MOVING PARTY: Defendants Kaiser Foundation Health Plan,

Kaiser Foundation Hospitals,

Southern California Permanent Medical Group, and

Sheri Falcone

OPPOSITION: Plaintiff Marielou Mendoza

Plaintiff Marielou Mendoza sues Defendants Kaiser Foundation Health Plan (“KFHP”), Kaiser Foundation Hospitals (“KFH”), and Southern California Permanent Medical Group (“SCPMG”), and her former supervisor Sheri Falcone (collectively, “Defendants”). Plaintiff claims that she was employed by Defendants from 1991 until 2017, when she “retired,” when was constructively terminated by Defendants because of whistleblowing activities, her race, and age.

The Third Amended Complaint (“TAC”) alleges:

Violations of California Health & Safety Code § 1278.5;

Violation of California Government Code § 12940(j)- Race Discrimination;

Violation of California Government Code § 12940(j)- Age Discrimination;

Violation of California Government Code § 12940(K)- Hostile Work Environment

Retaliation in Violation of G