Chilone Payton vs. City of Carmel by the Sea, CA. FIRST AMENDED COMPLAINT FOR DAMAGES FOR: (1) RACE DISCRIMINATION IN VIOLATION OF FEHA; (2) HARASSMENT ON THE BASIS OF RACE IN VIOLATION OF FEHA; (3) SEX DISCRIMINATION IN VIOLATION OF FEHA; (4) HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF FEHA; (5) RETALIATION FOR COMPLAINING ABOUT DISCRIMINATION AND HARASSMENT ON THE BASIS OF RACE IN VIOLATION OF FEHA; (6) RETALIATION FOR COMPLAINING ABOUT DISCRIMINATION AND HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF FEHA; and (7) FAILURE TO TAKE ALL REASONABLE STEPS NECESSARY TO PREVENT DISCRIMINATION AND HARASSMENT FROM OCCURRING IN VIOLATION OF FEHA.

ABSTRACT: RE: IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF MONTEREY CHILONE PAYTON, Plaintiff, VS. CITY OF CARMEL-BY -THE-SEA, CA, and DOES 1 through 21, inclusive, Defendants. Case No.: 16CV003820 FIRST AMENDED COMPLAINT FOR DAMAGES FOR:
(1) RACE DISCRIMINATION IN VIOLATION OF FEHA;
(2) HARASSMENT ON THE BASIS OF RACE IN VIOLATION OF FEHA;
(3) SEX DISCRIMINATION IN VIOLATION OF FEHA;
(4) HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF FEHA;
(5) RETALIATION FOR COMPLAINING ABOUT DISCRIMINATION AND HARASSMENT ON THE BASIS OF RACE IN VIOLATION OF FEHA;
(6) RETALIATION FOR COMPLAINING ABOUT DISCRIMINATION AND HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF FEHA; and
(7) FAILURE TO TAKE ALL REASONABLE STEPS NECESSARY TO PREVENT DISCRIMINATION AND HARASSMENT FROM OCCURRING IN VIOLATION OF FEHA.
On February 13, 2017, Jose A. Gonzalez, Attorney for Chilone Payton, submitted to the Superior Court of California, County of Monterey, FIRST AMENDED COMPLAINT FOR DAMAGES FOR: (1) RACE DISCRIMINATION IN VIOLATION OF FEHA; (2) HARASSMENT ON THE BASIS OF RACE IN VIOLATION OF FEHA; (3) SEX DISCRIMINATION IN VIOLATION OF FEHA; (4) HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF FEHA; (5) RETALIATION FOR COMPLAINING ABOUT DISCRIMINATION AND HARASSMENT ON THE BASIS OF RACE IN VIOLATION OF FEHA; (6) RETALIATION FOR COMPLAINING ABOUT DISCRIMINATION AND HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF FEHA; and (7) FAILURE TO TAKE ALL REASONABLE STEPS NECESSARY TO PREVENT DISCRIMINATION AND HARASSMENT FROM OCCURRING IN VIOLATION OF FEHA. On April 4, 2017, a Conference Case Management was held. A Conference Settlement is scheduled for February 16, 2018, Department 14 and a Jury Trial: Long Cause is scheduled for March 19, 2018, Department 14, according to the SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY website. The FIRST AMENDED COMPLAINT FOR DAMAGES document copy is embedded; named and referenced in the amended complaint, including but not limited to, Mike Calhoun (Chief of Police), Janet Bombard (Director of Library Services and Director of Community Activities), Leticia Livian (Senior Human Resources Analyst), Lori Frontella (City Clerk), Al Fasulo (Code Enforcement Officer), Cleve Waters (Public Works Department), Stu Ross (Public Works employee), Paul Tomasi (Police Officer), Joe Boucher (Police Officer), Ashlee Wright (Library Assistant), Tim Woods (Public Works employee), Tim Meroney (Police Officer), Deanna Allen (Finance Department) and Mayor Jason Burnett.

 WHEREFORE, Ms. Payton prays for judgment against the defendants as follows:

1. For compensatory damages. including lost wages and other lost employment benefits according to proof. on each cause of action;

2. For mental and emotional distress damages on each cause of action;

3. For prejudgment and post-judgment interest. at the legal rate;

4. For an award of attorney fees pursuant to California Government Code Section 12965(b) on each cause of action;

5. For costs of suit incurred;

6. For such other and further relief as the court deems proper and appropriate.

16cv003820 First Amended Complaint for Damages 2-15-2017 by L. A. Paterson on Scribd

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF MONTEREY
CHILONE PAYTON, Plaintiff, VS. CITY OF CARMEL-BY -THE-SEA, CA, and DOES 1 through 21, inclusive, Defendants.
Case No.: 16CV003820
FIRST AMENDED COMPLAINT FOR DAMAGES FOR:
(1) RACE DISCRIMINATION IN VIOLATION OF FEHA;
(2) HARASSMENT ON THE BASIS OF RACE IN VIOLATION OF FEHA;
(3) SEX DISCRIMINATION IN VIOLATION OF FEHA;
(4) HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF FEHA;
(5) RETALIATION FOR COMPLAINING ABOUT DISCRIMINATION AND HARASSMENT ON THE BASIS OF RACE IN VIOLATION OF FEHA;
(6) RETALIATION FOR COMPLAINING ABOUT DISCRIMINATION AND HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF FEHA; and
(7) FAILURE TO TAKE ALL REASONABLE STEPS NECESSARY TO PREVENT DISCRIMINATION AND HARASSMENT FROM OCCURRING IN VIOLATION OF FEHA.