Nature of Proceedings: Demurrer to Second Amended Complaint

The factual allegations of the second amended complaint (SAC) mirror those of the first amended complaint (“FAC”). Plaintiff Jennifer Herrington (“plaintiff” or “Herrington”) alleges she was employed by defendant The Nature Conservancy in 2000. In 2018, plaintiff was offered and accepted the role of Project Manager of the Dangermond Preserve located in Lompoc. She alleges that there were very traditional gender roles on the preserve’s ranches; that Preserve Director Michael Bell demonstrated resistance to allowing a woman perform a leadership role; that the rules she promulgated were disregarded; and that her attempts to address County and Coastal Commission compliance issues were circumvented. Upon successfully advocating for a meeting with County officials regarding permitting requirements, defendant restructured the Preserve team “to increase his control over Plaintiff” and “reduce[] [her] ability to mak........