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I required to make time adjustments to Human Resources, which was very time consuming. Ms. Ortiz 2 witnessed the wage theft and immediately reported it to her supervisor, Rodolfo ("Rudy") Hernandez 3 at the beginning of September, one month after Ms. Ortiz began to oversee Roosevelt Walker 4 Community Center. Mr. Hernandez expressed frustration from Ms. Ortiz's complaints, but failed to 5 take any action to discipline the employees. Ms. Ortiz continued to complain about employee 6 timesheets every pay period, as she felt uncomfortable signing off on tiinesheets she knew to be 7 fabricated. Despite having this knowledge, Mr. Hernandez did nothing to assist Ms. Ortiz in figuring 8 out a solution to ensure employees adequately filled out the timeshects and failed to take her complaints 9 seriously. Rather, Mr. Hernandez would simply sign off on the employee time sheets himself, despite 10 knowing the time sheets were fabricated. U z 11 C. Ms. Ortiz is Forced to Endure Sexual Harassment Throughout her Employment °u a0 12 11. Throughout her employment with the City, Ms. Ortiz was also forced to endure numerous F �4 W0 13 instances of sexual harassment by her supervisor, Mr. Hernandez. On numerous occasions, Mr. W >>,, 14 Hernandez would rub Ms. Ortiz's shoulders and be overly affectionate with her in front of other female a 15 employees, which made her uncomfortable. On other occasions, Mr. Hernandez would comment on zx 16 Mr. Ortiz's appearance, specifically her butt, and repeatedly talk about "how pretty" she was. The 0 ¢ 17 harassment continued for roughly three months, and although Ms. Ortiz did not directly report the >4 a18 harassment to Human Resources, Ms. Ortiz expressed her discomfort directly to Mr. Hernandez by 19 putting him on notice that such conduct would be reported to the proper authorities. Mr. Hernandez 20 subsequently began retaliating against Ms. Ortiz by completely ignoring her, negating all his 21 supervisory duties. 22 d. Ms. Ortiz's Supervisors Fail to Take Her Complaints Seriously 23 12. In December 2022, with the permission of Mr. Hernandez, Ms. Ortiz asked City Garden 24 employees to remove numerous gardens and shed items belonging to Garden Program Coordinator Ms. 25 De Vol Roach out of their shared working space as they were deemed unsafe and dangerous to contain 26 in an office space. Upon Ms. De Vol Roach's return to the office, she yelled at Ms. Ortiz for moving 27 their belongings, making Ms. Ortiz uncomfortable. Following this incident, Ms. Ortiz emailed Ms. 28 Devol Roach and Mr. Hernandez explaining that what transpired was unacceptable and there needs to PLAINTIFF PALOMA ORTIZ'S COMPLAINT 3