Giuliana Mendiola Lawsuit

Case 5:20-cv-00832 Document 1 Filed 04/18/20 Page 1 of 15 Page ID #:1
1 DAN SIEGEL, SBN 56400

2 EMILYROSE JOHNS, SBN 294319
SIEGEL, YEE, BRUNNER & MEHTA
3 475 14th Street, Suite 500
4 Oakland, California 94612
Telephone: (510) 839-1200
5
Facsimile: (510) 444-6698
6
Attorneys for Plaintiff
7
GIULIANA MENDIOLA
8
9
10 UNITED STATES DISTRICT COURT
11 FOR THE CENTRAL DISTRICT OF CALIFORNIA
12
13 GIULIANA MENDIOLA, ) Case No.
14 )
Plaintiff, ) COMPLAINT FOR DAMAGES
15 ) AND INJUNCTIVE RELIEF
16 vs. )
)
17
THE REGENTS OF THE UNIVERSITY )
18 OF CALIFORNIA; JOHN )
19 MARGARITIS, Head Coach of )
Women’s Basketball, and TAMICA )
20 SMITH JONES Athletic Director, )
21 )
Defendants. )
22 )
23
24 PRELIMINARY STATEMENT
25 1. GIULIANA MENDIOLA served as Assistant Coach for the University
26 of California, Riverside women’s basketball team for seven years. She was
27 successful, well-regarded, and received excellent reviews. In 2018, Ms.
28 MENDIOLA was being considered for the Head Coach position at Riverside after
Mendiola v. Regents, No.

Complaint for Damages and Injunctive Relief - 1
1 then-Head Coach JOHN MARGARITIS came under investigation for mistreating

2 female athletes. Two months after Ms. MENDIOLA participated in an interview
3 regarding the investigation of Mr. MARGARITIS, her contract was not renewed.
4 JURISDICTION AND VENUE
5
2. This action arises under Title IX of the Education Amendments of
6
1972 (20 U.S.C. § 1681(a)) and Title VII of the Civil Rights Act of 1964 (42 U.S.C.
7
2000(e)). The Court has jurisdiction over this matter under 28 U.S.C. § 1331.
8
3. The state law claims in this action are so related to the claims in the
9
action within the original jurisdiction of this Court that they form part of the
10
same case or controversy under Article III of the United States Constitution. The
11
Court's jurisdiction over these claims is invoked under 28 U.S.C. § 1367.
12
4. Venue is proper in the United States District Court for the Central
13
14
District of California pursuant to 28 U.S.C. § 1391(b)(1) because the defendants
15 are located in the Central District of California and § 1391(b)(2) because all of the
16 acts and/or omissions complained of herein occurred within the Central District
17 of California.
18 PARTIES
19 5. At all times relevant hereto, plaintiff GIULIANA MENDIOLA was the
20 assistant coach for the University of California, Riverside, women’s basketball
21 team.
22 6. At all times relevant hereto, defendant THE REGENTS OF THE
23 UNIVERSITY OF CALIFORNIA was a governmental agency established under
24
the California Constitution. THE REGENTS owns and operates the University of
25
California, Riverside, with full powers of organization and governance of the
26
University of California, a public trust. THE REGENTS is a recipient of federal
27
funds and must comply with Title IX.
28

1 7. At all times relevant hereto, defendant JOHN MARGARITIS was the

2 Head Coach of the University of California, Riverside, women’s basketball team.
3 8. At all times relevant hereto, defendant TAMICA SMITH JONES was
4 the Director of Intercollegiate Athletics at the University of California, Riverside.
5
STATEMENT OF FACTS
6
9. GIULIANA MENDIOLA was a star basketball player for the
7
University of Washington Huskies.
8
10. She played professionally for seven years, both internationally and in
9
the Women’s National Basketball Association, before beginning her coaching
10
career in 2011.
11
11. On July 1, 2012, Ms. MENDIOLA was hired as the Assistant Coach
12
for the women’s basketball team at University of California, Riverside (“UCR” or
13
14
“the University”).
15 12. Ms. MENDIOLA was very successful at her job and received excellent
16 reviews. Her contract was renewed each of the six times it came up for renewal.
17 13. In the summer of 2016, Mr. MARGARITIS informed Ms.
18 MENDIOLA that he was planning to retire within seven years and that he
19 believed that she was the best candidate to take over the program. Ms.
20 MENDIOLA asked whether Mr. MARGARITIS would consider promoting her to
21 Associate Head Coach, and Mr. MARGARITIS told her that he did not believe in
22 the position of Associate Head Coach. Despite this, he continued to reassure her
23 that she was his choice to take over the program.
24
14. During her tenure with the program, Ms. MENDIOLA was subject to
25
abusive behavior based on her gender by Mr. MARGARITIS. Mr. MARGARITIS
26
would berate Ms. MENDIOLA regularly and behaved inappropriately towards
27
her, at one time asking for a hug after losing his temper at her and belittling her
28

1 and on another occasion, physically blocking her from leaving her office when
2 the two were alone after hours.
3 15. Mr. MARGARITIS’ mistreatment of Ms. MENDIOLA was often
4 related to her efforts to intervene in Mr. MARGARITIS’ mistreatment of the
5
women on the basketball team. Mr. MARGARITIS would berate and belittle the
6
women on the basketball team, often using gendered language. He made
7
inappropriate jokes about the student athletes both in their presence and outside
8
of their presence, commenting on their sexual orientation and on the bodies of
9
other female athletes. He also ridiculed an African American player for her
10
hairstyle choices and accused her of shooting poorly during games when she had
11
braided styles typically associated with African American women.
12
16. Mr. MARGARITIS treated Ms. MENDOLA and female coach Seyram
13
14
Bell differently than male coaches. Mr. MARGARITIS dismissed Ms.
15 MENDIOLA’s and Ms. Bell’s coaching comments in favor of coaching comments

16 of male coaches. When Mr. MARGARITIS would adopt Ms. MENDIOLA’s
17 coaching tips, he would take credit for them. When he lashed out at Ms.
18 MENDIOLA, he would accuse her of having nothing to offer the program in light
19 of his considerable disregard of her contributions.
20 17. Ms. MENDIOLA endeavored to handle her concerns privately, by
21 addressing Mr. MARGARITIS personally. However, beginning in late 2016, Mr.
22 MARGARITIS’ behavior began to escalate.
23 18. In 2016, Ms. MENDIOLA and assistant coach Ms. Bell discovered
24
that a male assistant coach was viewing pornographic images of women on a
25
shared computer in an office the male coach shared with Ms. MENDIOLA. Ms.
26
Bell and Ms. MENDIOLA raised their discomfort and concern with Mr.
27
MARGARITIS, and he refused to intervene or correct the behavior of the male
28
coach. Ms. MENDIOLA was still required to share an office with the male coach.

1 19. In February 2017, while Ms. MENDIOLA was on maternity leave, she
2 discovered that her alma mater, University of Washington, had an opening for
3 Head Coach of women’s basketball. Members of the University of Washington
4 reached out to her to encourage her to apply. Ms. MENDIOLA asked her agent to
5
gauge the University of Washington’s interest in her. Before she heard back from
6
her agent, Mr. MARGARITIS called Ms. MENDIOLA. He yelled at and
7
demeaned Ms. MENDIOLA and called her disloyal.
8
20. That same day, Mr. MARGARITIS passed Ms. MENDIOLA up for
9
promotion and promoted Ms. Bell to Associate Head Coach instead.
10
21. When Ms. MENDIOLA returned from maternity leave in June 2017,
11
Mr. MARGARITIS informed her that he was upset that Ms. MENDIOLA did not
12
work or stay in contact with him while she was on leave. He informed her that he
13
14
reported her to the Senior Woman Administrator. Ms. MENDIOLA understood
15 that to mean that he inquired about firing her for not speaking to him while she
16 was on maternity leave. Following the conversation, Mr. MARGARITIS asked
17 Ms. MENDIOLA for a hug, an unwanted and jarring request that she declined.
18 22. Towards the end of 2017, Ms. MENDIOLA witnessed Mr.
19 MARGARITIS become increasingly abusive towards the female athletes. He
20 treated the female athletes in a manner that subjected them to a hostile
21 environment based on their gender.
22 23. In November 2017, Ms. MENDIOLA confronted Mr. MARGARITIS
23 and told him that he was behaving inappropriately towards the students. In
24
response, Mr. MARGARITIS berated her and threatened to fire her.
25
24. From June 2018 to September 2018, Ms. MENDIOLA again went on
26
maternity leave. Mr. MARGARITIS insisted that Ms. Bell contact Ms.
27
MENDIOLA to discuss work while she was on leave. Mr. MARGARITIS had done
28
a similar thing to Ms. MENDIOLA while Ms. Bell was on maternity leave, which

1 made Ms. MENDIOLA feel manipulated and uncomfortable. Mr. MARGARITIS

2 never asked male coaches to contact female coaches while they were on
3 maternity leave.
4 25. On November 13, 2018, Mr. MARGARITIS made Ms. MENDIOLA
5
stay late at work. Mr. MARGARITIS spent most of the morning yelling at her
6
because she had advocated on behalf of a female athlete. That night, when just
7
the two of them remained in the office, Mr. MARGARITIS stood in the doorway
8
of Ms. MENDIOLA’s office and insisted that she leave with him and walk
9
together to his car. She asked him to leave separately from her, but he insisted.
10
His behavior was inexplicable as Ms. MENDIOLA regularly locked up the office
11
herself. He continued to berate her during the walk from the office to the car.
12
26. In mid-November 2018, Ms. MENDIOLA again intervened in Mr.
13
14
MARGARITIS’s mistreatment of players after the team lost a significant game.
15 27. Following the team’s poor performance, TAMICA SMITH JONES

16 contacted Ms. MENDIOLA and informed her that she was upset with how Mr.
17 MARGARITIS was behaving.
18 28. Later that month, Ms. MENDIOLA met with Rosalie Burns from the
19 University’s Human Resources Department and discussed Mr. MARGARITIS’
20 mistreatment of players and of her. Ms. Burns wanted to report Mr.
21 MARGARITIS, but Ms. MENDIOLA expressed concern with her job security,
22 considering the number of times Mr. MARGARITIS threatened to fire her in
23 retaliation for her intervention in his mistreatment. Ms. Burns did not report Mr.
24
MARGARITIS.
25
29. In December 2018, captains of the team met with Ms. MENDIOLA to
26
report their experiences of mental abuse at the hands of Mr. MARGARITIS. The
27
captains then reported this misconduct to Ms. SMITH JONES.
28

1 30. That same month, Ms. SMITH JONES met with Mr. MARGARITIS
2 and Ms. MENDIOLA to discuss the players’ concerns. Ms. SMITH JONES
3 expressed her displeasure with Mr. MARGARITIS’ behavior and his approach to
4 coaching. Ms. MENDIOLA attempted to explain the players’ concerns about Mr.
5
MARGARITIS’ behavior, but she had to parse her words very carefully in the
6
presence of Mr. MARGARITIS.
7
31. Ms. SMITH JONES informed Ms. Bell and then Ms. MENDIOLA
8
about her plan to replace Mr. MARGARITIS with Ms. MENDIOLA. Ms. SMITH
9
JONES asked Ms. MENDIOLA to keep the plan to herself.
10
32. Ms. MENDIOLA and Ms. SMITH JONES had several follow-up
11
conversations regarding Ms. MENDIOLA taking over the program.
12
33. In January 2019, Mr. MARGARITIS again lost his temper with the
13
14
team in front of Ms. MENDIOLA and then berated and humiliated Ms.
15 MENDIOLA for confronting him about his inappropriate behavior.

16 34. Later that month, Ms. MENDIOLA and Ms. SMITH JONES met to
17 plan Ms. MENDIOLA’s budget for when she assumed control of the team. Ms.
18 MENDIOLA again tried to speak in detail about Mr. MARGARITIS’
19 mistreatment of the female athletes, but Ms. SMITH JONES stopped Ms.
20 MENDIOLA and told her not to go into detail about his actions. Ms. SMITH
21 JONES told Ms. MENDIOLA that she had a plethora of detailed reports from the
22 athletes and from the community. Ms. SMITH JONES assured Ms. MENDIOLA
23 that she would take over the team and that it was best for her to keep her
24
thoughts about Mr. MARGARITIS private.
25
35. On March 15, 2019, Mr. MARGARITIS asked Ms. MENDIOLA to
26
sign an agreement not to get pregnant again and implied that her job depended
27
on it. Ms. MENDIOLA refused to sign the agreement.
28

1 36. On March 18, 2019, the women’s basketball team suffered another
2 big loss. Mr. MARGARATIS began yelling at the team. Ms. MENDIOLA
3 attempted to stop him. Mr. MARGARITIS accused Ms. MENDIOLA of sowing
4 disharmony in the team by failing to support him when he yelled at the team.
5
37. On April 18, 2019, Ms. MENDIOLA was interviewed as a part of an
6
investigation into the behavior of Mr. MARGARITIS. She corroborated the
7
misconduct reported by the athletes, but she refrained from providing much
8
detail and from reporting his mistreatment of her, per the advice of Ms. SMITH
9
JONES.
10
38. In May 2019, the University extended Ms. MENDIOLA’s contract as
11
Assistant Coach for two months, to June 30, 2019, while it concluded its
12
investigation into Mr. MARGARITIS.
13
14
39. During the two-month extension and following her participation in
15 the investigation, Mr. MARGARITIS started to exclude Ms. MENDIOLA from

16 coaching decisions. Although Ms. MENDIOLA was the recruiting director for the
17 team, he sent another coach out to recruit.
18 40. On May 30, 2019, Ms. SMITH JONES met with the team and told the
19 team that Mr. MARGARITIS would be fired, no matter the outcome of the
20 investigation.
21 41. On or about July 6, 2019, Mr. MARGARITIS informed Ms.
22 MENDIOLA that the investigation had concluded and that he had received a
23 brief suspension. He explained that he was found responsible for yelling at the
24
players and causing them emotional pain, intimidating players to return early
25
from injury, and threatening scholarships or not caring about academics.
26
42. On July 8, 2019, Ms. MENDIOLA met with Michael Boele, UCR’s
27
Senior Woman Administrator, and Wesley Mallette, Senior Associate Athletics
28
Director for External Affairs, to express her concern regarding the investigation

1 and the outcome. Mr. Boele and Mr. Mallette told Ms. MENDIOLA to remain
2 patient and to refrain from speaking about the investigation or the outcome.
3 43. On July 22, 2019, Stacey Ramos of the UCR Human Resources
4 Department informed Ms. MENDIOLA that her contract would not be renewed.
5
She was not given a reason for the non-renewal. On information and belief, Ms.
6
SMITH JONES, on behalf of the University, made the decision not to renew the
7
contract.
8
44. Following the meeting, Ms. MENDIOLA met with Ms. SMITH
9
JONES, who informed her that it was Mr. MARGARITIS’ decision not to retain
10
her. Ms. SMITH JONES then warned Ms. MENDIOLA that if she spoke
11
publically about Mr. MARGARITIS’ behavior, her future job prospects would be
12
in jeopardy.
13
14
45. Mr. MARGARITIS remained Head Coach of the women’s basketball
15 team following Ms. MENDIOLA’s termination.

16 46. In August 2019, members of the women’s basketball team publicized
17 the complaints they had shared privately with the University. In September,
18 following the publicizing of his mistreatment to major media outlets, the
19 University put Mr. MARGARITIS on indefinite leave, and he ultimately resigned.
20 47. Although she is highly qualified, UCR did not appoint Ms.
21 MENDIOLA as Head Coach. Ms. MENDIOLA applied for the Head Coach
22 position at UCR, but she was not considered for the position.
23 EXHAUSTION
24
48. GIULIANA MENDIOLA filed a complaint of discrimination with the
25
Department of Fair Employment and Housing on October 2, 2019. The
26
Department of Fair Employment and Housing issued Ms. MENDIOLA a right to
27
sue letter on October 2, 2019.
28

1 49. GIULIANA MENDIOLA filed a claim with the Equal Employment

2 Opportunity Commission on October 7, 2019. The Equal Employment
3 Opportunity Commission issued Ms. MENDIOLA a right to sue letter on January
4 22, 2020.
5
FIRST CLAIM FOR RELIEF
6 HOSTILE WORK ENVIRONMENT IN VIOLATION OF TITLE VII OF
THE CIVIL RIGHTS ACT
7
(By plaintiff GIULIANA MENDIOLA against defendants THE REGENTS OF THE
8 UNIVERTSITY OF CALIFORNIA and JOHN MARGARITIS.)
9 (42 U.S.C. § 2000e et seq.)
50. Plaintiff incorporates paragraphs 1 through 49 as though fully set
10
forth herein.
11
51. During her employment with University of California, Riverside,
12
plaintiff GIULIANA MENDIOLA was subjected to intimidation and verbal or
13
14
physical conduct of a sexual nature by defendant JOHN MARGARITIS.
15 52. Defendant Mr. MARGARITIS’ conduct was unwelcome.
16 53. Defendant Mr. MARGARITIS’ conduct was severe and pervasive, so

17 much so it altered the conditions of Ms. MENDIOLA’s employment and created
18 a hostile work environment.
19 54. Ms. MENDIOLA perceived the working environment to be abusive or
20 hostile.
21 55. Mr. MARGARITIS was Ms. MENDIOLA’s supervisor empowered by
22 THE REGENTS OF THE UNIVERSITY OF CALIFORNIA to take tangible
23 employment actions against the Ms. MENDIOLA.
24 SECOND CLAIM FOR RELIEF
25 RETALIATION IN VIOLATION OF TITLE VII OF THE CIVIL RIGHTS
ACT
26
(By plaintiff GIULIANA MENDIOLA against defendant THE REGENTS OF THE
27 UNIVERTSITY OF CALIFORNIA.)
28 (42 U.S.C. § 2000e et seq.)

1 forth herein.
2 57. Plaintiff GIULIANA MENDIOLA opposed JOHN MARGARITIS’
3 mistreatment of student athletes and reported Mr. MARGARITIS’ misconduct in
4 cooperation with an investigation.
5
58. Following her reporting, THE REGENTS OF THE UNIVERSITY OF
6
CALIFORNIA failed to renew Ms. MENDIOLA’s coaching contract.
7
59. Ms. MENDIOLA had been successful and received excellent reviews
8
prior to her termination and was being considered for Head Coach. Ms.
9
MENDIOLA was subjected to non-renewal of her contract because of her candid
10
participation in the investigation of Mr. MARGARITIS.
11
THIRD CLAIM FOR RELIEF
12
RETALIATION IN VIOLATION OF TITLE IX OF THE EDUCATUION
13 AMENDMENTS OF 1972
14
(By plaintiff GIULIANA MENDIOLA against defendants THE REGENTS OF THE
UNIVERTSITY OF CALIFORNIA, JOHN MARGARITIS and TAMICA SMITH
15 JONES.)
16 (20 U.S.C. § 1681 et seq.)
17 60. Plaintiff incorporates paragraphs 1 through 59 as though fully set
18 forth herein.
19 61. Defendant THE REGENTS OF THE UNIVERSITY OF CALIFORNIA
20 receives federal funding and is subject to the conditions placed upon it by Title IX
21 of the Education Amendments of 1972.
22 62. Defendant JOHN MARGARITIS subjected female student athletes to
23 mistreatment based on their sex.
24 63. Plaintiff GIULIANA MENDIOLA opposed Mr. MARGARITIS’
25 mistreatment of student athletes and reported Mr. MARGARITIS’ misconduct
26
towards student athletes in cooperation with an investigation.
27
64. Ms. MENDIOLA attempted to report her concerns about Mr.
28
MARGARITIS’ misconduct to defendant TAMICA SMITH JONES. Ms. SMITH

1 JONES refused to accept the complaints and discouraged Ms. MENDIOLA from
2 elaborating on her personal experiences of harassment.
3 65. Following her participation in the investigation, THE REGENTS OF
4 THE UNIVERSITY OF CALIFORNIA declined to renew Ms. MENDIOLA’s
5
coaching contract. Ms. SMITH JONES indicated that she would work to prevent
6
Ms. MENDIOLA from acquiring another coaching job if Ms. MENDIOLA made
7
her concerns about Mr. MARGARITIS public.
8
66. Ms. MENDIOLA had been successful and received excellent reviews
9
prior to her termination, and she was being considered for Head Coach. Ms.
10
MENDIOLA was subjected to non-renewal of her contract because of her candid
11
participation in the investigation of Mr. MARGARITIS and her opposition to his
12
sex-based mistreatment of female athletes.
13
14
FOURTH CLAIM FOR RELIEF
HOSTILE WORK ENVIRONMENT IN VIOLATION OF THE FAIR
15 EMPLOYMENT AND HOUSING ACT
16 (By plaintiff GIULIANA MENDIOLA against defendants THE REGENTS OF THE
UNIVERTSITY OF CALIFORNIA and JOHN MARGARITIS.)
17 (Cal. Gov’t Code § 12940(a) et seq.)
18 67. Plaintiff incorporates paragraphs 1 through 66 as though fully set
19
forth herein.
20
68. Defendant THE REGENTS OF THE UNIVERSITY OF CALIFORNIA
21
employed defendant JOHN MARGARITIS and plaintiff GIULIANA MENDIOLA.
22
69. Defendant Mr. MARGARITIS mistreated Ms. MENDIOLA and
23
threatened to terminate her on numerous occasions.
24
70. Ms. MENDIOLA’s sex was a substantial motivating reason for Mr.
25
MARGARIRIS’s conduct.
26
71. Ms. MENDIOLA suffered harm, and Mr. MARGARITIS’ conduct was
27
28
a substantial factor in causing her harm.

1 is vicariously liable for the decisions of Mr. MARGARITIS.

2 FIFTH CLAIM FOR RELIEF
3 RETALIATION IN VIOLATION OF THE FAIR EMPLOYMENT AND
HOUSING ACT
4 (By plaintiff GIULIANA MENDIOLA against defendant THE REGENTS OF THE
5 UNIVERTSITY OF CALIFORNIA.)
(Cal. Gov’t Code § 12940(h) et seq.)
6
7
forth herein.
8
9
10 employed defendant JOHN MARGARIRIS and plaintiff GIULIANA MENDIOLA.

11 75. Defendant THE REGENTS OF THE UNIVERSITY OF CALIFORNIA
12 refused to renew Ms. MENDIOLA’s contract for employment after she described
13 the misconduct of Mr. MARGARITIS towards female athletes and following her
14 refusal to sign an agreement not to become pregnant.
15 76. Ms. MENDIOLA’s complaints about Mr. MARGARITIS were
16 substantial motivating reasons for the decision not to renew her contract.
17 77. Ms. MENDIOLA suffered harm, and THE REGENTS OF THE
18 UNIVERSITY OF CALIFORNIA’s decision was a substantial factor in causing her
19
harm.
20
DAMAGES
21
78. As a result of the actions of defendants, plaintiff has been injured and
22
has suffered damages as follows:
23
a. She has lost compensation and other employment-related
24
benefits to which she has been entitled and will lose such compensation and
25
benefits in the future;
26
b. She has suffered from emotional distress, embarrassment and
27
humiliation, and has suffered damage to her professional reputation and
28
standing;

1 c. She has incurred out-of-pocket expenses for health care

2 benefits.
3 PUNITIVE DAMAGES
4 79. Defendant JOHN MARGARITIS mistreated plaintiff GIULIANA
5 MENDIOLA for years because she was a woman and a woman who became
6 pregnant, and because she intervened in his mistreatment of female athletes. As
7 such, he acted with malice and oppression and/or with reckless indifference to
8
Ms. MENDIOLA’s protected rights and is liable to Ms. MENDIOLA for punitive
9
damages.
10
80. Defendant TAMICA SMITH JONES took steps to prevent plaintiff
11
GIULIANA MENDIOLA from participating openly in an investigation into the
12
wrongdoing of Mr. MARGARITIS and attempted to induce her compliance by
13
making false promises to MS. MENDIOLA. Ms. SMITH JONES acted with
14
malice, oppression and/or with reckless indifference to plaintiff GIULIANA
15
MENDIOLA’s federally protected rights and is liable to Ms. MENDIOLA for
16
17
punitive damages.
18 PRAYER FOR RELIEF

19 WHEREFORE, plaintiff requests that this Court grant her relief as follows:
20 (1) Injunctive relief to require defendant THE REGENTS OF THE
21 UNIVERSITY OF CALIFORNIA to reinstate plaintiff together with all pay,
22 benefits, seniority, and emoluments of that position; and treat her without
23 retaliation;
24 (2) Compensatory damages for past and future lost wages and
25 benefits, in an amount to be determined;
26 (3) Interest at the legal rate;
27 (4) General damages for emotional distress, pain and suffering, in
28 an amount to be determined;
(5) Special damages for out-of-pocket expenses;

1 (6) Punitive and exemplary damages against each individually

2 named Defendant in an amount appropriate to punish defendant(s) and deter
3 others from engaging in similar misconduct;
4 (7) Attorney fees;
5 (8) Costs of suit; and
6 (9) Such other and further relief as the Court may deem proper.
7 DEMAND FOR JURY TRIAL
8 In accordance with the Federal Rules of Civil Procedure, Rule 38(b), and
9 Central District Local Rule 38, plaintiff GIULIANA MENDIOLA hereby demands
10 a jury trial.
11
12 Dated: April 18, 2020
13 SIEGEL, YEE, BRUNNER & MEHTA
14
15
By: _/s/EmilyRose Johns_____
16 EmilyRose Johns
17
Attorneys for Plaintiff
18 GIULIANA MENDIOLA
19
20
21
22
23
24
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Case 5:20-cv-00832 Document 1 Filed 04/18/20 Page 1 of 15 Page ID #:1

1 DAN SIEGEL, SBN 56400

Mendiola v. Regents, No.

1 then-Head Coach JOHN MARGARITIS came under investigation for mistreating

Mendiola v. Regents, No.

1 7. At all times relevant hereto, defendant JOHN MARGARITIS was the

Mendiola v. Regents, No.

15 MENDIOLA’s and Ms. Bell’s coaching comments in favor of coaching comments

Mendiola v. Regents, No.

Mendiola v. Regents, No.

1 made Ms. MENDIOLA feel manipulated and uncomfortable. Mr. MARGARITIS

15 27. Following the team’s poor performance, TAMICA SMITH JONES

Mendiola v. Regents, No.

15 MENDIOLA for confronting him about his inappropriate behavior.

Mendiola v. Regents, No.

15 the investigation, Mr. MARGARITIS started to exclude Ms. MENDIOLA from

Mendiola v. Regents, No.

15 team following Ms. MENDIOLA’s termination.

Mendiola v. Regents, No.

1 49. GIULIANA MENDIOLA filed a claim with the Equal Employment

15 52. Defendant Mr. MARGARITIS’ conduct was unwelcome.

16 53. Defendant Mr. MARGARITIS’ conduct was severe and pervasive, so

Mendiola v. Regents, No.

Mendiola v. Regents, No.

Mendiola v. Regents, No.

1 is vicariously liable for the decisions of Mr. MARGARITIS.

10 employed defendant JOHN MARGARIRIS and plaintiff GIULIANA MENDIOLA.

Mendiola v. Regents, No.

1 c. She has incurred out-of-pocket expenses for health care

18 PRAYER FOR RELIEF

Mendiola v. Regents, No.

1 (6) Punitive and exemplary damages against each individually

Mendiola v. Regents, No.

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