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Becerra, Alexis From: Jackie Angel Investor < Sent: Friday, October 3, 2025 10:22 AM To: eComment; Durham, Daniel Cc: Vazquez, Benjamin; Ryberg, Erinn Subject: CITY OF SANTA ANA PARKS AND RECREATION Lawsuit Sexual Harassment in Violation of FEHA; Attachments: Paloma Ortiz vs City of Santa Ana Parks and Recreation.pdf Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. City of Santa Ana is FIRED HERE. Plaintiff, V. COUNTY OF ORANGE CITY OF SANTA ANA PARKS AND RECREATION, a California Government Entity; Complaint for Damages: 1. Retaliation in Violation of Labor Code § 1102. 5; 2. Quid Pro Quo Sexual Harassment in Violation of FEHA; and 3. Wrongful Termination in Violation of Public Policy. DEMAND FOR JURY TRIAL PLAINTIFF Reports Wage Theft to her Supervisor witnessed the wage theft and immediately reported it to her supervisor, Rodolfo (" Rudy") Hernandez at the beginning of September, one month after Ms. Ortiz began to oversee Roosevelt Walker Community Center. Mr. Hernandez expressed frustration from Ms. Ortiz' s complaints, but failed to take any action to discipline the employees. Ms. Ortiz continued to complain about employee timesheets every pay period, as she felt uncomfortable signing off on timesheets she knew to be fabricated. Despite having this knowledge, Mr. Hernandez did nothing to assist Ms. Ortiz in figuring out a solution to ensure employees adequately filled out the timesheets and failed to take her complaints seriously. Rather, Mr. Hernandez would simply sign off on the employee time sheets himself, despite knowing the time sheets were fabricated. Ms. Ortiz is Forced to Endure Sexual Harassment Throughout her Employment 11. Throughout her employment with the City, Ms. Ortiz was also forced to endure numerous instances of sexual harassment by her supervisor, Mr. Hernandez. On numerous occasions, Mr. Hernandez would rub Ms. Ortiz' s shoulders and be overly affectionate with her in front of other female employees, which made her uncomfortable. On other occasions, Mr. Hernandez would comment on Mr. Ortiz' s appearance, specifically her butt, and repeatedly talk about " how pretty" she was. The harassment continued for roughly three months, and although Ms. Ortiz did not directly report the harassment to Human Resources, Ms. Ortiz expressed her discomfort directly to Mr. Hernandez by putting him on notice that such conduct would be reported to the proper authorities. Mr. Hernandez subsequently began retaliating against Ms. Ortiz by completely ignoring her, negating all his supervisory duties. d. Ms. Ortiz' s Supervisors Fail to Take Her Complaints Seriously Ms. Ortiz' s Employment is Terminated Following Protected Complaints 15. When Ms. Ortiz returned to work on January 3, 2023, she diligently continued her work in preventing wage theft by implementing a new policy regarding employee attendance and reported working hours. The new policy instructed employees to call the Community Center to report when employees were unable to work or would be late to their respective shifts. On January 5, 2023, after one of the employees she oversaw falsified their timeshect, Ms. Ortiz again complained to Mr. Hernandez, stating that the conduct was not conducive to the City' s new policy and the employee needed to be held accountable. Mr. Hernandez continued to disregard Ms. Ortiz' s complaints. City never critiqued Ms. Ortiz' s performance during the meeting, nor did the City provide a legitimate reason for her termination. Furthermore, upon information and belief, the City did not take the required steps to 1