4 11CShegerian@ egEerlanlaw.com en, _s ASSOCIATES, INC. Santa Monica, California 90401 Telephone Number: E3103 860-0770 Number: 310 860-0771 Attorne for Plaintiff, JEFF GOTTLIEB JEFFREY GOTTLIEB, Plaintiff, VS. LOS ANGELES TIMES COMMUNICATIONS LLC, DAVAN MAHARAJ, and DOES 1 through 100, Incluswe, Defendants. N12 Carney R. She erian, Esq., State BarNo. 150461 Anthony ., State Bar No. 259154 egerian aw.com 225 Santa Monica Boulevard, Suite 700 Case PLAINTIFF JEFFREY FOR DAMAGES BASED (1) DISCRIMINATION ON THE BASIS OF AGE IN VIOLATION OF (2) HARASSMENT ON THE BASIS OF . 009\ 00 D7 L?i Tm gm Smac?xa 47940004 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT AGE IN VIOLATION OF RETALIATION FOR COMPLAINING OF DISCRIMINATION (3) HARASSMENT ON THE BASIS OF AGE IN VIOLATION OF (4) FAILURE TO PREVENT DISCRIMINATION HARASSMENT, Am 33 RETALIATION IE MA r451" VIOLATION OF LABOR SECTION 1102.5; (7) WRONGFUL CONSTRUCTIV TERMINATION IN VIOLAT 33d .0 (5) :13 3 a: Q?1311215114233 RETALIATION FOR TAKING A CFRA LEAVE IN VIOLATION OF 160 F: COMPLAINT FOR DAMAGES SIDDE938 PUBLIC (8) FAILURE TO (9) NEGLIGENT (10) NEGLIGENT [11) INTENTIONAL INFLICTION OF EMOTIONAL [12) VIOLATION OF LABOR CODE REGARDING PERSONNEL FILE AND DOCUMENTS SIGNED. DEMAND FOR JURY TRIAL -2- COMPLAINT FOR DAMAGES Plaintiff, Jeffrey Gottlieb, alleges: PARTIES 1. Plaintiff, Jeffrey Gottlieb (?plaintiff? or ?Gottlieb?), is, and at all times mentioned in this Complaint was, a resident of Los Angeles County, in the State of California. A 2. Defendant Los Angeles Times Communications LLC (?defendant? or Times?) is, and at all times mentioned in this'Complaint was, authorized to operate by the State of California and the United States government and authorized and quali?ed to do business in the County of Los Angeles. LA Times? place of business, where the following causes of action took place, was and is in the County of Los Angeles, at 202 West First Street, Los Angeles, California 90012. 3. Defendant Davan Maharaj (?defendant? or ?Maharaj?) is, and at all times mentioned in this Complaint was, employed by LA Times and was Managing Editor and later Editor for LA Times. At all times known to Plaintiff, Defendant Maharaj was a resident of Orange County. Defendants Does 1 through 100 are sued under ?ctitious names pursuant to Code of Civil Procedure section 474.? Plaintiff is informed and believes, and on that basis alleges, that each of the defendants sued under ?ctitious names is in some manner responsible for the wrongs and damages alleged below, in so acting was functioning as the agent, servant, partner, and employee of the co-defendants, and in taking the actions mentioned below was acting within the course and scope of his or her authority as such agent, servant, partner, and employee, with the permission and consent of the co- defendants. 5. Defendants directly and indirectly employed plaintiff Gottlieb, as de?ned under the Fair Employment and Housing Act at Government Code section 12926(d). 6. In addition, defendants compelled, coerced, aided, and abetted the -3- PLAINTIFFS COMPLAINT FOR DAMAGES a; if $3319discrimination, which is prohibited under California Government Code section 12940(i). INTRODUCTORY ALLEGATIONS 7. Plaintiff is a sixty?two year old male. 8. Defendants hired plaintiff on or around March 1997 as Assistant City Editor. From on or around 1998 to 2006, plaintiff was a Staff Writer. From around 2006 to 2008, plaintiff was Assistant City Editor. From 2008 until the end of his employment with. defendants, plaintiff was Senior Writer. At all times during his employment, plaintiff performed his job in an exemplary manner, receiving numerous accolades, including a Pulitzer prize, for his work while employed by defendants. 9. On or around 2010, Plaintiff and co-journalist Ruben Vives (?Ruben?) co-wrote more than 100 stories about corruption within theCity of Bell. The stories they wrote received national recognition, as it helped uncover various corruption scandals within the City of Bell. Ruben and plaintiff received a ?ood of congratulatory emails and phone calls, some even asking for plaintiff and Ruben to investigate their cities. The stories helped to put behind bars several Bell of?cials. 10. Following the story being published, Russ Stanton (?Stanton?), Editor for LA Times, told plaintiff and Ruben that they were singlehandedly boosting morale. LA Times reporters would stop plaintiff in the halls to say how proud they were of his work and that this was the kind of journalism the paper should be producing. 11. During the journalism award season, Shel-by Grad then city-editor, sent an email congratulating and thanking Ruben and plaintiff for their work that helped put accountability of local government on the national agenda. '12. After the stories ran, plaintiff won several awards, including the Pulitzer Prize for Public Service, which is given to the paper; the George Polk Award; the Investigative Reporters and Editors Medal; the Selden Ring for Investigative Reporting; American Society of News Editors Award for Local Accountability Reporting; the Society of Professional Journalists Award for Investigative Reporting; and the Los Angeles Press -4- COMPLAINT FOR DAMAGES Club?s Public Service in Journalism Award. Notably, plaintiff was the only person on the staff with two George Polk Awards. 13. On or around February 2011, the top editors, including Marc Duvoisin (?Duvoisin?), did not tell plaintiff or Ruben that the two had won the George Polk Award, which is one of journalism.?s top honors. Almost by accident Duvoisin told plaintiff, who was walking out of the: building at 11 pm. 14. On or around February 8, 2011, plaintiff was announced one of six ?nalists for the Goldsmith Prize for Investigative Reporting, awarded by Harvard University. 15. On or around February of 2011, David Lauter (?Lauter?), then Assistant Managing Editor/Metro of the LA Times, told plaintiff and Ruben that the paper would pay their expenses to attend the Polk Award ceremony in New York. He also said that if they won the Pulitzer Prize, the paper would pay for their expenses and those of plaintiff?s wife and Ruben?s girlfriend. 16. On or around February 2011, USC aWarded the Selden Ring Award for Investigative Reporting to plaintiff, Ruben, and staff. The award came with $35,000, and it was to be distributed to the reporters and editors, not to the newspaper. However, the check was made out to LA Times. Vicky Porter (?Porter?), the director of the Knight Digital Center and the mistress of ceremony, handed plaintiff the winner?s check. The check was made out to the LA Times, so plaintiff passed it to Stanton. Porter told Stanton, ?I?m sorry, Russ. I?m going to make this clear. It?s going to the reporters and the editors, nOt the newspaper.? 17. Following the award ceremony, plaintiff and Ruben each received about $5,000, and other reporters received a smaller amount, while the Editors decided the rest of the money wOuld be used to throw a party for the staff. The party was supposed to be held at a restaurant owned by a relative of Maharaj. 18. The LA Times also kept $1 ,000 that had been won on another award. 19. A few weeks after the Selden Ring ceremony, plaintiff found the foot-high award with plaintiffs and Ruben?s names haphazardly thrown into a box above -5- COMPLAINT FOR DAMAGES iisome cabinets in Defendant Maharaj?s of?ce; it was chipped. I 20. On or around April 2011, plaintiff attended the George Polk ceremony in New York. The LA Times display at the Roosevelt Hotel where the ceremony was held did not mention plaintiff?s name or that of Ruben, even though the award was given to plaintiff, Ruben, and staff. When plaintiff returned to Los Angeles, he saw that the same poster had been placed on a wall at the LA Times. Plaintiff told Duvoisin that the poster was inaccurate and that their names should be on there. The poster was redone. Not long after, Assistant City Editor Kimi Yoshino told plaintiff, ought to be careful because word is going to get around that you?re mad that your name wasn?t ?rst on the Polk award, and you wanted it changed.? 21. On or around April 18, 2011, the LA Times won the Pulitzer Prize in Public Service for the Bell stories. When reporting about the Pulitzer, the New York Times stated that the public service award went to the LA Times for reporting by plaintiff and Ruben. In his speech to the newsroom after the award was announced, Stanton, Editor of the LA Times, stated, ?When you look up ?grizzled veteran? in the AP stylebook, it says ?See also Gottlieb, Jeff.? This was quoted in the LA Times pro?le of plaintiff and Ruben that appeared the next day. 22. On or around April 19, 2011, plaintiff and Ruben appeared on the CBS Evening News and in an 8-minute interview on the PBS News Hour. In addition, plaintiff has also appeared on other major news networks in which he was interviewed for the City of Bell stories he wrote. 23. On or around May 2011, Stanton sent out an email saying that'no one should make arrangements to go to New York for the Pulitzer ceremony at Columbia University because Stanton wanted to see how many tickets the paper would receive. 24. On or around May 13, 2011, Stanton sent out a list of people who would get tickets to the Pulitzer ceremony. Plaintiff?s wife was on the list, but the paper reneged on paying for her ?ight. Because of the late decision, plaintiff would have to pay $730 for his wife?s ?ight. Plaintiff sent an email to Stanton expressing his frustration that -6- PLAINTIFF COMPLAINT FOR DAMAGES ?34. i-i 26 ii 27 28 Lauter had promised to pay for plaintiff?s wife?s ?ight but that promise now was broken. Stanton took no action. 25. On or around May 20, 2011, an aide to Ricardo Lara sent an email to Maharaj and Ashley Dunn the Assistant Managing Editor/Metro, stating that the Assembly and State Senate would like to have a ceremony in Sacramento to honor Ruben and plaintiff. - Maharaj refused to allow it. 26. In the fall of 2011, after his various travels speaking at events and being honored for his work, plaintiff approached Dunn about his next job assignment. Dunn eventually told plaintiff he was not going to add anyone to the investigative team and that he was assigning plaintiff to Orange County, where plaintiff had started his career at the LA Times. Plaintiff told Dunn he would not go. Dunn stated that that is where his of?ce will be. Meanwhile, two other reporters were given the title of investigative reporter. When plaintiff and another journalist agreed to share a desk, Dunn would not allow it and told plaintiff that the desk was instead assigned to him and that the assignment of the desk to him meant that the company would not cover plaintiff 5 home of?ce expenses any longer. I i 27. After winning the Pulitzer, plaintiff did not get asked to take on an investigative project again. 28. A year after the Selden Ring Award was given, no party had been thrown and the award money had still not been distributed. Plaintiff asked Maharaj about it. Maharaj told plaintiff to speak to Dunn. On or about February 12, 2012, plaintiff . emailed Dunn that the money should be distributed to the reporters. Dunn responded that there was going to be a party thrown by the LA Tiines for the Metro staff. 29. On or around November 2012, months after the Award, there was still no word abOut the remainder of the award money. Plaintiff emailed Dunn, Maharaj, and Duvoisin and requested that the money be distributed. Dunn responded that he had checked with Maharaj, effectively stating that the paper would be keeping the money. 30. On or around April 2013, plaintiff was assigned to cover the Michael Jackson PLAINTIFF COMPLAINT FOR DAMAGES wrongful death civil trial. Plaintiff asked Grad why he was assigned to this case, as it seemed like a story that should be covered by one of the paper?s court or entertainment reporters. Grad responded that ?we want someone high pro?le.? 31. On or around May 3, 2013, more than two years after the Selden Ring ceremony, plaintiff sent an email to the publisher and president of the LA Times, explaining what happened with the award money. The president told plaintiff she would look into what was going on with the money. 32.1 Two weeks later, Dunn called plaintiff into his of?ce and said that his email had caused quite an uproar but that Maharaj was refusing to pass out the money. Dunn stated that there was no record of how much money the paper had siphoned off, but that they decided it was $5,000, even though he recalled it to be $7,000. Dunn told plaintiff he thought there should be a party to boost the low morale at the LA Times. 33. Plaintiff sent Dunn an email following that conversation in which he complained of illegal activity by the LA Times. Plaintiff complained that the money could not be accounted for and that it was ridiculous to celebrate the awards at a party more than two years after they had won them. 34. Following these events, the Washington Post wrote a story with an interview with plaintiff regarding the Selden Ring Award and distribution of money. The story appeared on June 12, 2013 and quoted Washington Post and New York Times editors saying that their reporters kept award money. 35. Following the story, Maharaj stopped speaking to plaintiff. He would pass plaintiff in the hall, glance down at his cell phone, and not say a word. 36. On or around Labor Day weekend of 2013, two months after the Post story appeared, plaintiff received an email from Grad that he thought the money should be used to pay for a holiday party for the staff. Plaintiff responded that he found it outrageous to use the money from the Award, more than two and a half years after it was awarded, for something that had nothing to do with the Award or story. At one point, Grad told plaintiff, ?Frankly Jeff, I?m not sure you want to resolve this.? -3- COMPLAINT FOR DAMAGES 37. Finally, plaintiff and Ruben. got $1,500 each from the Award without being provided an accounting of the award money. 38. On or around June 2014, plaintiff turned in an investigative report story that was still not edited by the time of plaintiff resignation. Plaintiff complained to several different editors but the story never was completely edited. 1 39. In or around August 2014, Grad told plaintiff that for the next several weeks, plaintiff would be the backup obituaries reporter, which was the equivalent of a demotion for someone with plaintiff?s experience level. 40. In or around November 2014, Grad gave plaintiff the choice of several types of stories to cover, one of which was religion, a story plaintiff would have enjoyed covering earlier in his career, but not at this stage. The other choices were covering the city Department of Water and Power or working out of the paper?s city/county bureau. 41. On or around March 4, 2015, plaintiff went on disability leave for seven and a half weeks because of surgery for prostate cancer. 42. During plaintiff?s leave, plaintiff received an email that it was time to submit an evaluation. Plaintiff wrote his evaluation, discussing his frustration with the fact that he had written a great story but it had been sitting for months. Plaintiff explained that this had embarrassed him with his sources and hurt the credibility of the LA Times. Plaintiff?s evaluation received no response. 43. Also during plaintiff 3 leave, Steve Marble, Assistant City Editor, asked plaintiff to cover a press conference. Plaintiff covered the press release despite the fact that he was still on leave. 44. During plaintiff?s leave, on or around April 15, 2015, Grad asked plaintiff to cover the LA Times Book Festival. Plaintiff did not cover this festival. 45. When plaintiff returned from leave on or around April 27, 2015, he was assigned to write obituaries, a demotion. Rather than assign Plaintiff to work on stories that were the same or similar to those on which Plaintiff worked when he left, Defendants assigned him to work that was substantially inferior. When he stated that he -9- COMPLAINT FOR DAMAGES could not do it, Grad told him that he could do the 8 am. web shift, which meant writing about traf?c incidents and breaking news and was, likewise, a demotion. Plaintiff said, quit? in response and provided a two week notice of his resignation. Grad remarked that when older, experienced reporters quit, he had learned not to talk them into staying. Plaintiff felt forced to resign due to his intolerable working conditions, effectively constructiVely terminating his employment with defendant?s. 46. On or around December 2015, the LA Times had a buyout, targeting older, more experienced reporters. About 90 people left. 47. Nobody has been assigned to cover religion since Plaintiff? resignation. No reporter has been assigned to write obituaries since Plaintiffs termination. Listed on the website is an obituaries editor, but no reporter. 48. After Plaintiff?s termination, Plaintiff requested a copy of his complete personnel ?le from Defendants on three separate occasions. Defendants neither responded to Plaintiff?s requests nor provided Plaintiff with his requested personnel ?le, including copies of payroll and wage records. 49. Economic Damages. As a consequence of defendants? conduct, plaintiff has suffered and will suffer harm, including, without limitation, lost past and future income and employment bene?ts, and damage to career, and wages, overtime, unpaid expenses, and penalties, as well as interest on unpaid wages at the legal rate from and after each payday that those wages should have been paid, in a sum to be proven at trial." 50. Non-Economic Damages. As a consequence of defendants? conduct, plaintiff has suffered and will suffer and emotional distress, humiliation, and mental and physical pain and anguish, in a sum to be proven at trial. 51. Punitive Damages. Defendants? conduct constitutes oppression, fraud or malice under California Civil Code Section 3294, so as to entitle plaintiff to an award of exemplary/punitive damages. a. Mali?. Defendants' conduct was done with malice within the meaning of California Civil Code Section 3294, including that defendants acted with intent to - 0- COMPLAINT FOR DAMAGES cause injury to plaintiff, and/or acted with reckless disregard toward plaintiff injury, including by terminating and/or taking other adverse job action against plaintiff based on plaintiffs age, medical leave, andfor good faith complaints; and/or defendants'I conduct was despicable, with willful and conscious disregard of plaintiff? 5 rights, health and safety, including plaintiff?s right to be free of discrimination, harassment, retaliation. b. Oppression. In addition, and/or alternatively, defendants' conduct was done with oppression within the meaning of California Civil Code Section 3294, including that defendants' actions against plaintiff based on plaintist age, medical condition and/or good faith complaints Was ?despicable? and subjected plaintiff to cruel and unjust hardship, in knowing disregard of plaintiff?s rights to a workplace free of discrimination, harassment, retaliation, abuse of requirement of accommodation and engaging in the interactive process, and wrongful termination. c. m. In addition, and/or alternatively, defendants'_ conduct, as alleged, was fraudulent within the meaning of California Civil Code Section 3294, including that defendants asserted false (pretextual) grounds for other adverse job action(s), to thereby harm plaintiff and deprive plaintiff of legal rights. 1 52. Attomeys? Fees. Plaintiff has incurred and continues to incur legal expenses and attorneys? fees. 53. Exhaustion Of Administrative Remedies. Prior to ?ling this action, plaintiff timely exhausted administrative remedies, by timely filing an administrative complaint with the Department of Fair Employment and Housing and receiving a DFEH right to sue letter. FIRST CAUSE OF ACTION Violation of FEHA, Cal. Govt. Code Sections 12900, et seq. Age Discrimination?Against Defendants LA Times, Inclusive of DOES 1 to 100 54. The allegations set forth in paragraphs 1 through 53 are re-alleged and incorpo- _1 1- COMPLAINT FOR DAMAGES rated herein by reference. 55. At all times herein mentioned, FEHA, Government Code section 12940, et seq., was in full force and effect and was binding on defendants. This statute requires defendants to refrain from discriminating against any employee because he or she is more than 40 years old. Within the time provided by law, plaintiff ?led a complaint with the DFEH, in full compliance with administrative requirements, and received a right-to- sue letter. 56. During plaintiff?s employment with defendants, defendants, through their supervisors, engaged in actions that had a negative impact on the treatment of employees who were more than 40 years old. Speci?cally, defendants discharged older employees with greater frequency than younger employees, hired fewer employees who were older than 40, and gave better jobs and bene?ts to younger employees. 57. During plaintiff?s employment with defendants, defendants intentionally en- gaged in age discrimination by discharging employees over the age of 40 with greater. . frequency than other employees. During plaintiff?s employment with defendants, defen? dants had a pattern and practice of discriminating against employees who were more than 40 years old. 58. Defendants, through their managers and supervisors, made a number of com- ments to and about plaintiff that exhibited ageist motivations, intentions, and consciousness. Plaintiff was a quali?ed employee at the time of his constructive termination. Plaintiff believes and on that basis alleges defendants? real motivation was to discharge him because of his age. 59. Defendants? conduct, as alleged, violated the FEHA, and defendants committed unlawful employment practice(s), including, without limitation, by the following, separate bases for liability: a. Terminating, barring, discharging, refusing to transfer, retain, hire, select, and/or employ; and/or otherwise discriminating against plaintiff based, in whole or in part, on plaintiff?s age and/or other protected characteristic(s), in violation of Cal. Govt. -12- PLAINTIFF COMPLAINT FOR DAMAGES Code 12940(a). b. Harassing plaintiff andfor creating a hostile work environment, based, in whole or in part, on plaintiff?s age and/or other protected characteristic(s), in violation of Cal. Govt. Code 129400). c. Failing to take all reasonable steps to prevent discrimination and/or harassment based on age and/or other protected characteristic(s), in violation of Cal. Govt. Code 12940(k). d. Retaliating against plaintiff for seeking to exercise rights guaranteed under the FEHA and/or opposing defendants? failure to provide such rights, in violation of Cal. Govt. Code 12940(h). 7 60. On the basis of the above, plaintiff believes and alleges that his age was a substantial motivating factor in defendants? demotion of plaintiff and refusal to address plaintiff?s good faith concerns. As a proximate result of defendants? willful, knowing, and intentional discrimination against plaintiff, plaintiff has sustained and continues to sustain substantial losses of earnings and other employment bene?ts. 61. As a proximate result of defendants? willful, knowing, and intentional discrimi- nation against plaintiff, plaintiff has suffered and continues to suffer humiliation, emo- tional distress, and mental and physical pain and anguish, all to his damage in a sum according to proof. 62. Defendants? discrimination was done intentionally, in a malicious, oppressive, fraudulent manner, entitling plaintiff to punitive damages. 63. Plaintiff has incurred and continues to incur legal expenses and attomeys? fees. Plaintiff is at present unaware of the precise amounts of these expenses and fees and will seek leave of court to amend this Complaint when the amounts are fully known. -13- PLAINTIFF COMPLAINT FOR DAMAGES it$ild$dii$il ?4 00 SECOND CAUSE OF ACTION Violation of FEHA, Cal. Govt. Code Sections 12900, et eq. Age Harassment?Against All Defendants, Inclusive of DOES 1 to 100 64. The allegations set forth in paragraphs 1 through 63 are re-alleged and incorpo- rated herein by reference. 65. Defendants? conduct, as alleged, violated the FEHA, Cal. Govt. Code Sections 12900 et seq., and defendants committed unlawful employment practice(s), including, without limitation, by the following, separate bases for liability: a. Harassing plaintiff and/or creating a hostile work environment, based, in whole or in part, on plaintiff?s age, and/or other protected characteristic(s), in violation of Cal. Govt. Code Section 129400). b. Failing to take all reasonable steps to prevent discrimination, harassment, and/or retaliation based on age, in violation of Cal. Govt. Code Section 12940(k). 66. As a proximate result of defendants' willful, knowing, and intentional discrimi- nation against plaintiff, plaintiff has sustained and continues to sustain substantial losses of earnings and other employment bene?ts. 67. As a proximate result of defendants? willful, knowing, and intentional discrimi- nation against plaintiff, plaintiff has suffered and continues to suffer humiliation, emo- tional distress, and physical and mental pain and anguish, all to his damage in a sum according to proof. 68. Plaintiff has incurred and continues to incur legal expenses and attorneys? fees. plaintiff is at present unaware of the precise amounts of these expenses and fees and will seek leave of court to amend this Complaint when the amounts are fully known. 69. Defendants? misconduct was committed intentionally, in a malicious, oppressive, fraudulent manner, entitling plaintiff to punitive damages against defendants. -14- COMPLAINT FOR DAMAGES 1:526 ?f?c25 28 THIRD CAUSE OF ACTION Violation of FEHA, Cal. Govt. Code Sections 12900, et seq. Retaliation for Complaining of Age Discrimination and/or Harassment?Against Defendants LA Times, Inclusive of DOES 1 to 100 70. The allegations set forth in paragraphs 1 through 69 are re-alleged and incorpo- rated herein by reference. 71. Plaintiff?s age and/or other characteristic(s) protected by the FEHA, Cal. Govt. Code Sections 12900 etseq., were motivating factors in Defendants? decision to treat him poorly despite his success as a journalist following the City of Bell stories, to not retain, hire or otherwise employ plaintiff in any position, to harass plaintiff while he was on his leave, and/or take other adverse job action(s) against plaintiff. 72. Defendants? conduct, as alleged, violated the FEHA, Cal. Govt. Code Sections 12900 et seq. and Defendants committed unlawful employment practice(s), including, without limitation, by the following, separate bases for liability: a. Terminating, barring, discharging, refusing to transfer, retain, hire, select, and/or employ; and/or otherwise discriminating against plaintiff, based, in whole or in part, on plaintiff?s age, and/or other protected characteristic(s), in violation of Cal. Govt. Code Section 12940(a). b. Harassing plaintiff and/or creating a hostile work environment, based, in whole or in part, on plaintiff?s age, and/or other protected characteristic(s), in violation of Cal. Govt. Code Section 129400). c. Failing to take all reasonable steps to prevent discrimination, harassment, and/or retaliation based on age, in violation of Cal. Govt. Code Section 12940(k). d. Retaliating against plaintiff for seeking to exercise rights guaranteed under the FEHA and/or opposing defendants? failure to provide such rights, including, without limitation, rights of reasonable accommodation, interactive process, leave rights, and/or the right to be free of discrimination, in violation of Cal. Govt. Code Section 12940(h). -1 5- PLAINTIFF COMPLAINT FOR DAMAGES proximate result of defendants? willful, knowing, and intentional discrimi- nation against plaintiff, plaintiff has sustained and continues to sustain substantial losses of earnings and other employment bene?ts. 74. As a proximate result of Defendants? willful, knowing, and intentional discrimi- nation against plaintiff, plaintiff has suffered and continues to suffer humiliation, emo- tional distress, and physical and mental pain and anguish, all to his damage in a sum according to proof. 75. Plaintiff has incurred and continues to incur legal expenses and attorneys? fees. plaintiff is at present unaware of the'precise amounts of these expenses and fees and will seek leave of court to amend this Complaint when the amounts are fully known. 76. Defendants? misconduct was committed intentionally, in a malicious, fraudulent, oppressive manner, entitling plaintiff to punitive damages against Defendants. FOURTH CAUSE OF ACTION Violation of FEHA, Government Code 12900, et seq. (Retaliation for Taking Protected CFRA Leave)?Against - Defendants' LA Times, Inclusive of DOES 1 to 100 77. The allegations set forth in paragraphs 1 through 76 are re-alleged and incorpo- rated herein by reference. 78. Defendants' conduct, as alleged, violated the FEHA, Cal. Govt. Code Sections 12900 et seq., and defendant committed unlawful employment practice(s), including, with-out limitation, by the following, separate bases for liability: a. Terminating, barring, discharging, refusing to transfer, retain, hire, select, and/or employ; and/or otherwise discriminating against plaintiff, based, in whole or in part, on plaintiff 3 taking medical leave, in violation of Cal. Govt. Code Section 12940(a). Defendants also gave plaintiff various work ?assignments while he was on leave. -16- COMPLAINT FOR DAMAGES Retaliating against plaintiff for seeking to exercise guaranteed rights and/or opposing defendants' failure to provide such rights, including, without limitation, rights of reasonable accommodation, interactive process, leave rights, and/or the right to be free of discrimination, in violation of Cal. Govt. Code Section 12940(h). 79. As a proximate result of defendants' willful, knowing, and intentional discrimi- nation against plaintiff, plaintiff has sustained and continues to sustain substantial losses of earnings and other employment bene?ts. 80. As a proximate result of defendants' willful, knowing, and intentional discrimi- nation against plaintiff, plaintiff has suffered and continues to suffer humiliation, emo- tional distress, and physical and mental pain and anguish, all to his damage in a sum according to proof. 81. Plaintiff has incurred and continues to incur legal expenses and attorneys? fees. Plaintiff is at present unaware of the precise. amounts of these expenses and fees and will seek leave of court to amend this Complaint when the amounts are fully known. 82. Defendants' misconduct was committed intentionally, in a fraudulent, malicious, despicable, oppressive manner, entitling plaintiff to punitive damages against defendant. FIFTH CAUSE OF ACTION Violation of FEHA, Government Code 12940(k) (Failure to Prevent Discrimination, Harassment, and Retaliation)? Against Defendants LA Times, Inclusive of DOES 1 to 100 83. The allegations set forth in paragraphs 1 through 82 are re-alleged and incorpo- rated herein by reference. 84. At all times herein mentioned, FEHA, Government Code section 12940(k), was in full force and effect and was binding on defendants. This statute states that-it is an unlawful employment practice in California for an employer ?to fail to take all rea- sonable steps necessary to prevent discrimination and harassment from occurring.? Prior -17. PLAINTIFF COMPLAINT FOR DAMAGES ?ling the instant Complaint, plaintiff ?led a timely administrative charge with the DFEH and received a right-to-sue notice. 85. During the course of plaintiffs employment, defendants failed to prevent their employees from engaging in intentional actions that resulted in plaintiff?s being treated less favorably because of plaintiff?s protected status his age, CFRA leave, and/or good faith complaints). During the course of plaintiff?s employment, defendants failed to prevent their employees from engaging in unjusti?ed employment practices against employees in such protected classes. During the course of plaintiff?s employment, defendants failed to prevent a pattern and practice by its employees of intentional discrimination and harassment on the basis of age, medical leave, and/or other protected status and/or protected activity. 86. Plaintiff believes and on that basis alleges that his age, CFRA leave, good faith complaints, and/or other protected status and/or protected activity was a substantial motivating factor in defendants? employees? discrimination and retaliation against him. 87. As a proximate result of defendants? willful, knowing, and intentional miscon- duct, plaintiff has sustained and continues to sustain substantial losses of earnings and other employment bene?ts. 88. As a proximate result of defendants? willful, knowing, and intentional miscon- duct, plaintiff has suffered and continues to suffer humiliation, emotional distress, and physical and mental pain and anguish, all to his damage in a sum according to proof. 89.- Plaintiff has incurred and continues to incur legal expenses and attorneys? fees. Plaintiff is at present unaware of the precise amounts of these expenses and fees and will seek leave of court to amend this Complaint when the amounts are fully known. 90. .Defendants? misconduct was committed intentionally, in a malicious, fraudulent, oppressive manner, entitling plaintiff to punitive damages against defendant. -1 g- COMPLAINT OR DAMAGES SIXTH CAUSE OF ACTION Violations of Labor Code 1102.5, et Defendants LA Times, Inclusive of DOES 1 to 100 91. The allegations set forth in paragraphs 1 through 90 are re-alleged and incorpo- rated herein by reference. 92. At all relevant times, Labor Code section 1102.5 was in effect and was binding on defendants. This statute prohibits defendants from retaliating against any employee, including plaintiff, for raising complaints of illegality regarding the LA Times? refusal to properly account for the money from the Selden Ring Award. 93. While he worked for Defendants, Plaintiff raised complaints of illegal activity, including defendants? failure to account for and wrongful withholding of awards money, and defendants retaliated against him by discriminating against him, harassing him, and taking adverse employment actions, including demoting him and ignoring his good faith complaints, against 94. As a proximate result of defendants? willful, knowing, and intentional viola? tions of Labor Code section 1102.5, plaintiff has suffered and continues to suffer humili- ation, emotional distress, and mental and physical pain and anguish, all to his damage in a sum according to proof. 95. As a result of defendants? adverse employment actions against plaintiff, plaintiff has suffered general and special damages in sums according to proof. 96. Defendants? misconduct was done intentionally, in a malicious, fraudulent, oppressive manner, entitling plaintiff to punitive damages against defendants. A -19- COMPLAINT FOR DAMAGES 3-2} 28 SEVENTH CAUSE OF ACTION- Wrongful Constructive Termination in Violation of Public Policy in Violation of Labor Code 1102.5, FEHA, Cal. Govt. Code Sections 12900, et seq. Against Defendants LA Times, Inclusive of DOES 1 to 100 97. The allegations set forth in paragraphs 1 through 96 are re-alleged and incorpo- rated herein by reference. 98. Defendants constructively terminated plaintiff?s employment in violation of various fundamental public policies underlying both state and federal laws. Speci?cally, plaintiff was constructively terminated in-part because of plaintiff?s protected status age, CFRA leave, and/or good faith complaints), and for engaging in protected activities. These actions were in violation of FEHA and the California Constitution and California Labor Code 1102.5. 99. As a proximate result of defendants? wrongful termination of plaintiff 3 employment in violation of fundamental public policies, plaintiff has suffered and continues to suffer humiliation, emotional distress, and mental and physical pain and anguish, all to his damage in a sum according to proof. 100. As a result of defendants? wrongful termination of plaintiff?s employment, plaintiff has suffered general and special damages in sums according to proof. 101. Defendants? wrongful termination of plaintiff?s employment was done intentionally, in a malicious, oppressive, fraudulent manner, entitling plaintiff to punitive damages. 102. Plaintiff has incurred and continues to incur legal expenses and attorneys? fees. Pursuant to Code of Civil Procedure sections 1021.5 and 1032, let seq., plaintiff is entitied to recover reasonable attorneys? fees and costs in an amount according to proof. -20- PLAINTIFF COMPLAINT FOR DAMAGES EIGHTH CAUSE OF ACTION Violation of FEHA, Cal. Govt. Code Sections 12900, et seq. Failure to Promote Because of Discrimination on the Bases of Age, CFRA Leave?Against Defendants LA Times, Inclusive of DOES 1 to 100 103. The allegations set forth in paragraphs 1 through 102 are re-alleged and incorporated herein by reference. 104. At all times herein mentioned, FEHA, California Government Code section 12900, et. seq., was in full force and effect'and was binding on defendants. These statutes require defendants to refrain from discriminating against any employee on the basis of age and CFRA leave, among other things. Prior to ?ling the instant Complaint, plaintiff ?led a timely administrative charge with the DFEH and received a right-to-sue notice. 105. After eighteen years of dedicated and exemplary service to defendants, including receiving numerous accolades as a journalist and speci?cally for his work on the City of Bell stories, defendants demoted plaintiff, refusing to give him assignments that corresponded to his level of experience and instead giving him assignments ?tting someone with little experience or someone at the beginning of his or her career. All this happened despite plaintiffs receiving praise from journalists and supervisors for his performance as a journalist while with defendants and plaintiff receiving various accolades for his journalistic work. 106. During the course of plaintiffs employment, defendants and their supervisors intentionally engaged in actions that resulted in plaintiff being treated less favorably because of age, CFRA leave, and/or good faith complaints. Speci?cally, defendant refused to promote plaintiff because he is over 40, took a leave of absence for his medical condition of cancer, and made good faith complaints to defendants. Defendants and their supervisors took these actions intentionally. During the course of plaintiffs employment, defendants and their supervisors also engaged in employment practices that -21- PLAINTIFF COMPLAINT FOR DAMAGES unfavorable impact on employees who were older. 107. Plaintiff believes and on that basis alleges that his age, medical leave, and/or good faith complaints were factors in defendants? failure to promote him. 108. As a proximate result of defendants? willful, knowing and intentional misconduct, plaintiff has sustained and continues to sustain substantial losses of earnings and other employment bene?ts. 109. As a proximate result of defendants? willful, knowing and intentional misconduct, plaintiff has suffered and continues to suffer humiliation, emotional distress, and mental and physical pain and anguish, all to his damage in a sum according to proof. 110. Defendants? misconduct was committed intentionally, in a malicious, fraudulent, oppressive manner, entitling plaintiff to punitive damages. 111. Plaintiff has incurred and continues to incur legal expenses and attorneys? fees in a sum according to proof. NINTH CAUSE OF ACTION Negligent Supervision?Defendant LA Times, Inclusive of Does 1 through 100 112. The allegations set forth in paragraphs 1 through 111 are re-alleged and incorporated herein by reference. . 113. At all times herein mention, defendants had a duty to supervise its employees in a non-fraudulent, non-negligent, non-harassing manner. 114. Defendants breached that duty in supervising Maharaj. 115. As a result of defendants? breach, plaintiff has been damaged in a sum accord- ing to proof. .22. PLAINTIFF COMPLAINT FOR DAMAGES 5:13.34 as 7 8 TENTH CAUSE OF ACTION Negligent Retention?Against Defendants LA Times, Inclusive of DOES 1 to 100 116. The allegations set forth in paragraphs 1 through 115 are re-alleged and incorporated herein by reference. 117. At all times herein mention, defendants had a duty not to retain any supervisor, including defendant Davan Maharaj, who was incapable of properly supervising employees, but who instead would berate, harass, and retaliate against plaintiff. 118. Defendants breached that duty in retaining defendant Davan Maharaj. 119. As a result of defendants? breach, plaintiff has been damaged in a sum accord- ing to proof. ELEVENTH CAUSE OF ACTION Intentional In?iction of Emotional DistresswAgainst All Defendants, Inclusive of DOES 1 to 100 120. The allegations set forth in paragraphs 1 through 119 are re-alleged and incorporated herein by reference. . 121. Defendants? discriminatory, harassing, and retaliatory actions against plaintiff constituted severe and outrageous misconduct and caused plaintiff extreme emotional distress. 122. Defendants were aware that treating plaintiff in the manner alleged above, including depriving Plaintiff of livelihood would devastate plaintiff and cause plaintiff extreme hardship. 123. As a proximate result of Defendants? extreme and outrageous conduct, plaintiff has suffered and continues to suffer severe emotional distress. Plaintiff has sustained and continues to sustain substantial losses of earnings and other employment bene?ts as a result of being emotionally distressed. 124. As a proximate result of Defendants? extreme and outrageous conduct, plaintiff -23- . COMPLAINT FOR DAMAGES "1.133., in; liwiegllg61has suffered and continues to suffer humiliation, emotional distress, and mental and physical pain and anguish, all to his damage in a sum according to proof. 125. Defendants? misconduct was done intentionally, in a malicious, fraudulent, op~ pressive manner, entitling plaintiff to punitive damages. TWELFTH CAUSE OF ACTION Violation of Labor Code Section 432; 1198.5; and 226(b) and (c)?Against Defendants LA Times, Inclusive of DOES 1 to 100 126. The allegations set forth in paragraphs 1 through 125 are re-alleged and incor- porated herein by reference. 127. At all relevant times, Labor Code section 432 provided that, ?If an employee or applicant signs any instrument relating to the obtaining or holding of employment, he shall be given a copy of the instrument upon request.? 128. At all relevant times, Labor Code section. 1198.5 provided that every California employee has a right to inspect the personnel ?le an employer maintains for him or her. This requirement applies to records related to an employee?s performance and to any grievance concerning the employee, including any reason an employee?s employment has been terminated. 129. At all relevant times, Labor Code section 226(b) provided that an employer shall afford current and former employees the right to inspect or copy records pertaining to their employment, upon reasonable request to the employer. 130. At all relevant times, Labor Code section 226(0) provided that an employer who receives a written or oral request to inspect or copy records pursuant to subdivision pertaining to a current or former employee shall comply with the request as soon as practicable, but no later than 21 calendar days from the date of the request. 131. On three separate occasions December 1, 2015, February 2, 2016, and April 15, 2016 Plaintiff made requests for his complete personnel ?le from Defendants. -24- PLAINTIFF COMPLAINT FOR DAMAGES 10Despite repeated requests by Plaintiff, Defendants have not provided the requested ?le to Plaintiff. 132. As a result, Plaintiff seeks damages, attomeys? fees, and costs for having to re- sort to legal action to obtain compliance with these laws. WHEREFORE, plaintiff, Jeffrey Gottlieb, prays for judgment against defendants as follows: 1. For general and special damages according to proof; For exemplary damages according to proof; For pre-judgment and post-judgment interest on all damages awarded; For declaratory relief; For reasonable attorneys? fees; For costs of suit incurred; ?asheer For such other and further relief as the Court may deem just and proper. ADDITIONALLY, plaintiff, Jeffrey Gottlieb, demands trial of this matter by jury. The amount demanded exceeds $25,000.00 (Government Code 72055). Dated: August 9, 2016 SHEGERIAN ASSOCIATES, INC. Attorne for Plaintiff, JEFF GOTTLIEB -25- COMPLAINT FOR DAMAGES ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number. and address): ATTORNEY FOR (Name): Plaintiff, Jeffrey Gottlieb FOR COURT USE ONLY Carnev R. Esq. (SBN 150461) Shegerian Associates. Inc. 225 Santa Monica Boulevard, Suite 700. Santa Monica. CA 90401 TELEPHONE N0: (3 01860-0770 1 FAX N0: 01860-0771 SUPERIOR COURT OF CALIFORNIA. COUNTY I no A naeleq Court Of Gamma ?Sgii?r?iiv of L05 We? STREET ADDRESS 111 North Hill Street MAILING 111 North Hill Street CITY AND ZIP CODE. . Los Angeles AUG 09 2015 . - - . - .lClerk . - uiive 0009? - BRANCH NAME: Stanlev Mosk Courthouse 3 She" 8' Qat ner', CASE NAMECristina Oriiai a A Gottlieb v.'Los Angeles Times at. al. - Unlimited :]Limited CIVIL CASE COVER SHEET. Complex Case Designation CASE NUMBER: Counteri- i:i JOinder (Amount (Amount _7 . demanded - demanded is 7 Filed with ?rst appearance by defendant exceeds $25,000) $25,000 or less) (Cal. Rules ofCourt. rule 3.402) DEPT: Items 1?6 below must be completed (see instructions on page 2). . Check one box below for the case type that best describes this case: Auto Tort Auto (22) Uninsured motorist (46) Other'PiiPoer (Personal injuryiProperty DamagelWrongful Death) Tort Asbestos (04) Product liability (24) Medical malpractice (45) Other PIIPDIWD (23) condemnation (.14) (Other) Tort Wrongful eviction (33) Business tort/unfair business practice (07) '3 Civil rights (08) Unlav?vful Detainer Defamation (13) 3 Commercial (31) Fraud (16) Residential (32) Intellectual property (19) El Drugs (38) Professional negligence (25) Judicial Review Other tort (35) Asset forfeiture (05) oyment Petition re: arbitration award (11) Wrongful termination (36) Writ of mandate (02) El Other employment (15) :1 Other judicial review (39) Contract I Breach of contracttwarranty (06) Rule 3.740 collections (09) Other collections (09) Insurance coverage (18) Other contract (37) Real Property Eminent Provisionally Complex Civil Litigation (Cal. Rules of Court, rules 3.400-3.403) i:i regulation (03) (Constniction defect (10) Mass tort (40) Securities litigation (28) Environmentaer oxic tort (30) Insurance coverage claims arising from the above listed provisionally complex case types (41) Enforcement of Judgment Enforcement of judgment (20) Donna Miscellaneous Civil Complaint i:i RICO (27) Other complaint (not speci?ed above) (42) Miscellaneous Civil Petition Partnership and corporate governance (21) '3 Other petition (not speci?ed above) (43) 5 Ogre: August 9. 2016 C-?rnev R. Escr. This case I: is [El is not complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the factors requiring exceptional judicial management: a. l: Large number of separately represented parties b. Extensive motion practice raising dif?cult or novel issues that will be time-consuming to resolve c. i: Substantial amount of documentary evidence d. Large number of witnesses e. Coordination with related actions pending in one or more courts in other counties, states, or countries, or in a federal court f. Substantial postjudgmentjudicial supervision Remedies sought (check all that apply): am monetary OEI nonmonetary; declaratory or injunctive relief Number Of causes 0f action (8960M: Twelve 12) causes of action This case i: is i] is not a class action suit. if there are any known related cases, ?le and serve a notice of related case. (Y c. 13 punitive ay use for - (TYPE OR PRINT NAME) OF PARTY OR ii .?rr i-i 0 Unless this is a collections case under rule 3.740 or a com olex case. this cover sheet will be used for statistical purposes only. 1 age NOTICE Plaintiff must ?le this cover sheet with the ?rst paper ?led in the action or proceeding (except small claims cases or cases ?led under the Probate Code, Family Code. or Welfare and institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result in sanctions. File this cover sheet in addition to any cover sheet required by local court rule. If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all other parties to the action or proceeding. 012 Form Adopted tor Mandatory Use Judicial Council of Califomia CM-010 (Rev. July 1. 2007] CIVIL CASE COVER SHEET - Cal. Rules of Court. rules 2.30, 3.220. 3.400?3.403. 3.740; Cal. Standards otJudicial Administration. std. 3.10 SHORT TITLE: Gottlieb v. Los Angeles Times et. al. CASE NUMBER BC630018 CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) This form is required pursuant to Local Rule 2.0 in all new civil case filings in the Los Angeles Superior Court. Item I. Check; the types of hearing and ?ll in the estimated length of hearing expected for this case: . JURY YES CLASS '1 YES LIMITED EYES TIME ESTIMATED FOR TRIAL DAYS Item ll. Indicate the correct district and courthouse'location (4 steps If you checked ?Limited Case", skip to Item Ill, Pg. 4): Step 1: After ?rst completing the Civil Case Cover Sheet form. find the main Civil Case Cover Sheet heading for your case in the left margin below. and. to the right in Colen A, the Civil Case Cover Sheet case type you selected. Step 2: Check 9113, Superior Court type of action in Column below which best describes the nature of this case. Step 3: In Column C, circle the reason for the court. location choice that applies to the type of action you have - checked. For any exception to the court location, see Local Rule 2.0. Step 4: Fill in the information requested on page 4 in Item complete Item IV. Sign the declaration. Auto Tort Other Personal Injury! Property Damage! Wrongful Death Tort Applicable Reasons for Choosing Courthouse Location (see Column below) . Class actions must be ?led in the Stanley Mosk Courthouse. central district. . May be ?led in central (other county. or no bodily damage). . Location where cause of action arose. . Location where bodily injury. death or dama occurred. . Location where performance requnred or de endant resndes. Location of property or permanently garaged vehicle. Location wherein defendant/res ondent functions wholly. 6. 3. Location where petitioner resides. 93 10. Location of Labor Commissioner 0 Location where one or more of he ?iarties reside. ce . Civil GaseiCoverSheet?; TypegofAction: - 1' . jApplic'able Reasons} category. I - a ., See StepaAbove;=? Auto (22) El A7100 Motor Vehicle - Personal Injury/Property Damage/Wrongful Death 1.. 2.. 4. Uninsured Motorist (46) El A7110 Personal lnjuryIProperty Damage/Wrongful Death - Uninsured Motorist 1.. 2.. 4. El A6070 Asbestos Property Damage 2. Asbestos (04) El A7221 Asbestos- Personal Injury/Wrongful Death 2. Product Liability (24) El A7260 Product Liability (not asbestos or toxiclenvironmentalA7210 Medical Malpractice - Physicians Surgeons 1.. 4. Medical Malpractice (45) El A7240 Other Professional Health Care Malpractice 1.. 4. El A7250 Premises Liability slip and fall) Other . 1.. 4. personal Injury El A7230 Intentional Bodily Injury/Property DamageNVrongful Death 1" 4_ property Damage assault. vandalism. etc.) El A7270 Intentional ln?iction of Emotional Distress 1"3' El A7220 Other Personal DamagelWrongful Death 1"4? LACIV 109 (Rev. 013/11) LASC Approved 03-04 CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION Local Rule 2.0 Page 1 of4 SHORT TITLE: Gottlieb v. Los Aneeles Times ethal. CASE NUMBER Business Tort (07) El A6029 Other CommerciallBusiness Tort (notfraudlbreach ofcontract) 1g. 3. as - . gr? Civil Rights (08) A6005 Civil Rights/Discrimination 1..2..Defamation (13) El A6010 Defamation (slander/libel) 22.3. l: on 5 Fraud (16) El A6013 Fraud (no contractA6017 Legal Malpractice I g_ 9 Professional Negligence (25) I - a El A6050 Other Professional Malpractice (not medlcal or legal) 1., 2.. 3. a 3 Other (35) A6025 Other Non-Personal Injury/Property Damage tort 2.3. Wrongful Termination (36) A6037 Wrongful Termination 3. . 2 A6024 Other Employment Complaint Case 1.. 2.. 3. 2' Other Employment (15) - - A6109 Labor CommissionerAppeals 10. A6004 Breach of RentalILease Contract (not unlawful detainerorwrongful 2 5 eviction) Breach of Contract! Warren (06) A6008 ContractIWarranty Breach -Seller Plaintiff(no fraudlnegligence) 2"5' insurance) El A6019 Negligent Breach of Contract/Warranty (no fraud) 1"2"5' Ct A6028 Other Breach of Contract/Warranty (not fraud or negligenceA6002 CollectlonsCase-SellerPlalntl? 2.. 5.. 6. 33 Collections (09) 8 El A6012 Other Promissory NoteICollections Case 2.5. insurance Coverage (18) El A6015 Insurance Coverage (notcomplex) 1., 2.. 5., 8. El A6009 Contractual Fraud 1..2.. 3.. 5. OtherContract (37) CI A6031 Tortious Interference 1,2. 3., 5. A6027 Other Contract Dispute(not 1.. 2.. 3., 8. EninentDomainlinverse . . - . Condemnation (14) A7300 EmlnentDomalnICondemnatlon Number of parcels 2. r? a Wrongful Eviction (33) El A6023 Wrongful Eviction Case 2..6. 2 n. 3 El A6018 Mortgage Foreclosure 2.6. '1 Other Real Property (26) A6032 Quiet Tltle El A6060 Other Real Property (not eminent domain, landlord/tenant. foreclosure) 2.6. un'awm'Detig'?r'commerc'al El A6021 Unlawful Detainer-Commercial (notdrugs orwrongful evictionA6020 Unlawful Detainer?Resldentlal (not drugs orwrongful ewctlon) 2.. 6. Unlawful Detainen . Post_Foreclosure(34) A6020FUnlawful Detalner Post Foreclosure gill: Unlawful Detainer-Drugs (38) El A6022 UnlawfuiDetainer?Drugs 2., 6. LACIV109 (Rev. (13/11) CIVIL CASE COVER SHEET ADDENDUM Local Rule52.0 LASC Approved 03-04 AND STATEMENT OF LOCATION Page 2 6M SHORT TITLE: Gottlieb v. Los Angeles Times et. at. CASE NUMBER - ?Applica?blei?e?a Asset Forfeiture (05) 1:1 A6100 Asset Forfeiture Case 2.. 6. Petition re Arbitration (11) . El A6115 Petition to CompellCon?rmNacate Arbitration 2.5 '5 . . . A6151 Writ-Administrative Mandamus 2.. 8. a I. - 7 2'2" Writ of Mandate (02) A6152 Writ-Mandamus?on Limited Court Case Matter A6153 writ-OtherLimited Court Case Review 2. OherJudiciaIReview (39) El A6150 OtherWrit/JudicialRevieW 2..8. Antitrust/T rade Regulation (03) El A6003 Antitrust/Trade Regulation I 1..2..8. 1; In 3 Construction Defect (10) CI A6007 Construction Defect 1.. 2.. 3. .3 . . C'a?ms'mmg'gf Mess TM :1 A6006 Claims Involving Mass Tort 1.. 2.. 8. Securities Litigation (28) El A6035 Securities Litigation Case 1..2.. 8. rt a oxnc 0 . . Environmental (30) El A6036 Toxrc To?rUEnVIronmental 1.. 2..3..8. . - . Insurance Coverage Claims . IL hm Co mplex Case (41) A6014 Insurance Coverage/Subrogatlon (complex case only) 1..2..5..8. A6141 Sister State Judgment 2.. 9. A6160 Abstract of Judgment - 2.6. 5 Enforcement El A6107 Confession of Judgment (non-domestic relations) 2.. 9. 3 OfJUdgme"t(20) El A6140 Administrative Agency Award (not unpaid taxes) 2.. 8. IE '75 El A6114 Petition/Certi?cate for Entry ofJudgment on Unpaid Tax 2..8. A6112 Other Judgment Case 2.. 8., 9. RICO (27) El A6033 Racketeeri'ng (RICO) Case 1..2..8 3 .E El A6030 Declaratory Relief Only 1.. 2.. 3. 8 Othercomplaints El A6040 Injunctive Relief Only (not domesticlharassment) 2.. 6. 52-9 (N?tspe?'?ed Aboveu?) El A6011 OtherCorrmercial Complaint Case (non-tortinon-complex) 1.. 2..8. A6000 OtherCivil Complaint (non-torUnon-complex) ma Partnership Corporation . Governance (21) El A6113 Partnership and Corporate Governance Case 2.. 8. A6121 Civil Harassment 2.. 3.. 9. (D El A6123 Workptace Harassment 2.. 3.. 9. ?3 El A6124 EIderlDependent Adult Abuse Case 2.. 3.. 9. ?73 o. Other Petitions (Not Specified Above) 1:1 A6190 Election Contest 2. 43 A 13 A6110 Petition forChange ofName 2.. 7. If A6170 Petition forRelieffrom Late Claim Law 2.3.4.8. 1:1 A6100 OtherCiviIF?etition 2..9- '23" LACIV 109 (Rev. 03111) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.0 LASC Approved 03-04 AND STATEMENT OF LOCATION Page 3 of4 GottIieb v. Los Angeles Times et. a1. Item Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or other circumstance indicated in Item Ii., Step 3 on Page 1, as the proper reasonfor?ling in the court location you selected. - . . - . ADDRESS: - - - REASON: Check the appropriate boxes for the numbers shown I under Column for the type of action that you. have selected _for 20-2 West.13t Street thiscaseE11. CITY: 3 STATE: ZIRCODE: Los Angeles CA 9002 Item IV. Declaration of Assignment. I declare under penalty of perjury under the lei/vs of the State of California that the foregoing is true and correct and that the above-entitled matter is properly ?led for assignment to the Stanley Mosk courthouse in the Central District of the Superior Court of California. County of Los Angeles [Code Civ. Pros, 392 et seq., and Local Rule 2.0. subds. and (all. . . . . Dated: August 9, 2016 . (SIGNATURE PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY I COMMENCE YOUR NEW COURT CASE: 1 1. Original Complaint or Petition. I 2 If ?ling a Complaint, a completed Summons form for issuance by the Clerk. 3. Civil Case Cover Sheet, Judicial Council form ClVl-010. 4 Civil Case Cover Sheet Addendum and Statement of Location form, 109, LASC Approved 03-04 (Rev. 03/11). 9" Payment in full of the ?ling fee, unless fees have been waived. 6. A signed order appointing the Guardian ad Litem. Judicial Council form 0, if the plaintiff or petitioner is a minor under 18 years of age will be required by Court in order to issue a summons. 7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum must be served along with the summons and complaint, or other initiating pleading in the case. .d . - SHORT TITLE: CASE NUMBER I I I I LACIV 109 (Rev. 06/11) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.0 LASC Approved 03-04 AND STATEMENT OF LOCATION - Page 4 of 4