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1 Plaintiff Paloma Ortiz ("Ms. Ortiz" or "Plaintiff') hereby files this Complaint against City of
<br /> 2 Santa Ana Parks and Recreation, a California Government Entity ("Defendant"). Plaintiff is informed
<br /> 3 and believes, and based thereon alleges, as follows:
<br /> 4 I. NATURE OF THE ACTION
<br /> 5 1. Plaintiff files this action to recover damages and obtain other remedies afforded to her by law
<br /> 6 for violations of the California Labor Code arising from Defendant's unlawful practices. Plaintiff
<br /> 7 brings this action against Retaliation in Violation of Labor Code § 1102.5, Quid Pro Quo Sexual
<br /> 8 Harassment in Violation of FEHA and Wrongful Termination in Violation of Public Policy; and
<br /> 9 statutory damages and penalties, prejudgment interest, special and general damages, costs, attorneys'
<br /> 10 fees, and other appropriate relief for Defendant's unlawful conduct.
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<br /> p` 11 II. PARTIES, JURISDICTION,AND VENUE
<br /> a <0 12 2. Plaintiff Paloma Ortiz is an individual who, at all times relevant to this action, resided in the
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<br /> �Z 13 County of Los Angeles, State of California.
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<br /> s14 3. At all times herein mentioned, City of Santa Ana Parks and Recreation was and is a nonprofit
<br /> aw x 15 corporation organized under the laws of the State of California, was and is registered for and is doing
<br /> W 16 business in California, including the County of Orange, City of Santa Ana, with headquarters at 1651
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<br /> 17 E 4th St. Ste 250, Santa Ana, CA 92701-5169.
<br /> 18 4. Plaintiff is ignorant of the true names and capacities, whether individual, corporate, associate
<br /> 19 or otherwise, of the Defendant sued herein under fictitious names Does 1 through 30, inclusive, and
<br /> 20 for that reason sues said Defendant, and each of them, by such fictitious names. Plaintiff is informed,
<br /> 21 believes, and thereupon alleges that each of the Defendant Does 1 through 30, inclusive, is and was in
<br /> 22 some manner responsible for,participated in, or contributed to the matters and things of which Plaintiff
<br /> 23 complains herein, and in some fashion,has legal responsibility, therefore. When Plaintiff ascertains the
<br /> 24 names and capacities of the fictitiously named Defendant Does 1 through 30, inclusive, Plaintiff will
<br /> 25 seek leave to amend this Complaint to set forth such facts.
<br /> 26 5. Plaintiff is informed, believes, and thereupon alleges that each Defendant is, and at all times
<br /> 27 relevant herein was, the agent of its co-defendants, and in committing the acts alleged herein, was
<br /> 28 acting within the scope of its authority as such agent, and with the knowledge,permission, and consent
<br /> PLAINTIFF PALOMA ORTIVS COMPLAINT
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