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1 be a consensus in disciplining employees properly moving forward. <br /> 2 13. Thus, during this meeting on December 19, 2022, Ms. Roach, Mr. Hernandez, Ms. Ortiz <br /> 3 brought up the unprofessional atmosphere, including the employees' false reporting of wages. Rather <br /> 4 than acknowledging Ms. Ortiz's concerns, Mr. Hernandez insinuated that if he brought her concerns <br /> 5 up to Parks and Recreation Manager, Tim Pegano, Ms. Oritz's employment would be terminated. Mr. <br /> 6 Hernandez stated that "[he] knows what [Mr. Pegano] is going to tell him, and [he] does not want to <br /> 7 do that to [Ms. Ortiz]." <br /> 8 14. On December 20, 2022, Ms. Ortiz's supervisors, Mr. Pegano and Mr. Hernandez, asked for a <br /> 9 "cheekin-in" meeting stating that they were "concerned for [Ms. Ortiz's] wellbeing. Ms. Ortiz <br /> 10 reiterated her concerns and asked for a transfer to another community center. Rather than taking Ms. <br /> V <br /> 11 Ortiz's complaints seriously,her supervisors scolded her, simply stating that, "[Ms. Ortiz doesn't]have <br /> o¢ <br /> a <0 12 the rank to call the shots" and "by moving locations, [Ms. Oritz's] reputation would be that she does <br /> ZEQ <br /> 13 not work well with others." Ms. Ortiz felt she had no support working for the City following the <br /> W <br /> 14 behavior of Mr. Hernandez and lack of concern from both of her supervisors. 1t was clear to Ms. Ortiz <br /> ao¢ <br /> ►� 15 that the City did not intend to take any of her complaints seriously and resented her for bringing such <br /> w� <br /> W a 16 matters to their attention. <br /> 4024 <br /> O 3 17 e. Ms. Ortiz's Employment is Terminated Following Protected Complaints <br /> aU� <br /> 18 15. When Ms. Ortiz returned to work on January 3, 2023, she diligently continued her work in <br /> 19 preventing wage theft by implementing a new policy regarding employee attendance and reported <br /> 20 working hours. The new policy instructed employees to call the Community Center to report when <br /> 21 employees were unable to work or would be late to their respective shifts. On January 5, 2023, after <br /> 22 one of the employees she oversaw falsified their timeshect, Ms. Ortiz again complained to Mr. <br /> 23 Hernandez, stating that the conduct was not conducive to the City's new policy and the employee <br /> 24 needed to be held accountable. Mr. Hernandez continued to disregard Ms. Ortiz's complaints. <br /> 25 16. On January 18,2023,Mr. Hernandez and Mr. Pogano met with Ms. Ortiz and informed her that <br /> 26 her employment was terminated. Given that Mr. Hernandez had been visibly frustrated by Ms. Ortiz's <br /> 27 complaints throughout her employment, it is not surprising that her termination came only two weeks <br /> 28 after her most recent refusal to sign off on employees' time sheets that she knew to be fabricated. The <br /> PLAINTIFF PALOMA ORTIZ'S COMPLAINT <br /> 4 <br />