Courthouse News Service

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P VELEZ,ESQ,(SBN 163484)
A_WEBBER,ESQ,(303721)
TIIE VELEZ LAⅥ /FIRM
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KELSEY
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6940 Destmy Dnve
Rockl二 Califomia 95677
Telephone:(916)774-2720
Facslrulc: (916)774-2730
vdezlawの live com
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Attomeys for Plaintiff RANDA FANOUS
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OFSACRAMENT0
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RANDA FANOUS,
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Plamtl鶴
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KAISER FOllNDAT10N HOSPITALS;THE
PERⅣ 鵬NEME NIEDICAL GROUP,NC.,and
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T FOR DAMAGES
Breach of Labor Code§ 1102.5 et
seq.:
2. Breach of Cal.Govt.Code§ 12940;
Gender Discrimination;Sexual
Ⅱarassment;
3.
WrOnnl Ternination lm
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of Publc Pohcy.
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PLAIINTIFF'S
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Defendants.
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[UNLIⅣ IITED CIW■ L CASE〕
J■lRY DE卜園 DED
Plamtl∬ RANDAFANOUSeerehaner,``PlaintiffFANOUS')States
hercomplamt against
Dcfendants,KAISER FOllNDATION HOSPITALS;THE PERⅣ 幽 ENTI MEDICAL GROUP,
INC,and Docsl■ rough
50,as follows
PLAINTIFF'S COMPLAINT FOR DA■ IAGES
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I.
STATEMENT OF TIIE FACTS
Plaintiff RANDA FANOUS is a resident of Sacramento, County of Sacramento and
former employee
of
a
Defendant KAISER FOUNDATION HOSPITAIS; THE
INC.,
PERMANENTE MEDICAL GROUP,
(hereinafter collectively "Defendants
KATSER").
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Defendants KAISER FOUNDATION HOSPITALS; THE PERMANENTE MEDICAL
a corporation doing business
KAISER
was at all times herein relevant, the
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the County of Sacramento. Defendants
in Sacramento, Califomia, located within
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GROUP, INC.,
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PlaintifPs "employet''as that term is defined in the Califomia Fair Employment and
Housing Act, Califomia Govemment Code Section i 2900., et. seq. Defendant KAISER, had
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actual and constructive notice of the wrongful conduct and harassment perpetrated upon
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Plaintiff, set forth below, had both the authority and the duty to prevent and correct the same,
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failed to take reasonable action to prevent and correct the same and, by its conduct,
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condoned, supported and ratified such wrongful conduct and harassment.
The true names and capacities, whether individual, corporate, associate or otherwise of
us
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through 20 are unknown to Plaintiffs, who therefore
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Defendants named herein as Does
sues said Defendants by such fictitious names, and Plaintiffs
will
amend this Complaint to
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show their true names, involvement and capacities when the same have been ascertained.
Does 1 through 25 are residents of the State of Califomia and/or have their principal place
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ofbusiness in the State of California. Plaintiffs are informed and believe and on that basis
allege that each of the Defendants named herein
as
Doe was in some manner responsible
for
the injuries and losses suffered by Plaintiff.
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At
al1 times herein mentioned, each
ofthe Defendants was the actual and apparent agent,
servant and employee ofeach of the remaining Defendants and in doing the things herein
after alleged was acting within the course and scope oftheir actual and apparent agency and
ernployment and with the knowledge, notification, consent and subsequent ratification
PLAINTIFF'S COMPLAINT FOR DAⅣ 臥 GES
2
of
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each of the other Defendants.
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At all times herein relevant, Defendant KAISER owed plaintiffa duty to take all
reasonable action to provide Plaintiffs with
harassment and retaliation and
a
workplace free from unlawful discrimination,
to take all
reasonable action to prevent and corect
discrimination, harassment, and retaliation in the workplace. Specifically, Defendant
KAISER owed Plaintiffaduty: (1) to promulgate, in an effective way, policies, practices and
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guidelines regarding employment discrimination, harassment and retaliation; (2) to provide
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effective and adequate training to managers, supervisors and employees regarding
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emplol,rnent discrimination, harassment and retaliation, how to take effective, timely and
reasonable action to prevent ernployment discrimination, harassment and retaliation and,
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particularly, how to handle, in a reasonable, prompt and effective manner, complaints and
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noticed situations raising issues of employment discrimination, harassment and retaliation,
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(3) to provide realistic assurance to anployees that Defendant KAISER was serious about
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enforcing such policies against discrimination and harassment and retaliation, (4) to protect
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from retaliation ernployees who made or supported discrimination, harassment orretaliation
of
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complaints; (5) to conduct, in response to a complaint or actual or constructive notice
discrimination, harassment and retaliation in the workplace, a good faith, reasonable, fair
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and prompt investigation ofsuch complaint or in response to such notice; (6) to bring such
investigation to a conclusion in
a
timely manner; (7) to take prompt and effective rernedial
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action, where appropriate, to prevent and correct discrimination, harassment and retaliation;
(8) to maintain reasonably through and adequate records regarding discrimination
an,
harassment and retaliation complaints, investigations, conclusions, and remedial action; and
(9) to avoid engaging in and promoting actions which has the intended purpose
and
foreseeable effect of silencing and quashing the voices of discrimination, harassment or
retaliation complainants and others who support or have supported discrimination,
harassment or retaliation complaints.
PLAINTIFF'S COⅣ IPLAINT FOR DAル IAGES
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Defendant I(AISERbreached the above-mentioned duties in that, at all times herein relevant,
Defendant KAISER acted in a manner which it knew, should have known, and did not care
to know, condoned and supported discrimination, harassment and retaliation in
the
workplace. Defendant KAISER failed and refused to take reasonable action to publish and
promulgate,
in an effective
manner, policies, practices and guidelines regarding
discrimination, harassment and retaliation. Defendant KAISER failed and refused to take
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reasonable action to provide adequate and effective training to managers, supervisors and
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ernployees regarding discrimination, harassment and retaliation, failed to effectively train
harassment and retaliation, and failed
to
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managers, supervisors and empl0yees regarding how to prevent employment discrimination,
adequately train managers, supervisors and
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employees in how to reasonably, promptly and effectively handle complaints and noticed
to
actual and constructive notice
of and complaints
regarding
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KAISER responded
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situation raising issues of employmen! discrimination, harassment and retaliation. Defendant
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discrimination, harassment and retaliation in a manner calculated to defend and delay, rather
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than fairly and timely investigate, situation noticed and complaints regarding discrimination,
harassment and retaliation, with the intended purpose and foreseeable effect of supporting
at all costs, condoning and supporting discrimination, harassment
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management
and
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retaliation. Defendant KAISER engaged in the above acts and omissions knowingly and as
a matter
of general business practice, without regard to the rights of employees, inciuding
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PlaintiffFANOUS.
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PlaintiffRANDA FANoUS was a longtime ernployee ofDefendants KAISER commencing
her employment in 2004 as a registered nurse. From about 2004 through 2013 plaintiff
FANoUS worked
at the
"Tele departrnent", in stoke care at Defendant's Roseville Hospital.
In about June 2015, Plaintiffwas transferred to the "Wound Clinic,,at Defendant's South
Sacramento Hospital.
From about late 2013 through May
l2,2}l4,Planritrmade
several complaints over the lack
PLAINTIFF'S COMPLAINT FOR DAⅣ IAGES
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offproper "Stroke Scale Assessments" being performed in her department. In her May
12,
2014 complaint plaintiffreiterated the hospital's lack ofprocesses inplace to assess ,.Stroke
Scale Protocols." Plaintiff informed Kaiser manager, Ruby
D. Acojedo, that
the
department's stroke scale protocols were not being consistently adhered to in that a nurse
refused to perform a stroke handoffwith
training requires
a
her. Prudent medical procedures including Kaiser
stroke care assessment and handoff.
Plaintiff written complaint included:
as a patient advocate and
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"l continue to bring forth the issue ofstroke scale solely
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for fear that one day the current mediocre stroke assessment path that we appear
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to tread will be a harmful experience to all. . . .Stroke class (mandatory) with an
emphasis on the importance ofsystanatic stroke scale assessment with real
ofnot doing proper stroke assessment."
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stories and the impact
life
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20 1 5 Defendant Kaiser, through its Department Manager, Ruby
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retaliation. In about March
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Plaintiffs complaints over inadequate stroke assessment scales protocols was met with
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Acejedo, issued Plaintiff a written verbal waming. This adverse emplol,rnent action
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contained false accusations of co-worker conflicts on the part of Plaintiff. Plaintiff then
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provided a rritten rebuttal to Ms. Acejedo's false allegations. in her written rebuttal,
plaintiff detailed her past engagernent in protected activity which was aimed at correcting
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deficient instances ofpatient care including instances ofpatient abuse. Defendant Kaiser had
sought to
"chill" plaintiff from complaining further in the Stroke Department. However,
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plaintiff continued to advocate for patients.
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Previously, on about March 2014, Plaintiffhad made a complaint of sexual harassment in
the form of a stalking harassment complaint against a male co-worker, Welsey Varbick.
Plaintiffwas in fear of Varbick since had proceeded on numerous occasions to stalk Plaintiff
within her work environment. Plaintiff maintains that the March 2015 written waming
issued to her was also in retaliation for raising her complaints of sexual harassment.
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ln about June 28,2015 PlaintiffFANOUS transferred to Kaiser's Wound and Ostomv Center
PLAINTIFF'S COMPLAINT FOR DANIIAGES
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at Kaiser's South Sacrament Hospital. The wound department was managed by Lane
Phillips, Dir., and Mark Kaufrnan, Assistant Director. The departrnent was "sloppy," with
poor sanitization and patient safety protocols. Initially, Plaintiff rvas promised Would
Classes Certification
training. But that was reneged by Assistant Director Kaufman.
Plaintiff went ahead and paid for her certification with her own monies.
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Commencing
in about early August 2015, Plaintiff FANOUS
observed the following
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instances ofgross patient care and neglect. Kaiser nurse Kathy Miller was allowed to work
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with Wound Patients. Nurse Miller was however, ill with MRSE viral infections, with open
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"Pus" wounds on her upper left shoulder. Plaintiff observed this firsthand because Miller
requested Plaintiff to help her clean her MRSE afflicted and infectious shoulder. On one
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occasion nurse Miller touched a patients buttocks and anal area and proceeded to open a
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drawer with the same hand and same giove on and take out medical supplies from the now
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infected supply drawer. Additionally, nurse Miller rvould never change her disposable
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yellow gowns following entering and exiting a wound patient's room. The purpose for the
it
before and after entering the patients rooms.
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disposable yellow gonn is to change
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Additionally, nurse Miller infected patients with the MRSE bacterial since one patient went
into a "Code
1".
Code 1 denotes a seriously i1l patient.
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PlaintiffFANOUS raised her complaints about nurse Miller's exposure of the MRSE virus,
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the use of a contaminated hand onto medical supplies and her failure to change disposable
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yellow gowns to the Wounds Department upper management, Lane Phillips, Dir., and Mark
Kaufrnan, Assistant Administrator. Instead ofany remedial measurg5 lging undertaken by
Defendant Kaiser,
plahtiff was subjected to further adverse ernployment actions. On
October 25, 2015 Plaintiffwas writtar up on sham and bogus charges ofvague accusations
of failure to get along rvith co-workers. Thereafter, on Novernber 1, 2015 Plaintiff was
placed on administrative leave pending an investigation into
plaintiff. This was oukageous
conduct on the part ofDefendant Kaiser, and notably, an effort to send plaintiffa
PLAIrOTIFF'S COⅣ IPLAINT FOR DAⅣ IAGES
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"Chilling"
message to stop raising complaints ofpatient care neglect and abuse. uitimately, Defendants
Kaiser retaliated against Plaintiff on January 4, 2016, when Defendant Kaiser terminated
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plaintiff from her employmant. The offered
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mask ernployment retaliation.
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reasons for the termination were pretextual to
The sexual harassment, retaliation and discrimination, described above as it relates to all
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This conduct as afore stated constitutes the "incident" giving rise to this action or
proceeding, as that term "incident" is used on page 1 ofthe form interrogatories approved
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by the Judicial Council for the State of Califomia.
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Within the time provided by law, plaintifffiled
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Plaintiff herein, and the retaliatory termination constituted an adverse employment action.
a complaint
with the Califomia
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102.5 (a), in pertinent part, provides:
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"An employer, or any person acting on behaifofthe ernployer, shall not
make, ado_pt, or. enforce any rule. regulation. or policy pieventing an
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employee from disclosing information lo a govemment or iaw enforcerient
agency, to q person with authority over the employee, or to another
ernployee who has authority to investigate, disi:over, or correct the
violation or noncompliance, or from providing information to, or testit/ing
!:fore, any.public body conducting
an invesligation, hearing, or inquiry]
the employee has reasonable ciuse to believe fhat thjinformation
discloses a violation of state or federal statute, or a violation of or
noncompliance_ with a local, state, or federal rule or regulation, regardless
ofwhether disclosingthe information is part ofthe employee's job'rluties.,'
if
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Plaintiff incorporates by reference the allegations set forth above and beiow.
Califomia Labor Code
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FIRST CAUSE OF ACTION
Breach of CaI. Labor Code S lf 02.5, et seq., Employment Retaliation for
Opposing Wrongful Employmenf Conduct
(Against AII Defendants)
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"righlto-sue" letter.
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Department of Fair Employment and Housing, in full compliance with FEHA and received
18
Labor Code
g
I 102.5 subsections (c)&(d) provides:
"[a]n employer, or any person acting on behalf of the anployer, shall not
THE VELEZ
LAW FII● I
Attomeys at
6940… Dn● ●
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CA'“ 77
PLAINTIFF'S COMPLAINT FOR DARIAGES
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retaliate against an employee for refi$ing to participate in an activity that
would result in a violation of state m federal statute, or a violation ofor
noncompliance with a local, state, or federal rule or regulation. (d) An
ernployer, or any person acting on behalf of the employer, shall not
retaliate against an employee for having exercised his oi her rights under
subdivision (a), (b), or O in any fomrer employment."
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Plaintiff informed Kaiser manager, Ruby D. Acojedo, that the departrnent's stroke scale
protocols were not being consistantly adhered to in that a nurse refused to perform a stroke
scales protocols
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handoffwith her. PlaintifPs complaints over inadequate stroke assessment
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was met with retaliation. In about March 2015 Defendant Kaiser, through its Departrnent
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Manager, Ruby Acejedo, issued Plaintiffa written verbal waming. This adverse anployment
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action contained false accusations of co-worker conflicts on the part of Plaintiff. Plaintiff
then provided a written rebuttal to Ms. Acejedo's false allegations.
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Additionally, in about early August 2015, Plaintiff FANOUS observed the following
instances of gross patient care and neglect. Kaiser nurse Kathy Miller was allowed to work
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with Wound Patients. Nurse Miller was however, ill with MRSE viral infections, with open
e
"Pus" wounds on her upper left shoulder. Plaintiffobserved this firsthand because Miller
us
requested Plaintiff to help her clean her MRSE afflicted and infectious shoulder. On one
Millff
touched a patients buttocks and anal area and proceeded to open a
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occasion nurse
drawer with the same hand and same glove on and take out medical supplies from the now
ou
rt
infected supply drawer. Additionally, nurse Miller would never change her disposable
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yellow disposable gowns following antering and exiting a wound patient's room. The
purpose for the disposable yellow gown is to change it before and after entering the patients
rooms. Additionally, nurse Miller infected patients with the MRSE virus since one patient
went into a "Code
1".
Code
I
denotes a seriously
ill patient.
う‘
PlaintiffFANOUS raised her complaints about nurse Miller's exposure of the MRSE virus,
the use
ofa contaminated hand onto medical
supplies and her failure to change disposable
yellow gowns to the Wounds Departrnent upper management, Lane Phillips, Dir., and Mark
Kauftnan, Assistant Director. lnstead of any rernedial measures being undertakat by
PLANTIFF'S COⅣ IPLAINT FOR DAMAGES
8
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Defendant Kaiser, plaintiff was subjected to further adverse employment actions. On
October 25, 2015 Plaintiffwas written up on sham and bogus charges ofvague accusations
of failwe to get along with co-workers. Thereafter, on November 6, 2015 Plaintiff was
placed on administrative leave pending an investigation into
plaintiff. This
was outrageous
conduct on the part ofDefendant Kaiser, and notably, an effort to send plaintiffa "Chilling '
messageto stop raising complaints ofpatient care neglect and abuse. Ultimately, Defendants
reasons for the termination were pretextual to
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plaintifffrom her ernplol,rnent. The offered
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Kaiser retaliated against Plaintiff on January 4, 2016, when Defendant Kaiser terminated
As
a
result ofdefendants' conduct and breach ofthe code section, plaintiffhas suffered and
will continue to suffer
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mask employment retaliation.
damages, the exact amount of which has not been fully ascertained
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but is rvithin thejurisdiction ofthis Court. Plaintiffis entitled to damages, including, but not
limited to lostwages, salary, benefits and certain other incidental and consequential expenses
As a direct and proximate result of the acts of Defendants, Plaintiff has sustained and
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and damages in an amount to be shown at the time of trial.
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continues to suffer severe emotional distress. Plaintiffseeks general damages for her severe
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emotional distress and other consequential damages in an amount not less than an amount
within the jurisdiction of this court, the exact amount to be proven at trial.
Plaintiffis informed, believes
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and thereon alleges that defendants, and each ofthern, acted
fraudulently, maliciously and oppressively with a conscious, reckless and willfi.rl disregard,
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and/or with callous disregard of the probable detrimental and economic consequences to
plaintiffs, and to the direct benefit of defendants, knowing that defendants' conduct was
substantially certain to vex, annoy and injure plaintiff and entitle plaintiff to punitive
damages against the individual defendants under Califomia
Civil Code $3294, in an amount
sufficient to punish or to make an example ofthe individual defendants.
WHEREFORE, plaintiff prays for judgrnent against defendants, and each of them,
hereinafter set forth.
PLAINTIFF'SCO卜 IPLAIPIT FOR DA■ IAGES
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as
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SECOND CAUSE OF ACT10N
Breach of Cal.Govt.Code§ 12940;Retaha● on for Opposing Gender Ⅱarassment,Sexual
Harassment
(Against Defendants KAISER)
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う４ う乙
Plaintiff incorporates by reference the allegations set forth above and below.
Defendants KAISER has breached their statutory and self-imposed duties owed to
as a
plaintiff
result ofDefendant's representation, policies and procedures, and under Califomia law,
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including Section, 12940 et. seq., of the Califomia Government Code by: (1) ratifuing and
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tacitly approving gender discrimination; and (2) retaliating against Plaintifffor complaining
Plaintiff is a member of a class entitled to protection under the Califomia Fair Emplolment
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of sexuai harassmant, gender harassment.
and Housing Act and have obtained a "Right to Sue" letter.
As a result of the conduct of Defendant KAISER and Defendant KAISER's breach ofthe
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the
jurisdiction of this court. Plaintiffis entitled to damages
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fully ascertained but is within
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code section, Plaintiff has suffered damages, the exact amount of which has not yet been
including, but not limited to, lost wages, salary, benefits and certain other incidental and
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consequential expenses and damages in an amount to be shown at the time of
trial. In
addition, Plaintiffhas been forced as a result ofDefendant's breach to retain a law firm to
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enforce their rights, and has incurred and
will
continue to incur costs and reasonable
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attomeys' fees in connection herewith, recovery of which Plaintiff is entitled to according
to proof.
Plaintiffis inforrned, believe
and thereon allege that Defendant
KAISER acted fraudulently,
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maliciously and oppressively with a conscious, reckless, and willful disregard, and/or with
callous disregard of the probable detrimental and economic consequences to Plaintiff, and
to the direct benefit to Defendant, knowing that Defendant's conduct was substantially
certain to vex, annoy and injure Plaintiffand entitle her to punitive damages under Califomia
Civil Code $3294, in
an amount sufficient to punish or to make an example of Defendants.
WHEREFORE, Plaintiffprays judgrnent against Defendants
as
PLAINTIFF'S COMPLAINT FOR DAⅣ IAGES
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hereinafter set forth.
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THIRD CAUSE OFACTION
(WRONGTUL TERMINATION IN \TOLATION OF A CLEARLY
STATED PUBLIC POLIC9
(Against Defendants KAISER)
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Plaintiff incorporates by reference the allegations set forth above and below.
Pursuant to the Califomia Fair Employment and Housing Act, Caiifomia
Govemment Code Section 12900., et. seq., defendants owed Plaintiff a duty to take all
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co[ect discrimination, harassment and retaliation in the
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reasonable action to prevent and
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rvorkplace and to provide plaintiff and other employees with a work environment free from
Additionally, Califomia
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sexual harassment, discrimination, harassment and retaliation.
Labor Code $1102.5 et seq., prohibits retaliation for reporting internally violations of law.
law.
Defendants, and each of them, also
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Patient care neglect and abuse is a violation of
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owed Plaintiffa duty not to take any adverse ernployment action against Plaintiffdue to her
opposition to said breaches of law.
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The conduct of Defendants as set forth above, constitutes unlawful retaliation, in violation
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of the Public Policy of the State of Califomia including the FEHA and the Califomia Labor
Code.
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Defendants Kaiser retaliated against Plaintiff on January 4, 2016, when Defendant Kaiser
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terminated plaintiff from her employment. The offered reasons for the termination were
pretextual to mask employment retaliation.
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As a direct and proximate result of the conduct of Defendants, in violation of Califomia's
public policy, as set forth above, Plaintiffhas suffered severe humiliation, anbarrassmant,
anxiety, distress, loss ofself-esteern and other highly unpleasant emotions. Further, Plaintiff
has suffered severe physical injuries, injwies to her reputation, has lost wages and job
benefits including her porsion, has lost the benefit ofjob experience, has incurred medical
expenses and has been forced to
anploy legal counsel and to incur attomey's fees, costs of
suit and rclated expenses in an amount not yet fully ascertained. Plaintiffhas suffered general
PLAINTIFF'S COⅣIPLAINT FOR DAⅣ IAGES
ll
damages as set forth above
in
a sum
in excess of the jurisdictional limits of this Court and
has suffered speciai damages in an amount according to
35.
proofat the time oftrial.
ln engaging in the conduct set forth above, and in failing to act,
as set
forth above,
Defendants acted inteationally, negligently, recklessly, outrageously, despicably, maliciously,
oppressively, fraudulently, and in bad faith, with the intent ofharming Plaintiff and without
regard to her rights. Accordingly,
Plaintiffis entitled to recover exemplary
damages.
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WHEREFORE, Plaintiff prays for judgnent against Defendants, and each of thern, as set
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forth below.
as set
forth
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WHEREFORE, Plaintiffprays judganent against Defendants, and each ofthern,
below:
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For general, special and consequential damages in an amount of excess of the
For exanplary damages in an amount necessary to punish defendants and to deter
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jurisdictional limits of this Court, according to proof;
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such conduct in the future, accordingto proofon PlaintifPs causes ofaction allowing
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punitive damages;
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For reasonable attomey's fees under the FEHA and under any applicable statute,
costs and expenses of litigation, according to proofon
Plaintiffs
causes of action
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allowing for attomeys fees;
d
For pre-judgmant and post-judgnent interest;
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For Injunctive relief to abate physical disability discrimination; including all
reasonable attorney's fees under the holding of Harris v. City of Santa Monic4
(2013) 56 Cal.4th 203;
For economic damages;
〃 〃 〃
PLANTIFF'S COPIPLANT FOR DANIAGES
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For non-economic damages;
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For such other and further relief as the Court may deem proper.
THE VELEZ LAW FRNI
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DATED:March 3,2016
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Kelsey A. Webber Esq.
Attomey for Plaintiff FANOUS
JURY DE市 AND
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PlalniffFANOUS hcrcby dmandstrlal byjury
Respectfu
lly Submitted,
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DATED:NIarch 3,2016
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THE VELEZ LAW FRNI
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Kelscy A Webber,Esq_
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Attorney for Plaintiff FANOUS
PLAINTIFF'SCOンIPLAINT FOR DAIIAGES
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