Daniel Feder (SBN 130867)
LAW OFFICES OF DANIEL FEDER
332 Pine Street, Suite 700
San Francisco, CA 94104
Telephone: (415) 391—9476
Facsimile: (415) 391 -9432
Daniel dfederlawcom

FILED
SAN MATEO COUNTY
"5

Attorneys for Plaintiff
Arne Wilberg

2018

'

SUPERIOR COURT IN AND FOR THE STATE OF CALIFORNIA

COUNTY OF SAN MATEO
10
11

18C1V00443

ARNE WILBERG

12

CASE NO.:

PLAIN TIFF’S FIRST COMPLAINT FOR
DAMAGES FOR:

Plaintiff,

13

V.

GOOGLE, INC. and DOES
16

DiScrimination in Violation of California
Government Code § 12940 et seq. (Sex)
2. Discrimination in Violation of California
Government Code § 12940 et seq. (Race)
Failure to Take Reasonable Steps to
Prevent Discrimination and Retaliation
from Occurring in Violation of California
Government Code §‘ 12940 et seq.
Retaliation in Violation of Government
Code 12940 et seq. for Complaining
About Discriminatory Hiring Practices
Retaliation in Violation of Government
Code Section 12940 Based on Race and
1.

14
15

BY FAx

1

THROUGH 25,

INCLUSIVE,

-

Defendants.

17
18

19
20
21

Gender

22

Wrongful Termination in Violation of
Public Policy [California Labor Code

23

18—clV—00442

‘

—D.

CMP
.

Complaint

24

947996

Section

1

102.

Violation of Business and Professions
Code

§

17200

Violations of the Unruh Act

25
\

26
27
28'

Wilberg v. Google

1111111111111111J

DEMAND FOR JURY TRIAL
DEMAND FOR PUNITIVE DAMAGES

 Plaintiff ARNE WILBERG alleges

as

follows:

PARTIES
1.

At all times relevant hereto, Plaintiff ARNE WILBERG (“Plaintiff’ or “Wilberg was

employed as a recruiter by Defendant Google, Inc. (“Defendant”, “Google” or “YouTube”. Plaintiff

worked at Defendant’s facilities in San Bruno, California.
2.

Defendant Google is a Delaware corporation with its principal place of business in
_

California. In addition to the Defendant named above, Plaintiff sues ﬁctitiously Defendants DOES

1

\OOO\]O\

through 25, inclusive, because their names, capacities, status, or facts showing them to be liable are

not presently known. Plaintiff is informed and believes, and thereon alleges, that each

of the

10

ﬁctitiously named Defendants is responsible in some manner for the occurrences herein alleged, and

11

such Defendants proximately caused Plaintiffs’ damages as herein alleged.

12

complaint to show their true names and capacities, together with appropriate charging language, when

13

such information has been ascertained.
3.

14

Plaintiff is informed and believes,

Plaintiff will amend this

and thereon alleges, that Defendant, and/or DOES 1-25,

of them, was always relevant herein the agent,

servant, employee, and/or representative

of

15

and each

16

each

17

within the course and scope of such agency, service, employment and/or representation. Plaintiff is

18

further informed and believes and thereon alleges that Defendant,.and/or DOES

19

them, are the employers

20

Plaintiff, and therefore Defendant, and/or DOES

21

responsible and liable to Plaintiffs for the damages hereinafter alleged.

of the other Defendants,

and in doing the acts and things alleged in this complaint was acting

of the managers and supervisors herein complained of,
and each

of them,

and each

and supervising over

are jointly and severally

4.

Plaintiff brings this action pursuant to and under the provisions of the Fair Employment and

24

Housing Act, California Government Code §§ 12900, et seq. (hereinafter referred to

as

FEHA);

25

California Constitution, Article I, §1; and other common and statutory laws,

as

various

26

provisions of the California Labor Code.

27

of

JURISDICTION & VENUE

22
23

1—25,

1—25,

5.

Plaintiff was considered

28

Wilberg v. Google

an

as

well

“employee” within the meaning of Fair Employment Housing

 Act (hereinafter referred to
each

“FEHA”). Plaintiff is informed

as

of the Defendants were always relevant hereto

an

and believes and thereupon alleges that

“employer”

as

deﬁned by FEHA.

6.

The amount in controversy exceeds the minimum jurisdictional threshold of this Court.

7.

At all times relevant herein, Defendant and/or DOES

(5) or more employees for each working day in each

1-25, and each

of them, employed ﬁve

of tiNenty or more calendar weeks in the current

'or preceding calendar year and is otherwise subject to the provisions

of FEHA and other applicable

laws.
\OOO\IO\

8.

Venue is proper in this Court because the certain

Cal. Gov. Code

§

12

acts in violation

of

12940 et seq. occurred in San Mateo County.

EXHAUSTION OF ADMINISTRATIVE REMEDIES

10
11

of the alleged unlawful

9.

Plaintiff ﬁled a timely charge of discrimination with the California Department of Fair

Employment and Housing (DFEH). The DFEH issued

a Right—To-Sue

notice in December of 2017.

I

GENERAL FACTUAL ALLEGATIONS

13

14

10.

Plaintiff Arne Wilberg (“Wilberg” or “Plaintiff’) was employed by Defendant Google, Inc.,

of YouTube (“Google” or “YouTube”) as Recruiter for the YouTube Tech

15

the parent company

16

Stafﬁng Management Team for 7 years

17

and two additional years as a contractor onsite at Google before becoming a Google employee. In

18

this capacity, he was responsible for identifying qualiﬁed candidates for engineering and technology

19

positions and recruiting them for positions in technology jobs at Google/YouTube. Plaintiff was an

20

exemplary employee and received positive performance evaluations until he began opposing illegal

21

hiring and recruiting practices at Google.

22

as a

recruiter for Google, including his last 4 years at YouTube

11. For the past several years, Google has had and implemented clear and irrefutable policies,

of systematically discriminating in

23

memorialized in writing and consistently implemented in practice,

24

favor job applicants who are Hispanic, African American, or female, and against Caucasian and Asian

25

men. These policies were reﬂected in multiple bulletins, memorandum, charts, and other documents

26

prepared by Google’s highest-level managers, and approved by Google’s C-level ofﬁcers and

27

directors. The stated purpose of these policies was to achieve “Diversity” in the Google workforce,

28

Wilberg v. Google

 and to manage public relations problems arising from the underrepresentation

of women

and certain

minority groups in the Google workforce, particularly in engineering positions.
12.

For example, Google policy documents state that, for Q3 of 2017, YouTube recruiters,

including Plaintiff, would hire only individuals who were “diverse.” The policy document states:

“Beginning of Q3——we hire for 2018—all diverse.” Further, Google used Weekly Recaps to track the
number

of hires who were “Female,” “Black”,

and

“WeeklyRecap” reﬂected that Google had hired

“LatinX.” For the ﬁrst quarter of 2017, Google’s

14 females

(with

of 82), 1 Black (with a goal

a goal

,

of 21) and 5 LatinX (with a goal of 13). A true and correct copy of one of Google’s “Weekly Recap”
of Diversity Hiring, for the week of 3/20/17

is attached hereto as Exhibit

1

and made a part hereof. To

10

execute is “Diversity” hiring program objectives, Google would carefully track the race and gender

11

each applicant

12

of the candidates

13

candidates and applicants to reject. In March

14

Management Team, Allison Alogna, wrote an e-mail to the stafﬁng team in which she writes,

15

Team: Please continue with L3 candidates in process and only accept new L3 candidates that are from

16

historically underrepresented groups.” A true and correct copy of Alogna’s e-mail dated March

17

2017 is attached hereto as Exhibit 2. For several duarters, Google would not extend an offer

18

employment for any applicants for technical positions who were not “diverse,” which Google deﬁned

19

as

20

4 Software Engineers. However, YouTube recruiters were given permission to hire Level 3 and Level

21

4 Software Engineers,

22

for a position in its technology workforce and use these characteristics to choose which
and applicants for technology positions to make offers

of employment,

and which

of 2017, the manager of YouTube’s Tech Stafﬁng

Women, Blacks and LatinX. Google had a policy that recruiters were not to hire Level

13.

of

“Hi

1,

of

3 and

Level

if they were diversity hires.

In April of 2017, Google’s Technology Stafﬁng Management team was instructed by Alogna
(0-5 years experience) software engineering interviews with every

23

to immediately cancel all Level

24‘

single applicant who was not either female, Black or Hispanic, and to purge entirely any applications

25

by non-diverse employees from the hiring pipeline. Plaintiff refused to comply with this request.

26

27

3

14. As described in detail below,

Plaintiff repeatedly opposed these illegal and discriminatory

hiring practices by complaining ‘to his managers and HR. He repeatedly told them that it was illegal to

28

Wilberg v. Google

 F“\

,

have such hiring quotas favoring certain groups based on race and gender, that

it violated state and

federal law, and that Google must immediately cease and desist from engaging, in such illegal hiring
practices. In response to Plaintiff’ 5 complaints, Google on occasion would circulate e-mails

instructing its employees pUrge any and all references to the race/ gender quotas from its e-mail

.

database in a transparent effort to wipe out any paper trail

of Google’s illegal practices. Google

ON

repeatedly retaliated against Plaintiff for opposing Google’s illegal hiring practices by subjecting him

\1

to unsubstantiated performance reviews, performance criticisms and terminating his employment in

00

November

i

15.

\O

of 2017.

In approximately December of 2015, Plaintiffs Supervisor, Terry O’Conner (0"Conner”)

'

10

emailed the entire Youtube Tech Stafﬁng team (alias - recruitytswes@google.com), to tell the entire

11

team that the goal for Q1 2016 was

1.2

SWE candidates which means they must be black, Hispanic or women. Google internally and

13

externally states that is does not make any hiring decisions based upon race ethnicity or gender.

14

Wilberg believed Google’s policy on non-discriminatory hiring practices was not followed on the

15

YouTube tech stafﬁng team. Based upon this belief that O’Conner was. asking recruiters to

16

discriminate against men and non-minority applicants, Plaintiff believed that pressure was exerted by

17

management on Wilberg and other recruiters, including only giving recruiters credit against the

18

recruiters’ hiring goals they hired Woman, Black or Hispanic applicants (Google’s deﬁnition of

19

diversity). Wilberg felt uncomfortable reporting to O’Conner as her disregard for following important

20

hiring policies put Google at signiﬁcant risk and made recruiters vulnerable for ﬁring or legal action

21

by following management discriminatory hiring goals. In addition, O’Conner yelled at recruiters in

22

.

SWE hires per recruiter and all

of the hires had to be diverse

meetings and made people on the team feel completely uncomfortable and psychologically unsafe

reporting to her.

23

24‘

5

.

16.

In approximately, January of 2016, Wilberg and 3 additional YouTube Google recruiters

25

agreed to escalate their complaints about O’Conner to her manager Lisa Pisacane (“Pisacane”), the

26

YouTube Stafﬁng Manager. The four recruiters previously referenced spoke with- Pisacane to let her

27

know that O’Conner was a micromanager that made almost everyone feel uncomfortable on the team,

28

Wilberg v. Google

 and that they had signiﬁcantissues

with O’Conner’s management. Two other YouTube technical

team recruiters were not invited .to the meeting with O’Conner because the recruiters had spoken with

-

Pisacane

with respect to their complaints about O’Conner resulting in one recruiter’s work being taken

away from her.
17.

In retaliation for complaining about O’Conner,

a co—worker was

given a poor performance

review and had her level reduced from a L6 recruiter to an L5 recruiter in’ what was perceived as.

'O\

\l

‘

retaliation for complaining to about O’Conner. In addition, two recruiters both transferred

O’Conner’s Team, the YouTube Tech Recruiting team, based on the fact that one

00

‘

off of

of the recruiters was

uncomfortable reporting to O’Conner. Additionally, another co-worker was unhappy about and felt

\D

of hiring 5

10

uncomfortable with being given a goal

11

team complaints about O’Conner’s management style and the “diversity hiring” policies, and told the

1’2

team that she ‘would get back them with follow up feedback about the concerns.
18.

13

diverse hires for Q1 2016. Pisacane listened to the

In approximately early January of 2016, members of the You Tube recruiting team escalated

14

their concerns about hiring practices to their overall function boss, who was the Director of Google

15

Stafﬁng Services. Google Stafﬁng Services is the team that oversees recruiting support functions such
'

as

16
‘

managing recruiting coordinators who schedule interviews. The Recruiting Coordinators for

17

YouTube lodged a complaint about Diversity hiring practices at YouTube that made them

18

uncomfortable. The coordinators complained about the way the O’Conner and Lisa Pisacane spoke

19

about black candidates as the team needed to hire more blacks. One team member complained that

2.0

managers were speaking about Blacks like they were objects. Managers asked coordinators to have 2

21

black Google/YouTube engineers as interviewers on each interview panel for black candidates, or 2

22

Hispanic engineer interviewers on each panel for Hispanic candidates or 2 female interviewers on each

23

panel for female candidates. This interview panel policy for diversity candidates at YouTube was

24

called Project Mirror.

25

which was comprised of recruiting managers at YouTube and YouTube engineering managers who

26

were to review close call diversity candidates who didn’t meet the hiring bar to try to ﬁnd them homes

27

and

At the same time, O’COnner and Pisacane, ran a diversity steering committee

ﬁnd manager support to make the diversity hire. This Youtube Policy contradicted Google’s

28

Wilberg v. Google

‘

 policy around

a

non-speciﬁc, non-separate and general process for hiring. The Stafﬁng Director

ﬂagged the complaints
19.

of her team members around diversity hiring concerns to HR.

In January of 2016, Wilberg reached out to the Stafﬁng Director over instant message and

asked to have a meeting about YouTube hiring practices. Wilberg let the Staffing Director know that
V

many employees on the hiring team were uncomfortable with YouTube’s “Diversity Hiring Practices”
because they believed these policies were discriminatory. Wilberg described another recruiter’s

feedback around this “diversity” hiring program where the other recruiter told other recruiters that she
©00\]O\

felt the way the team talked about black people in team meetings was like we were talking about black
slaves as slave traders on a ship. The other recruiter asked Wilberg to speak with HRBP about this
10

issue and Wilberg participated in the investigation. The Stafﬁng Director aid she would ﬂag this issue

ll

to the VP

12

HRBP (Human Resources Business Partner).

13

of Google People

Services, who oversees HR and that she would speak with Wilberg’s

20. In' approximately January

of 2016, a black engineer named S.N. (initials) reported to her

14

manager that she was only being asked to interview only black SWE candidates'and this made her feel

15

uncomfortable. SN. and her manager escalated their complaints to HR. As a result

16

complaints, Google deleted the Youtube Candidate Tracker for the Youtube Diversity Steering

17

Committee from the Google Drive. Further O’Conner and others deleted all\emails around diversity

18

hiring goals from the YouTube Technical Stafﬁng Team’s Gmail inboxes. Pisacane conﬁrmed to

19

Wilberg in

20

Pisacane also told the entire YouTube recruiting team in a team meeting thatI-[R was involved in an

21

investigation of YouTube hiring practices and the team had to change its specialized diversity hiring

22

process. Pisacane told Wilberg that these changes were only temporary and told him that YouTube

23

would soon continue with the quota-based hiring practices. Pisacane told Wilberg not to share outside

a

of S.N.’s

meeting that there that the team was asked to “clean up” its diversity hiring practices.

24. of the core recruiting team what the team was doing, such as sharing with Recruiting Coordinators.
25

21. In January

of 2016, recruiters

at Google were asked. to

of 2016: the manager feedback survey results were released, and O’Conner

26

feedback. In February

27

scored —30% satisfaction that is exceptionally low. In February

28

Wilberg v. Google

ﬁll out a survey that included manager

of 2016, Wilberg had a follow up

 conversation with Pisacane. Pisacane told Wilberg that she had [decided she would not make any
changes in replacing O’Conner as the team manager. In February

of 2016, Wilberg spoke with the

Google Technical Stafﬁng Director to let him know that Wilberg wanted to change teams. The

Technical Stafﬁng Director asked Wilberg why and Wilberg told him that O’Conner made him
ﬂaw-AWN

uncomfortable. The Technical Stafﬁng Director recommended staying put for now and that HR was
I

looking into the situation.
22. In February

of 201 6, Wilberg told a few coworkers

about speaking with the Technical

Stafﬁng Director. One of these co-workers spoke with Pisacane about Wilberg’s complaints.
Pisacane immediately asked Wilberg to a meeting where she demanded to know what Wilberg had

if she could trust him any longer

10

told Pisacane’s manager. Pisacane told Wilberg that she wasn’t sure

11

in that meeting for going above her head. Wilberg told Pisacane in this meeting the environment was

12

toxic on the team.

13'

23. Pisacane told O’Conner that Wilberg had escalated his concerns about O’Conner to the

result, O’Conner retaliated against Wilberg by not speaking with

14

TechnicalStafﬁng Director. As

15

him and by cancelling all weekly one—on-one meetings. Wilberg told Pisacane that O’Conner was

16

retaliating against Wilberg. In response, Pisacane told Wilberg, “what do you expect, you complained

17

to the director about O’Conner.” Pisacane failed to take any corrective steps to

18

environment or to address any

a

ﬁx the toxic work

of the complaints that Wilberg had made about Google/YouTube’s
I

19

discriminatory hiring practices.
‘

20

24. In February

.

of 2016, Wilberg spoke with HRBP A.L. (initials) at Google. HR met separately

21

with every full-time member of the YouTube Stafﬁng team. At the beginning of the meeting A.L. said

22

she was there to help Pisacane and

23

questions about Wilberg’s experiences working with O’Conner.

24

25. In March or'April

O’Conner through this situation and then proceeded to ask

of 2016, A.L. followed up with Wilberg and conveyed to him that all

of the YT recruiting team felt the same about O’Conner. In approximately March or April

25

members

26

2016, Wilberg began seeing an onsite mental health counselor for mental stress.

27

26. In

April of 2016, Wilberg received poor performance review for QTR4-2015

28

Wilberg v. Google

and

QTRl-

 2016 from O’Conner in retaliation for his complaints to stafﬁng leadership and to HR regarding

.

discriminatory hiring practices at Google. The reason proffered by management for the poor
performance review were allegations that Wilberg had received a low candidate survey feedback score

of 60%. However, another recruiter on the team received an exceeded expectations rating even though
she had a feedback score

of just 30% satisfaction, just half of Wilberg’s

score. Wilberg’s performance

review also cited this client escalation for the low rating. However, the escalation had actually
\]O\

occurred after the performance review period had ended and managers were calibrating feedback for
the previous cycle. Wilberg was not told what the “escalation” was in the performance review.

During the performance review meeting, Pisacane told Wilber'g that didn’t remember anything about
10

the “escalation”. Wilberg was not told about what the client escalation was until July

11

lodged a complaint with HR.
27.

12

of 2016 after he

After the negative performance review, Wilberg ﬁled complaints about retaliation against

13

him by his managers with his HRBP, which forwarded the complaints to Employee Relations. After

14

investigating Wilberg’s complaints, HRfound that O’Conner had retaliated against Wilberg in

15

violation of Google Policies. Google considered Wilberg’s complaints to have been resolved based on

Allison Alogna (“Alogna”) being hired to replace O’Conner as Wilberg’s manager and manager of the

16
‘

17
18

rest

of the tech staffing team at YouTube.
28. O’Conner remained the team manager until Alogna started in July 2016. In the second one-

/
meeting between Wilberg and Alogna, Alogna become hostile and angry towards Wilberg for

19

on—one

2o

no apparent reasons and created a hostile work environment. In subsequent meetings, Alogna told.

21

Wilberg she wanted him to leave the tech recruiting team, that the team was not a good fit, and that

22

'Wilberg didn’t know how to do his job. She was hostile and angry for months in every weekly one on

23

one. Wilberg became fearful about attending the one on ones and meeting

24

Wilberg requested to work in another Google building next to the building Wilberg ’s desk was in.

25

Even though Or’Conner had been replaced, O’Conner was the stafﬁng business partner and responsible

26

for training Alogna. In addition, when Alogna told Wilberg he should transfer off the team, Wilberg

27

informed Alogna that Pisacane asked Wilberg to stay on the team before Alogna had joined and that

28

Wilberg v. Google

'

with Alogna each week,

so

 Alogna’s allegations that Pisacane did not want Wilberg on the team were untrue. Wilberg reported
Alogna’s hostile, angry and toxic behavior to HRBP A.L, but she took no action to intervene.
29. O’Conner continued to be hostile to other team members including a new hire who was

responsible for training and mentoring.

4’;

A YouTube recruiting peer came to Wilberg and let him know

that the new hire needed help creating hiring offer packets stating that she was not getting proper

training from O’Conner and that O’Conner was treating the new hire in an abusive manner

as she sat

next to the new hire and overheard their conversations where .O’Conner was speaking di'srespectfully
\OOQQQUI

and talking down to the new hire.~ The new hire came to Wilberg to ask

for packet training which was

core to her job and training she did not successfully receive yet from Wilberg. The new hire was upset

1

10

when she asked for help and Wilberg’agreed to stay after hours, from

11

new hire gave Wilberg a peer bonus for this help.

5

to 7pm and help train her. The
‘

30. In August

12

of 2016. Alogna was grilling Wilberg in a

he helped the new hire when he was the mentor

13

1:1 and she asked

him to explain why

for the new hire. Wilberg explained that she needed

‘

14

help. Alogna became even angrier and asked why Wilberg didn’t escalate the issues that the new hire

15

was having to Aldgna and Pisacane. Alogna became more angry and hostile than ever and demand that

16

Wilberg ﬁnd another team immediately. Alogna was so angry that Wilberg explained that he didn’t

17

want to make trouble for O’Conner as O’Conner had been found by HR to retaliate against Wilberg in

18

the past. Wilberg showed Alogna the email from the HR employee relations team that found

19

O’Conner was retaliatory to Wilberg in the past and violated Google’s policy around retaliation.

21)

Wilberg told Alogna not to share this information with Pisacane

21

complaint against O’Conner and caused the HR investigation. Alogna said Pisacane must already

22

know and refused to keep the informmon in conﬁdence and signaled she would let Pisacane know that

23

Wilberg was the one that ﬁled a cOnﬁdential complaint against O’Conner.
31. Wilberg interviewed

24

didn’t know who ﬁled the

with and found a new team in San Francisco. Wilberg was going to

with Alogna in the weekly

25

share the news

26

were joined by HRBP A.L. Alogna and

27

PIP was

1:1 and instead

during the week’s 1:1, Wilberg and Alogna

AL. put Wilberg on a Performance Improvement Plan. The

full of lies, exaggerations and misinformation. Also, the PIP was mostly written with

28

‘

as Pisacane

Wilberg v. Google

1

0

 complaints about Wilberg from O’Conner, who was an acting retaliatory against Wilberg in violation

of Google’s anti-retaliation policies. Wilberg refused to sign the PIP as it was a strong
misrepresentation of Wilberg

"3

work. Wilberg met with A.L. immediately Wilberg told HR the

majority of info was from O’Conner who was proven to be retaliatory toward Wilberg. ,A'L' said she

J;

was suspicious as well about the timing
reasons

for the PIP were reasonable and that Pisacane, who Wilberg did not work directly With and

had only second-hand knowledge

\OOO\)O\U1

of the PIP. However, she told Wilberg that she though the

of Wilberg

’s work, wrote the PIP with input from O’Conner.

‘

Wilberg told A.L. that he had another team lined up to internally transfer to and that he needed to
change teams because he would continue to be retaliated against on this team for raising HR concerns.
'10

A.L. said

she did not support a move

off the team.

11

32. Wilberg then escalated the retaliation issue to

12

33. In December

of 2016, Wilberg

A.L.’s manager HRBP who took over the‘case.

’s recruiting performance was strong and Wilberg hit all

13

the metrics required in the PIP and after the 3 months on the PIP. Wilberg’s new HRBP removed

14

Wilberg from

a PIP and recommended

of

that Wilberg change teams.

34. In early 2017, Wilberg interviewed and found another team in Google Data Science

15
‘

16

recruiting and the manager wanted to quickly speak with Alogna before making the transfer official.

17

Alogna gave Wilberg

18

transfer, so Wilberg was stuck on Alogna’s team. Alogna later denied speaking with this manager,

19

a

bad recommendation and the manager withdrew her support to have Wilberg-

however, the manager conﬁrmed with Wilberg that the 1:1 happened.

1

35. In March

2o

of 2017, Alogna let Wilberg know that he would be ﬁred if he did not meet

diversity-hiring goals he was given. Alogna also relayed the same threats to other recruiters. For

21
‘

23

if she did not
hire 3 black engineers in the quarter. Alogna encouraged the recruiter to leave the team if she thought

24

she could

22

25

example, one recruiter told him thatAllison Alogna told her that her job was in jeopardy

not meet her hiring goals.

36. In

April of 2017, Wilberg emailed Allison Alogna and his HRBP that he was having stress-

26

related medical issues. Wilberg went on 2—week medical leave approved by his doctor for a weakened

27

immune system, which was a stress—related illness.

2s

Wilberg v. Google

1 1

 37. In

April of 2017, Allison Alogna let the team entire YouTube Stafﬁng team know that they

Were not allowed

for a time to hire any non-diverse Junior and Mid—Level engineers and that the

YouTube Stafﬁng Team needed to make a list of all

of the Junior and Mid—Level

engineers the

YouTube Tech recruiting team was working with and cancel all onsite and phone interviews for
candidates who were not Black, Hispanic or a Woman. Recruiting made a list

of all interview for

Junior and Mid-Level engineers in process and the team proceeded to cancel all interviews except

diversity candidates who were allowed to continue interviewing. The decisions on who to interview
was not made by the candidate’s qualiﬁcations for the role,

it was solely made by gender and race

whereas only females could continue to interview for Junior and Mid-Level Engineering roles as well

Black and Hispanic engineers. Wilberg did not follow the team policy, which opposed Google’s

10

‘as

11

policy and canceled all interviews for candidates he was working with regardless of race and gender.

12

Wilberg proceeded to revive

13

was not diverse. Alogna was not happy about this and threatened Wilberg that he needed to follow the

14'

team policy or he could lose his job.
38. In June

15

a male engineer candidate

during this time and hire one engineer who

of 2017, Wilberg’s I-IRBP left and Wilberg met with his new HRBP to let her know

16

about the toxic culture. on the team, the policy violations and the continued retaliation against Wilberg

17

for his earlier complaints. Wilberg’s new HRBP met immediately with Alogna about Wilberg ’5

18_

concerns about retaliation. Alogna also met with Wilberg and another manager on the YouTube

19

Stafﬁng Team, to let Wilberg know he was meeting ekpectations for Q317. Alogna sent an email to
i

.

20

Wilberg to conﬁrm this.
39. In June

21

of 2017, the You Tube Stafﬁng Team was restructured. Google formed a group of

.

22

“Diversity Only” technical recruiters. They were responsible for College Recruiting where the goal in

23

college recruiting was to hire only (100%) Black, Hispanic and woman Engineers. The goal for 2018

24

hiring was to hire a total of 80 engineers and they were to all required to be “diverse.”

25

40. Google continued to pursue its Diversity hiring practices. However, to mask the

of these policies,

an email came out from Google Tech stafﬁng leadership that stated

26

implementation

27

that a Recruiters should no longer be tracking candidate’s diversity status and that Google recruiters

I

28

Wilberg v. Google

_12

 .should moving forward not be making decisions about who should be hired based on diversity status.

Management asked Wilberg and other tech recruiters to delete all references in Google’s internal
records reﬂecting diversity trackers. Allison Alogna sent an email to the team urgently asking that the
team delete all diversity tracke‘rs as each week they had to provide diversity hiring numbers to Allison.

Google’s Stafﬁng Team continued with Googlezs illegal hiring policies, but stopped tracking and
engaged in an effort to delete all the evidence

of the preferences given to women

and minorities in

Google’s hiring practices.
\000\]O\

41. In June

of 2017, Allison Alogna went on Leave and manager Jae Jun became Wilberg

manager. In October

of 2017, Wilberg

’s performance continued to be top 2 out

of between

’s

10-15-

10

recruiters on the tech recruiting team (people transferred in and out of the team so the Size of the team

ll

changed month over month), however, Wilberg continued to receive bad performance reviews for

12'

exaggerated reasons like talking too much in meetings.
42. In September and October

13

of 2017, Wilberg met with his HRBP and informed her that he and

of the team found that the team’s new leader Jae Jun was difﬁcult to work with.

1.4

other members

15

Wilberg also shared his ongoing concerns about violations of the law around discriminatory hiring

16

practices, which was Wilberg’s concern with manager O’Conner. He told his HRBP he was upset that

‘17

the discriminatory hiring practices were continuing even after multiple complaints. Furthermore,
‘

18

Wilberg let HR know that Lisa Pisacane had continued to encourage policy violations to be the team

19

policy by encouraging or pressuring each manager who led YouTube tech stafﬁng to violate the law

20

and that

21'
‘

43. The HRBP started setting up meetings with team member to investigate. Several YouTube

23

recruiters met with their HRBP to discuss their issues.

‘

44. In October

25

26
‘27

policy violations around unfair hiring practices and discrimination against non-diverse applications
based on their race and gender.

22

24

it was Lisa Pisacane who was driving the Federal and State Law violations and the Google

of 2017, Wilberg was given a bad performance review by Jae Jun in retaliation

for his ongoing complaints about Gobgle’s illegal hiring practices. She cited criticisms in the
'

evaluation that were based on events that had taken place much earlier and which were the basis for
l

28

Wilberg v. Google

l3

 ‘

the bad performance review 6 months earlier. Wilberg informed Jae that her rationale was not

relevant to this performance cycle and Jae stated she did not know that he had been given

a bad

performance review six months before these same events.
45. Google had a practice

of systematically discriminating

against older engineers in its hiring

practices. Wilberg opposed these practices. Wilberg gave a job applicant over 40 years old who had

applied for an engineering position a lower experience level than the level his supervisors wanted him

to give the applicant because he didn’t qualify for the higher level under Google’s standards.

However, his supervisors wanted him to require that the applicant interview for a position of a higher
level, knowing that he could not meet the requirements

of the higher position,

because they didn’t

of his age. Google’s hiring policies allowed exceptions to the hiring

1o

want to hire him because

11

guidelines. Wilberg’s managers were angry with him because he was seeking an exception for hiring

12

an engineer over 40 years

of age as

a mid—level

engineer.

13

46. Under pressure from Jae Jun, Wilberg brought the candidate back in for two additional

14

design interviews. The applicant failed both interviews as he didn’t have Level 5 skills. Wilberg

15

brought the employee back to the YouTube Hiring Committee Where he was re-approved as an Level

16

4. Wilberg

17

as an

18

would not. There was tremendous pressure on recruiters at Google not to hire candidates with over 10

19

years

20

complained about this discrimination against older workers to his managers, and resisted the efforts to

21

force order applicants to apply for positions that they would not get because they didn’t have the

22

requisite experience and skills.

felt that Jun was pressuring Wilberg to discriminate against this candidate and not hire him

Level 4

if he didn’t meet the Level 5 hiring bar, which she should have reasonably known he

of industry experience

47. In the Fall

23

as an

Level 4.Wilberg protested Google’s age discrimination. Wilberg

'

of 2017, Wilberg sent many emails with HRBP around illegal hiring practices

on

24

the YouTube Stafﬁng team. About two weeks later, Lisa Pisacane and Jae Jun met with the entire

25

YouTube Tech Stafﬁng team and told everyone the team was no longer having a dedicated Diversity

26

hiring team or individual recruiter diversity hiring targets. In this meeting Lisa Pisacane wouldn’t look

27

at Wilberg when he asked questions. In retaliation

for his opposition to discriminatory practices,

28
-

Wilberg v. Google

l4

 Google gave Wilberg a poor performance review.
48. In October

of 2017, Google’s

college recruiters gave an update in the bi-weekly YouTube

team recruiting team meeting that for 2018 college hiring, 75%
had hired over 30

of the

49. In November

80 all Diverse Software engineer

of all hires were diverse and the team

hiring goal.

of 2017, Jae Jun stepped down and went on a 3-month leave of absence and

Lisa Pisacane took over as Wilberg ’s manager. On Friday, November 3, 2017, Wilberg was brought
‘

into a meeting with HR and Lisa Pisacane and terminated for client escalations, not meeting goals,

KOOO\]O\

talking too much in meetings and not being collaborative. These reasons for Wilberg’s termination
were all pretextual.
10

FIRST CAUSE OF ACTION

11

Discrimination in Violation of California Government Code §12940, et seq. [Sex]
.

[Against All Defendants]

12
13

50.

Plaintiffs incorporate by reference the ‘allegationsgset forth above

as

though fully restated

I
1

14
15

herein.
51.

At all times material to this complaint, Plaintiff was

an employee

within the meaning of the

i

16
17
18
19

20
21

22
23

FEHA.
52.

At all times mentioned herein, Defendant qualiﬁed as an “employer” within the meaning of

the FEHA in that they each regularly employed ﬁve or more workers.
53.

Within the time provided bylaw, Plaintiff filed

a

complaint with the Department of Fair

Employment and Housing (“DFEH”) and received a Right to Sue Notice.
54.

At all times during Plaintiff s tenure with Defendants,

and each

his duties in an acceptable manner.
55. California’s FEHA makes

it an unlawful employment practice for an employer to

24

discriminate against an employee in the terms, conditions, or privileges

25

altering the working conditions or discharging an employee because

26
27

of them, Plaintiff performed

of employment, including

of his sex.

56. Defendants made decisions based on Plaintiff’s sex which adversely affected

regarding the terms and conditions and privileges

of his employment.

28'
1

Wilberg v. Google

5

Plaintiff

Such actions included, but were

 not limited to subjecting Plaintiff to negative performance criticisms, evaluations and a PIP which
were unjustiﬁed and the result

of standards of performance that were different from other employees

who were not men.
57. As a direct and proximate result
has suffered damages in the form

of the above violations of his rights under FEHA, Plaintiff

of past and future wage loss, other pecuniary

losses, loss

of potential

promotion and pay increase, emotional distress, loss of self-esteem, grief, stress, anxiety, mental
anguish, and lossof enjoyment

of life in an amount that exceeds the jurisdictional threshold of this

\DOO\]O\

Court, the exact amount of which
58. Because
10
11

will be proven at trial.

of Defendants’ unlawful

acts,

Plaintiff is entitled to and

seeks compensatory

damages, equitable relief, attorneys’ fees, and costs.
59. Defendants, and each

of them, committed the acts herein alleged with malice, fraud and

of Plaintiff’s rights

and with the wrongful intention

12

oppression, with

13

and motive

14

justiﬁed. The actions directed at Plaintiff were done by supervising employees acting in

15

callous, and intentional manner to injure and damage Plaintiff.

16
17

willful

and conscious disregard

of injuring Plaintiff, and therefore

an award

of exemplary

and punitive damages is
a deliberate,

WHEREFORE, Plaintiff requests relief, including punitive damages, as more fully set forth
below.

18

SECOND CAUSE OF ACTION

19

Discrimination in Violation of California Government Code §12940, et seq. [Race]

20

[Against All Defendants]

21

22
23

24
25

26

27

60. Plaintiffs incorporate by reference the allegations set forth above as though

fully restated

herein.
61.

At all times material to this complaint, Plaintiff was an employee within the meaning of the

FEHA.
62.

At all times mentioned herein, Defendant qualiﬁed as an “employer” within the meaning of

the FEHA in that they each regularly employed ﬁve or more workers.
63. Within the time provided by law,

Plaintiff ﬁled a complaint with the Department of Fair

28
1

Wilberg v. Google

6

 Employment and Housing (“DFEH”) and received a Right to Sue Notice.
64.

At all times during Plaintiff’s tenure with Defendants,

and each

of them, Plaintiff performed

his duties in an acceptable manner.

65(California’s FEHA makes it an unlawful employment practice for an employer to
discriminate against an employee in the terms, conditions, or privileges
altering the working conditions or discharging an employee because

of employment, including

of race.

\DOOQONM-b

66. Defendants made decisions based on Plaintiff’s race which adversely affected

regarding the terms and conditions'and privileges

of his employment.

Such actions included, but were

not limited to treating Plaintiff differently than other employees because
10

.

Plaintiff

of his race and terminating

Plaintiff because of his race.
67. As a direct and proximate result

11

of the above violations of his rights under FEHA, Plaintiff

form of past and future wage loss, other pecuniary losses, loss of potential

12

has suffered damages in the

13

promotion and pay increase, emotional distress, loss of self-esteem, grief, stress, anxiety, mental

14

anguish, and loss

15

Court, the exact amount

16

68. Because

17

of enjoyment of life in an amount that exceeds the jurisdictional threshold of this
of which will be proven at trial.

of Defendants’ unlawful acts, Plaintiff is entitled to and seeks compensatory

damages, equitable relief, attorneys’ fees, and costs.
I

18

69. Defendants, and each

willful

of them, committed the acts herein alleged with malice, fraud, and
of Plaintiff 5 rights

and with the wrongful intention

19

oppression, with

20

and motive

21

justiﬁed. The actions directed at Plaintiff were done by supervising employees acting in

22

callous, and intentional manner to injure and damage Plaintiff.

23

and conscious disregard

of injuring Plaintiff, and therefore an award of exemplary and punitive damages is
a deliberate,

»

WHEREFORE, Plaintiff requests relief, including punitive damages,

as

more fully set forth.

24
25

THIRD CAUSE OF ACTION

26

Failure to Take Reasonable Steps to Prevent Discrimination

27

and Retaliation from Occuring in Violation of Government Code § 12940 et seq.

28
1

Wilberg v. Google

'

7

 [Against All Defendants]
70.

Plaintiff incorporates by reference the allegations

set forth above as though

fully restated

I
.

herein.
71.

At all times mentioned herein, Defendant was

an

“employer” within the meaning of the

FEHA in that it regularly employed ﬁve or more workers.
72. Within the time provided by law,

Plaintiff ﬁled a complaint with the Department of Fair

Employment and Housing (“DFEH”) and received a Right to Sue Notice.
73.

At all times during Plaintiff’s tenure with Defendants,

and each

of them, Plaintiff performed

her duties in an acceptable manner.
10

74.

It is an unlawful employment practice under the FEHA, Government Code § 12940, for an

,

11

employer to fail to take all reasonable steps necessary to prevent discrimination and retaliation from

12

occurring. Defendants had a duty to prevent discrimination and retaliation against Plaintiff and others

13

from occurring.

14
15

16

75. Defendants failed to prevent, and in fact allowed continued discriminatory conduct and

retaliation against Plaintiff his complaints of discrimination.
76; On information and belief, Defendants failed to maintain and enforce adequate policies and

17

procedures,‘failed to provide‘adequate training

18

necessary to prevent the violations

19

20
21

of personnel,

and failed to take other reasonable steps

of the FEHA alleged herein from occurring.

77. The above-described actions and omissions

of Defendants constitute a failure to prevent

discrimination and retaliation under the FEHA.
72;}.

As

a

direct and proximate result of the above violations of his rights under FEHA, Plaintiff

of past and future wage loss, other pecuniary losses,

of potential

22

has suffered damages in the form

23

promotion and pay increase, emotional distress, loss of self-esteem, grief, stress, anxiety, mental

24

anguish, and loss

25

Court, the exact amount

26

79. Because

27

of enjoyment of life in an amount that exceeds the jurisdictional threshold of this
of which will be proven at trial."

of Defendants’ unlawful acts, Plaintiff is entitled to and seeks compensatory

damages, equitable relief, attomeys’ fees, and costs.

28

Wilberg v. Google

loss

18

 80. Defendants, and each

of them, committed the acts herein alleged with malice, fraud,

oppression, with willful and conscious disregard
and motive

and

of Plaintiff’s rights and with the wrongful intention

of injuring Plaintiff, and therefore an award of exemplary and punitive damages

justiﬁed. The aetions directed at Plaintiff were done by supervising employees acting in

is

a deliberate,

callous, and intentional manner to injure and damage Plaintiff.
.

WHEREFORE, Plaintiff requests relief, including punitive damages,

as

more fully set forth

below.
\DOO\]O\

FOURTH CAUSE OF ACTION
Retaliation in Violation of Government Code

§ 12940 et seq.

[Against All Defendants]

10

81. Plaintiffs incorporate by reference the allegations set forth above as though

11

fully restated

herein.

12

82..

13

At all times mentioned herein, Defendant qualiﬁed as an “employer” within the meaning of

the FEHA in that

14

it regularly employed ﬁve or more workers.

83. Within the time provided by law,

15

Plaintiff filed a complaint with the Department of Fair

Employment and Housing (“DFEH”) and received a Right to Sue Notice.

16

84.

17

It is an unlawful employment practice under the FEHA, Government Code

§

12940, for an

18

employer to retaliate against an employee for complaining about conduct and/or practices prohibited

19

by FEHA.
85. Defendants retaliated against

20

Plaintiff for complaining about Defendants’ illegal

and

discriminatory hiring practices by subjecting him to unfair and unwarranted performance criticisms

21

and thenlterminating his employment.

22
V

23

86. As a direct and proximate result

of the above violations, Plaintiff has suffered damages in the

24

form of past and future wage loss, other pecuniary losses, loss

25

increase, emotional distress, loss

26

enjoyment

27

of which will be proven at trial.

of potential promotion and pay

of self-esteem, grief, stress, anxiety, mental

anguish, and loss

of

of life in an amount that exceeds the jurisdictional threshold of this Court, the exact amount

28
1

Wilberg v. Google

9

 87. Because

of Defendants’ unlawful

acts,

Plaintiff is entitled to and

seeks compensatory

damages, equitable relief, attorneys’ fees,land costs.

of them, committed the acts herein alleged with malice, fraud,

88. Defendants, and each

oppression, with
and motive

willful

and conscious disregard

of injuring Plaintiff,

and

of Plaintiff’s rights and with the wrongful intention

and therefore an award

of exemplary and punitive

damages is

justiﬁed. The actions directed at Plaintiff were done by supervising employees acting in

a deliberate,

‘

callous, and intentional manner to injure and damage Plaintiff.
.

\OOO\]O\

WHEREFORE, Plaintiff requests relief, including punitive damages, as more fully set forth

FIFTH CAUSE OF ACTION
Wrongful Termination in Violation of Public Policy

10

[Against All Defendants]

11

89. Plaintiffs incorporate by reference the allegations set forth above as though

12

fully restated

9

'

13

herein.
90. Defendants terminated

14
15

Plaintiff because of his opposition to Defendants’ unlawful hiring

practices.
91. Defendants’ actions in terminating

16

17

the fundamental policies

18

Constitution, Art.

1, §8;

of the

State

Plaintiff under the circumstances alleged herein violate

of California embodied, among elsewhere, in the California

California Government code §12940 et seq., and Labor Code 1102.5.

92. Defendants’ conduct in terminating

19

Plaintiff under these circumstances constitutes

a

2

20

wrongful termination in violation of public policy.
93. As a direct and proximate result

21

of past and future wage loss,

22

damages in the form

23

and pay increase, emotional distress, loss

24

loss

25

amount

26
27

of the above violations of his rights, Plaintiff has suffered
other pecuniary losses, loss

of self-esteem, grief,

of potential promotion

stress, anxiety, mental anguish, and

of enjoyment of life in an amount that exceeds the jurisdictional threshold of this Court, the exact
of which will be proven at trial.

94. Because

of Defendants’ unlawful

acts,

Plaintiff is entitled to and

damages, equitable relief, attorneys’ fees, and costs.

28

Wilberg v. Google

20

seeks compensatory

 95. Defendants, and each

~

oppression, with

willful

and motive of injuring

of them, committed the acts herein alleged with malice, fraud, and

and conscious disregard

of Plaintiff’s rights and with the wrongful intention

Plaintiff, and therefore an award of exemplary and punitive damages is

justiﬁed. The actions directed-at Plaintiff were done by supervising. employees acting in

a deliberate,

callous, and intentional manner toinjure and damage,Plaintiff.

WHEREFORE, Plaintiff requests relief, including punitive damages, as more fully set forth
I
\OOONONLh-b

V

'

'

below.

SIXTH CAUSE OF ACTION
California Business and Professions Code §§ 17200 et seq.
I

[Against All Defendants]

1o

Plaintiff has incurred, and will continue to incur, attorneys’

11‘

96.

12

of this action,

13

law.
97.

14
15

and

Plaintiff therefore seeks attorneys’

Plaintiff re-alleges

fees and costs in the prosecution

fees and costs under all applicable provisions

and incorporates herein by reference each allegation contained in this

complaint as though fully set forth herein.
98.

16

Plaintiff further brings. this action pursuant to the BUSiness

and Professions Code, sections

17

17200, et seq., seeking injunctive relief against Defendants for proﬁling employees, prospective

18

employees and others based on their race and gender in violation

21

of California law.

99. Defendants have inequitably and unlawfully conspired, agreed, arranged, and combined to

19

2o

violate California labor laws, and anti-discrimination laws

as

alleged herein.

WHEREFORE, Plaintiff prays for judgment as more fully set forth below.

SEVENTH CAUSE OF ACTION

22
23

Violations of the Unruh Civil Rights Act

24

[Against All Defendants]
1100.

25

26

of

Plaintiff re-alleges

and incorporates herein by reference each allegation contained in

this complaint as though fully set forth herein.
101.

27

Plaintiff further brings this action pursuant to The Unruh Civil Rights Act, California

28
.

Wilberg v. Google

21

 Civil Code sections

51

through 52, which provides protection from discrimination by all business

establishments in California, including housing and public accommodations. California Civil Code
DJ

section 51(b) describes the protections found under the Unruh

Civil Rights Act: All persons within the

jurisdiction of this state are free and equal, and no matter what their sex, race, color, religion, ancestry,
kl]

national origin, disability, medical condition, genetic information, marital status, or sexual orientation
are entitled to the

full and equal accommodations, advantages, facilities, privileges, or services in all

\10\

business establishments

of every kind whatsoever. Civil Code section 51(b). The language of the

Unruh Civil Rights Act (see above) speciﬁcally outlaws discrimination. in housing and public
accommodations based on sex, race, color, religion, ancestry, national origin, disability, medical
10
11

12
13

condition, genetic information, marital status, or sexual orientation.
102.

Defendants have inequitably and unlawfully conspired, agreed, arranged, and

combined to violate The Unruh Civil Rights Act.
103.

As a direct and proximate result of the unfair, unlawful, and/or fraudulent business

14

practices alleged herein, Plaintiff has been denied due process and has suffered, and continues to

15

suffer, from the discriminatory practice

16

alleges that, through the acts described in this complaint, the Defendants have deceived the public by

17

illegally depriving Plaintiff and others from being subjected to hiring quotas based on their race and

18

gender.

of Defendants. Plaintiff is informed and believes and thereon

‘

19

104. WHEREFORE,

Plaintiff prays for judgment as more fully set forth below.
REQUEST FOR RELIEF

20
21

22
23

24
25

26'
27

WHEREFORE, Plaintiff requests judgment against Defendants as follows:
1.

For general, special, actual, and compensatory damages against Defendants in an amount

to be determined at trial;
2.

For punitive damages in an amount to be determined at trial sufﬁcient to punish, penalize

and/or deter Defendants and others from engaging in the conduct described herein;
3. For back and

front pay and other beneﬁts Plaintiff would have been afforded but-for

Defendants’ unlawful conduct;

28

Wilberg v. Google

2,

 Waverly.

Defendants’ unlawful conduct;

.,

w
n

ix.)

of this litigation;

4.

For costs and expenses

5.

For reasonable attorneys’ fees pursuant to California Government Code

§

12965 and

other applicable statutes.
OO\]O\Ul-S>La~)

6.

For pre and post-judgment interest on all damages and other relief awarded herein from

all entities against whom such relief may be properly awarded;
7. For a temporary and permanent injunction prohibiting Defendants from implementing,

using, distributing, and training its employees to use their discriminary proﬁling,
\0

8.

For such other and further relief as the Court deems just and proper.

10

ll

DATED: January 24, 2018

Law Ofﬁces of Daniel Feder

12

By:

13

{9M /

/~ 149 «<44

14

Daniel Feder

15

Attorneys for Plaintiff

16

DEMAND FOR JURY TRIAL

17
18

19

Plaintiff Arne Wilberg hereby demand a trial by jury for each and every claim for which he
has a right to jury trial.

20
21

DATED: January 24,

20' 1 8

Law Ofﬁces of Daniel Feder

22

/ LA.
Dwarf, A
‘

By:

23

24

Daniel Feder

25

Attorneys for Plaintiff

26
27
28
23
Wilberg v. Google

  

EXHIBIT 1

Apri§27th 2m? YouTube Tech Stafﬁng“; Team
’‘

(7
1

=3

a»;

>2

0

{:2 Cause! Dev av Nam.

Elms! & Youth.

:5:

n

'3

7

sou-A

-

a

Adda»:

Heb

auxin-s: Opemion-

511 me Tech Seamh

:M ﬁne: at cu: E1 SovlccUSc-‘cenor 9.. Kg Shim Engineer Scar...

7“-

53:.

Table

Norman“:

1

(10,491)

(34 Inbux

8§~weekiy SWE Stafﬁng Agenda
ﬁle Edit View Insert Fan-nu: Tools

<5)

1mm

--

3;

-

..

t

=

'

xm w
'20 waging

,2

-.~

39¢ new changes
11

z

~

I

[I
3

‘3!

A<

09

E

c

ii

' ‘

E5

.

:.

=—.

192-?

-

:E

g,

ARecurring topics:

4/27
0

Cha and team join
0 Al: Allison to share GB rescurcas wi‘h Cha and team
Tcam wins
Best practices

0...

£5.19.m mamas
Goodburger updaies
0 Next steps
:1
HM Meeﬁna

Minniné

m... ”u

of Qi 4 gel-wire {or 2018 - an diverse

w.

b

-

-

SE

r

....

m;

"r
g ﬁg.
y:

I:

_~

A»

'I

v

,

ab
t- E3

emu Gookmarks

Comma/3;!

Edlﬂng

..

:3

m

l

 Q'Weekiy ReCap

.

ewéf' Mada» :Iﬁéb

awgmyswewm;m-r
mCJBEhSWPD

an

* Mow.»

a: 549'!!!

E

sang-z: Vaicc .

keg- its-n necmrcng Tenn m usexmznm In: sum. 3:

Weekly SWE Hiring Recap

1-, ﬁ'mnéléna’ama

:-

.Meweazwa'mccvssa;

r. Minna mu:

‘1:-

6: '3: -; a :3: $3 a B I
,.
n rm Ham: ﬁrm m t: ‘oogle:Decn‘m :5 saw: hawking M: (3m

9?.
.

File

Ea!

Vnew

ﬁrw?

Insert

Formal

Too‘s

Yabfe

iw'a.nemwuon«

Add-ans

Am:
7

Help

-l2

Lasmdfzwesmaﬁciranuiesaybymlcn

S3533.

59‘1""

-Bi~g_é_~¢e.is‘§’4§3’é‘
=

lee o 3I20

a

=

.=.

x

  EXHIBIT 2

Mail

'

h

a

g

a;

E

.,

%

V

Mom"

3of21.580

Fwd: lmportanti Guidance for dealing with your NG candidatesthat are still in pipeline
nbax

lnbox (13,500)
Starred
lmpoﬁanl
SentMaiI
Drafts {420)
1 Vault

“

x

“09na
E! ““5”
:0 Team
—

,3

<

>

People (2)

V

3:16 PM (15 minutes ago)

a

Allison Alcgna

‘

F ollaw

.

EQUE'

Hi T

.

Ragga: pastas

Pleasé continue with L3 candidates in process and only accept new

groups

g;

1.3

mndidales lhal are lmm historically underrepresented

Show dexails

.,

 acme https: ‘lmaii. googlecom/maﬂgC/mnoox, 5b85bc59’1 160044 :compese=1 k2382(18 .m/OO‘! q2"Jﬁ. 235w;
I EY Naba Ernst & Youn... M tnbax {10 5.91) 331 Business Operation . Ea PTO Tech Search ﬁ' QA Filter of C(lP E Sourcer/Scn

m

E

4—.

a

w

_

«Q,

-

IMPORTANT: Goodburger UPDATE and REMINDER
“I.

A

Mom

mm

_

'1

“Open Date a Time Preferences...

‘

-

-

x

Alﬁson Nogna
‘0 7'33”? '

View as Analog

-‘/ View as Digital

4of643

a

,

'

12:00 PM (3 hours ago)

.

.5.

0‘

~

Any other questions in the meanume?
Anison

more

Alﬁsoa A!
5:;

.

Show ceaa'us

~

mam‘mc:

mat Read pre‘anmwmn
- Other PAS have moved over already. so it you may get a different message flom OR ana'or Chan

1

3

A few important upduies:

”Va ans still pro-Gaodburgcr cox out, so ma: means the only candidaaes

g

>

Stafﬁng Max

Hi Team.

5. In me

3

<

.35. And we shcu‘d only cons. der. L35 from cur undarraprasenlumgroups
Is the case please Se: mg or yaur mansger know.
'

>