Cherniss Declaration

Case 2:18-cv-04987-FMO-GJS Document 35-2 Filed 06/15/18 Page 1 of 74 Page ID #:222
1 APALLA U. CHOPRA (S.B. #163207)

achopra@omm.com
2 DIMITRI D. PORTNOI (S.B. #282871)
3 dportnoi@omm.com
O’Melveny & Myers LLP
4 400 South Hope Street, 18th Floor
Los Angeles, CA 90071
5 Telephone: (213) 430-6000
6 Facsimile: (213) 430-6407
7 MATTHEW T. KLINE (S.B. #211640)

mkline@omm.com
8 PATRICK S. MCNALLY (S.B. #302062)
pmcnally@omm.com
9 O’MELVENY & MYERS LLP
10 1999 Avenue of the Stars, 8th Floor
Los Angeles, CA 90067
11 Telephone: (310) 553-6700
Facsimile: (310) 246-6779
12
Attorneys for Defendants
13 San Marino Unified School District, San
14 Marino Unified School District Board of
Education, Shelley Ryan, Lisa Link, Nam Jack,
15 C. Joseph Chang, Alexander Cherniss, and
Linda de la Torre
16
17 UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
18 WESTERN
19
20 CHRISTOPHER NORGAARD, Case No. 2:18-cv-04987-FMO (GJSx)
21 Plaintiff, DECLARATION OF DR. ALEX
CHERNISS IN SUPPORT OF
22 v. DEFENDANTS’ OPPOSITION
TO PLAINTIFF’S EX PARTE
23 SAN MARINO UNIFIED SCHOOL APPLICATION FOR
DISTRICT, et al., TEMPORARY RESTRAINING
24
ORDER
25 Defendants.
Hearing Date: N/A
26 Time: N/A
Place: Courtroom 6D
27 Judge: The Hon. Fernando M. Olguin
28
CHERNISS DECL. ISO OPP. TO TRO
2:18-CV-04987-FMO (GJSX)
1 DECLARATION OF DR. ALEX CHERNISS

2 I, Alex Cherniss, do hereby declare and state:
3 1. I am the superintendent of the San Marino Unified School District (the
4 “District” or “SMUSD”). I have personal knowledge of the matters set forth in this
5 declaration and if called to testify to the facts stated herein, I could and would do so
6 competently.
7 The SMUSD and My Role as Superintendent
8 1. The SMUSD is regularly recognized as one of the best school districts
9 in the state and nation, and oversees the education of over 3,000 students in San
10 Marino, CA, from Kindergarten through twelfth grade.
11 2. I have served as superintendent of the SMUSD for approximately four
12 years. In that role, I oversee the SMUSD’s day-to-day operations. Prior to joining
13 the SMUSD, I worked at the Los Angeles County Office of Education, and the
14 Beverly Hills Unified School District, among other education institutions.
15 3. I work with a capable, experienced team. One key member of my
16 team is Linda de la Torre, a 29-year veteran of the SMUSD who serves as the
17 District’s assistant superintendent for human resources.
18 Allegations Against Board Member Christopher Norgaard
19 4. In January 2018, I became aware that two female SMUSD employees
20 had alerted Ms. de la Torre to allegedly inappropriate behavior by Christopher
21 Norgaard, a member of the SMUSD Board of Education (“Board”).
22 5. One employee (“Jane Doe 1”) provided a written statement about two
23 disturbing alleged incidents, one in 2015 and another in 2016, in which
24 Mr. Norgaard allegedly hugged her and kissed her on the lips at SMUSD events.
25 6. Another SMUSD employee told Ms. de la Torre that a teacher had
26 reported that Mr. Norgaard was a “sloppy kisser.” While the teacher in question
27 noted that she did not want to pursue any claims against Mr. Norgaard, the
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1 employee who witnessed this and other conduct—including his frequently visiting
2 young, female employees—noted that this behavior made her uncomfortable.
3 7. These were not the first complaints of inappropriate behavior that I
4 have heard against Mr. Norgaard. When I became superintendent in 2014, I
5 became aware that in 2010, two complaints concerning conduct of a sexual nature
6 were made against Mr. Norgaard by two women who were not employees (“Jane
7 Doe 4” and “Jane Doe 5”). Attached hereto as Exhibit A is a true and correct copy
8 of a redacted email my predecessor Dr. Gary Woods received from his assistant
9 regarding one of those complaints. I also learned that Dr. Woods had raised the
10 claims with Mr. Norgaard, who denied them. In March 2015, a female SMUSD
11 employee (“Jane Doe 6”) alerted SMUSD leadership that she was regularly
12 receiving text messages from Mr. Norgaard during and after school hours that had
13 no relevance or relationship to her job with the SMUSD. As to the latter
14 allegations, the SMUSD spoke with Mr. Norgaard, but took no further action per
15 Jane Doe 6’s request.
16 8. As I understand it, the law imposes a duty on SMUSD to investigate
17 claims of potential workplace harassment, even when the allegations are made
18 against non-employees such as Mr. Norgaard. In light of the law and the
19 allegations made against Mr. Norgaard, SMUSD retained legal counsel to
20 investigate the allegations. The investigation was conducted by Nicole Miller &
21 Associates, a firm retained by our outside counsel.
22 The Investigation and What Followed
23 9. On January 22, 2018, Ms. de la Torre and I met with Mr. Norgaard and
24 gave him a letter informing him that “allegations of sexual assault [have been]
25 made against [him] involving District employees,” that the SMUSD “takes such
26 allegations very seriously,” and that we had initiated an investigation. We also
27 instructed Mr. Norgaard to refrain from visiting the SMUSD campuses absent
28
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1 authorization from me. Attached hereto as Exhibit B is a true and correct copy of
2 the January 22 letter.
3 10. Later that evening, I received a phone call from Mr. Norgaard, who
4 called to express his displeasure with our meeting earlier in the day, and told me
5 that the allegations and investigations better not be made public. I interpreted
6 Mr. Norgaard’s statement as a threat.
7 11. SMUSD had no intention to publicize the investigation or allegations
8 against Mr. Norgaard. On January 29, however, the San Marino Police Department
9 (to whom we had reported the complaints) issued its own press relief stating that it
10 was investigating an allegations made against a SMUSD Board member. Attached
11 hereto as Exhibit C is a true and correct copy of the San Marino Police
12 Department’s January 29 press release. SMUSD received press inquiries asking it
13 to confirm the press’ sources that Mr. Norgaard (and not another male Board
14 member) was the person in question. The SMUSD gave a brief statement (it did
15 not issue a press release, as Mr. Norgaard suggests) confirming that he was the
16 subject, declining to release any other details of the investigation, and confirming
17 that Mr. Norgaard remained an active member of the Board. Attached hereto as
18 Exhibit D is a true and correct copy of the SMUSD’s January 29 press release.
19 12. Just four days after Mr. Norgaard received the directive not to enter
20 campus without my permission, he violated it. On January 26, 2018, he went to
21 San Marino High School without first receiving or even seeking prior approval.
22 We again wrote to Mr. Norgaard and reiterated that he was not to go to any
23 campuses absent express authorization from the superintendent. Attached hereto as
24 Exhibit E is a true and correct copy of our January 26 letter to Norgaard.
25 13. Several weeks later, Mr. Norgaard again made what I perceived to be a
26 retaliatory threat. He asked for a copy of my employment contract. I found this to
27 be a threat because Mr. Norgaard had never before asked for a copy of my
28 employment contract, and it was highly unusual for him to make a point of
-5- 2:18-CV-04987-FMO (GJSX)
1 requesting a copy, when it is already publicly available and he had helped negotiate
2 it. Attached hereto as Exhibit F is a true and correct copy of an email I sent to
3 Ms. de la Torre on March 12, 2018 right after I was notified of Norgaard’s request.
4 14. On March 22, 2018, Nicole Miller & Associates completed its
5 investigation. Attached hereto as Exhibit G is a true and correct copy of the Miller
6 & Associates report, which has been redacted to protect confidentiality. I can
7 provide an unredacted copy to the Court and Mr. Norgaard, as a Board member,
8 received one as well.
9 15. Approximately two weeks after the release of the Miller report, Jane
10 Doe 1 filed a new confidential complaint regarding Mr. Norgaard’s behavior.
11 Attached hereto as Exhibit H is a true and correct copy of the redacted confidential
12 complaint, filed with Jane Doe 1’s permission.
13 16. And following the release of the Miller report, SMUSD was notified
14 that other individuals who were interviewed as part of the first investigation had
15 subsequently had uncomfortable experiences with Norgaard. Jane Doe 2 was
16 uncomfortable with Mr. Norgaard’s unannounced, unnecessary visits to her
17 workplace. Jane Doe 6, a former employee of SMUSD, also reported that Mr.
18 Norgaard twice attempted to phone one of her family members.
19 17. In response to these new allegations and the above, SMUSD
20 determined that it needed to launch a second investigation, led by another law firm.
21 That investigation remains pending.
22 18. On April 23, 2018, Norgaard sent claim notices pursuant to the
23 California Tort Claims Act to SMUSD, Ms. de la Torre, and myself. Attached
24 hereto as Exhibit I is a true and correct copy of the claim notice that he sent, along
25 with a copy of the draft complaint, which has been redacted to be consistent with
26 redactions made in the complaint Mr. Norgaard filed in this action.
27
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19. During the events above, Mr. Norgaard and his counsel have been
2 quoted in the press many times about these events and concerning this lawsuit.
3 Attached hereto as Exhibit J is a sampling of such news stories.
4
5 I declare under penalty of pe1jury under the laws of the State of California
6 and the laws of the United States of America that the foregoing is true and correct.
7 EXECUTED this �- day of June 2018 at Los Angeles County, California.
8 �1-+--11-r�--
9
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Surerintendent
11 San Marino Unified School District
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CHERNISS DECL. [SO OPP. TO TRO
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EXHIBIT A
Debra Kallas
From: Debra Kallas [dkallas@smusd.us]
Sent: Tuesday, August 03, 2010 12:32 PM
To: 'Gary Woods'
Subject: Call Received Concerning Board Member
Gary,
I received a voicemail message on Thursd , Jul 22nd from� concerning one of our Board
Members. After a few attempts to contact . she ref�oday at 12:00 Noon to explain the
situation. Frankly, I am a bit uncomfortab e in s ar ng this information but must do so.
shared that Mr. Nor aard had corresponded with her in numerous.(''1,000's")--
She was upset as he had denied this behavior�
eing unstab e and claimed she ha been stalklng him. �said she indicated she could provide proof
from IM messages and e-mails of this ongoing behavior. - Is considering filing a defamation of character
lawsuit against Mr. Norgaard at this point.
I do not know what our capacity is concerning this issue but suggested·- provide you with an e-mail
explaining the situation. Please let me know what my next steps should be.
may be reached at . Her e-mail address is
Thanks.
P. S. I also received an e-mail from an ... on 07/24 concerning the same Issue. I will forward that e-mail to
you.
Assistant to the Superintendent

San Marino Unified School District
1665 West Drive
San Marino, CA 91108
626.299.7000 x310
8/3/2010
EXHIBIT A
8
Pagel of l 1
Debra Kallas
From: schoi@smusd.us
Sent: Saturday, July 24, 2010 6:49 PM
To: dkallas@smusd.us
Subject: Fwd: Mail from San Marino Unified School District
Hi Debra,
This message came in through the website. Not sure if it1 s worth following up since there's very little to
follow on ..
Thanks, SC
-------- Original Message --------

Subject:Mail from San Marino Unified School District
Date:Sat, 24 Jul 2010 12:08:31 -0400 (EDT)
From: Elain �11.fil.Q.IJlrul.er��fltionaln��Qr�
Reply-To:Elain �Sir:nply t.,SN2826.@aol,�
To:sQ.ntact�musd.us>
This email Is automatically sent by IP address on Saturday, July

24, 2010 at 09:08 AM US/Pacific timezone.
>
Dear Sir,
You need to make contact with a woman regarding one of your board members. This mans behavior Is not acceptable
and is cause for concern,
-
It's lmpotant this information be kept confidential. If he dicovered this information was let out, he would become
emotionally abusive. I don't think the woman involved could handle more of 11'1at.
Please let me know sot can give you the contact information.
7/29/2010
EXHIBIT A
9
Case 2:18-cv-04987-FMO-GJS Document 35-2 Filed 06/15/18 Page 10 of 74 Page ID
#:231
EXHIBIT B
#:232
========San Marino U11ificd School :District

ADMINISTRATIVE OFFICES
1665WtsTORIVE
SAN MARINO, CALIFORNIA 91108-2594
TELEPHONE: (626) 299-7000
FAX: (626) 299-7010
January 22, 2018
Mr. Chris Norgaard

1615 S. Euclid Avenue
San Marino, CA 91108
Dear Mr. Norgaard,

The District has been notified of allegations of sexual harassment made against you involving
District employees. The District takes such allegations very seriously and as required by Board
policy and by law, has initiated a formal investigation regarding this matter.
To ensure the propriety of the investigation and to provide a safe environment for our employees,
effective immediately you are directed to refrain from contacting any District employee and to
remain off school and District grounds, except to attend a scheduled Board meeting, pending the
outcome of the investigation and any subsequent remedial steps, unless written approval is
obtained from the Superintendent at least 48 hours in advance. During any school visits or
activities on campus approved by the Superintendent, you would be accompanied by an
administrator and directed not to approach employees.
Should you have any questions or concerns, please do not hesitate to contact me or the
Superintendent at 626-299-7000 ext. 1310.
Sincerely,
. ssistant Superintendent/Human Resources
C: Dr. Alex Cherniss, Superintendent
EXHIBIT B
10
#:233
EXHIBIT C
Case 2:18-cv-04987-FMO-GJS Document 35-2 Filed 06/15/18 Page 13 of 74 Page
SMPD Press Releases I San Marino, CA - Official Website
ID
Page 1 of29
#:234
SMPD Press Releases
PRESS RELEASE
RELEASE DATE: January 29, 2018
SUBJECT: Battery Investigation
On Fri day, January 19, 2018, the San Marino Police Department received information
frcm tlhe San Marino Unified School District of an ongoing administrative investigation
related to a School Board Member.
Based on this information, the San Marino Police Department initiated a criminal
investigation, which is currently ongoing.
If you or someone you know has information that could lbe related to this investigation,
please contact Detective Sergeant Tebbetts of the San Marino Police Department at (626)
300-0722.
If you prefer to provide information ANONYMOUSLY, you may call ..Crime Stoppers"
by diaEing 800-222-TIPS (8477), te.xting the letters T!PLA plus your tip to CR.IMES
(274637).
http://v.n,vw. cityofsanmarino.org/808/SMPD-Press-Releases 6/14/2018

#:235
EXHIBIT D
#:236
Media Statement- Revised

January 29, 2018
The District has received allegations of improper conduct on the part of Mr. Chris
Norgaard, and has retained an outside investigative firm to handle the matter. The
District takes allegations of sexual harassment extremely seriously. The Board of
Education has adopted a clear policy, which requires the District to investigate
complaints of sexual harassment. When we receive complaints, it is our practice to
separate the accused from the school district while we investigate the matter so as to
not compromise the integrity of the investigation. The District is unable to comment on
behalf of the San Marino Police Department.
EXHIBIT D
12
#:237
EXHIBIT E
#:238
/<fl
_____�1/
____ San Marino Unified School District.__l_
1665 West Drive Telephone (626) 299-7000
San Marino, California 91108 Website: www.smusd.us
Superintendent
Dr. Alex Cherniss
Board President January 29, 2018

Mr. C. Joseph Chang
Board Vice President Dear Mr. Norgaard,

Mrs. Shelley Ryan
On Monday, January 22, 2018, you received a letter notifying you of sexual
Board Clerk harassment allegations made against you involving District employees. The letter
Mrs. Lisa Link stated in part,
Board Member To ensure the propriety of the investigation and to provide a
Mr. Chris Norgaard safe environment for our employees, effective immediately
you are directed to refrain from contacting any District
Board Member
Mrs. Nam Jack
employee and to remain off school and District grounds,
except to attend a scheduled Board meeting ...
It was brought to my attention that subsequent to receiving this letter, on Friday,

January 26th, you entered the San Marino High School campus at approximately
3:25pm and met with the high school principal, Dr. Issaic Gates, until
approximately 4:05pm.
Your failure to follow the District directives threatened the integrity of the
investigation. If this occurs again, it will be treated as trespassing under Penal
Code sections 626.4, 626.7, and 626.8.
I ask that you respect the integrity of the investigation process and cooperate
with the District directives.
·�
Sincerely,
� ��
Al�, ..
Superintendent
Our Vision
"Delivering a world-class
education with recognized
excellence in academics,
arts, and athletics."
005878.00001
18721127.1
EXHIBIT E
13
#:239
EXHIBIT F
#:240
5/31/2018 Sao Marioo Umfied School Distmrt Ma,I - Call tooight
IF!)
SMUSD Linda de la Torre <hrtorre@sm�
Call tonight
1 message
Alex Cherniss <acherniss@smusd.us> Mon, Jan 22, 2018 at 9:27 PM

To: Linda de la Torre <hrtorre@smusd.us>, SAndelson@aalrr.com
Chris Norgaard called me tonight at 8:30 pm and expressed his displeasure at the "tone of the meeting". He also
threatened me by saying that this incident "better not become public or else".
I told Chris that Linda and I were just following our direction of counsel and making sure we were following the law.
He stated a desire to go to the basketball game on Friday but only if he did not have to adhere to the rules outlined in the
letter.
I told him I could not accommodate this. He would need to be accompanied by a school administrator per the directives
in the letter he received today. He said he would not go to the game if this was the case.
Alex Cherniss, Ed.D.

Superintendent
626-299-7000 X1310
https://mail .google .com/mail/u/0/?ui=2&ik=db2b97 cbcc&jsver=-dxVNc9Y02g .en .&cbl=gmail_fe _180516.06 _p8&view=pt&q=alex&qs=true&search=query&th=1612
EXHIBIT F
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#:241
EXHIBIT G
#:242
NICOLE MILLER & ASSO CIATES, INC .

PRIVATE I NVES'".rI GAT I ONS PI 28276
CONFIDENTIAL ATTORNEY-CLIENT PRIVILEGE

INVESTIGATION SUMMARY
Date of Report;
Thursday, March 22, 2 0 1 8
Reporting lnvestj�ators;
Lisa Strachan, Senior Investigator, Administrative and Em p loyee Relations
N icole Miller & Associates, I nc. conducted an investi gation involving rep o rted claims by
several female em p l oyees that Boa rd of Education member, Chris Norgaard, at the San
Marino Unified School District e n ga ged in ina pp rop riate conduct and p otential sexual
harassm ent toward female District em p loyees wh ich included unsoli cited huggin g and
kissin g of female em p l oyees , visiti n g youn g female em p loy ees in the workp lace, and
co ntacti n g female em ployees outside of work hours re gardin g non-District related matters .
N icol e M iller & Associates, I nc., con cl uded M r. Nor gaard d i d en gage in this behavior.
H owever, Mr. Norgaard's conduct was not found to be sexually motivated , nor was it
p erceived to be sexually motivated or rega rded as offensive by the female witnesses.
Rather, M r. Norga ard was commonly described as someone who is considerably friendl y
and may not be p ercep tive in observin g p rofessional boundaries at times.
lNYESTIGATIYG PRQC6DURES
Based on th ese claims, and pursuant to B oard Policy, the District's law firm of Atkinson ,
Andelso n , Loya , Ruud and Romo, on Tuesday, J anuary 2 3, 2018, re q uested that Nicole
Miller & Associates, I nc. conduct an investi gation i nto these concerns.
A tota l of 1 0 ind ividuals, i nclud i n g M r. Norgaard , we re intervi ewed in fu rtherance of the

nvestigation. All i ndivid uals inte rviewed for p urposes of the in vesti gation were n otified of
the Distri ct's retaliation policy, and were further advised to kee p the informati on discussed
herein confi dential in order to protect the rights of all parties J nvolved. Investi gative
determinations were made based on witness testimony and witness credibility. For all
factual fi ndings in th is re port, Nicole M iller & Associates, Inc., used a p rep onderance of the
evidence standard. This standard requires findin gs to be substantiated when the evidence
i ndicates a p articular fact or event was m ore likely than not to have occurred.
ALLEGATIONS AND FINDINGS
Allei:ation No, t:
It was alleged that Mr. Norgaard often gave unsolicited hugs and kisses as a form ofgreeting.
These kisses h a ve been described as "sloppy, " and on at least two occasions, Mr. Nor{Jaard was
a lleged to have kissed a female District employee on the lips.
905 Calle Negocio # 74182 San Clemente, CA 9 2 673
Te l 949. 3 1 0 .7645 email nmHler@nmillerfnv.com
EXHIBIT G
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CONFIDENTIAL ATTORNEY-CLIENT PR!VJLBGB
findine to AHeeationNo,1;
The allegation that Mr. Norgaard often greets others with a hug or kiss is substantiated.
When asked about the matter, Mr. Norgaard admitted he ''might" hug or kiss people who he
has known for a long time, but that the greeting is often initiated by the. other person
leaning toward him first Mr. Norgaard said some District employees and "lots of PTA
people" hug or kiss him on the cheel< as a form of greeting. Mr. Norgaard was unable �o
estimate how often he engaged in such greetings, but alleged this did not occur in a
professional setting, on campus or near classrooms. Mr. Norgaard said hugs or kisses as a
form of greeting were more likely to occur during social events, such as school sporting
events or community gatherings. Mr. Norgaard said that while hugs and kisses as a form of
greeting are not necessarily a pervasive occurrence within the District, "it happens." Mr.
Norgaard provided several examples of female District employees or representatives who
have hugged or kissed him, sometimes on the lips, as a form of greeting. Mr. Norgaard said
that even though he maintains professional relationships with these individuals, he
considers some to be personal friends. Mr. Norgaard said his kisses as a form of greeting
are generally limited to the cheek and, even then, are not a frequent occurrence,
Mr. No11gaard confirmed there have been occasions wherein a kiss on the lips occurred
between him and a female District employee. The investigation revealed both parties
perceived the other person to have initiated the kisses as a form of greeting. The witness
who reported this occurrence did not perceive the kisses as sexual advances or threatening
in any way; however, the incidents still made her uncomfortable. It should be noted,
however, that this witness perceived Mr. Norgaard to have respected her boundaries and
refrained from engaging with her further after she made efforts to physically distance
herself from Mr. Norgaard on occasions when they were present in the same place.
Although Mr. Norgaard claimed his hugs and kisses as a form of greeting did not occur In a
professional setting, on campus or near classrooms, two witnesses corroborated an
occasion when Mr. Norgaard approached them on campus and kissed them on the cheek as
a form of greeting. When specifically questioned about this incident, Mr. Norgaard
admitted the behavior likely occurred as he considers both parties to be friends. The
investigation finds it important to note, both witnesses maintained they were not offended
or made to feel uncomfortable by Mr. Norgaard's behavior, nor did they perceive Mr.
Norgaard's actions as sexual in nature.
AlleJ:ationNo. 2;
It was alleged that Mr. Not-gaard often engaged In prolonged conversations with female staff
members. He was reported as visiting the offices ofthese staff members during the course of
their work day. It was alleged that Mr. Norgaard most often visited with young, attractive
female employees over others.
FiodlnatoAUee-atioo No.2:
In consideration of credible witness statements and Mr. Norgaard's own admission, the
allegation that Mr. Norgaard visited the offices of female staff members during the course
EXHIBIT G
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CONFIDENTIAL ATTORNEY-CLIENT PRIVILEGE
of their work day is substantiated. Mr. Norg aard said that on occasions when he visits
District campuses for the purpose of meeting with school site admi nistrators, he sometimes
greets or enga ges in small tal k with employees whose offices are in close p roximi ty to the
p erson with whom he ori ginally p lan ned to meet. The i nvestigator finds it im p ortant to
note that none of the witnesses who experienced M r. Norgaard's visits firsthand re p orted
the y were made to feel uncomfortable by M r. N orgaard's behavior. Further, they did not
re p ort that Mr. Norgaard en ga ged in p rolon ged conversations, notin g instead that the
conversations were limited to brief small talk.
While the claim was made that M r. Norgaard most often visited with youn g, attractive
femal e em p loyees over others, the investi gator finds this to be a subj ective and somewhat
limited observation. Although the em p l oyees who were s p ecifically named as p arties with
whom Mr. Norgaard sometimes visited may be described as youn g, attractive females, the
nvestigation revea led no evidence to suggest Mr. Norgaard only visited with young,
attractive female em p loyees. Rather, Mr. Norgaard named several male facul ty and
administrators with whom he regularly· visited as well.
Alleeation No. 3:
Jt was reported tha t in the past Mr. Norgaard contacted female District employees on their
personal time about non -work related matters anrl despite verbal admonition by Human
Resources, he con tinued to con tact or send text messages to female employees about personal
ma tters outside of work hours.
Findioe to Alleeation No, 3:

The allegation that M r. Norgaard communicates with District em ployees outside of work
hours about matters that could be considered non -work related is substantiated. M r.
Norgaard stated that these exchan g es typ ically involve logistics about District-related
matters or activities, such as sportin g events, M r. Norgaard admitted he has also en gaged
in a mutual text messa ge exchan g e about with one female em p loyee - a
matter that was corroborated by the em p loyee but not re p orted as a matter of concern.
The investi gator finds it i m p ortant to note Mr. Norgaard did not recall havi n g received an
admonition by Human Resources not to en gage in contact with female Distl'ict em ploy ees;
since th e admo nition was not documented, the investi gation revealed no evidence to
su ggest M r. N orgaard knowingly defied the District's re q uest.
One female witness reported a pl:"olonged exchange with Mr. Norgaard about non-District
related matters. The exchan ge wa initiated by M r. Norgaard after the witness s to pp ed
working for the District. Per M r. Norgaard's own admission, he reached out to the witness
sim pl y to "catch u p ." M r. Norgaard corroborated on his own accord many of the details
shared by this witness to include that he
Their statements were mostly In line althou gh Mr. Norgaard and the former em p lo yee
exhibited different perceptions of the exchan ge. For exam p le, while the former em p loyee
erceived M r. Nor aard's invitation as somewhat of a date, alleging that he suggested they
, M r. Norgaard claimed the invitation
was for the former employee to join a group. M r. Norgaard denied suggesting the two go
EXHIBIT G
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CONFIDENTIAL ATTORNEY-CUBNT PRJVIl.EGE
. While Mr. Norgaard described the interaction as a

mutuaJ and pleasant conversation, the former employee expressed discomfort about the
situation as a whole.
CONCLUSION
In accordance with our findings, N icole M iller & Associates, Inc., concluded Mr. Norgaard
did, at times, engage in unsolicited hugging and kissing of female employees, visited young
female emp loyees in the workplace, and conta cted female employees outside of work hours
regarding non-District related matters.
Overall, Mr. Norgaard was described by witnesses as a friendly individual who is well
known within the community. The majority of witnesses interviewed in conjunction with
the current investigation denied concerns regarding M r. Norgaard's behavior. While one
female employee was made to feel uncomfortable by M r. Norgaard kissing her on the lips,
and another former employee expressed concerns about a telephone conversation shared
with Mr. Norgaard after she left the District, none of the witnesses interviewed perceived
M r. Norgaard's behavior as sexually motivated. Rather, M r. Norgaard was commonly
described as someone who at times fails to recognize professional boundaries and may not
pick up on social cues in his interactions with others.
Mr, No rgaard appeared to understand h ow his behavior could be perceived as a concern by

the District, although he maintained he did not have negative or inappropriate intentions.
Given Mr. Norgaard's demonstrated reasonableness, the investigation finds it highly likely
that as result of this investigation, M r. Norgaard would be willing to abide by clarified and
reasonable guidelines as to his behavior moving forward.
Sincerely,
Lisa Strachan, Senior Investigator, Administrative and Employee Relations

Nicole Miller & Associates, Inc.
EXHIBIT G
18
#:246
EXHIBIT H
#:247
CONFIDENTIAL Complaint
To: Linda de la Torre, Assistant Superintendent Human Resources
From:
Re: Sexual Harassment/Gender Discriminatio

Date: April 9, 2018
In January 2018, I provided the Human Resources Department with a written statement regarding two
incidents which occurred wherein Board Member Mr. Christopher Norgaard kissed me on the lips. The
first incident occurred at the Hauntington Breakfast in October of 2015.
Mr. Norgaard approached me, gave me a hug, and kissed me on the lips. I was shocked
and taken off guard; but, it happened in a crowd of people and I didn't know how to react so I just kept
talking and acted like nothing had happened. I felt very uncomfortable afterward and wondered why he
would think that it was justifiable to kiss me on the lips.
In March of 2016, I was during open house. Mr.

Norgaard approached me and abruptly kissed me on the lips again. I felt violated and embarrassed
because he crossed a boundary, that as my superior, he should not have crossed. I immediately walked
away and started talking with other people. The second kiss on the lips bothered me even more than the
first because it validated that the first was not an accident.
I feel that Mr. Norgaard has taken advantage of my vulnerabilities as his subordinate. He is a Board
Member perceived by many to have a lot of power and influence in the community and certainly over
employees in the District. During the last several years,
, he would frequently stop by my desk and make small talk, which was unrelated to school
business. Once he invited me to join him at the Lacy Park 4th ofJuly event. He told me he had VIP tickets
and that I should come. I politely declined telling him I had other plans with my family. I did not want to
create problems for the District so I just decided that instead of complaining, I would work hard to avoid
being in a situation ever again where Mr. Norgaard would be close enough to kiss me. My plan was to
intentionally keep my distance from him. When I saw him coming , I would either walk to
the back or make sure to stand behind some physical barrier like a desk or counter.
l am and need my Job to . I have worked for the District for
without any problems. I consistently receive high marks on my performance evaluations and have. a long
history of receiving promotions.
In January when I told the Assistant Superintendent of Human Resources about the kisses, I told her that
I didn't want to complain about Mr. Norgaard because I didn't want to get in trouble.
EXHIBIT H
19
--
#:248
a i,d that I didn't want to jeopardize our relationship with the District. She assured
me that I would not be reta liated against.
On April 2, 2018, The Assistant Superintendent asked to meet with me to discuss the investigative findings.
She said that she would discuss the releva nt part of the decision affecting my specific complaint. She told
me that the allegation that Mr. Norgaard greets othe rs with a kiss was substantiated and that Mr.
Norgaa rd confirmed there h ave been occasions wherein a kiss on the lips occurred between him and me.
She also said the investigation revea led that Mr. Norgaard perceived that I initiated the kiss. The
investigator wrote that I said that Mr. Norgaard respe cted my boundaries after these incidents and
refrained from e ngaging me further a fte r I made efforts to physically distance myself from him when we
were in the same roo m . She also informed me that the investigator i ndicated that I did not perceiv_e the
kisses as sexua lly motivated or threatening in any way, She then stated that the law firm found that the
incidents did not rise to the level of "severe and pervasive" and that it was therefore concluded that the
Board Member's con d uct did not constitute sexual harassment.
I d isagree with the results of this investigation. Is the District saying that it is ok for bosses (Board
Members) to kiss the ir employees o n the lips at school events? Is it acceptable for a Board M ember to
a ccuse his accuser of initiati ng the kisses when he knows that is a lie? Is this the retaliation that I feared
would come if I complained? I feel like this whole thing is a nightmare. I am sick to my stomach, haven't
been able to sleep, have anxiety and feel like the District isn't ta king these complaints seriously.
I was afraid to complain for fea r of retaliation. I have spe nt a lot of time thinking about the questions I've
been asked by the District investigator and the police and the truth is I DO believe that the kisses were
sexually motivated. Why else would he kiss m e o n the lips? How many people do you know who get
kissed on the lips by their boss's boss at wo rk? I felt uncomfortable beca use I knew it wasn't appropriate
behavior. I felt uncomfo rtable because my personal boundaries were violated by a ma n in a position of
power. Does he kiss other people/employees on the lips or just me? Why me? I have neve r been kissed
by any other Boa rd Membe r, Superintendent, Assistant Superintendent, Principal, Assistant Principal or
Director on the lips. This is NOT right and no one should have to come to work every day worrying about
having a boss come in and kiss them on the lips. Why should I as a victim, have to figure out how to
physically avoid him instead of him being told by the District to stop violating me? It's demeaning,
h umiliating and disgusting. I was afraid to compla in out of fear and now my fears are coming true.
I a m now forced to consult with a n attorney to make sure that I am protected against further retaliation
from this Board Member and would like the District to reconsider the u n professional manner in which it
allows fts a uthority figures to treat/ha rass employees.
EXHIBIT H
20
#:249
EXHIBIT I
#:250
.Jf\ Z ER.
E
LOS ANGELES PARTNERS A LI M ITED LIAnlL.ITY IAW P,\RTNERSH IP 7CJ7 \\'IL.SHIRE BOULEVARD
GUY P. G LAZIER SUITE 2025
DEBORAH M PARKER LOS ANGELES, CALIFOR�IA 900 1 7
SAN FRA NCISCO PARTNERS

April 23, 20 1 8 TELEPHONE (2 1 3) 31 2-9200
LAURA PATRICIA YEE FACSIMILE (2 1 3) 31 2-920 1
B RIAN T CLARK W\�w.glazierycc.<:om
Via Personal Deliverv and U.S. Mail

c/o Dr. Alex Cherniss, Superintendent
1665 West Drive
San Marino, California 9 1 1 08
Re: Clrristop/rer Norgaard vs. San Mari1to U11ijied Sc/rool District, et al.
Dear Dr. Chemiss,

Pursuant to California Government Code Section 8 1 0 et seq. , Government Claims Act,
Christopher Norgaard provides San Marino Unified School District ("SMUSD"), Superintendent
Alex Chemiss, and Assistant Superintendent (Human Resources) Linda de la Torre with this
timely claim.
Claimant's name and address:
Mr. Christopher Norgaard, 1 6 1 5 South Euclid Ave., San Marino, California 9 1 1 08.
The post office address to which Mr. Norgaard desires notices be sent:
Glazier Yee LLP, 707 Wilshire Blvd., Suite 2025, Los Angeles, California 900 1 7.
Please find attached a draft complaint in the subject case. This complaint has not yet
been filed or served. The complaint provides a written accounting signed by Mr. Norgaard's
legal representative of the following:
1 . The dates, places, and circumstances giving rise to this claim;
2. A description of the injury incurred thus far;
EXHIBIT I
21
#:251

April 23, 20 1 8
Page 2
3. The names of the employees involved; and

4. The amount of damages, which exceed the limited civil case jurisdiction.
Guy P. Glazier
EXHIBIT I
22
#:252
LOS ANGELES PART:'l: ERS A LII\IITED LIABILITY LAW PARTN ERSHIP 707 WIL'iH IRE BOULC\'ARD
GUY P. GLAZIER SU ITE 2025
DEBORAH M PARKER LOS ANG ELES, CALIFORNIA 900 1 7
SAN FRANCI SCO l'ARTNERS

April 23, 20 1 8 TELEPHONE (2 1 3) 3 1 2-9200
LAURA PATRICIA YEE FACSIMILE (2 131 3 1 2-920 1
B RIAN T. CLARK www.glazieryee.rom
Dr. Alex Cherniss

1 665 West Drive
Re: Cl,ristopl,er Norgaard vs. Sa11 Marino Unified Scl,ool District, et al.
Dear Dr. Cherniss,
Pursuant to California Government Code Section 8 1 0 et seq., Government Claims Act,

Alex Chemiss, and Assistant Superintendent (Human Resources) Linda de la Torre with this
timely claim.
Mr. Christopher Norgaard, 1 6 1 5 South Euclid Ave., San Marino, California 9 1 1 08.
1 . The dates, places, and circumstances giving rise to this claim;
2. A description of the injury incurred thus far;
EXHIBIT I
23
#:253
Dr. Alex Cherniss

April 23, 2018
Page 2

Guy P. Glazier
EXHIBIT I
24
#:254
_./-\ZI
E
LOS ANGELES PARTNERS A LIM ITED LIABll lTY l .:\W PARTI\ERSHIP 707 WILSHIRE BOU LEVARD
GUY P. GLAZIER SUITE 2025
DEBORAH M. PARKER LOS ANGELES, CALIFORNIA 900 1 7
April 23, 20 1 8 TELEPHONE (2 13) 3 1 2-9200
SAN FRANCISCO PARTNERS
u\U RA PATRICIA YEE FA CSIMILE (2 13) 31 2-920 1
BRIAN T. CLARK w\,w.glazit:ryee.<.:om
Linda de la Torre
1 665 West Drive
Re: Christopher Norgaard vs. Sa11 Marino Unified School District, et al.
Dear Ms. de la Torre,
Pursuant to California Government Code Section 8 1 0 et seq., Government Claims Act,

Alex Cherniss, and Assistant Superintendent (Human Resources) Linda de la Torre with this
timely claim.
Mr. Christopher Norgaard, 1 6 1 5 South Euclid Ave., San Marino, California 91 1 08.
I . The dates, places, and circumstances giving rise to this claim;
2. A description of the injury i ncurred thus far;
EXHIBIT I
25
#:255
Ms. Linda de la Torre

April 23, 2018
Page 2

Guy P. Glazier
EXHIBIT I
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#:256
GLAZIER YEE LLP

1 GUY P. GLAZIER, SBN 1 62628
glazier@glazieryee.com
2 DEBORAH M. PARKER, SBN 228203
parker@glazieryee.com
3 707 Wilshire Boule\'ard, Suite 2025
Los Angeles. California 900 1 7
4 Telephone: 2 1 3-3 1 2-9200
Facsimile: 2 1 3-3 1 2-9201
5
Attorneys for Plaintiff
6 CHRISTOPHER NORGAARD
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
FOR THE COUNTY OF LOS ANGELES
9
CHRISTOPHER NORGAARD. CASE NO.
10
Plaintiff.
11
COMPLAINT FOR:
12
\"S.
1. DEFAMATION PER SE;
THE SAN MARINO UNIFIED SCHOOL 2. INTENTIONAL INFLICTION OF
13 DISTRICT; El\lOTIONAL DISTRESS;
3. NEGLIGENT INFLICTION OF
14 ALEX CHERNISS, INDIVIDUALLY AND AS EMOTIONAL DISTRESS;
SAN MARINO UNIFIED SCHOOL DISTRICT 4. VIOLATION OF 42 U.S.C. § 1983;
15 SUPERINTENDENT; 5. VIOLATION OF Cl\'IL CODE § 52.1;
16 and
LINDA DE LA TORRE. INDIVIDUALLY
AND AS SAN MARINO UNIFIED SCHOOL 6. INJUNCTIVE RELIEF PURSUANT TO
17 D ISTRICT ASSISTANT SUPERINTENDENT CAL. Cl\'. PROC. CODE §§ 527, 527.6.
(HUMAN RESOURCES); and
18 DEMAND FOR A JURY TRIAL
DOES 1 through 20.
19
Defendants.
20
21
I. INTRODUCTION
22
1. Apparently seizing upon the #MeToo movement for cover, San Marino Unified
23
School District (S1'.·f USD) Superintendent Alex Chemiss and Assistant Superintendent for Human
24
Resources Linda de la Torre fabricated false claims of allegations of sexual harassment and embarked
25
on an effort of which the only reasonably foreseeable effect would be to pennanently damage and
26
possibly destroy the personal and professional name. character, and life of San Marino School Board
27
member. Mr. Christopher Norgaard. In \'iolation of Sl'vtUSD policy concerning the confidentiality of
28
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EXHIBIT I
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1 on-going investigations. Chemiss and de la Torre published to multiple news media outlets false and
2 scurrilous claims that allegations of sexual harassment had been made for which Mr. Norgaard was
3 under investigation. In violation of California Penal Code § 148.5, Cherniss and de la Torre falsely
4 reported to the San Marino Police Department (SMPD) claims that Mr. Norgaard was alleged to have
5 engaged in sexual harassment constituting what the SMPD would characterize in its own public
6 announcement as '·battery." and "based on [which] infonnation," the SMPD ••initiated a criminal
7 investigation:·
8 2. In fact. contrary to the published statements distributed by Chcrniss and de la Torre to
9 multiple news media outlets. law enforcement, and others no ·'complainant(s)" had e,·er made any
10 "allegations'· against Mr. Norgaard as ·'the accused" of ··sexual harassment.•· sexual assault. other
11 assault. or battery. Mr. Norgaard has never committed any such misconduct. never violated any law
12 or policy related to such matters. and never bcha,·ed in a manner that reasonably could be interpreted
13 to constitute such misconduct. Nobody ever claimed that he did. Aware that no \'iable complainant
14 o f such misconduct existed. Chemiss and de la Torre nevertheless claimed that there were
15 '·allegations• · of "sexual harassment.'" c011\"ened an official investigation using SMUSD resources
16 (but without obtaining prior authorization from the S MUSD Board o f Education), publicized the
17 im·estigation. and marshalled a parade of humiliations to publicly demean Mr. Norgaard. After
18 devoting more than fourteen years of dedicated and recognized service to the advancement of the
19 primary and secondary education of San i\farino's youth. Mr. Norgaard can now find himself
20 featured on social media sites as the sponsor of ··rape culture."
21 "· After an independent im·estigation that exonerated i\lr. Norgaard. Defendants .
22 unsatisfied with the hann that they already had inflicted upon Mr. Norgaard. aware of their own
23 precarious legal position. and intent on further silencing and intimidating Mr. Norgaard. le\'eled yet
24 another set of false and outrageous claims against Mr. Norgaard. Their next salvo sought completely
25 to strip Mr. Norgaard of his ability to pcrfonn his duties as a member of the School Board pending a
26 second investigation of what Defendants claim is Mr. Norgaard " s ongoing retaliatory threats.
27 bullying. intimidation. and harassment of Chemiss. de la Torre. and other SMUSD personnel . Yet.
28 Defendants again can supply no factual basis for such an investigation. in large part because Mr.
2
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EXHIBIT I
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1 Norgaard has had ,·ery little contact with Cherniss, no contact with de la Torre, and minimal contact
2 with any other SMUSD employees since the beginning of the first in\'estigation.
3 4. Cherniss, de la Torre. and the SMUSD ha\'e slandered, harassed. and publicly
4 humi liated Mr. Norgaard. subjected Mr. Norgaard to severe emotional distress, and deprh·ed Mr.
5 Norgaard of his civil rights under California and federal law.
6 II. PARTIES
7 5. Plaintiff Christopher Norgaard is a resident of the City o f San Marino i n the County of
8 Los Angeles. California. At all times relevant, he was a member of the San Marino Unified School
9 District's Board of Education.
10 6. Defendant Alex Cherniss is a resident of Los Alamitos in the County of Orange.
11 California. At all times relevant, he was the Superintendent of Schools for the San Marino Unified
12 School District located i n San Marino. California. Defendant Cherniss is sued i n his individual and
13 official capacities.
14 7. Defendant Linda de la Torre is a resident of Azusa in the County of Los Angeles.
15 California. At all times relevant. she was the Assistant Superintendent fo r Human Resources o f the
16 San Marino Unified School District located in San Marino. California. Defendant de la Torre i s sued
17 in her indi,·idual and official capacities.
18 8. The District offices of Defendant San Marino Unified School District arc located at
19 1 665 West Dri\'e, San Marino. California 9 1 1 08 i n the County of Los Angeles. Upon infonnation
20 and belief. Defendants Cherniss and de la Torre were the policy-makers for Defendant SMUSD on
21 the actions taken against Plaintiff as alleged herein. Defendants C'herniss and de la Torre. directly or
22 by delegation. had final policy-making authority with respect to SMUSD's actions in dcpri\'ing
23 Plaintiff of his constitutional rights as alleged herein including. but not limited to. his First
24 Amendment right to freedom of association and freedom of speech. his Fourteenth Amendment right
25 not to be deprived of constitutional rights without substantive and procedural due process of law, and
26 his constitutional right to privacy.
27 9. Plaintiff does not presently know the true names and or capacities with respect to the
28 acts complained of herein of the defendants sued herein as Does I through 20. inclusive. Plaintiff
CO:\IPLAl�T
EXHIBIT I
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1 will file an Amendment to Complaint (Fictitious 'lncorrect Name) Los Angeles Superior Court fonn
2 CACI\' 105 to allege such Doe defendants' true names and capacities as soon as Plaintiff ascertains
3 them.
4 1 0. At all times rele\'ant. unless otherwise alleged, each of the defendants was the ser\'ant.
5 principal. employer, employee, coconspirator and or agent of every other defendant, and doing the
6 acts alleged in this complaint, was acting individually and within the authority of that agency o r
7 employment, and in furtherance of the conspiracy and with knowledge and consent of each of the
8 other defendants.
9 III. VENUE AND JURISDICTION

10 1 1. \ 'enuc and jurisdiction arc proper because at least one of the indi\'idual defendants
11 resides in the County of Los Angeles. State of Califomia.'and defendant SMUSD is located in the
12 County of Los Angeles, State of California.

13 IV. COMPLIANCE WITH GOVERNMENT CLAIMS ACT
14 1 2. On or about April 23. 201 8, Plaintiff Christopher Norgaard presented Defendants
15 SMUSD. Alex Chemiss. and Linda de la Torre with a claim pursuant to California Go\'crnmcnt Code
16 Section 8 1 0 et seq .. Go\'cmment Claims Act. Plaintiff Christopher Norgaard's legal represcntati\'e
17 signed the claim that stated the following: �lr. Norgaard's name and address: the post office! address
18 to which .M r. Norgaard desires notices sent; the dates. places. and circumstances gh"ing rise to his
19 claim; a description of the injury incurred thus far: the names of the employees in\"Ol\'cd: and the
20 amount of damages. which exceed the limited ci\'il case jurisdiction.
21 13. After a rejection of Plaintiff Christopher Norgaard 's claim or no response. Plaintiff
22 Christopher l'iorgaard filed the present action.
23 \'. BACKGROUND
24 1 4. San Marino. California is a small Los Angeles suburb bordered by Pasadena, South
25 Pasadena, Alhambra, and San Gabriel. San Marino is three square miles of close. tight-knit
26 community. Many of its residents know each other and greet each other affectionately. San Marino
27 families are active in local churches. charities. and civic organizations and clubs. Little League
28 baseball and softball and Crown City soccer are major youth activities. The editor of the oldest local
CO:\IPLAI�T
EXHIBIT I
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1 newspaper is a community favorite, who doubles as the announcer for high school games and emcees
2 local charity auctions. In S an Marino . City Council and School Board candidates are neighbors of
3 one another and of their voters. TI1ey stand and are introduced at community events like Rotary Club
4 meetings, high school sporting e\·ents. and the annual Memorial Day Remembrance in Lacy Park at
5 the end of every May. Most School Board members greet their friends, neighbors. colleagues, and
6 associates with a hand shake or a hug and a kiss. It is customary and it is considered common
7 courtesy and friendliness in this town.
8 1 5. By far and away the greatest source of pride to its residents are San Marino's
9 unparalleled and award-winning schools. For the past 1 5 years, S[\vfUSD has ranked as the number
1O one unified school district in California on the Academic Performance Index (API) and the more
11 recent C AASPP system that replaced the API. Each of its four schools, Carver Elementary.
12 Valentine Elementary. Huntington Middle School. and San Marino High School have consistently
13 ranked i n the top echelon of California schools. If Little League is big. the PTA is enormous. To say
14 that the residents of San Marino care about their schools is to say that the Dodgers care about
15 wiMing the World Series.
16 1 6. For more than fourteen years. elected to his scat on the San Marino Board of
17 Education (School Board) i n 2003 and re-elected in 2007 and 10 1 1 (there was no election in 20 1 5
18 because no candidate ran i n opposition). Mr. Christopher Norgaard has been entrusted by San l\forino
19 voters with the stewardship. guidance. and leadership of SMUSD. Mr. Norgaard has served as
20 President of the Board . Vice President. and Clerk. He is the Board Chair for legislati\·c action and
21 was a founding member of the Board " s Academics Advisory Committee . its Athletics Ad\'isory
22 Committee. and its Cell Tower Ad\'isory Committee. He was a Board rcpresentati\'e on the Task
23 Force for the Stoneman School site. He is also a member of the Board of the Los Angeles County
24 School Trustees Association. He is directly responsible for the success of San Marino schools over
25 the last fifteen years.
26 1 7. Prior to his election to the School Board. Mr. Norgaard served as a trustee and
27 President of the San Marino Schools Foundation. the private charitable organization that ser\'es as a
28 key component of financial support for the San Marino schools. He continues to sen-e as an
5
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1 associate trustee of the Foundation. He ser\'ed as a member of the SMUSD budget ad\'isory
2 committee before being elected to the Board. He is a member of the San Marino City Club and
3 fonnerly scr;ed on its Board of Go\'emors. He is also a member of the San Marino Rotary Club.
4 1 8. Mr. Norgaard has lived in San Marino for more than 37 years. He and his family ha\'e
5 been inrnlved in a wide range of ciYic activities. A graduate of Stanford University and the
6 Georgetown Uni\'ersity Law Center. Mr. Norgaard is a lawyer in downtown Los Angeles. He has
7 authored a book and several articles on a \·ariety of legal issues. Before the events outlined in this
8 complaint, Mr. Norgaard maintained a successful law practice focusing on business litigation,
9 intellectual property and real estate.
10 VI. THE BOMBSHELL FALSE ACCUSATION AND THE FOLLOW-ON
11 INTll\llDATION AND HARASSMENT
12 1 9. On l\fonday, January 22. 20 1 8. at the start of a scheduled weekly update meeting
13 between SMUSD Superintendent Alex C'hemiss and l\fr. Norgaard. Chcmiss and Assistant
14 Superintendent Linda de la Torre handed Mr. Norgaard a letter that read as follows:
15 Dear Mr. Norgaard,
16 The District has been notified of allegations of sexual harassment against you in\'Oh'ing
17 District employees. The District takes such allegations \·ery seriously and as required by
18 Board policy and by law, has initiated a formal investigation regarding this matter. To ensure
19 the propriety of the investigation and to pro\'ide a safe e1wiromncnt fo r our employees,
20 effective immediately you arc directed to refrain from contacting any District employee and to
21 remain o ff school and District grounds. except to attend a scheduled Board meeting. pending
22 the outcome of the investigation and any subsequent remedial steps. unless written approYal is
23 obtained from the Superintendent at least 4S hours in advance. During any school \'isits or
24 activities on campus approved by the Superintendent, you would be accompanied by an
25 administrator and directed not to approach_ employees. Should you have any questions or
26 concerns. please do not hesitate to contact me or the Superintendent at 626-299-7000 ext.
27 1 3 1 0.
28 S incerely, Linda de la Torre. Assistant Superintendent Human Resources
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1 C: Dr. Alex Chemiss. Superintendent
2 20. Unbeknownst to Mr. Norgaard at the time. this letter was materially and maliciously
3 folse in that nobody had notified the SMUSD of allegations of sexual harassment against Mr.
4 Norgaard in\'ol\'ing SMUSD employees (or anyone else). Also. this letter constituted a ,·iolation of
5 20 U.S.C. § § 1 68 1 - 1 688 (''Title IX") in that it purported immediately and unreasonably to restrict Mr.
6 Norgaard from the \'alid exercise of his duties as a member of the San Marino School Board and
7 access to his work sites to accomplish those duties. Upon reading this letter, knowing that he had
8 done nothing wrong. Mr. Norgaard immediately expressed his concern and his expectation that the
9 SMUSD policy to maintain confidential ity surrounding any in\'estigation would be observed. Mr.
1O Norgaard also expressed his desire that any investigation be concluded as rapidly as possible. de la
11 Torre infonned �Ir. Norgaard that the other four Board members would ha\'e to be apprised. that
12 SMUSD would have to retain an investigati\'e fim1 to handle the in\'estigation, and that law
13 enforcement would be inYoh·ed.
14 21. That C\'cning. Mr. Norgaard spoke on the telephone with Chemiss to request
15 pennission to attend a high school basketball game that coming Friday. January 26, 20 1 8 (something
16 l\fr. Norgaard does regularly). Upon Chemiss' response that the high school principal. lssaic Gates.
17 would have to be infonned of the allegations. l\lr. Norgaard stated that. rather than jeopardize
18 confidentiality, he would reluctantly forgo attendance at the basketball game.
19 22. The following morning. January 23. 20 1 8. Chcmiss sent an email to Mr. Norgaard in
20 which he purported to summarize the con\'ersation of the night before. Chemiss wrote: ··You
21 requested that r approYe you attending the SMHS basketball game o n Friday. You requested that I
22 consider not following the protocol as set forth in the letter you received yesterday. Specifically. you
23 requested that you be allo\.vcd to attend the game without being accompanied by a district
24 administrator. but that you would be located within view of everyone in the g}m while most likely
25 standing near one of our assistant principals." Other than the request to attend the game, all of
26 Chemiss · statements 1,vere false. Chemiss then stated. in bold: "Based on the need to NOT create a
27 hostile work environment for any potential accuser and based on the advice of counsel, I am unable
28 to accommodate your request.'' As detailed below. there were no accusers and no hostile 1,vork
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1 environment. Chcmiss then purported to quote Mr. Norgaard as ha\'ing said on the phone the night
2 before that · ·this better not be made public.'' C'herniss stated that he '·took this comment as a threat
3 and this type ofbeha\'ior is not acceptable. Linda de la Torre, myself. and other administrath·e
4 colleagues are simply doing our job and should not ha,·e any fear of retribution by you.'' Mr.
5 Norgaard ne,·er threatened anyone with retribution or anything else. Finally, confirming that Mr.
6 Norgaard "s concerns about confidentiality had been well-founded. Cherniss stated: "I ha\'e no control
7 over who says what to who. nor do I ha\'c any intention of covering up this serious matter. Currently.
8 to the best ofmy knowledge. the people that arc aware of this matter are Linda de la Torre. the other
9 four Board members. each school site principal. law enforcement. and the accusers.' · When C'hcmiss
1O aftd de la Torre handed Mr. Norgaard the letter late the previous afternoon. they stated or clearly
11 implied that not e,·en the other Board members were yet "aware of this matter," and the previous
12 evening on the telephone. Chcrniss had indicated that Gates was not '·aware of this matter.'" I n any
13 case, as C'herniss knew at the time. there was no matter at all, let alone a "serious matter.''
14 23. On January 26. 20 1 8, Mr. Norgaard attended a previously scheduled meeting with S an
15 �farino High School principal. Issaic Gates. at the high school. Because Chcmiss had informed Mr.
16 Norgaard that Gates now was aware of the allegations and the investigation and because Gates' office
17 continued the meeting by enrnil and c-in\'itation. l\lr. Norgaard did not separately seek permission
18 from C'hcrniss to attend the scheduled meeting. The meeting. largely concerning AP courses, was
19 productive and took place in Gates· office without incident and without any mention o f the purported
20 allegations or the im·estigation.
21 24. On Monday. January 29. 10 1 8. C'herniss emailed Mr. Norgaard with the subject l ine
22 ··January 26 Incident.'' Attached was a January 29 letter from Chemiss that stated: '· It was brought to
23 my attention that subsequent to receiving [the January 22] letter. on Friday. Januar y 26th. you entered
24 the San Marino High School campus at approximately 3 :25 p.m. and met with the high school
25 principal. Dr. Issaic Gates. until.approximately 4:05 p.m. Your failure to follow the District
26 directi\'es threatened the integrity of the investigation. If this occurs again. it will be treated as
27 trespassing under Penal C'ode sections 626.4. 626. 7, and 616.8. I ask that you respect the integrity of
28 the investigation process and cooperate with the District directi,·es." As Chemiss knew when he sent
8
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1 this email, and as detailed below. the 'fotegrity•· of the iin-estigation was a fallacy because there was
2 no credible allegation upon which to base the investigation in the first place. The cited Penal Code
3 sections did not have applicability to a meeting such as the meeting with Gates or to any other visit
4 by Mr. Norgaard to a school campus for a meeting or attendance at. for example, a sporting event
5 school play, or classroom visit. Further. Chemiss· email constituted yet another ,·iolation of Title IX
6 as this email again sought prospectively and unreasonably to restrict Mr. Norgaard from his work
7 sites and duties as a School Board member.
a \'JI. THE PRESS RELEASE
9 25. That same day, on January 29. 20 1 8, the office of the Superintendent of the San
10 Marino Unified School District identified Mr. Norgaard by name in a news release to be under
11 investigation by SMUSD and an im·estigath·e finn retained by ''the Districf' for ' "improper conduct"
12 apparently alleged to be ·'sexual harassment." Chemiss and de la Torre made certain to reach out to
13 any and all news media outlets that would take their calls and emails. Cherniss and de la Torre sent
14 the news release to: 1 ) the San Marino Tribune newspaper, 2 ) the San !\.-larino Outlook newspaper, 3)
15 KPCC (the local National Public Radio station), 4) the Pasadena Star-News newspaper, and 5) KCBS
16 television station. This release was a direct violation of SMUSD policy to keep confidential the
17 names of S:\IUSD personnel under on-going in\'cstigation. r-.Iorc importantly. this release was
18 materially and mali ciously false in that nobody had alleged that Mr. Norgaard had engaged i n sexual
19 harassment or other such improper conduct.
20 26. On the same date. the San Marino Police Department (SMPD) issued a news release
21 that a "School Board Member•· was the subject o f an initiated criminal inn�stigation for "battery."
22 based on ·'recei\·ed infonnation from the San Marino Unified School District of an ongoing
23 administrative investigation related to a School Board Member:· Chemiss and de la Torre had
24 falsely and in ,·iolation of California Penal Code § 148.5 alleged to law enforcement that Mr.
25 Norgaard was under investigation for conduct they had characterized as sexual harassment and which
26 led the SMPD to label it as · ·battery.''
27
28
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1 27. From January 29. 201 8, forward to the present and continuing, Mr. Norgaard has been
2 forced to endure multiple instances of harassment and humiliation perpetrated directly or caused as
3 an expected and reasonable consequence of Cherniss ' and de la Torre's actions and statements.
4 VIII. FURTHER HARASSMENT AND HUI\IILIATION

5 28. For example. recently. Mr. Norgaard was instrumental in staffing and helping to
6 organize a joint San Marino High School-California Institute of Technology ( . .Caltech") program.
7 In support of that program. Mr. Norgaard lined up the first two Caltech professors under
8 consideration. Both were friends of his, and one was a fonner member of the SMUSD Academics
9 Advisory Committee. Mr. Norgaard knew two other Caltech professors who he thought could add
1O \·ision to the program. H e therefore requestt.-d to be present at a meeting scheduled at Caltech on
11 February 6. 20 1 8. Cherniss initially agreed but later decided that the meeting '·will strictly he an
12 administrati\·e meeting between Caltech. the high school principal and assistant principal. and
13 myself." Therefore, "we arc not able to facilitate your attendance." Immediately after the meeting.
14 Cherniss emailed the School Board that the meeting had been with the three Caltech professors
15 ''along with'' "the Caltech Administration.'' lbe meeting was anything but ';strictly . . .
16 administrati\'e.''
17 29. On February I . 20 1 8. Mr. Norgaard was scheduled to attend a San l\forino Schools
18 Foundation annual dinner. The afternoon before the c\·ent. Mr. Norgaard received an email from
19 Chris Kealey. the Executi\·e Director of the Schools Foundation, with the subject line "SMSF Event-
20 Cancel,'' stating in part "I need to request that you NOT attend the Foundation event on Thursday.
21 a m sorry. but given the circumstances i t would create some \·cry bad PR for yourself and the
22 Foundation.'' Kealey followed with a text message the next day ..just want to make sure you got my
23 email about tonight.'' Mr. Norgaard hnd been personally invited by the Foundation. had rsvp 'ed and
24 e,·en made a dinner selection. Mr. Norgaard is a fonucr President and current Associate Trustee of
25 the Foundation.
26 30. In addition. the Cherniss and de la Torre "directive" that puqmrted to bar Mr.
27 Norgaard from school and SivlUSD property came at a crucial time of the school year. particularly for
28 Mr. Norgaard. In the past. Mr. Norgaard has participated in San Marino High School aMual mock
10
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1 college inten-iews, offering guidance to students. He was not able to participate in this year's mock
2 intcr,iews. Mr. Norgaard likewise could not attend Academics AdYisory Committee "focus group''
3 meetings. For the first time in years. he missed the San :tvlarino Little League Opening Day
4 ceremony. which takes place on Huntington Middle School grounds. Similarly. he was forced to
5 miss not only San Marino High School basketball games but the annual basketball banquet that he
6 has attended in the past.
7 31. The actions of Chemiss and de la Torre from January 22, 20 1 8 to the present
8 concerning Mr. Norgaard arc in keeping with a pattern of recent unprofessional and abusiYc behaYior
9 directed toward SMUSD personnel as well as others who are perceived by S MUSD administrators to
1O present a challenge or threat to their seemingly unbridled authoritarian power. The unreasonable
11 malice with which C'hemiss. de la Torre. and SMUSD act and react to infonnation concerning
12 SMUSD personnel amounts to a campaign of policy, legal. and ciYil rights ,·iolations and abuses.
13 f\.lr. Norgaard is the latest unfortunate Yictim.
14 IX. THE IN\'ESTIGATION
15 32. Chemiss and de la Torre authorized the retention of the pri\·ate investigative finn of
16 Nicole Miller & Associates to in\'estigate the so-called "allegations" o f ' ·sexual harassment.'' In
17 ,·iolation of SMUSD policy. Chemiss and de la Torre nei ther sought nor obtained School Board
18 authorization to conduct any such in,·estigation or to retain an in\'estigati\'e firm to do so. Such
19 matters were ne,·er discussed or authorized by or at any School Board meeting.
20 33. Following se\'eral weeks of interYiews. Nicole Miller & Associates concluded, on
21 March 22. 2018. that Mr. Norgaard had committed no "sexual harassment'' or other misconduct and
22 \'iolated no law or policy. They concluded that Mr. Norgaanl's conduct at all times was not sexually
23 motivated and. critically. that 110 person illfen·iewed percefred it to be sexually motfruted 01·
24 offensive. Thus. Nicole l\r[illcr & Associates confirmed that there never was any complainant and
25 that no sexual harassment, sexual or other assault. or battery complainant ever existed. There had
26 ne\'er been r�asonable cause to convene a formal in\'estigation. let alone to publish news of purported
27 ' "allegations" to the media and to cause the SMPD to initiate a criminal investigation of "battery."
28
11
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1 x. THE HARM
2 34. As a direct and proximate result of Chemiss and de la Torre unleashing the power of
3 #l\leToo without the slightest factual basis. Mr. Norgaard now suffers this:
4
5
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7
8
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1 35. There is no recovery from that. Forever, Mr. Norgaard will endure the stigma of
2 ha,·ing been #MeToo'd. His personal and professional reputation are substantially and pennanently
3 damaged. Prospecti\'e legal clients pcrfonn internet searches on lawyers they are considering hiring.
4 £\·ery single prospecti\'e client in the future can and will ,·iew and consider internet-available
5 material such as the above MeTook 1 2 posting. Mr. Norgaard 's business associates and personal
6 friends around the United States arc aware or will become aware of the false allegations made against
7 Mr. Norgaard by Chemiss and de la Torre. Mr. Norgaard has a range of friendships with present and
8 fonncr federal and state government officials in all three branches of government, including trial
9 court and appellate court judges. that make the impact of this situation particularly distressing to him.
10 36. Additionally, C'hemiss and de la Torre were aware at the time that they made the false
11 allegations against Mr. Norgaard to the media. the SMPD, and others. that Mr. Norgaard was
12 particularly susceptible to personal emotional trauma, because they knew that his wife suffers from
13 cancer and was and is undergoing comprchensi\'e treatment for that cancer.
14 XI. THE AFTERMATH AND YET FURTHER HARASSMENT AND INTll\IIDATION
15 37. Despite the exoneration of Mr. Norgaard by the investigath·c finn hired on behalf of
16 the SMUSD. Defendants C'herniss. de la Torre. and the SMUSD hnve remained mute-no retraction.
17 no apology. no press release. nothing. Mr. Norgaard remained subject to C'hcrniss ' and de la Torre ' s
18 directive prohibiting Mr. Norgaard from entering S�lUSD property without 48 hours· advance
19 written appro\'al and prohibiting Mr. Norgaard from having any contact with SMUSD employees,
20 until Cherniss sent Mr. Norgaard an email at 5 :04 p.m. on April 5. 20 1 8 . C'herniss. apparently
21 without copying anyone else o n the email. stated: '·The in\'cstigation has concluded. There arc no
22 longer visitation rl!strictions.'' Indeed. the written r�port that exonerates l\fr. Norgaard is shrouded in
23 a purported assertion of ..attorney-client" privilege between SMUSD and a law finn. Thus. the
24 Defendants' unsubstantiated and untrue claims of •·allegations" of . .sexual harassment" that Chemiss
25 defiantly claimed he had . .no intention of covering up'' and then. true to his word, broadcast to the
26 world at large. remain the public ··truth." Meanwhile. the Defendants intentionally bury the
27 documented proofof Mr. Norgaard's innocence. Defendants' silence. inaction. and purposeful
28
13
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1 cover-up now pro,·e beyond any doubt that the entire concoction of "allegations'' was designed to
2 injure the personal and professional reputation, name, and character of Christopher Norgaard.
3 38. O n April I O. 20 1 8 . realizing their own liability. Defendants referred this entire matter
4 to their insurer. hoping for representation in anticipation of litigation. Then, on April 1 9, 20 1 8,
5 apparently dissatisfied that their first investigation resulted in Mr. Norgaard 's complete exoneration.
6 and apparently realizing the full extent of their exposi.1rc, Defendants again leveled outrageous and
7 false claims against Mr. Norgaard through a purported ··cease and desist" letter. which. in pertinent
8 part. accused Mr. Norgaard of:
9 1 ) threatening Chemiss and threatening Chemiss· job.
1O 2) threatening de la Torre and threatening de la Torre's job. and
11 3 ) intimidating. bullying. and harassing other Sl\IUSD employees in a retaliatory manner.
12 I n further violation o f Title IX. Defendants' purported '·cease and desist'' letter attempts to prevent
13 l\fr. Norgaard from having any contact with srvIUSD personnel and fellow School Board members
14 and to prohibit Mr. Norgaard from entering upon School District property while Defendants launch
15 yet another in vestigation into what they belie,·e is •·nc,,· information regarding harassing. bullying
16 and retaliatory conduct and commentary on [Mr. Norgaard 's] part that [he is] directing at School
17 District employees who ha,·e prc\'iously rniced complaints about [Mr. Norgaard] engaging in acts of
18 sexual harassment. [his] creating a sexually hostile work environment. and [his] engaging in acts of
19 retaliation.•·
20 39. The first investigation. contrary to the Ycry lan&,,uage of the purported "cease and
21 desist'' letter. documented the ab.\·ence of anyone who "prc,·iously rniced complaints about [Mr.
22 Norgaard] engaging in acts of sexual harassment . . . [or] creating a sexually hostile work
23 environment." Furthermore. between the conclusion of the first inn:stigation and Defendants '
24 issuance of their false and harassing '·cease and desist" letter. Mr. Norgaard: 1 ) had one telephone
25 call with Cherniss (an amicable discussion concerning their agreement about the qualifications of a
26 prospective San Marino school assistant principal candidate); 2) had no indiYidual contact
27 whatsoever with de la Torre: 3) had a few briet: uneventful. and cordial meetings with SMUSD
28 personnel concerning a variety of official SMUSD business. and 4) attended one community
14
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1 gathering well-attended b;· SMUSD personnel and San Marino residents where he engaged in small
2 talk in public with a number of such other attendees.
3 40. It is no coincidence that Defendants' second assault upon the rights of Mr. Norgaard
4 comes just after Defendants referred this matter to its insurer in anticipation of litigation. It is no
5 coincidence that Defendants' second round of attempted intimidation, humiliation. and harassment of
6 Mr. Norgaard comes just as the San Marino School Board begins its annual review process o f the
7 perfom1ance of the SMUSD superintendent. As part of that process. each School Board member
8 submits numerical .and substantive evaluations of the superintendent. Completely separate and apart
9 from the facts and circumstances underlying the incidents discussed in this complaint. Mr. Norgaard,
10 in the past, has been critical of Chcmiss ' perfomiance as superintendent. Now. Defendants seek to
11 prevent Mr. Norgaard even from participating in the evaluation process.
12 CAUSES OF ACTIOX
13 First Cause of Action Against All Defendants

14 (Defamation Per Sc)
15 41. Plaintiff repeats and incorporates the allegations contained i n Paragraphs 1 through 40,
16 as i f fully restated here.
17 42. Defendants Cherniss. de lu Torre. StvlUSD. and Docs 1 -20 made one or more
18 statcment(s) as described herein to news media. to the police. and to others:
19 43 . Defendants Cherniss. de la Torre. S�fUSD, and Docs 1 -10 reasonably understood that
20 their stutement(s) were about Plaintiff Christopher Norgaard:
21 44. Defendants Chcmiss. de la Torre:. SMUSD. and Docs 1 -.20 reasonably understood
22 their statement(s) to mean that Plaintiff Christopher Norgaard had been reported as having acted. and
23 had acted. in a way that constituted sexual harassment and battery that warrantt!d police reporting and
24 an official investigation:
25 45. The statement(s) were and arc false. No one, let alone an accuser or complainant.
26 reported any behavior by Plaintiff Christopher Norgaard that could reasonably be considered sexual
27 harassment. sexual assault. or battery. Not a single interviewee corroborated any "allegation'" of
28 sexual harassment. sexual assault. or battery:
15
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1 46. Defendants Cherniss. de la Torre. SMUSD, and Does 1 -20 knew the statement(s) were
2 false or had serious doubts about the trnth of the statement(s): and
3 47. Defendants' wrongful conduct was a substantial factor in causing:
4 a. Hann to Plaintiff Christopher Norgaard's business, profession, and
5 occupation:
6 b. Ham1 to Plaintiff Christopher Norgaard's reputation: and·or
7 C. Shame. mortification. and,or hurt feelings.
8 Second Cause of Action Against All Defendants
9 (Intentional Infliction of Emotional Distress)
10 48. Plaintiff repeats and incorporates the allegations contained in Paragraphs I through 40 .
11 as if fully restated here.
12 49. The conduct of Defendants Chcmiss, de la Torre. SMUSD, and Does 1 -20 was
13 outrageous:
14 50. Defendants C'hcmiss. de la Torre, SMUSD, and Does 1 -20 intended to cause Plaintiff
15 Christopher Norgaard's emotional distress or acted with reckless disregard o f the probability that
16 Plaintiff Christopher Norgaard would suffer emotional distress. knowing that Plaintiff Christopher
17 Norgaard was present in the community in which the statements were made:
18 51. Plaintiff Christopher Norgaard suffered and continues to suffer sc\'ere emotional
19 distress. including physical manifestations such as dizzy spells and consequent falls: and
20 52. The conduct of Defendants Chemiss. de la Torre. SMUSD. and Docs 1 -20 was a
21 substantial factor in causing Plaintiff Christopher Norgaard's se\·ere emotional distress.
22 Third Cause of Action Against All Defendants

23 (Negligent Infliction of Emotional Distress)
24 53. Plaintiff repeats and incorporates the allegations contained in Paragraphs 1 through 40,
26 5..J. Defendants Chemiss . de la Torre, SMUSD, and Does 1 -20 were negligent:
27
28
16
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55. Plaintiff Christopher Norgaard suffered serious emotional distress in that he
2 experienced anxiety. shock. humiliation. shame, and physical manifestations such as dizzy spel ls and
3 consequent falls: and
4 56. The negligence of Defendants Cherniss. de la Torre. SMUSD, and Does 1 -20 was a
5 substantial factor in causing Plaintiff Christopher Norgaard's serious emotional distress.
6 Fourth Cause of Action Against All Defendants
7 (Violation of 42 U.S.C. § 1 983)
8 57. Plaintiff repeats and incorporates the all egations contained in Paragraphs I through 40.
9 as if folly restated here.
10 58. Defendants Chemi ss. de la Torre. SMUSD. and Does 1 -20. acting under color o f state
11 law. and by their actions set forth above. have deprived Plaintiff of his rights, privileges. and
12 immunities secured by the United States Constitution including. but not limited to. his First
13 Amendment right to freedom of associ ation and freedom of speech, his Fourteenth Amendment right
14 not t o be deprived of constitutional rights without substanti,·e and procedural due process of l aw, and
15 his constitutional right to pri,·acy. Ddcndant SMUSD. through the actions of its polic)n1aking
16 officials including. without limitation. Defendants Cherniss. de la Torre, and Does 1-20. has ratified.
17 authori1:cd. condoned and o r has failed to remedy these ci\'i l-rights ,·iolations. inducting. but not
18 limited to. those which ha,·e resulted in the damages to Plaintiff as alleged herein:
19 59. Defendants' conduct. as described above. is a ,·iolation of Plaintiffs ci\'il rights in
20 ,·iolation of 41 U.S.C. * 1 983:

21 60. As a proximati: result of Ddendants ' conduct as described abo\'e. Plaintiff has
22 suffered and continues to suffer loss of reputation, humiliation. embarrassment. loss of earnings. and
23 mental and emotional distress. all to Plaintiffs dt!trimcnt in an amount to be proven at trial:
24 61. Defendants Chemiss. de la Torre. SMUSD, and Does 1 -10 acted with the intent to
25 cause injury to Plaintiff Christopher Norgaard and or Defendants ' conduct was despicable and done
26 with a willful and knowing disregard of the rights of Plaintiff Christopher Norgaard to truth. privacy.
27 confidentiality. due process. liberty. favorable reputation. economic relations. and fair treatment.
28 Defendants acted with knowing disregard because Defendants were aware o f the probable dangerous
17
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1 consequences of their conduct and deliberately failed to a,·oid and affinnatively sought those
2 consequences. Defendants' conduct was despicable and subjected Plaintiff Christopher Norgaard to
3 cruel and unjust hardship in knowing disregard of his rights. The conduct constituting malice and ·or
4 oppression was authorized by the Superintendent and Assistant Superintendent (Human Resources)
5 of SMUSD or SMUSD adopted or appro,·ed the conduct after it occurred; and
6 Fifth Cause of Action Against All Defendants
7 (Violation of Cal. Ch·il Code § 52.1)
8 62. Plainti ff repeats and incorporates the allegations contained in Paragraphs I through 40
9 and 56 through 60. 11s if fully restated here.
10 63. The Defendants interfered or attempted to interfere by threats. intimidation. or
11 coercion with the exercise or enjo)ment by Plaintiff Christopher Norgaard of rights. prh·ileges. and
12 immunities secured by the California Constitution including. but not limited to. his right to freedom
13 o f association and freedom of speech. his right not to be depri\'ed of constitutional rights- without
14 substanti\'c and procedural due process of law. and his constitutional right to prirncy. Defendant
15 SMUSD. through the actions of its polic)making o fficials including. without limitation. Defendants
16 Chcrniss. de la Torre, and Does 1 -20 has ratified. authorized. condoned and or has failed to remedy
17 these ci\'il-rights ,·iolations. incl uding. but not limited to. those which ha,·c resulted in the damages to
18 Plainti ff has alleged herein;
19 6-l. The actions and conduct of Defendants that interfered or attempted to interfere with
20 Plainti ffs rights were done deliberately or spitefully: and
21 65. As a direct and proximate result of the conduct of defendants. and each of them.
22 Plaintiff has suffered and will continue to suffer injury. damage. loss and hann for loss of rc!putation,
23 humi liation. embarrassment. loss of carnings. and mental and emotional distress. all to Plaintiffs
24 detriment in an amount to be proven at trial.
25 Sixth Cause of Action Against All Defendants
26 (lnjunctin Relief Pursuant to Cal. Ch·. Proc. Code §§ 527, 527.6)
27 66. Plaintiff repeats and incorporates the allegations contained in Paragraphs I through 65.
18
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1 67. Defendants Cherniss, de la Torre. SMUSD, and Does 1 -20 have harassed and continue
2 to harass through a knowing and willful course of conduct directed at Plaintiff Christopher Norgaard
3 that seriously alanns. a1moys, and or harasses Plaintiff for no legitimate purpose:
4 68. As a direct result of Defendants pattern of conduct starting with their first letter on or
5 about January 22, 201 8 and continuing through email communications and further letters until the
6 filing of this compliant have caused Plaintiff to suffer substantial emotional distress: and
7 69. Plaintiff needs intervention from this court to protect Plaintiff and stop Defendants
8 from harassing. intimidating, threatening. and abusing Plaintitl: directly or indirectly through
9 writings, communications. or otherwise or by disturbing the peace and rights of Plaintiff.
1O Punith·e Damages as to the First, Second, Fourth, and Fifth Causes of Action Against All
11 Defendants
12 (Cal. Ch·. Code § 3294)
13 70. Defendants Cherniss. de la Torre. SMUSD, and Does 1 -20 acted with the intent to
14 cause injury to Plaintiff Christopher Norgaard and 1or Defendants' conduct was despicable and done
15 with a willful and knowing disregard of the rights o f Plaintiff Christopher Norgaard to truth, prh·acy,
16 confidentiality. due process. liberty. favorable reputation. economic relations, and fair treatment.
17 Defendants Cherniss and de la Torre acted on behalf of SMUSD. Defendants acted with knowing
18 disregard because Defendants were aware of the probable dangerous consequences of their conduct
19 and deliberately failed to avoid and affinnati\'cly sought those consequences. Defendants' conduct
20 was despicable and subjected Plaintiff Christopher Norgaard to cruel and unjust hardship in knowing
21 disregard of his rights. The conduct constituting malice and or oppression was authorized by the
22 Superintendent and Assistant Superintendent (Human Resources) of SMUSD or SMUSD adopted or

23 appro\·ed the conduct after it occurred.
24 Prayer for Relief
25 WHEREFORE, Plaintiff prays judgment against Defendants as follows:
26 1 . For compensatory damages in an amount to be proven at trial. but in no event less than
27 $25,000:
28
19
COMPLA�T
EXHIBIT I
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#:275
1 2 . For special damages in an amount to be pro,·en at trial, but in no e\'ent less than
2 $25.000:
3 3. For interest on the sum of damages from and after January 29. 20 1 8:
4 4. For exemplary damages as to the First, Second. Fourth. and Fifth Causes of Action
5 alleged herein:
6 5. For prospecti\'e injuncti\'e relief prohibiting all Defendants from engaging in the
7 viol ation of Plaintiff's constitutional rights as set forth herein:
8 6. For costs of suit:
9 7. For Attorneys· Fees: and
10 8. For such other and further relief as the court may deem proper.
11
12 Dated: Apri l Z� 20 1 8 GLAZIER YEE LLP
13
14
By
15 Guv
� P. Clazi
Dcbornh l\.l Parker
16
17 Attorneys for Plaintiff
CHRISTOPHER NORGAARD
18
19
Demand for Jury Trial
20
P laintiff Christopher Norgaard requests a tria\ by jury on all issues so triable.
21
: ,� ·
22
Dated: April _� 20 1 8
23
24
25 Guy P. Glazier
Deborah M. Parker
26
Attorneys for Plaintiff
27 CHRISTOPHER NORGAARD
28
20
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EXHIBIT I
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#:276
1 PROOF OF PRESENTATION
2 I, Kimberly Hartley, declare as follows:
3 I am employed in the County of Los Angeles. State of California. I am over the age of 1 8 and
4 not a party to the within action. I am empl oyed by Glazier Yee LLLP, whose business address is 707
5 Wilshire Blvd .. Suite 2025, Los Angeles. California 9001 7.
6 On April 23, 201 8, I presented the attached document(s) described as:
7 GOVERNMENT CLAIMS ACT CLAIM
8 by placing a true copy thereof in an envelope addressed to the following:
9
San Marino Unified School District Linda de la Torre
10 c/o Dr. Alex Cherniss, Superintendent San Marino Unified School District
1 665 West Drive 1 665 West Drive
11 San Marino, California 9 1 1 08 San Marino, California 9 1 1 08
12
Dr. Alex Cherniss
13 San Marino Unified School District
1 665 West Drive
14
San Marino. California 9 1 1 08
15
16 [x] VIA PERSONAL DEL IVERY: I placed a true copy in a sealed em·elope addressed to each
pcrson(s] named at the address[es] shown and givi ng same to a messenger employed by
17 Express Network whose business address is 1 533 Wilshire Blvd., Los Angeles, California
900 1 7, for personal delivery before 5:00 p.m. on April 23, 20 1 8.
18
[ ] VIA NORCO OVERNITE : On the below noted date, I placed a true copy of the above
19 mentioned document(s), in a sealed envelope or package designated by Norco with deliver
fees paid or provided for, addressed to the person(s) as indicated abo\·e and deposited same in a
20 box or other facility regularly maintained by Non:o or dcli\'ered same to an authorized courier
or driver authorized by Norco.
21
[x] VIA MAIL: I placed a true copy in a sealed envelope addressed as indicated above, on the
22 above mentioned date. I am familiar with the firm's practice of collection and processing
correspondence for mailing. It is deposited with the U. S. P ostal Service on that same day in
23 the ordinary course of business. I am aware that on motion of party served, service is
presumed inval id if postal cancellation date or postage meter date is more than one day after
24 date of deposit for mailing in affidavit.
25 I declare under penalty of perjury under the laws of the State of California that the foregoing is
26 trne and correct, that the original of the aforementioned document(s) was 1were printed on recycled
27 paper, and that this Proof of Presentation was executed by me on April 23, 20 1 8 , at Los Angeles,
28 California.
PROOF OF PRESENTATIO_ .
EXHIBIT I
47
#:277
EXHIBIT J
#:278
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59
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60
#:291
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EXHIBIT J
63
#:294
SAN MARINO
THURSDAY, JUNE 14, 2018 VOL. 6 NO. 24 ·
Norgaard Seeks
Restraining Order as He
Sues District Officia.ls
By Zane Hill The court asked ·that Glazier,
The Outlook should he refile it, take a dif
ferent legal approach and prop
erly present a persuasive case for
L awyers for school board

member Chris Norgaard are
expected to refile paperwork
needing the order.
"The cowt has simply asked
us to follow a slightl different
this week seeking a temporary procedure to file a temporary re
restraining order against.his San straining order," Glazler said in a
Madno Unified School District phone Interview on Monday.
Beard of Education colleagues The reqqesced restraining
after they froze him out of the su order Villi till demand that Nor
perintendent evaluati@n process gaard be included in Chemiss'
in May. annual evaluation, which began
In the meantime, tl10se four thls month, desplte Cherniss new
board members, Superlntend�nt. being a defendant in Norgaard's
Alex Chemiss and Assistant Su lawsuit. The other board mem
perintendent Linda de la Tcme bers - C. fosepb Chang, Nam
also are the focus of Norgaard1s Jack, Lisa Link and Shelley Ryan
federal lawsuit alleging -civil - vot�d on May 8 to form a sub
rights vioJations, defamation committee to evaluate Cbemiss
and emotional distress. Norgaard without Norgaard, who .had, by Emmy-winning soccer broadcosterAndres Cantor will call his first
filed t,bat lawsuit last week after then, filed a legal complaint.
having filed a similarly worded Norgaard is alleging a viola
legal complaint against Cherniss,
de la Torre and MUSD in J\prU.
No.rgaard's attorney, Guy Gla
tion of his irst AmendrQ�nt
rights, specifically to speech and
assocjation, and bis 14th Amend
S.MH,S Grad's
zier, also applied fer a temporary
.restraining order last week, but
the U. . Di trlct Court for the
ment rights in the lawsuit; these
violations also fomu the basis of
hi restraip.ing order application,
Attract World C
Central District of California has in which he argues for his right By Oscar Areliz radio network, Futbol
denied that application because The Outlook durmgthe past four'-"
it did not meer filing standards. See NOAGAA� page 4 occer fans will no1
put a face to the man
T ege,ndary soccel' broadcaster Ieng goal cry begin
LA.i:idn!s Cantor has one of'the as Cantor will call hi1
HMS' Faure Takes most recognizable galls in all
of pol'tS Wjth his famous, pas
Cup match on tele,
1998.
sionate "G000000oooll" that bas "It's an honor m
Helm as Principal been heard by millions on 'the to lead the Telemun
EXHIBIT J
-. .., -- .... -- - ...
64
#:295
CIIMMl)MlTY UAl�flli
---,-•«•:e, rr11.u u•c l.lV'l:J(UJ [One waJ k 1.5 miles. and to arrange
-•,U •..,,,<a.r,uc, c:11t�r cupping the muniiy fl,md "\l;irrhing De of the parade, it's a casuiil their own tran,;portation. Caro�m; Purvis
gubernatorial primary, had 331 tachment"' will triumphantly affair. Music is provided in nw parcide starts at 4:-15
votes from San Marino. return to the city's 4th of July advance. rehearsals are min p.m. that day. Contact Matt
ecretary of ta(e AleX. Padilla. Parade. No longer content imal and attire is season;il Morris, a San Marino High Rachelle Gay!
a Democrat whl5 is seeking r marching for a few blocks, patriotic. School class of ·91 alumnus,
election. l1ad 736 San J\iiarino the group will now march the Participants are required to at p;iradeband(ii'shlu.org for OHie£ Al)>.lllllSH)P."Jt)R
votes. merely one vote ahead of whcile parncle from the gas bring their own instruments more information.
Sandra Belloso
NORGAARD (This is a sraodard practice in the victim who alleged orgaard of wlljch was HkeJ · ro 1"8tlect Sean Bumcrot
contd. from page I criminal investigations.) had contacted and kis. etl her SMUSD'S cont ·ll\l 1ed ranlcing Roh Carlson
Norgaard tiled a Jegal. com- inappropriately did not want the l(p distrl l in tbe • ate. Ne• Frank Glionna
to ass0d ate with and speak in plaint .in April, following the close to pursue criminal charges, ac tably; Norgaard had this past fall
Charles Hirsch
his cap.aCiry as a member of the of SMPD's investigation and the cording to documents. nominated Cherniss as a Los An
school board. disoict'-s first investigation with The districr'-s second investiga geles County Superintendent of Mary Jane Yee
"The immediate objective is sMUSD' second inve tlgation tion is pngoin� the Year.
to have me rein cated into the ongoing. Norgaaro �a the public di'>· Norgaard's peers, however, Plt O I OCR�Pl<ER$
uperin1endent evaluation pro ln hi complaint and lawsuit, closure of the investigation has were unconvinced and created l.arissa Althouse
ce ," Norgaard explained by orgaard denied even the exis substantially affeeted his da -to the subcommittee, They also Susan Bradtortb
phone tast week. tence of the harassment com day life as a longtime resident of created a separate subcom
San Marino, as a longtime public Alison Bur:k
Norgaard's complaints stem plaints which Chemiss said initi mittee to address matters re
from a publicly disclosed sexual ated the iove tigation. Norgaard official in San Marino and also lated to Norgaard's legal filings Eric Danielson
harassment investigation con cites the CGnclusions of the first in his capa iry as a lawyer. The against the districl, which Nor Melissa Kobe
ducted into his actions by inve tigation in this claim, al district's policy for subjects of gaard more lightly protested be Toni teBel
SMUSD, and are further com though the contents of that in sexual harassment investigations cause he al.t!!!ady had voluntarily
Staci Moraza
pounded by a second inve ttga vestigation have not been made require permission to attend recused h5ms elf from those dis-
tion into allegations he intimi public for privacy reasons. functions on campuses and also cussions. Ella Milcayelyan
dated a witnesses. According to the uit, that administrative escorts for those Cherniss declined comment Mary Emily Myers
Cherniss and de la Torre, in investigation apparently con activities, and Norgaard also has regarding the restraining erder Raymond Ouan
news releases sent to media in cluded that none of the people stated he was excluded from application or the latest lawsuit,
Erin Rodick
January; identified Norgaard by intervi.ewed deemed any actions other community events because but he has previously defel'lded
name as the SUbject of a sexual by Norgaard to be sexually mo of the bad press his attendance hi actions and disputed Nor Meghan Snyder
harassment investigation into tivated or ex.ual in nature. This might produce. gaard's c�aims thatno complaints
allegations from cuuent and investigation was conducted by When the board was dis agamsr him existed.
:_Oittloolc
former district employees. Simul a third-party firm, Nicole Miller cussing creating subcomroHtees Glazier said he �ected a
taneously, the San Marino Police and Associates. for Cb.emiss evaluation, a �efiant ruling on the reso:aining order
Department sent a similar news As for the SMPD investiga Norgaard insisted he would be "fairly quickly"' and expected ..
•
llfWSl'A.Pf' '
release to the meaia conaemin_g tion, Police Chief John locontro able to retain objectivfty in pite the legal parties to have a cas�
a criminal battecy investigation said it is closed. The Los Angeles af th� public and legal spats and management conference within www. instag ram. com/
of a school board membe(, al County District Attorney's Office would discu 0 nly facts about 30 days of the defendants being
though it did not.name Nor-gaard. declined to file charges bec::ause Cbemiss' performan e, much served. outlooknews
Piper
----·-----
---- ---- ----
--------
Emily
EXHIBIT J
65

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Case 2:18-cv-04987-FMO-GJS Document 35-2 Filed 06/15/18 Page 1 of 74 Page ID #:222

1 APALLA U. CHOPRA (S.B. #163207)

7 MATTHEW T. KLINE (S.B. #211640)

1 DECLARATION OF DR. ALEX CHERNISS

Assistant to the Superintendent

-------- Original Message --------

This email Is automatically sent by IP address on Saturday, July

========San Marino U11ificd School :District

January 22, 2018

Mr. Chris Norgaard

Dear Mr. Norgaard,

. ssistant Superintendent/Human Resources

C: Dr. Alex Cherniss, Superintendent

SMPD Press Releases

SUBJECT: Battery Investigation

http://v.n,vw. cityofsanmarino.org/808/SMPD-Press-Releases 6/14/2018

Media Statement- Revised

Board President January 29, 2018

Board Vice President Dear Mr. Norgaard,

It was brought to my attention that subsequent to receiving this letter, on Friday,

Alex Cherniss <acherniss@smusd.us> Mon, Jan 22, 2018 at 9:27 PM

Alex Cherniss, Ed.D.

https://mail .google .com/mail/u/0/?ui=2&ik=db2b97 cbcc&jsver=-dxVNc9Y02g .en .&cbl=gmail_fe _180516.06 _p8&view=pt&q=alex&qs=true&search=query&th=1612

NICOLE MILLER & ASSO CIATES, INC .

CONFIDENTIAL ATTORNEY-CLIENT PRIVILEGE

A tota l of 1 0 ind ividuals, i nclud i n g M r. Norgaard , we re intervi ewed in fu rtherance of the

ALLEGATIONS AND FINDINGS

CONFIDENTIAL ATTORNEY-CLIENT PR!VJLBGB

CONFIDENTIAL ATTORNEY-CLIENT PRIVILEGE

Findioe to Alleeation No, 3:

CONFIDENTIAL ATTORNEY-CUBNT PRJVIl.EGE

. While Mr. Norgaard described the interaction as a

Mr, No rgaard appeared to understand h ow his behavior could be perceived as a concern by

Lisa Strachan, Senior Investigator, Administrative and Employee Relations

To: Linda de la Torre, Assistant Superintendent Human Resources

Re: Sexual Harassment/Gender Discriminatio

In March of 2016, I was during open house. Mr.

SAN FRA NCISCO PARTNERS

Via Personal Deliverv and U.S. Mail

San Marino Unified School District

Dear Dr. Chemiss,

San Marino Unified School District

3. The names of the employees involved; and

SAN FRANCI SCO l'ARTNERS

Via Personal Deliverv and U.S. Mail

Dr. Alex Cherniss

Dear Dr. Cherniss,

Pursuant to California Government Code Section 8 1 0 et seq., Government Claims Act,

Claimant's name and address:

Dr. Alex Cherniss

3. The names of the employees involved; and

Via Personal Deliverv and U.S. Mail

Dear Ms. de la Torre,

Pursuant to California Government Code Section 8 1 0 et seq., Government Claims Act,

Claimant's name and address:

Ms. Linda de la Torre

3. The names of the employees involved; and

GLAZIER YEE LLP

15 '·allegations• · of "sexual harassment.'" c011\"ened an official investigation using SMUSD resources