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I of its co-defendants. <br /> 2 6. Jurisdiction is proper inter alia under Labor Code § 1102.5, and the FEHA. The amount in <br /> 3 controversy exceeds $25,000. <br /> 4 7. Venue is proper in the Superior Court of California, County of Orange, as this Court has <br /> 5 personal jurisdiction over Defendants pursuant to Code of Civil Procedure § 395. Plaintiff worked in <br /> 6 and violations occurred in Orange County, and the contract of employment was formed in Orange <br /> 7 County. <br /> 8 III. ADMINISTRATIVE EXHAUSTION <br /> 9 8. Plaintiff timely submitted a Government Tort Clairn Act Notice to the City of Santa Ana on <br /> U 10 June 5, 2023 pursuant to Government Code §§ 910 and 8547.10.More than 45 days have elapsed since <br /> 11 the submission of this claim without remedial action from the City of Santa Ana. Plaintiff also timely <br /> 44 <br /> a ; 12 submitted a complaint to the California Civil Rights Department on September 7, 2023, and has <br /> E.4 E <br /> WQ 13 received a Right to Sue Letter. Plaintiff has thus exhausted her administrative remedies and is now <br /> W <br /> s 14 authorized to bring this civil action. <br /> d �¢ <br /> w 15 IV. FACTUAL ALLEGATIONS <br /> Qx <br /> W 16 a. Background <br /> O � <br /> 3 17 9. Ms. Ortiz began her employment with City of Santa Ana Parks and Recreation(hereinafter, the <br /> 18 "City") on July 20, 2021 as a part-time Coordinator. In June of 2022, Ms. Ortiz was promoted to the <br /> 19 full-time position of Recreational Leader and became responsible for overseeing approximately ten <br /> 20 employees. As a new fiill-time employee, Ms. Ortiz was subject to a standard six-month probationary <br /> 21 period that expired in December 2022 and transitioned her position to that of a permanent, fiill-time <br /> 22 employee with certain employment protections. Throughout her time at the City of Santa Ana Parks <br /> 23 and Recreation, Ms. Ortiz was a diligent employee who took her supervisory duties seriously. <br /> 24 b. Ms. Ortiz Reports Wage Theft to her Supervisor <br /> 25 10. Part of Ms. Ortiz's responsibilities included signing off on employees' time sheets for accuracy. <br /> 26 Employees were paid in advance, but were required to keep track of their hours and days worked. <br /> 27 Because of this system, employees would often falsify hours by recording hours they did not work, <br /> 28 including on days they did not show up to work. Every time an employee falsified hour,Ms. Ortiz was <br /> PLAINTIFF PALOMA ORTIVS COMPLAINT <br /> 2 <br />