendant was
2 acting partly within and partly without the scope and course of their employment, and was acting
3 with the knowledge, permission, consent, and ratification of every other Defendant.

4 12. Employer fostered an environment in which illegal discrimination, harassment, and
5 retaliation were tolerated and condoned.
6 13. Employer allowed its supervisors to perpetrate illegal discrimination, harassment,

z 7 and retaliation at will, without consequence.
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M 8 14. Venue is properly laid in this Court inasmuch as the acts upon which Plaintiff sues

0 9 herein occurred within the County of Los Angeles, witnesses reside in the County of Los Angeles,
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0 10 and Employer is authorized to and does conduct business in the County of Los Angeles.
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11 15. Whenever and wherever reference is made in this Complaint to any act by a
z8 12 Defendant or Defendants, such allegations and references shall also be deemed to be the acts and

lh 13 failures of each Defendant acting individually, jointly and severally.
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& &o~ 14 16. Plaintiffhas exhausted his administrative remedies by filing timely charges of
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15 discrimination, harassment and retaliation with the California Civil Rights Department ("CRD")
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16 and received a notice of his right to sue in a California Superior Court pursuant to Cal. Gov't. Code
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17 $ 12965(b). A true and correct copy of such right to sue letter against Defendants is attached hereto

18 as Exhibit "A" and are incorporated herein by reference as though fully set forth at length.
z 19 OPERATIVE FACTS
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20 17. Employer is an aircraft maintenance service company located at Van Nuys Airport,
z California. According to its website www.thomtonaviation.corn, "As a FAA Certified Repair
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22 Station, we offer aircraft maintenance and avionics services for a wide range of corporate/business

23 aircraff including those operating under FAA Part 91 Regulations & 135 Air Carrier Certificate

24 requirements."

25 18. Employer presented Plaintiff with an offer letter on April I, 2022, for the position of
26 Avionics Technician, offering Plaintiff the position, subject to acceptable results of a pre-
27 employment background check, which background check was completed with acceptable results.

28 Plaintiff s start date was April 4, 2022, as an Avionics Technician.

-3-
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
19. Employer assigned Plaintiff to its "Airplane on Ground" department at the Van
Nuys Ariport. PlaintifFs job duties included providing flight line service and on-call service as
needed.

20. Employer scheduled Plaintiff to work a regular schedule, Sunday through Tuesday
from 10:00 a.m. to 9:00 p.m. Plaintiff also was assigned and worked along with new hire Sotea

Cheng, an A & P (Airframe & Powerplant) mechanic to work the same shifts. Plaintiff and Cheng

z were the only support for the shifts Sunday through Tuesday 10:00 a.m. to 9:00 p.m. Cheng was
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I the lead on all jobs, as only Cheng had an A & P license issued by the Federal Aviation
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0 Administration, which A & P license allowed Cheng to sign off on all work performed by Plaintiff
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10 and Cheng. Plaintiff did not hold an A & P license, nor any other FAA license. Plaintiff was not
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R authorized to sign off on any work performed as Plaintiff was not the holder of an A & P license.
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0 e 12 Defendant Thornton Aircrafl Company, LLC specifically assembled a technician and a licensed
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)IJ,R 15 vacation had been approved before Plaintiff started work on April 4, 2022. As of April 15, 2022,
.o9N0 16 because of Cheng's scheduled absence due to his vacation, Plaintiff was very limited in which job
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& 8 17 duties he was authorized to perform without Cheng's presence, because Cheng held the A & P
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18 license. Plaintiff, as an unlicensed Avionics Technician, did not have the appropriate licenses
z 19 enabling Plaintiff to drive within the Van Nuys Airport, or to sign off on aircraft logbooks or repair
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X 20 documents, or to release aircraft back to service. Plaintiff asked Employer's Operations Manager
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z Gary and Avionics Supervisor Vince Russo to schedule Plaintiff for the Van Nuys Airport driving
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g 22 test, and to submit Plaintiff for the Station Repairman License, which license would enable

23 Plaintiff to be able to drive throughout the Van Nuys Airport, and be able to sign off on any and all

24 documents in regards to the Aircraft Tasks and Return to Service.

25 22. Plaintiff was the only African American working for Employer during Plaintiff's
26 shifts, and one of two African American employees working for Employer.

27 23. On account of PlaintifFs race, Employer did not provide Plaintiff with appropriate

28 training, or opportunities to work.

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CDMPLAINf FoR DAMAGEs AND INJUNGTIVE RELIEF
24. On account of Plaintiff s race, Employer refused to provide Plaintiff with job related

tasks, as when Plaintiff would try to get work to do by asking other employees of Employer,
including Leads and Supervisors if they had any work for Plaintiff to do, none of the employees
would ever offer Plaintiff any work to do, nor would any of Employer's employees offer to let
Plaintiff work with them.
25. On or about April 27, 2022, Plaintiff felt sick and sought emergency medical

z attention for symptoms including difficulty breathing and sinus issues. Plaintiff sent a text message
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that morning to Employer's Avionics Supervisor Vince Russo, who approved a day off for

0 Plaintiff.
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M 10 26. On or about April 28, 2022, Employer's Avionics Supervisor Vince Russo sent
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8 Plaintiff a text message saying that Plaintiffs co-worker Cheng had quit working for Employer.
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zA tV 12 Russo told Plaintiff not to come for his regularly-scheduled Sunday shift and instead to start
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13 working on Monday, May 2, 2024, at 7:00 a.m.
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On or about Sunday, May I, 2022, Plaintiff sent a text to Employer's Avionics
0 &8 14 27.
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15 Supervisor Vince Russo that Plaintiff needed time off to attend two doctors'ppointments on May
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16 2, 2022. Russo approved Plaintiff" s time off on the morning of May 2, 2022.
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& g 17 28. On or about May 3, 2022, Plaintiff sent a text to Employer's Avionics Supervisor
18 Vince Russo explaining that he had COVID-19 symptoms including a fever and sore throat, and that
z 19 Plaintiff was going to stay home and take a COVID test. Plaintiff also sent text messages to
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2 20 Employer's Human Resources representative Morgan Halvorson about his symptoms. Plaintiff
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z asked Halvorson whether he should come to work pending his COVID test results. Halvorson told
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22 Plaintiff to stay home pending the test results.

23 29. Plaintiff s COVID-19 symptoms and his pending COVID test results required
24 Employer to adhere to the Emergency Temporary Standards promulgated by the California Division

25 of Occupational Safety and Health {Cal/OSHA), including Plaintiff to remain off-work and in

26 isolation for in accordance with state and local laws.

30. Plaintiff s COVID-19 symptoms affected his respiratory and immunological
28 symptoms. Plaintiff s condition limited his ability to do major life activities including performing

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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
work. As a result, Plaintiff qualified as having a physical disability within the meaning of the

California Fair Employment and Housing Act.
31. Employer regarded Plaintiff as having a physical condition that made the
achievement of major life activities difficult. Employer regarded Plaintiff as having a condition or
health impairment that had no present disabling effect but could become a physical disability

limiting a major life activity.

z 32. On or about May 4, 2022, Employer's Avionics Supervisor Vince Russo called
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Plaintiff and told Plaintiff was "let go" from employment. Russo did not provide any explanation foi

0l4 Plaintiff's termination.
10 33. Employer terminated Plaintiff in violation of state and federal law, motivated by
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Plaintiff s African-American race, PlaintifPs physical disability, and/or Employer's regarding
z A 12 Plaintiff as having a physical disability or having disabilities in the future.
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lh 13 FIRST CAUSE OF ACTION
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14 (Unlawful Race Discrimination,
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15 Cal. Gov 't. Code tj 12940(a)—
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16 Against Employer Defendants and DOES 1-25)
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m 8 z 17 34. Plaintiff realleges and incorporates herein all of the preceding paragraphs as if fully
18 set forth herein.
z 19 35. Plaintiff was at all times material hereto an African-American employee covered by
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20 Cal. Gov't. Code tj 12940 prohibiting discrimination in employment on the basis of race.
z 21 36. Employer Defendants and DOES to 25 were at all times material hereto employers
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22 within the meaning of Gov 't. Code It 12926(d) and, as such, are barred from discriminating in

23 employment decisions on the basis of race as set forth in Gov 't. Code g 12940.

24 37. The conduct of Defendants, and each of them, as alleged above, constitutes unlawful

25 race discrimination under Cal. Gov't. Code II 12940 in that Plaintiff was subjected to adverse

treatment, denied equal treatment and equal opportunities, terminated, and otherwise discriminated
27 against on account of his race.

28 38. None of the discriminatory conduct of Defendants, or any of them, as alleged above,

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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
was based upon a bona fide occupational qualification.
39. As a direct, foreseeable and legal result of Defendants'onduct, Plaintiff has sufferec

emotional distress, including but not limited to, embarrassment, humiliation, mental anguish, and
related mental, physical and emotional symptoms related thereto, all to Plaintiff s damages in an
amount according to proof. Furthermore, Plaintiff has incurred or will incur substantial losses in

seeking substitute employment and in earnings, bonuses, deferred compensation, and other

Z employment benefits, and has incurred and/or will incur medical expenses for treatment by
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I psychotherapists and/or other health professionals and for other incidental expenses. Plaintiff is
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0l4 thereby entitled to general and compensatory damages in amounts to be proven at trial.
40. Defendants committed the acts alleged herein willfully, maliciously, fraudulently and
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oppressively with the wrongful intentions of injuring Plaintiff, from a willful improper motive
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12 amounting to malice, and in conscious disregard of Plaintiff s rights and for the deleterious
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15 other.
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16 41. At all times herein, the aforementioned acts of oppression, fraud or malice were
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8 17 authorized and/or ratified, with advance knowledge and conscious disregard, by Defendants.
18 Consequently, Plaintiff is entitled to punitive damages against Defendants.
R 19 42. As a result of the Defendants'arassing acts as alleged herein, Plaintiff is entitled to
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20 reasonable attorneys'ees and costs of suit as provided by Cal. Gov'I. Code tj 12965(b).
z SECOND CAUSE OF ACTION
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22 (Unlawful Disability Discrimination,
23 Cal. Gov'I. Code tj 12940(a)-
24 Against Employer Defendants and DOES 1-25)
25 43. Plaintiff realleges and incorporates herein all of the preceding paragraphs as if fully
26 set forth herein.

27 44. Plaintiff was at all times material hereto a qualified employee covered by Cal. Gov't.
28 Code $ 12940 prohibiting discrimination in employment on the basis of physical disability.

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CoMPLAINT P'oR DAMAGEs AND INJvNGTIVE RKLIEP
45. Plaintiff suffered from a physical disability affecting his immunological and
respiratory systems.
46. Employer regarded Plaintiff as having a physical condition that made the
achievement of a major life activity or activities difficult, including but not limited to working,
47. Employer regarded Plaintiff as having or having had a condition or health
impairment that could become a physical disability limiting a major life activity in the future.

z 48. Employer Defendants and DOES 1 to 25 were at all times material hereto employers
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I within the meaning of Gov't. Code It 12926(d) and, as such, are barred from discriminating in

0l4 employment decisions on the basis of actual or perceived disability as set forth in Gov't. Code It

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10 12940.
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49. The conduct of Defendants, and each of them, as alleged above, constitutes unlawful
zH 12 disability discrimination under Cal. Gov't. Code It 12940 in that Plaintiff was subjected to adverse
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13 treatment, terminated, and otherwise discriminated against on account of his reported medical
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15 50. None of the discriminatory conduct of Defendants, or any of them, as alleged above,
16 was based upon a bona fide occupational qualification.
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Plaintiff
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8 17 51. As a direct, foreseeable and legal result of Defendants'onduct, Plaintiff has sufferec

18 emotional distress, including but not limited to, embarrassment, humiliation, mental anguish, and

19 related mental, physical and emotional symptoms related thereto, all to PlaintitTs damages in an

20 amount according to proof. Furthermore, ha incurred or will incur substantial losses in
z seeking substitute employment and in earnings, bonuses, deferred compensation, and other
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22 employment benefits, and has incurred and/or will incur medical expenses for treatment by

23 psychotherapists and/or other health professionals and for other incidental expenses. Plaintiff is

24 thereby entitled to general and compensatory damages in amounts to be proven at trial.

25 52. Defendants committed the acts alleged herein willfully, maliciously, fraudulently and
oppressively with the wrongful intentions of injuring Plaintiff, from a willful improper motive
27 amounting to malice, and in conscious disregard of Plaintiff's rights and for the deleterious

28 consequences of the Defendants'ctions. Defendants and each of them, and/or their

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CoMPLAINT FQR DAMAGES AND INJUNcTIYE RELIEF
agents/employees or supervisors authorized, condoned, and ratified the unlawful conduct of each
other.

53. At all times herein, the aforementioned acts of oppression, fraud or malice were
authorized and/or ratified, with advance knowledge and conscious disregard, by Defendants.

Consequently, Plaintiff is entitled to punitive damages against Defendants.
54. As a result of the Defendants'arassing acts as alleged herein, Plaintiff is entitled to

z reasonable attorneys'ees and costs of suit as provided by Cal. Gov '6 Code () 12965(b).
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THIRD CAUSE OF ACTION

0 (Failure To Prevent Harassment, Discrimination, and Retaliation,
10 Cal. Gov'r. Code $ 12940(k)—
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Against Employer Defendants and DOES 1-25)
12 55. Plaintiff realleges and incorporates herein all of the preceding paragraphs as if fully
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14 56. At all times herein, Employer and Defendants DOES 1-25, and each of them, knew
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15 or reasonably should have known that the conduct alleged herein would and did proximately cause
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8 17 57. At all times herein, Employer and Defendants DOES 1-25, and each of them, had the
18 power, ability, authority and duty to cease the conduct alleged above and to intervene to prevent or
z 19 prohibit such conduct.
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20 58. ln violation of Cal. Gov't. Code tJ 12940(k), Employer and Defendants DOES 1-50,
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z through their officers, managing agents and/or supervisors, failed to take all reasonable steps
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22 necessary to prevent the above-alleged discrimination from occurring.
23 59. As a direct, foreseeable and legal result of Defendants'ctions, Plaintiff has suffered
24 and continues to suffer substantial embarrassment, extreme and severe humiliation, mental anguish,

25 and emotional distress, pain and suffering, all to Plaintiff's damage in an amount according to proof.

Furthermore, Plaintiff has incurred or will incur substantial losses in seeking substitute employment
27 and in earnings, bonuses, deferred compensation, and other employment benefits, and has incurred

28 and/or will incur medical expenses for treatment by psychotherapists and/or other health

-9-
COMPLAINT FOR DAMAGES ANO INJUNCTIVE RELIEF
professionals and for other incidental expenses. Plaintiff is thereby entitled to general and
compensatory damages in amounts to be proven at trial.
60. Defendants committed the acts alleged herein maliciously, fraudulently, and
oppressively with the wrongful intention of injuring Plaintiff and in conscious disregard of
Plaintiff s rights and for the deleterious consequences of the Defendants'ctions. Defendants,
through their officers, managing agents and/or supervisors, authorized, condoned and ratified the

z unlawful conduct of all of the other Defendants named in this action.
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61. At all times herein, the aforementioned acts of oppression, fraud or malice were

0 authorized and/or ratified, with advance knowledge and conscious disregard, by Defendants.
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0 10 Plaintiff is thus entitled to recover punitive damages from Defendants in an amount according to
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z A 12 62. As a result of Employer Defendants'nd Does'-50 conduct as alleged herein,
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15 FOURTH CAUSE OF ACTION
0 (Violation of Labor Code 6311—
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17 Against Employer Defendants and DOES 1-25)
18 63. Plaintiff realleges and incorporates herein all of the preceding paragraphs as if fully
z 19 set forth herein.
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20 64. Plaintiff refused to and/or could not perform work while experiencing COVID-19
z symptoms and awaiting results of a COVID-19 test.
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22 65. Plaintiff s COVID-19 symptoms and his pending COYID test results required
23 Employer to adhere to the Emergency Temporary Standards promulgated by the California Division

24 of Occupational Safety and Health (Cal/OSHA), including Plaintiff to remain off-work and in

25 isolation for in accordance with state and local laws.

26 66. Labor Code section 6311 provides: "No employee shall be laid off or discharged for
refusing to perform work in the performance of which this code, including Section 6400, any
28 occupational safety or health standard, or any safety order of the division or standards board will be

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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
violated, where the violation would create a real and apparent hazard to the employee or their fellow

employees."
67. In violation of Labor Code section 6311, Employer terminated Plaintiff for refusing
to perform work while experiencing COVID-19 symptoms in violation of local and state laws and
regulations, including Cal/OSHA Emergency Temporary Standards.
68. Pursuant to Labor Code section 6311, Plaintiff shall have a right of action and is

Z entitled to wages for the tinie Plaintiff was without work as result of Plaintiffs termination.
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I FIFTH CAUSE OF ACTION

0 (Wrongful Termination in Violation of Public Policy—
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10 Against Employer Defendants and DOES l-25)
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69. Plaintiff realleges and incorporates herein all of the preceding paragraphs as if fully
zH 12 set forth herein.
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13 70. Employer terminated Plaintiff's employment wrongfully and in violation of
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0 &gwo fundamental California public policies, which include policies against discrimination against
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15 employees based on race and disability as set forth in Government Code section 12940 et seq. and
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16 policies against retaliation of employees who refuse to work in a manner in violation of Cal/OSHA
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18 71. As a legal and proximate result of Defendants'ctions, Plaintiff has suffered special
Z 19 and general damages in an amount to be proven.
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20 72. Defendants'ctions were conducted with malice, oppression, and fraud. Defendants
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Z 21 allowed and fostered an environment in which racial and disability discrimination was encouraged
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22 and condoned.

23 PRAYER FOR RELIEF
24 WHEREFORE, Plaintiff prays for judgment against Defendants, and each of them, and

25 requests relief as follows:

26 l. For general and special damages according to proof at the time of trial;
27 2. For economic damages including loss of earning, bonuses, deferred compensation,
28 and other employment benefits, lost future earnings, a blot on Plaintiff s employment history, lack

-11-
COMPLAINT FOR DAMAGES AND INJUNCflVE RELIEF
of references, and other consequential damages;
3. For interest on the amount of losses incurred in earnings, bonuses, deferred
compensation and other employment benefits at the prevailing legal rate;
4. For compensatory damages for losses resulting from humiliation, mental anguish,
and emotional distress according to proof;

5. For reasonable attorney's fees in an amount according to proof;

z 6. For exemplary and punitive damages in an amount to be determined at trial;
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7. For injunctive relief against discriminatory, harassing, and retaliatory practices by
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10 8. For costs of suit incurred herein;
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9. For civil penalties pursuant to California Labor Code;
z qni 12 10. For prejudgment interest according to Iaw; and
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13 11. For such other and further relief as the Court deems just and proper.
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0 &omI8 14 DEMAND FOR JURY TRIAL:
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15 Plaintiff KEVIN PATTERSON hereby requests a trial by jury on all issues so triable.
.gzR 16 Dated: April 30, 2024 HANNEMANN LAW FIRM, APROFESSIONALCORPORATION
SE ZO$ Kathleen Doherty, Esq.
17

z 19
z Kathleen Doherty, Esq.
Z 20 Attorneys for Plaintiff, KEVIN PATTERSON
ial Cnmplami - final wpd
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22

27
28

-12-
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
STATE OF CALIFORNIA 1
8ueinooo, Consumer Samisen ans Nouung Aganev GAVIN NEWSOIA GOVERNOR

SEVIN EISN, OIRECTOR
Civil Rights Department
2218 Kauson Drive, SuEe 100 i 8th Grove { CA 95758
}

SCWSST SS4 {voice} i 800 700 2320 {TTY) 1 Cagfomia s Relet Service at 711
cauavaaghts.ca.gov canted.center@cahivilrighlsRa,gov
{

April 29, 2024

Kathleen Doherty
1042 N. Mountain Ave., Suite B-596
Upland, CA 91786

RE: Notice to Complainant's Attorney
CRD Matter Number: 202404-24521529
Right to Sue: Patterson I Thornton Aircraft Company, LLC

Dear Kathleen Doherty:

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 ali 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 - E{EF 80 RS (Rrarisod 02/23)
TATS OFP
STATE OF CALIFORNIA 1
e sn s,Cons S I sane tie SASs y GAVIN NEWSOM, GOVERNOR

KEVIN KIKH, OIRECTOR
Civil Rights Department
2218 Kausen Cnve, Suite 100 i Elk Grove ) CA i 95758
800-884-1884 )voice) i 800-700-2320 (TTY) i California s Relay Service at 711
calcivilrights ca gov ) contact.center@calcivitnghe.ca gov
oP Caog

April 29, 2024

RE: Notice of Filing of Discrimination Complaint
CRD Matter Number: 202404-24521529
Right to Sue: Patterson / Thornton Aircraft Company, LLC

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)
GTATS Dfrso STATE OF CALIFORNIA 0 s ess, Cons nne
1
S H g Agency GAVIN NEVVSOM, GOVERNOR

KEVIN KISH, DIRECTOR
Civil Rights Department
221 8 K susen Drive. Suite 100 i Elk Grove i CA i 95758

800-884-1884 ivoicei i 800-700-2320 iTTYi i Calaornia s Relay Service at 711
calcivilnghts ca gov i contact cenler@calcivilrights ca.gov
DF'ahtg

April 29, 2024

Kevin Patterson
c/o Kathleen Doherty, Esq., 1042 N. Mountain Ave., B-596
Upland, CA 91786

RE: Notice of Case Closure and Right to Sue
CRD Matter Number: 202404-24521529
Right to Sue: Patterson / Thornton Aircraft Company, LLC

Dear Kevin Patterson:

This letter informs you that the above-referenced complaint filed with the Civil Rights
Department (CRD) has been closed effective April 29, 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 02/23i
COMPLAINT OF EMPLOYMENT DISCRIMINATION
BEFORE THE STATE OF CALIFORNIA
Civil Rights Department
Under the California Fair Employment and Housing Act
(Gov. Code, 5 12900 et seq.)

In the Matter of the Complaint of
Kevin Patterson CRD No. 202404-24521529

Complainant,
vs.

Thornton Aircraft Company, LLC
7520 Hayvenhurst Ave.
Van Nuys, CA 91406

10 Respondents

12
1. Respondent Thornton Aircraft Company, LLC is an employer subject to suit under the
13 California Fair Employment and Housing Act (FEHA) (Gov. Code, t) 12900 et seq.).

14
15 2. Complainant Kevin Patterson, resides in the City of Upland, Stats of CA.
16
tk Complainant alleges that on or about May 4, 2022, respondent took the following
17 adverse actions:

18 Complainant was discriminated against because of complainant's color, disability
(physical, intellectual/developmental, mental health/psychiatric), race (includes hairstyle and
19 hair texture) and as a result of the discrimination was terininated, denied any employment
benefit or privilege, other, denied work opportunities or assignments.
20
21 Complainant experienced retaliation because complainant requested or used a disability-
related accommodation and as a result was terminated, denied any employment benefit or
22 privilege, other, denied work opportunities or assignments.
23
Additional Complaint Details:
24
25
26 -1-
Complaint — CRD No. 202404-24521529
27
Date Filed: April 29, 2024
28
CRO-ENF 80 RS (Revised 12/22)
1 VERIFICATION

I, Kathleen Doherty, 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 believe to be true.
I

On April 29, 2024, declare under penalty of perjury under the laws of the State of
I

California that the foregoing is true and correct.

Upland, CA

20
21

22
23

-2-
Complaint — CRD No. 202404-24521529
27
Date Filed: April 29, 2024
28
CRD-ENF 80 Rs (Revised 12/22l

Case Info

Judge

Maureen Duffy-Lewis Track Judge’s New Case

Case No.

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Document Filed Date

April 30, 2024

Case Filing Date

April 30, 2024

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Complaint,Petition: KEVIN PATTERSON VS THORNTON AIRCRAFT COMPANY, LLC

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