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I Andrea L. Cook,.SBN 164915
Jai)lep .W. Lewis, SBN J.44~5t)
2 ANDREA COOK & ASSOCIATES
401 East'ocean'Boulevard, Su1te 200
3 Long Bea'ch, californicJ 90802
FILED
LOS AN06LBS SUPRRIOR"COUR.T
Telephon~: (562) 951-913s··
· 4 Facsimile: · (562) 951-9126 NOV O; 2005
!i Attorneys for Plaintiff
ALEXANDRO VILL.Af)fJJE-VA
j.'i!._~_!!!G Ill
U¥&8 •• -~
6 ... ~~
7

8 SQPERlOgr(!OURT FOR THE STATE OF CAUFORNIA

9 FOR THE CQUNTY OF LOS ANGELES,.
JO
11 ALEXANDRO VILLANUEVA, case No.:
BC342416
12 COMPtAINTFORDAMAGES
Plaintiff,
l3 1, RACE PISCRIMINATION IN
VIOLATION OF CALIFORNIA
14 v. GOVERNMl:NT CODE SECTION.
12940(A)-DISPARATE
15 TREATMENT;
2. RACE DISCRIMINATION IN
16 LOS ANGELES COUNTY SHERIFF'S VIOLATION OF CALIFORNIA
DEPARll'1ENT; Sheriff Lee .Baca: in his GOVERNMENT CODE SECTION
I 7 officlal capacity; Captain Richard Adams, 12940(A) - DISPARATE
an indlviclual; and DOES 1 .through 100,
18 lnclusive, 3. ftr:t:m:I~NIN VIOLATION
OF CAUFORNIA
· 19 GQVl:RNMENTCODESECTION
) Defendants 12940(H)
20
DEMAND FOR JURY TRIAL
21

22 Complaint Filed: ~i~~9

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.25 Plaintiff, Alexan~ro Villanueva (hereinafter, "Plaintiff") com_pJains ~d

0,0 "'" f,;) , -
:"26 follows against Defendants Los Angeles County Sheriff's Depa_rtment, stjrif L~'I,
27 Captain Richard Adams, and DOES 1 through 100, Inclusive (colleg:ivety, f ~
.,.,,.,,.

28 "Defendants"), as follows:
, •-• , 11

oRrGI NA1.:
\'\JI'' ,.,,,.,f1-•,••;1~ll~·•fl!,•i)

- 1-
Complaint for Damages-
 ..
PARTIES. AND JURISDICUON
• ...
2 1. .
Plaintiff is and at all times relevant herein was an Individual residi1,1g In ~he city of
3 La Habra Heights, County of Los Angeles, State of ~ifornla and within this judicial
. '
4 district. Plaintiff is employed as a Sergeant by the Los Angeles County Slieriff's
s Department ('\LASO").
6 2. On November 18, ?004, Plaintiff timely filed an dalm of discrimination pertaining
7 to the acts -herein alleged with the Departmen~ of Fair Employment and Housing. On
8 February 11, 2005, Plaintiff was Issued a ''rlght to sue" letter from the Department.
9 Attached hereto as Exhibjt "A."
ffi 3. On October 12, 2005, plaintiff timely flied a dai_m for retaliation pertafnlng to the
11 acts herein alleged with the Department of Fair Employment and Housing aga(nst the
12 Los Angeles County Sheriff's Department and captain Richard Adams. On October 19,
13 2005, PJaintiff was issued "right to suen letters from the Department. Attached hereto
14 as Exhibits "B" and ''C."
1s 4. Venue Is properly ~laced 1n the County of Los Angeles, State of Callfornia, for the
I

16 followlng reasons, among others:.

t7 a. Plaintiff's claim arose In the County of Los Angeles, State of caufornia;
18 LASD employeq Plalntiff In the County of Los Angeles, State of canfornia;
19 b. The acts compfained of herein and as set fOrth below occurred In the
20 County of Los Angeles, State of califomia;
21. c. Defendant's oblfgatfons .and liability to Plaintiff arose In the County of Los
22 Angeles, Stpte of califomia;

..:23 d. The effects of such tortuous conduct and the damages resulting therefrom
-¥4 to Plaintiff occurred In the County of Los Angeles, State of califomla;
. 2S e. The County of Los Angeles is· the residence of Defendants, for venue
·26 purpo$es, as cASD ls operates In this co~nty and In this judicial district;
.
27 and,
28 Ill

-2-
Complaint for Damages
 l f.
• ·•
Jh~ County of _LO$ ~ngefes, State of Callfomia has an Interest in protecting
2 and vin~jcating tl1e rights of its residents as against LASD and Its agents
3 against wrorigfutand tortuous conduct.
4 g. This court has general juriS('Jlction over LASO as ft. ts and at all times
5 hereinafter mentioned was operating in the County of Los Angeles, State
6 of California arid, in tnJs judicial district, conducting ~ continuous,

7 pervasive,.wide ranging, and substantial public agency.

8 h. This court has general jurisdictlon over captaih Richard Adams, aresident .
9 of Los Ang.eles County.
10 I. More specifically, this court has jurisdiction over Defendant LASD with
11 respect tp th~ emplos,ment of Plaintiff, which occurred ln the County of
12 Los Angeles and within this judicial distrl~.
13 $TATEMENT OF FACTS
14 s. Plaintiff Afexan~ro Villanueva rvmanueva") is a. male Hispanic and resident of
15 Los Angeles County.
16 6. In 1992, Villanueva graduated from Regents College, University of the State of
17 New York With a B.S. d~ree lh liberal studies.
18 7. VIiianueva was first employed by the Los Angeles County Sheriff's Department
'
19 ("LASDj in 1986 as a deputy. Villanueva setved as a deputy until December 3, 2000.
:!O .During this time, he received regular raises in pay, outstanding perfonnance reviews,
21 and the fqllowing accolades: meritorious service award (1993); multiple unit level
22 commendations; and,. theSlieriffs's Commendation for participation in the Diversity
·;rs Steering Committee.
_..i4 8. In 1998, VIiianueva took the LASD examination fer promotion to the rank of
\s Sergeant. On this test, he successfully completed the examination and was placed in
£+6 Band One. Villanueva was promoted to the position of Sergeant on December 4, 2000.
27 9. Since being promoted-to the position of Sergeant, Plaintiff has applled for
~Jthi~· fhe depi~~~t ';rid for
1 1 1
28 numerolJs "co~~t~d" andior "high .Pr~fll~'' positions

C011Jplalnt for Damages

 promotion to Lieutenant in 2003 and 2005. All of Plaintiff's applications for other
2 positions and/or promotiohs have been denied.
3 10. In 1989, Plaintiff was yery Involved in a successful grassroots fight to eliminate
4 smoking within Custody faciliti.es. Pl9Intiff authored the pllot•study, and drafted the unit
5 level and division policies that mandated banning smoking from all custody facilities.
6 11. In l,996, Plaintiff began attending earstate Northridg~·University in a program
7 for-a Masters Degree.In Public Administration. Plaintiff received his M.P.A. degree in -
8 1997.
9 12. In .1997> Plaintiff authored a Master's thesis.entitled: "The RecnJltment and
10 Promotion of Hispanic Officers in Law Enforcemen,t in Southern California." Sheriff Lee
11 Baca (then Chief Baca) was an expert panel membl:r oh Plaintiff's thesis committee and
12 was provided with a final copy of Plaintiff's thesis. Plaintiff's thesis used statistical
13 methods and data collected from defendant LASD to lllystrate the disparate treatment
14 of Hispanics in the LASD'. Plaintift'.s thesis was higt11y critic.al of the policies and
15 · practices employed by dE!fendant LASO .in its promotion proc~sses and concluded that

16 the procedures em'ployed by the defendant l.ASD had a tjiscrimihatory impact on

17 Hispanic deputy sheriffs.
18 13. In 1998, Plaintiff organized gra.ssroots campaigning and precinct walking on
19 behalf of then challenger Lee ~aca in the sheriff's el~ctlon against incumbent Sherman
20 Block. Plaintiff was very involved in campaign efforts to expose fraudulent campaign
21 practices by.ALADS (Association for Los Angeles Deputy Sheriffs).
22 14. In 1999, Plaintiff became the founding president of LASPA {Los Angeles Sheriffs
- -~3 Professional Association), an employee organizatioh f9rmed to challenge the corrupt
'·
~;24 practices of Al.ADS an9 to.tfecertlfy them as the bargaining unit for deputy sheriffs.

25 While leading LASPA, Plaintiff was told by then Stieriff's Department Commander D.
_:.;26 Campl;>ell to not "push this union thi~g too hard," if Plaintiff valued his career.
27 15. ln April, 2001, .PJaintlff inquired about a va~ancy of the "Operations Sergeant" at
... . ,,, .. 111 , ll'i" .~ ''Ill 1 , •11~•1r , 11
28 Lennox station and was told that the position was ''unavailpble." Plaintiff later learned

Complaint for Damages

1
• •
t that the position was filled by a white ry,ale. Subsequently, Plaintiff made other
2 attempts to apply for "available" coveted and/or high profile positions within the LASO
3 in order•to advance his career and each time was met with rejection.
4 16. In;April of 2001, Plaintiff applied for the position of Operations Sergeant (a
s coveted and high profile positiQn) at the Lennox station where he worked. Plaintiff was
6 .informed by defendant captain Adams, his supervisor, that the position rtlay not
1· actually be available. Later, defendant Adams appointed a caucasian male to the
'8 position of Operations Sergeant. This caucaslao male would lat~r become defendant
9 Adams first choice for promotion to Lieutenant in place of Plairttiff.
JO 17. In December of 20Q3, P.laintiff again applied to defendant Adams for the position
11 of Operatibhs
. Sergeant at ..ttie Lennox~statlon. On this occasion, Plaintiff
.
was again
1;? rejected and defendant Adams seJected a lesser quallijed African American female.
1~ 1,.8. On all but one dccaslon, the coveted and/or .high profile positions that Plaintiff
14 appJied for were filled by defendant LASO with non-Hlspanlc employees.
1s 19. In September, 2001, Plaintiff authored a study entitled, 11The Los Angeles
16 Sheriff's Depar.tment - A Brlef Analysis of Diversity." :rhis. statlstically based study was
I7 critical oi the prom9tional practices of defendant LASD anq jllghlighted the disparate
18 impact of tt,ese policies and ·practices on Hispanics within the department. This study
J9 further outlined the continuing .problem of under-representation of Hispanics within the
20 LASO, and compared them to the figures from a similar 1997 study conducted by the
21 Plaintiff. This paper-was presented·to LASO executlve Commander GIi Jurado, who
warned Plaintiff that jf he wanted tD remain friends, Plaintiff should not insist on
. 22_
,
.23 pushing ''the bro~n thing."
...~4 · 20. In 2002, Plaintiff volunteered for the Diversity Steering Committee, Affirmative
.. .
25 Action Task Force In order to advocate on behalf of equal opportunity and diversity.
~ .
·_.26 After a promising start at addressing the i~sue of.diversity this group was summarily
27 dismissed and the Div~rstty Plan ~as written behi~d dosed doors, without Plaintiff's
28 Input, and" most Importantly, without ever producing any identified goals or timetables

-5-
Compl~irit for Dam,ges
 ..

• •
with ~which to achieve diversity as mandated by the Board of Supervisors. Plaintiff
2 voiced his objections to the authors of the report.
3 21. In 2002, Plaintiff ~xchanged e-mails with then Commander Paul Tanaka
4 regarding LASO Strategic Plan and diversity efforts. Plaintiff criticized the Department's
s promotlonal practices. In response, Commander Tanaka told Plaintiff that he was
6 "disappointed" that PJaJr,tlff had a '~negative view" of the pepartment, but dfd nothing to
7 address Plaintiff's ~oncems,;
8 22. In 2002, Plaintiff el')ro(led at tfle University of Laverne In the doctoral program
' 9 for Public Administration. Plaintiff received his D.P.A. degree In May of 2005. Plaintl~s
10 doctoral dissertation is entitled, "Leadersh1p Diversity in Law Enforcement."
ll 23. In May of 2003, Platntifftoo~ the examination for promotion to the position of
12 Lieutenant. Plaintiff received the third highest written score (an objective test), but
13 received a noncompetitive score of 95 on his Appraisal of Prcnnotablllty ("AP'') from
14 defendant•Adams. The AP process Is a subjective evaluation. At this same time,
15 aefendant Adams was responsible for AP scores for a total of 10 appllcants for
16 Lieutenant from the Lenn~)( station.. Of the 4 caucasian candidates evaluated by
17 defendant Adams, 3 received scores of 100 and the other a score of 95. When
18 evaluating the minority candiqates (4 Hispanic and 2 African-American), defendant did
19 not award a score of higher than 95 to any of these individuals. An AP score of Jess
20 than 100 virtualJy assures that a can~idate Sergeant will not be promoted to the
21 positlon,.of Lieutenant.
22 24. Of the November of 2003, a~ a result of hrs test scor~s, Plaintiff was placed ln
"Band TW011 and rankeq 4th out of nls station by defendant omtaln Adams. Such a
...:•:-23
..
··24 ranking insured that Plaintiff would not be promoted to the position of Lieutenant
':.

.25 25. Defendant Captain Adams has stated that-Plaintiffs advocacy of diversity was
=-~6 "self serving." Defendant Captain Adams selected a <;:aucaslan male Sergeant as the
27 top candidate from Lennox station. This caucasian sergeant Is the same individual that
28' / / /

-6-
complaint fOr'Damages
 defendant Adams selected over Plaintiff in the appointment to the position of Operation

~ Sergeant at the Lennox station.

3 26. Although Plainliff pursued all of the available appellate avenues lo seek a remedy

~ for denial of promotion to Lieutenant, he was repeatedly denied relief. During this

5 same time period, defendant LASD granted the appeals to a number of other non-

6 Hispanic Sergeants by artificially elevating thelr oral Interview scores and thereby

7 placing them in promotable Bands.

s 27. From December, 2003 to present defendant LASO has promoted approximately

9 81 candidates from the list generated by the 2003 Lieutenant exam. White mates and

IO other non-Hispanic Sergeants were selected in disproportionate numbers.

11 28. l n January, 2004, in pursuing the appeals process from the Lieutenant exam,

12 Plaintiff contacted Assistant Sheriff ("A/S") Campbell and complained of racial

13 discrimination. A/S Campbell told Plaintiff not lo "make a crusade" of his efforts
l<l regarding my allegations of discrimination. In violation of LASD policy, A/S Campbell

I5 failed to file a Policy of Equality report concerning Plaintiff's complaints of racial

16 discrimination.

17 29. In January, 2004, Plaintiff submitted a detailed appeal to the Appeals Unit,

18 Department of Human Resources for Los Angeles County, wherein he voiced his

19 concerns about discrimination, political patronage, and identified his Captain, defendant

20 Adams, as one who was responsible for t he discriminatory AP scores from the Lennox

21 Station. Again, contrary to LASD policy, there was no investigation of a Policy of

..,.., Equality violation based upon Plaintiff's complaint of racial discrimination and

23 identification of defendant Adams as the perpetrator of a violation. This failure to

~ -1 investigate continued a pattern by defendant LASO of ignoring Plaintlff's allegations of

25 racial discrimination.

:26 30. Shortly after filing this appeal, in February of 2004, Plaintiff was transferred from
27 patrol to the Lennox Youth Center.

28 ///

-7 -
Complaint for Damages
 31. On May 5, 2004, Plaintiff prepared Performance Log Entries for two Deputies that

2 were critical of their performance because they had failed to carry out direct orders

3 from Plaintiff regarding completion of a group project. The log entries that were

..J prepared by Plaintiff were reviewed and approved by Plaintiff's supervisor, Lieutenant.

s Dinsmoor, who witnessed Plaintiff giving lhe log entries to both deputies. One of these

6 deputies would later testify against Plaintiff in an Investigation of Plaintiff's alleged

7 violation of the LASD Policy of Equality.

8 32. On May 20th, 2004, Plaintiff flied an internal complaint of discrimination with

9 defendant LASO, Identifying specific practices and individuals he believed to be

1o responsible for the discriminatory policies and practices of defendant LASD in the

11 promotion process. Following a sham investigation, Plaintiff was notified that his

12 charges against defendant Adams and A/S Campbell "could not be substantiated."

13 33. Within a week of Plaintiff's complaint of discrimination, he became the subject of

14 an investigation alleging violation of Department policy (ironically, Plaintiff was now

1.s alleged to have violated the "Policy of Equality" reporting procedures. These are the
16 same " reporting procedures" that were repeatedly Ignored in response to Plaintiff's

I 7 complaints of discrimination). The complaint against Plaintiff was filed just one week

18 after Plaintiff filed his complaint of discrimination, naming defendant captain Adams a

19 perpetrator of such discrimination.

~o 34. July of 2004, Plaintiff became the subject of second Policy of Equality

21 investigation. Plaintiff was alleged to have failed to report immediately to the Intake

~2 Specialist Unit that defendant Captain Adams, in an off-duty function, referred to his

:D male deputies present as "whores and bitches," to which no one present took offense at
?-1 the t ime. As a result of both Investigations, Plaintiff was unjustly disciplined, however
1, the other supervisors that had actual knowledge of the same incidents, yet failed to file
. 26 reports, received no discipline whatsoever.

27 35. For the second time and within the period of one month, Plaintiff was again

28 chc:irged with violation of LASO policy. Again, Plaintiff alleges that the charges were

-8-
Complaint for Damages
 t'

..

• •
. >

.,

.1 unfounded and that the disclpllne was 15eing ~mposed in ret.aliatlon for Plaintiff speaking
2 out about the discrimirlatory ·policies af practices of the defendant LASD and ror filing
3 an interns)I complaint of discrimination~.
4 36. As a result of defendants unwarranted and retaliatory actions (including, but not
s limlted to the baseless finding that Pia·. tiff lied during the investigations of the alleged
1j· •

-6 violation of the reporting procedures I~ the Policy of Equality), Plaintiff's career has
7 been seriously impaired and his oppo i nlties for future promotions made very
8 uncertain.
9 · 37.
10
On July 15, 2004, Plalntlf.l' met r;,!

j!

!J
½5D Commandtl!rs Martin and Miller at
Headquarters and discussed concerns .'.ver promotional proce~s with them.
11 Commander Martin stated than "no·on·i cares about diversity," apd as far as he courd
,
12 tell, Plaintlff h~d ''nothing coming."
13 38. On July 25, 2004, Plaintiff was transferred, involuntarily, to the Carson station
14 and assigped to the graveyprd shift. This action~ls contrary to department policy and
15 was done in retalfation for.Plaintiff's continued efforts. to speak out against the
16. discriminat9ry poHcies ahd practices of.defendant LASD.
.
17 39. In December, 2004, Plaintiff prepared a memorandum outlining discriminatory-
18 and unethic;al practices. by Department executives and sent it to various Chiefs and
19 Col"(lmahdet-s. Again; contrary to the LASD Polley of Equality, no investigation of
20 Plaintjff's c9mplaints was initiated.
21. ~. On June 28th and July 12, 2005, Chief Ronnie Williams, In public speeches
. 22 before all sergeants in Plalntlff'~ ~Msion; informed everyone In attendance that the
:•23 LASO employs quotas In the prpmottonal process and that preference is given to
;,~4 caucasian males.
.,, .
-~
"26

27 42.
41.
dctobe~ 24, 2005, Plilintlff tool<the fl
In July, 2005, Plaintiff agalp took the written and AP examinations, and on
examination for promotion to Lieutenant.
On November 18, 2004,., Plaintl.I filed a charge with the cantomla Department of
28 i;af r Employment and Housing ("DFEH · alleging that the def.endant ~D had

, -9-
Complaint for Damag~

i,
 I
• •
discrimJnated against him based upon his race by repeatedly denying him job
2 opportunities and promotion to the position of Uel{tenant. On February 11, 2005,
3 -Plaintiff received a "Right to Sue" letter from the OFEH.(a true and correct copy of
4 which is attached -hereto as Exhibit "A").
s 43. On Octo6er 12, 2005, Plaintiff flied a charg_e with the california Department of
6 Fair. Employment and Housing r'D.FEH") alleging that the def~ndant LASD and
7 defendant Adams hatl retaliated· ~gainst him for his t)aving spoken out repeatedly about
8 the discriminatory policies and practices of the defendant LASO and for filing an internal
9 coniplarnt of discrimination. on Octobef 19, 2005, Plaintiff ~eceivecl a "Right to Sue"
Io· letters from the DFEH (a true and correct copy of .which ~re attached hereto as Exhibits
11 ''B" and "C").
·12 FIRST CAUSE OF ACTION
13 RACE DISCRIMINATION IN VIOLATION OF CALIFORNIA GQVERNMENT
0

14 (:ODE $ection l294D(A) • DISPA~TE TREATMENT

15 Against ~efeqdant Los Ang_eles Sheriff's Department
16 44. Plaintiff realleges and incorporates herein p}' referenGe each and every allegation
17 contained in paragraphs 1 through 43, inclusive, of this complaf nt as though fully set
1s forth herein.
19 45. Plaintiff daims that defendant LASO wrongfully discriminated against him based
20 upon his race, Hispanic.
21 46. Plaintiff was at an times relevant employed by defendant ~D as a Sergeant.
22 47. Plaintiff has applied to defendant LASO for numerous promotions Including, but
;23 not Umlted to the position of Lie~tenant in 2003 ~nd 2005. Plalntiff was qualified for
~M
{
each of the positions-for which he applied. Each ot Plaintiff's applications have been
'
. _7s denied and other less qualified individu~ls of different-races have received these
!26 positions.
27 48. Plaintiff's race, Hispanic, \Yc)S a motivating factor for defendant LASD's refusal to
28 promote him.

-10- .
Complaint for Damages
..

49. Plaintfff has suffered, and continues to suffer- damages as alleged herein and the
2 actions of defendant LASO i!'l· refusing to promqte Plaintiff was a substantial factor in
3 causing Plaintiff's hann.
4 50. Plaintiff alleges that at all times relevant, def~ndant LASO acfed·with malice,
'
:i oppression and/or fraud in denying him promotion b,i:ised upon, his race.
6 SECOND CAUSE OF ACTION
7 AACE DISCRIMINATION IN VI0[4TION OF CALIFORNIA GOVERNMENT CODE
8 section 12940(A) • DISPARATE TREATMENT
9 Against Defendan.t LQ~ Angles Sheriff's Department
1o 51. Plaintiff realleges and incorporates herein by reference each and every allegation
11 contained in paragraph 1 through 50, inclusive, of this complaint as though fully set
12 forth herein.
13 52. Plaintiff clarms that defendant LASD had, and continues to have, employment
14 practices and a se]ettion policy for promotions that wrongfully discriminated against
15 him, and other similarly situated Hispanic employees.
I 6 53. Plaintiff was at 911 times relevant employea by .defendant LASD as a Sergeant.
17 54. Plaintiff has applied fo defendant LASD for numerous promotions including, but
18 not limited to the position of Lieutenant in 2003 and 2005. Plaintiff was qualified for
19 eacli of the positions for Which-he applied. Each of Plaintiffs applications have been
20 denied and other less qualified individuals of different races have received these
21 positions.
22 55. Plaintiff alleges that defendant LASD has and continues to employ a testing
:23 procedure and selection p91icy for promotions that has a disproportionate adverse effect
•' •
l.: -~ .
24 on Hispanic employees. The disparate impact of defendant's employment practices and
..25 promotion policies is evidenced by the fylct that Hispanics are significantly under
·:_~6 represented at all levels of responsibility (e.g., Sergeant, lieutenant, etc.) beyond the
27 level of Deputy.
2s I l!

-.11-
Complaint for Damag~s
 56. Plaintiff is a Hispanic employee.of ,defendant LASD and he has suffered harm
2 (i.e., denied promotions after numerous applications) as a direct result of defendant
3 LASD's promotion practices and ~o!icies.
4 57. Plaintiff has suffered, and continues to suffer damag,es as alleged herein and the
5 promotion policies and pFactices of defendant LAS~ have been a substantial factor in
6 causing Plaintiff's harm.
7 58. Plaintiff alleges that at all times relevant, defendant-LASO acted with malice,
8 oppression and/or fraud by mi3intaining and implementing promotional poHcies and
9 procetiures that hav~ adisparate and discriminatory-impact on Plaintiff and all Hispanic
10 officers.
11 'fHil{D CAUSE OF ACTION
12 RETALIATION IN VIOLATION OF CALIFORNIA GOVERNMENT
13 , CODE section 12940(~)
14 Against All Defen_dants
15 59. Plaintiff reall~ges and incorporates herein by reference each and every
16 allegatiqn contained in paragraph 1 through 58, inclusive, of this complaint as though
17 fully set forth herein.
18 60. Plaintiff claims that def~ndant LASO and defendant Captain Adams retaliated
19 against him because PlairJtiff had spoken about repeatedly about rad ally discriminatory
20 policies arid practices of def~ndant LASD.
21 61. Plaintiff ha~ since 2001 spoken out repeatedly and to many members of the
,22 defendant LASO concerning what he believes are racially discriminatory policies and
-23 practices of the defendant LASO.
, 24 62. Plaintiff has on numerous occasions set forth herein has been "coveted" and/or

. 25 "high profile" positl,ons_that are important for career development. These acts were
26 committed by both defendant LASD and defendant Adams. Plaintiff was denie9 a
27 promotion to Lieutenant by defendant LASD and defendant Adams in retaliation for
"I Ill l I'" ~ • \ , . , ~ ,O I I!

28 Plaintiff'$ many complaints about racial discrimination in the Department. Further,

- 12 -
Complaint for Damages
 •J
•
defendant LASD aq.d defendant Adams ha.ve undertaken.a campaign of unwarranted
2 disciplinary actions against Plaintiff for the purpose of damaging his career.
3 63. Plaintlff's speaking out about,the.racially discriminatory policies and practices of
4 defendant LASD wa, a motivating" reason for defendant LASO and defendant Adams's
s decisions not to c1ppolnt· Pls'intiff to "coveted" or "hi~h profile" positions, not to
6. promote the Plaintiff to the po~ition of Lieutenant, and the.imposition of unwarranted
7 and unfair discipline.
8 64. Two of the unwarranted disciplinary charges agalnst Plaintiff (one resulting in a
9 5 days suspension and the other in a 10 day suspension) are currently subject to
,I

1o review by the Civil Service Comm1sslon. Depending UP.On the resolution of these
ll investigations and after pursuing all relevant legal re·medies, Plaintiff hereby reserves
12· the right to amend this complaint to include these retaliatory acts.
13 65. Plaintiff has suffered,: and continues to suffer damages as alleged herein and the
14 retaliatory conduct of defendant. LASD anctCaptaln•Rfchard Adams have been a
1s sub~ntfal factor in causing Plaintiff's harm.
16 66. Plaintiff alleges that at all times relevant, defentlant LASO acted with malice,
17 oppression and/or fraud by maintaining and Implementing promotional policies and
18 procedures that have a qlsparate and discriminatory Impact on Plaintiff and all Hispanic
19 officers.
20 REQUEST FOR.RELIEF t

21 WHEREFORE, Plaintiff respe¢'ully requests that the. Court:

22 1. Award compensatory and general damages ;Jgalnst Defendants and each of

· .~,23 them, in an amount to b.e determined according to proof;
Award Plalntlff's reasoneble attorneys' fees pursuant to California Code of Civil

.,25 Procedure §1021.5; GQvernment Q:>de §12940(A) and (H), or other theories and
)6 statutes as may be appropriate;
27 3. Award Plaintiff's costs of suit incurred herein;
.. •• ,. ' • • ·-~ • I • , ...... ,. I! ,,,, , , , ,.... - .. !'"'' ~··· "· ': ti

28 4. Award punitive damages as against all Defendants; and

-13-
Complalnt for Damages
 l s.
• •
Grant such other and~further rellef as this court may deem Just and proper.
6

2 Dated: November 2, 2005 ANDREA COOK & ASSOOATES

3
4
5

6 Attorneys for Plaintiff

ALEXANDRO VILLANUEVA
7

8 DEMAND·FOR JURY TRIAL

9 The Plalntiff in the above entitled action requests a trial by jury as provided by
1o Artide I of the CallfQmia Constitution and ).mendment VII of the United States
. 11 Constitution.
12 Dated: November 2,1 2005 .ANDREA coo~ & ASSOCIATES
13
\-X - t,
l4 r By: ' \ ~U- r--.
Ari
15
Attorneys for Plaintiff
16 ALEXANDRO VILLANUEVA
17

18

19
20
21
22
23

...2:4
25

27
28

-14-
Complaipt for Damages..
., trAff OF ('AIJ}'OMfl,\ ..St&cn14('c...-rScntce1A1t_,.

.DEPARTMENT OF FAIR EMPLTNT & HOUSING

6111 West 6th Street. Los J\ngeles., CA 900
(213) 439-67.01 TTY {800)700-232.0) FAX (213) 439•6?}5 •
February 11, 2005

ALEXANDRO VILLANUEVA
2183 El Cajooita Dr.
l:.a Habra Heights, CA 90631
~

RE: E200405S0765-00-e/37AA510154
VILLANUEV~t:os ANGEL~S. COUNW OF. SHERIFPS DEPT.

Dear 'ALEXANDRO VILLANUE'vA:

NOTICE.. OF CASE.CLOSURE
The consultant assigned "to handl(t the ~bo'(e-referenced. discrimination complaint that
was filed with the D.epartment of Fair Employment and Housing (DFEH} has
recommendE)d that the case be closed·on the basis of: Processing Waived To.Another
Agency.

Please be advised that this' recommendation hps been accepted and the case·has been
closed effective February 10, 2005:

This letter is a[so your Right:To-Sue Notice. According to Government Code section
12965, subdivision (b), a civD action may be brought under the provisions of the Fair
Employment and Housing Act against the person, employer, labor organization or
' employment agency named in the above-referenced complaint. This ·is also applicable
to DFEH complaints that are flied under, and allege a violation of Government Code
section 12948 which incorporates Civil Ccsde sections 51, 51.7, and 54. The civil action
must be filed within one year from th~ date of this letter. However, if your civil
complaint ~lieges a violation-of Civil Code section 51, 51.7 or 54, you sbould consult an
attorn~y abqut tile applicable.statutes of limitation. If you•signed a-setttement
agreement resolving your complaint. it is likely 'that you have waived your right to file a
priva~~ lawsuit.

.'
.
Notice of Case Closure
Page Two
•·
I
•
-This case may be referred to the U.S. Equal Employment Opportunity Commission for
further review. If so, pursuant to Government Code section 12965, subdivision (d)(1),
. to sue will be tolled during the pendency"of EEOC's
your right .. review of your complaint.
· • The Department of Fair Employment and Housing ~oes not retain ·case files beyond
three years after a complaint Js frlea, unless the case is still open at the end of the three-
year period. ~

Sincerely,

~/LY~
Lottie Waodruff
DJstrict Admini$trator
cc: Case Flle I

. ;

.
,·
..

Human Resources Mgr.

LOS ANGELES, COUNTY OF, ~HER(FF'S DEPT-._
4700 Ramona Blvd. .,.,i.,,,,.,,.. ,., ,"•'1 1
: : I "'~II 'I' I

Monterey Park, CA' 91754

DFEH-200-0Se (0.t/03)
SGRAHAMTG
STAT60FCAUIUN1A• SfA'[EANOCONSUMERSERVJCSS•·

DEPARTMENT OF FAIR EMP..LOYMENT & HOUSING

i,11. West Sixth street, SUite 1500 .Los Angeles. CA 90017
(213) 439-6700 (800) 700-2~20 Fax (213)..439-6715
• APJCCLDSCHWAIZENEOGER.~

October 19, 2005

Andrea t. Cobk
Attorney At Law
Andrea Cook & Associates
401 East Ocean·Blvd., Ste'200
Long Beach, CA 90802

RE: E200506S0590-00-rc
VltLANUEVAiLOS ANGELES. COUNTY OF, SHERIFPS DEPARTMENT

Dear Andrea L. Cook:

. TO COMP-LAINANT S ATTORNEY
1
NOTICE

Enblosed is a yopy of your.client's complaint of disQrimination filed with the Department

of Fair Employment and 'Ho~sing on 10/12/2005 pursuant to the callfomia Fair
f;mployment and Housing Act, Government Code sectioo 12900 et seq. Also enclosed
is a copy of your client's Notice of Case Closure, which constitutes your client's rjght-to-
"sue notice.
I .
Please-note that·under ~overnment Code section 12962, you are responsible for
service of the coinplalnt on respondent(s). You shourdalso enclose· a copy of the
Notice of Case Closure along with the compfaJnt. These documents must be served
within 60 days of the filing date of the complaint. Government Code section 12962(b)
further provides that complaints must be served either personally or by certified mail
with return recefpt requested.

For·additional information,.. please read the enclosed Noti~ of Cas~ "Closure that
explains the conditions for filing a private lawsuit In the State of Calffomfa.

Sincerely,

:!: / } ~ h0 _. _ /_ J1J.. '_

Crr/lQiT ~ ; -
Lottie Woodruff
Distrlct
... Adminl~traior
·1

Enclosure~ Complaint of Discrimination

,.., ·:.
Notf~ o.f Case Closure r
t
OFEH"200-08 (01/05)
Oocument2
.ffA1EOPCi roittllA•STA1UHDCOHSUMBSERV1Cf,U AlUfOU>SC'HWAllZ&N!OOElt. OolffllOr

0
DEPARTMENT OF FAIR EMPLO ENT & HOUSING
6l 1 West Sixth Street, Sulte 1500 ,(05 Angeles, CA 90017
(213) 439-6700 (800) 700-2320 Fox C213) A39-6715

October 19, 2005

Andrea L Cook
Attorney At Law
Andrea Cook & Associates
401 East Ocean Blvd., Ste 200
Long Beach, CA 90802

RE: E200506S0590-00-rc
VILLANUEVA/LOS ANGELES. COUN~ OF, SHERIFF'S DEPARTMENT

Dear Andrea L. Cook:

NOTICE OF CASE CLOSURE

This letter informs that the abov~referenced complaint that was filed,with the
Department of Fair EmploymeQt anti Housing (DFEH) has been closed effective
October 12, 2005 because an immediate right-10-sue notice was requested. DFEH will
take no further action on the complaint. • ·

This letter is also the Right-Tp•Sue Notiqe. According to Government Code section
12965, subdivision (b), a civil action may be brolJght under the provfsions of the Fair
Employment and Housing Act against the person. employer1 labor organization or
employment agency named In the above-ref~renced complaint. The civil action must be
filed wittiin one year from the date
.. of thls letter.
If a federal no~ice of Right-To-S.ue fs wanted, the U.S. Equal Employment Opportunity
Commissfon (EEOC) must bq visited to file a complaint.within 30 days of receipt of this
DFEH Notice of Case Closure or within 30Q days of the alleged discriminatory act,
whichever-is earlier.

t
i··
..
,,•

...
 '\

Notice of Case Closure

Page Two
• •
·The Department of Fair Employme,nt and Housing does not retain case files beyond
three years after t\. complaint is filed, unless the base Is still open at the end of the three•
year p~rlod. ·

Sincerely,

o{?,.a5-~
Lottie Woodruff
Distri~t Administrator

cc: Case File

,,

District Manager ·
LOS ANGELES, COUNTY OF. SHERIFF~ DEPARTMENT I •I " "
111
' I

4700 Ramona Boulevard

Monterey Park, CA 91754
OFEH-200-43 (04103)
 .
• *"' EMPLOYMENT**• •
COMPLAINT OF DlSCRIMINATION UNDER DFEH # £-~~ . . S -6J5'/0- 00 • re.
THE PROVISIONS OF THSCALIFORNIA DFEH USE ONLY
FAIR EMPLOYMENT AND HOUSIN~ ACT
CALIFORNIA DEPARTMENT OF FAIR EMPLOYMENT AND HOUSING
"YOUR NAME (lndlr.ate Mt. oc Ms.) TB.EPHONE N~SER ONClUDEAREA CODE)
Alexandro Villanueva (562) 694-2400
ADDRESS
2183 El Gaionita Dr
CJTY/STAlE/?IP COUNTY COUNTY CODE
La Habra Heights, CA 90631 Los Angeles County
NAMED IS THE EMPLOYER, PERSON, LABOR ORGANIZATION, .EMPLOYMENT AGENCY, APPRENTICESHIP
COMMITTEE, OR STATE OR LOCAL GOVERNMENT AGENCY WHO DISCRIMINATED AGAINst ME:
NAME TELEPHONE NUMBER (lndud~ Area CocfoJ
Los Angeles County Sherifrs Department • I (323¥ 526-5541
ADDRESS : OfEH use ONLY
4700 Ramooa Blvd. ·
CITY/STATE/ZIP • COUNTY COUN1YCOOE
· Monterey Park. CA 91754. Los Angeles County
NO. OF EMPlOYEES/MEMBERS (if known) DATE MOST ReceNT OR CONTIHUING DISCRIMINATION RESPONDENT CODE
approx. 15000 TOOi( PLACE (month. day. and year)
THE PARTICULARS ARE:
on ongoing I was_ fired _ denied cmploymeni _ ~nfed famil/ Ot medical leave
-•laidoff _ denied promotion - dellfed pregnal\ey leave
_demoleel _denledltan$fer _ denied equalJN>'/
_ harassed _ denied ccccmmoda6cn • _ denied rfQflt \Owear pants
_ gonefic Charac:terlsucs' tesllng _ tmpelffllsslble non{ob-rela!edtnqui,y _ dented pegnancv accommodatlon
- forced to quit .A.. other(spoeify) .... lia...,t_e_d....:;a__g_a_in....s;;;.;;;t_ _ _ _ _ __
re...,t...,,a....

by.-----------------------------------------
Name Person of Job TWe (SU~1Yliorl'mana9erlperspvlel d!tectortetc.)

because of my: _ sex L nalJcnal Olfg!iwncest,y - p~cJlsabillb' - QUICOJ _ (Cltdo Ck'\8) (ding;
_age _ nwte:1 status _metqtd\sabahy - gpnellcd'larac:tedslic prctostfng; ~1111g fn
_ religicn _ IDXUiJI onentallon
ln¥e$flga1Jon (retallaUcn tor,
_ mce/eotor _ association
- GIIC!(speaf)? - - - - - - - - - - - - - - - - - - - -

~e reason given·by
Name of Persan and lob ffle

Was because of I was subjected to severa( incidents of retaliation because of my fregyent complaints
(please state b . . h
what you beHeve a out_ racism mt e Department
to be reason(s)J

m~
Iwish tt> pursue (his fn court f herebyrequestthat the Department of Fair Employment and Housfng pcovlde a lfghl-to-sue noUet. l ~ lhattt Iwanla federal nob o1
righHO•S~, Imust~ lhe U.S. Equal ~ I Opportunity Comntisslon (EEOC) lo file O CO~nl wl1hfn 30 dap olrec:efpt of die OFBI °'Notice crease cioswe.• Ol wdlJlin 300
days of the aJ?eged dlscdmina10ey
,. act. whichever Is earner.

I havo not been coerced Into making Chls ,aqunt. nor do I moJce It based oR fearcrrctalalfon !rl do not cso so. I undCtSland It Is the 08pa,tment or Farr Emplc7/menl ancr ffousfng"s
pollcy lo nae p,ocesj er reopen a complalnt once the complaint has been dosed..on lhe basis or "Comp(amanl Elected Coult Acfion.•

I dedateuncserpe~Of pesJuryvnderthe laws cf the State ofCafffomla Uiallhe for090ln9 Is trua e1ld coc~-Ofmy
and beUef, and as ~those rnaae,u I be&ve Uto be ttuo. • •
l<...todgey11~co,,........._
r/ /
oaiecs October 1, , 2005 ·, 'a.~
COMPlAINANl"S SIGNATURE
·
A1
•
Long Beach
•
CA
C,ty
RF .. :-·., ,,-D
Alexandro Villanueva
--- :1 .. .I!--•• r:.II I

;,
·-

?- ..
DATE FILED.

DFEH-300.03 (01/03) STA1'E OF CALIFORNIA

DEPAR'IMENTOF FAIR E¥PLOYMENT ANO HOUSING LSollfEK1
STAliOS:C'AIJFOaNIA STATEANDCONSlfl,1ER5ERVICES
0

DEPARTMENf OF FAIR EMPLOYMENT & HOUSING

61 Ywest Sbdh stteef. suite 1500 ,Los AngeJ~·cA 90017
(213) 439-6700 (800) 700-2320 Fox (213) 43~-6715

October 19, 2005

Andrea L. Cook
Attorney At Lay,
Andrea Cook & Associates
401 East Ocean Blvcl:, Ste 200
Long Beach,, CA 90802

RE: E200S06S0590-03-rc
- .
VILLANUEYNADAMS, RICHARD QAPTAlN, As an Individual

t>ear Andrea L. Cook:

NOTICE TO COMPL~INANT1S ATTORNEY

Enclosed is a.copy of your client's comp(~int of discrimination filed with the Department
of Fair Employment and Housing on 10/12/2005 pursuant to the California Fair
Employment and Housing Act: Government Code section 12900 et seq. Also enclosed
is a copy of your cliepf•s Notioe of Case Closure, 'which constitutes your client's r1ght-to-
sue notice.

Please no1e that wnder Government Oode sec~ion 129p2, vou are.responsible for
~es:vlce of the complaint on re,pol}dent(s). You should also el}clos~ a copy of the
Notice of Case Closure along wjth the complaint. These .documents must be served
within 60 days of the filing date of the complaint. Govemment Code section 12962(b}
further provides.that complaints must be served either p~rsonally of by 9ertlfled mall
with return receipt requested.

For additional information, plea,se read the enclosed Notice of Case Closure that
explains the conditions for fUing a private lawsuit in the State· of California..

Sincerely, ✓

;~; /} - hn,.. . J__ L) .

{7~:iQ.u ~~
Lottie Woodruff
DfsJrict Administrator
~:.,..:
Enclosure: Complaint of Discrimlnqtipn
Notice of Case Closure ..
... . •..:
OFEH-200-06 (01/05)
Document2
Si"AT50FC.-LJfORNlA•STAl&AHDCONSUMERSER\1C6SA ARNOLDSCHWARZetEIJGER. (icr,c,s:lor

DEPARTMENT-OF FA-IR EMPLO ENT & HOUSING

611 West Sixth street# Suite 1500 ,Los Angeles. eA,90017
(213) 439-6700 (800) 700-2320 Fox (213) 439-6716

October 19, 2005

Andrea L. Cook
Attorney.At Law
Andrea ..Cook.& Associates
401 East Ocean Blvd., Ste 200
Long Beach, CA. 90802

~RE: E200506S0590-03-rc
VILLANUEVA/ADAMS. RICHARD CAPTAIN, As an Individual

Dear Anqtea L. Cook:

NOTICE OF CASE CLOSURE

. ~

This letter informs that the above-referenced complaint that was·filed with the
..
Department of Fair Employment and Housing (DFEH) h11s been closed effective
October#12 1 2005 because an immediate right-to-sue notice was requested. DFEH will
take no further actiqn on the c9mplaint.

This fetter is-also the. Right-To-Sue Notice. ~ccording to Government Code section
12965, subdivision (b), a c!IVIJ..actlon may be brought under the provisions of the Fair
Employment and Ho~slng Act against the person,-employer, labor organization or
employment agen..cy named in the above-referenced complaint. The civil action must be
filed 'within one year from the date of this letter.

If a federal notiqe of Righi-To-Sue is wanted, the U.S. ~qlfal Employment Opportunity

Comml~sion (EEO.O) must r,Et vi!iiled to file,, a complaint within 30 days of receipt of this
DFE,H Notice of Case Closure o.r within 300 days of the alleged discriminatory act.
whichever is earlier.

...
!

...
:
 •
..

•
...

Notice• of Case-Cfosu re
Page Two

Tfie Department of .Fair Employmerit and Housing ~oes not retain case files beyond
three years after a complaint· is filed, unless the case is stlll op.,en at the end of the three-
year period.

'Sincerely,

#~~
Lottfe Woodruff,.
District Administrator

cc: Case Fife

... ..,
, ;

..
•'
Captain Richard· Adams
As an Individual
LOS ANGELES,.C6U.NTY OF, SHERIFF'S DEPARTMENT
4700 Ramona Boulevard
Monterey Park, CA 91754 OFEH-200-43 (04/03)
,

COMPLAINT OF DISCRIMINATION UNDER

"THE PROVISIONS OF THE CALIFORNIA
.
l=AIR.,EMPLOYMENT ANO HOUSING
. ACT
• * •· EMPLOYMENT * * •

.
QFEH # •
£-'J.8c,'5o&,-s ""06t:f"O ...
OFEH USE ONLY
0'3-rc..,

CALIFORNIA DEPARTMENT OF FAIR EMPLOYMENT AND HOUSING

YOUR NAME (lndlcatO Mr. or Ms.) TElEPHONE NUMBER (lNCLUDEAREA CODE)
Alexandro·Villanueva • (562) 684-2400
~DDllESS
2183 El Caionita Dr
CITYISTATEIZJP COUNTY COUNTY COOE
La Habra Heights, CA 90631 • Los Angefes County
'NAMED IS THE EMPLOYER. PERSON, LABOR ORGANIZATION, EMPLOYMEtfr AGENCY, APPRENTrCESHIP
COMMlTTEE, OR STATE dR LOCAL GOVERNMENT AGENCY WHO DISCRIMINATEO.AGAINST ME·
NAME TELEPHONE NUM8ER (lnclc:de Alea CO®)
.Captain Richard Adams, Los Angeles County Sheriff's Dept. . (323} 526-5541
ADDRESS ' DfEH yse ONLY
4700 Ramona Blvd.
CITYISTATI:JZIP coumv COUNlYCODE
Monterey Park, CA 91754 Los Angeles County.
NO. OF EMPLOYEES/MEMBERS (If MOWn) DATE MOST RJ:CENT OR CONTINUJNO DJSORIMIAATCON RESPONDENT CObE
TOOK PLACE (month, Oay, and year)
THE PARTICULARS ARE:"'
On 'Ongoing I \Y8S - · fifed _ denied en~it _ denied family ormedbl leave
_ laldoff _ denledpromollon _ denled~leave
_ demoted _ denied ltansfer _ demcdequalPll)
_ harassed _ denied accommodation _ den!ed right to wear pants
_ ge~lo characterfatlC$ lesting _ impeanlsslble non-Jot,.ndaled Inquiry _ cktnied pregmncy accommodation
_ 'focced to quit i olher(specify) ..,.re=t_a...._fiat=ed-=--=a--::gir,;::;:;a.... st________
in....,•

by--------------------------------------
Name or Pinon Job Trite' (supmvlsor/n,wgertpersonneJ ditector/etc.)

bJ',cause of my: - sex ....K_ naliamd olfginlmslry _ physlcal dfsatxlfty _ cancer _ (Oirdo cine) fl&lg;
_age _ marftal status _ mental dlaabiZJl1 _. oeneuc c:hatlCtsrfsUc prolming; participating fn

_rel,gicn _ se1cuaJ orfen1ation lnvesllgation (AStala!Jon for)

_ othet(Specity) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
_ race/color _ association

the reason given by

'Name of Person enf Job T111o

Was because of Jwas sybje~ed to several Incidents of ret511iation becau$e of myfreguent complaints
[please state about racism in the Department
what you believe ~
to be reason(s)]
a
I 'Wish to pwsue DIis 'matter In c:curt. I heceby request that lhe Opp;rrfmenl ot Fair Employment and Housing provide rfghMo-sue notice. I understand that If I ~ a Eoderal notk.e of
0

ifsht-CC•sue. amust vlsll 1118 U.S. Eqvas Empk>ymtftt Oppo,1uitily CclM!Jssfon (EEOC) to file a comp&arn, wfthl1130 dl,Ja orrucelptof lheDFEH "Notice c1 case aosln.•« WIWn 300
.
days Cf~ alleg~scriminatc,y act. \lrtlfchever (S e.ufier.
.
r1:ave not been CCM!!dld Into rna:klno Vtls requost. nor do r matco ll baaod on tw of refclla11on If I do not Clo so. t undctrs1and It Is the Departmenl or Fa!r Em~tand Houstng's
pollcyto not poc:.eu_orreopena'cocnp1arnto0cc Vte ccmpfafnt has been ctosedoit lh9b11lsol'Complamanl EledeG eouitActloo.·

J declare uncferpe1!31tYofpeljuryunder\he laws of the Stale of Cdbnlo 1hatflle foregofng

ems belef. and as ~ those matters Ibel!eYe 11 Co 1>e we.
ii ltUe end;JZ?/2cocreclof
my cw.n kn iJ;C" BUers s\Dted ep,nylnfonna11on

oafed Octo~r 11. 2005 o,g,,,OC--......._--~-·_ _ _ _ _ _ _ __

.., COMPLAINANTS SIGNA11JRE

Long Beach, CA . ~le_xa~~Villan1:1ava,:••"• . ,.

At
aty QC
i \ ~-- . .•. ,-
LJ
DATEFILEO: 10/ti /0)
DFJ:H-300-al (01103) STATE OF CAUFORNV\
DEPAl\lMEHTOF FAIR EMPI.OYMENT AHD HOUSING LS-DFEtCt
,.

CM-010
ATTOR,fEY OR PARTY wn t(OUT ATIORHEY ,mn,.. s FORCOURTUSeONLY
Anarea L. CooK
ANDREA COOK & ASSOCIATES
401 E. Ocean Blvd., Sfe 200
Long B&ach, CA 90802
, 11:LEPH0NUO , (5a2).951-9135 FAXHO: f'aX: (562) 951-91
mOR FOR H°am~ • ti
Ale nd o Viii eva
SUPERIOR COURT OF ~1fPIU1Jlh5(0.JlNTY OF•
smee1 ~REss 1111 N. 11111 ~treet
MAILIHC:NmRESS:
e11YAN021Pcobe Los Angeles, GA 90012
sRANcH NAME. Centrar .
CASE NAME~ Villanueva v. ~so. et al.
•CIVIL CASE COVER SHEET Complox Case..Deslgnation CAJEN~BER 8 C3 42 4 16
[i] Unlimited D U~lted D counter D Jolnder
t';.~':~d ~e':.~~~~ is Filed with first appeara,nce by defendant ~ JUDGE
exceeds 25 000 S2S00o or fess Cal, Rules of Court, rule 1811) DEPT"

1. Check one box below for the case type that best describes this case:
Auto Tort
D Auto (22)
D Uninsured m,otorist (46)
Olfler PI/PDIWD (Personal lnjurylProperty
Damage/WroQgfuJ Deaeh) Tort
D Asbestos (04)
D Producl liability <24>
.Contract Provlsronally Complex Civil Litigation
D Breach of cobtractlwarranty (06) (cal. Rules of Court. rules 1B0D-1812)
D Collections (09) D Antitrust/Trade regulatlon (03)
D
D
Insurance coverage (18)
~·
•o Consrrr.rctlon defect (10)
Other contract (3,, D Mass toft (40) •
Real Property D Securities litigation (28)
D Emtnent domain/Inverse
4

0 EnvironmentalfroxJc tort (30)

D Medfcal matpracUce (45) condemnation (14) D ln;u,ance c:O'Jersge claims arising from the
D Other PIIPDIWD (23> D Wrongful eviction (33) above rrsted provisfonalJy complex case
types (41)
Non-PJIPD/WD (Other) Tort D Olher real property C26)
D Business 1orVunfalr business ~ractlce (07) Enforcement of Judgment
[jJ Civil rights (08) Unlawful Detainer D Enforcement of Judgmenl (20)
D Deremation (13) D Commercial (31) Mlscellaneous CMI Complalnt
0Fraud(1B)
D ·Resltfenlial (32) 0 RIC0(27)
D Intellectual property (19) 0orugs(38)
D Other complaint (not spac/flfKI above) (42>
D Professlonal neglfllence
·q,
(25) Judlclal Review
DAssat f _.~ ure '~os) Miscellaneous Civil Petition
D Other non.PI/PDJWO lort (35) 011 1
D PetlUon re: a.rtdtraffon award (11 ).
"'
D Parlnership and corporate governance (21)
Emp1oyment
D Wrongful termination (36) D Writ of mandate (02) D Other petiUon (not specif,ed abOve) (43)

D Other emptoymenl (15) D OlheJ Judicial review (39)

2. This case D is 00 is not complex under rule 1800ofthe Ce&fom1a Rules of Court. If case iscornprex, mark the factors
requiring «m:eptional judicial manag~ment:
a. D t:arge number or separately representect parties d. D Large number of witnesses
b. D ExtenJlve motion pra9iice raising difficult er novel e. D
Coordination with related actions pending in one er more courts
issues that will be time:,consuming to resolve in other counties, states or countries, or in a federal court
c. D. Substantial at11ount of documentary evidence f. D Substantfal post-Judgment Judfcial supervision
3. Type of remedies sought (check all that apply):
a. [ j ] monetary b. 00 nonmonetary: declaratory or lnjuffctlve retlef c. OD punitive
4. Numbfir of causes of action (specify):
5. Thi& case O fs ·oo Is not a class actloq suit.
qate: Noyember 2, 2005
Andrea L. cook ►
NO"FICE
• •Plalnllff must file thls cover sheet with the flrst paper flied Ip the adfon or proceeding (except sm\111 claims eases or cases filed
under'the Probate, Family. or Welfare and Institutions Codef. (Cal. Rules of Court. rule 201.8.) Failure to file may result in
sandions. '
• File this cover ,1.teel in addlti9~ \9, !'Ry, ~er she.et required b~..•~1 court rule. ,,, "'" ,, , '" , . '" 1 ,., 1 1,~ 1 1
• Jf this case is complex under rule 1800 et seq. of the CalifomJa Rules of Court. yob must serve a copy of ~,s~~/er's'h~et on alt
olher parties to Uie action or proceedfng.
• Unless this Is a com lex case this cover sneet shall be used for statrs I I u s onl . P• t o12•

~••Ptt,~\~ORI GINAL
~~ICc,u,do(CMitcr· CASE COVER SHEET
S<h~
~... StatldaldsOfMie~~~f19
 •
" .

&«)RTllJU[ Cl.5Ef4'JMBER
Villanueva v. LASD, et a~. B.C3424 J
CIVIL PASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION
CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTROUSE LOCATION
This form Is required pursuar,t to LASC Local Rule.2.0 in all n11w civil case fillngs in the l;os Angeles Superior CQurt
Item J. Check the types 9f hearing and fill in the.estimated Jength of ~earing expected for this case:
JURY TRIAL? 14 YES CLASS ACTION? Oves LIMITED CASE? Oves TIME ESTIMAT~o FOR TR1AL-2!._OHoURsiiAoAvs.
Item If. Select the correct district "nd courthouse locatlon (4 steps - If you checked ·Limited Case''. skip to Item m. Pg 4):
Step 1: Mer first completing the Civil Case Cover Sheet Form, fend the main civil case cover sheet heading for your case fn
the left margin below. and. to.the right in Column~. the CKril Case Cover Sheet case type you select~.
Step 2: Check 2M Superior Court type of action in Column B .be!ow which best describes the nature of this case.
Step 3: In Column C, clrcte the reason for the court rocation choice that applies to the type of action you have checked.
For any ,s>ecer.itron to the court'location, see Los Angeles Superidr Court Local Rule 2.0.
Appll(?able Reasons for Choosing Courthouse Location (see Column C below)
1...Class Acllons must be riled In the County Courthouse. Central Oislrfel, • '6, Location of Pl'ODetlY or penminenUy garaged vehlde.
2 May be filed fn Central (Other county. or no Bodfly lnJwylPropcrty Qamaue). 7. Location wtiefo petlffoner resides.
• 3 location where cause of actfon arose. 8, LocaUon v.t\=re d'efendanl/tesDOfldent functJons W1\0Uy.
4. Location where bod!!)' injury, death or damage occurred. 9. Loc:ation one or more of fhe ~rtics reside.
5. Location where performance requfted or defendant resides. 10. Location of bot Commissioner omce.
Step 4 : Fill in the information
. reauested on t>aae 4 in Item Ill: complete Item IV Sian th e declarat,on.
A B C
ClvH Casa Covor Sheet 'JpaofACCJon •Appllcable Reasons -
~
category No. (C.hock only ono) see Step 3 Above
~
..
0
::I
<C
Atllo(22) Q A7100 MolorVehtela • Pcrsona1 lnfury/Property OamageMtrongful Death

□ A7◄ 10 Per1'on~I ~urylProperty OamageJ\Jvrcngful Death - UnlnsuIed M'otorisl

1•• 2.. 4.

Unlnsured MolOtist (46) 1 .• 2.• ◄

~

0 A6070 Asbestos Prcpe,1y Damage 2

Asbestos (04)
0 A7221 Asbestos - Per&onat rnjurylWrongful Dea!Jl 2.

Product Liability (24)

. Q A7260 PrOduct Liablbly (not asbestos or l~t/envlfonmental) 1.. 2.,3.. 4.,8.
-
Medical Matpractfce (45) Q A7210 Medical Malpradice • Physfeians & SUrgeons 1•• 2•• 4.
Q A7240 Other Professfanal Health Care Malpractice 1., 2 .• 4
.

ODler 0 A7~0 Premises UabDJty (e.g .• slip and fall) 1.. 2•• 4.
Personal lnJu,y
Property Damage
Q A7230 lntentrcnaJ BOdDy lnjwy/Ptoperty OarnageNVror(gM Death (o.g..
1., 2., 4.
as~uft, vandaBsm. etc.)
Wrongful ~ath 1.,2., 3.
(23J . 0 A7270 Intentional tnffletion of Emotional Distress
1., 2.,4.
Q A7220 Olher Penon~ Injury/Property Damage1Wrongfu1 Oealh

~uslness Tor1 (07)

. a A6029 Other COmmerclallBuslness Tort (not fraud/breach of contract)
.
1.,2.,3.
•.
eMr Rights <os>
l;a,A600!i ClvD RJghtisJDlsctfmlnatfon 1., 2•• 3.

~famatlon (13)
.. •'
Q A6010 Defamation (slanderlllbe0 ..
.
1 •• 2 •• 3. .
: • Fraud (16)
□ A6013 Fraud (llO con~taet) 1.• 2.. 3,
.
ln1ellectuaJ Property (19)
Gl A6Q16 JoteDectual PropertY., 2•• 3.
. ..

CIV 109 03:()4

LASC Approved
CIVIL CASE COVER,SHEET'ADDENDUM
AND STATEMENT OF LOCATION oRI GI N~t LASC, ru1,2.o
1 of 4
 e
S1IO'lTTITlE
Vl l l ~nuev~ v . LA~O. e t al .

A 8 C
Civil Caso Covor App licablo Roasons
Type of Action
Shoot Catogory No.
(Ch oc k on ly one) -Soo Slop 3 Abovo

Professlonnl I.] A6017 Legal MalpraClice I .2.3

Neghqenr.E'
(25>
0 A6050 Other Professional Malpractice (not medical or legal) 1. 2 .. 3.

01her (35) 0 A6025 O ther Non-Personal lnj\Jry/Pcopcrty Damage IOfl 2 ,3

... Wrongful Tenmnallon

C
C,
(36) ..J A6037 Wtonglul TermrnaUon I. 2, J .
E
>-
0 Other Employment
0.. (1!i) . 0 A6024 other Emp!uyrnent C o rnpla nl Case I .?. 3
ifi 0 A6 109 Labo, Comm1ssroner Appeal& 10.

Breach o f Conliaci/
Warranty
0 AS004 Ocead1 of RentaVLeasc Contract (not Unlawful Oe!alne1 or wrongful evidt0n) i 2,5

i05) 0 A6008 Con!rec\Mfilrr anty Breach -Seller Pl;11n1i'I (no fraud/n~9 ,gence) I 2 5.
1not lr1~1,1r.incc) 0 1\6019 N egligent Breach of Contracl/Warranly (no fra ud) 1., 2., 5.

u 0 A6028 0 111e< Breach of CMlraclM'arran1y (not fraud or negl:gence) 1.. 2 . 5

l:!
C:
0 0 A6002 Colie ct,on~ Case-SeUer Pla,nttrt 2 . 5. 6.
Colleetions
(J
(09) :J A6017 Other Promissory NoteiCo l1ec11ons Case 7 .5

-
Insur a11ee Coverage
(1 8)
0 A6015 Insurance Cover90e (no1 r.omplexJ 1 , 2. 5. 8

0 1he: Conlract LJ A6009 Contractual Fraud 1 , ;>, 3. 5

(37)
0 A603 1 Ton ious Interference 1, 2, 3.. 5
1., 2. J., 8
0 A6027 Other Conlracl Olspul e(nol bleach/insuranee/lreud/neglrgence)

Eminen1
DomDinllnvcrse 0 A7300 E m,nene Oorna,n/Condemn ahon Number of pare.els _ _ 2.
>- Conclemnat,on 114)
.,
t::
C. W rongful Evic1ion
0
(33) 0 A602 3 Wrongful Eviction Cose 2 .. 6
ct
iii
~
ex: 01hor Re a! Propot1y 0 A6018 Mongage Foreclosure 2., 6
(?8)
0 A60J2 Q uiet TIiie 2 .. 6
0 A6060 01hcr Reel Property(nOI eminent d omilln. landlord/\cnant foreclosure)
2 ' ,;

Ulllawful Oeloinor-
~ornmc rc,al \31J 0 A602 1 Ur.lawful Delainer-Commerc,al (not drug, or wiongl ul ev1ct1on) 2.. 6

~nlawful Oet~lncr•
Residential (32\ 0 A6020 Urolawful Oetalner-Re~idenlial (not drugs or wrongful ell\ci,on) 2 .6

Unlawlul Detainer
· Druga (38) 0 A6022 UnJay..ful Oelainer-Drvgs 2,6

A sset Fotfeduae (05; 0 A6 10 8 .A$se1 Forlel1ure Case 2.6

Pelibon re Albitral•on
( 11) 0 A6 115 Petition lo Compel/Conflrll1/Vacate Arb~ral lon
... . ,,.. 2., 5
""'"" • • I • •••

CIV 109 03 04 CIVIL CASE COVER SHEET ADDENDUM LASC. rulo 2.0
LASC Approved AND STATEMENT OF LOCATION Page 2 ol 4
I
SHORr TIRE'
V~llanueva v. LASQ. et al~
• ••
1.,...,......
.. -

A· B C
Clvll Cesa Cover Sheet \,,, Type of Adlon AppUctble Reasons -
catogo,y No. . (Check only ont) See S~p 3 Above
. .
0 :A8151 Writ • Admlnls1rB1JVe Mandamus 2.. 8.
Writ of Mandel~ 0 A6152 Writ• Mandamus on Umlted Court Case Maller- 2.
(02) .. 0 A6153 Wdl • qther Llrnlted Court Case Re,,tew z.
Other Judidaf Review
(39) 0 A,6160 Olher l/lhil /Judlelal Review 2..8.

Anlllrust/Trackt"
..
Regutatlon (03)- Q A6003 Anlitrust!Trade Reg~latlon t .• 2 .• 8.
.
Construdfon Defect (1 OJ
.
0AS007 Construction defect . 1.. 2.• 3.
'
Clalms lnvoMng Mass
Toit(40) Q AS008 Clafms fnvolvfn9 Mass Tort 1.,2..a.

Securllles UUgaUon (28)

0 • Seeti\itles Utlgalion Case 1_2.• a.
.A6005
.
TOXic Tort
EnvironmenlaJ f3m ·□ A6036 Toxfq TortlEnvinxtptenlaJ 1.. 2., 3.. 8.

Insurance Coverage
□ A6014, Insurance CoveragelSUbr~eU6n (complex case only) 1.. 2.,5.. 8.
Claims from Comprex
Case (41)
- .
0 A6141 Sister Stam Judgment 2.,9.
,. Cl A6160 AbStract of JUdgment 2•• 6.
Enforcement
ofJudgmenl 0 A6107 Confessfon or Judgment (~on-domesUo relations) ,2.. 9.
[20) Q A6140 Admfnlstratlvo Agonr:jAward (not unpaid taxes) 2., 8.
□ A8t 14 PeUtfon/Certilicalo for Entry of Judgment on Unpaid Tax 2.,8.
0 A6112 Other Enfon:ement of Judgment Case 2..~•• 9.

RIC0(27) □ A8033' RackeCeering (RICO) c~ 1~2.• 8.

.
0 A6030 Declarator, Reltef Olly 1.. 2.. 8.
OU\el' Complaints
(Not Spedfied Abo"')
0 AB040 Jn)unctlve ReUef only,(not doinesllclharassment) 2..8.
0 A8011 other Cornmerclal Corns,lelnt case (non-tol1/noft-complex) 1.,2 .. 8.
(42)
a A6000 Other Civll Complaint (non-tort1non•complex) 1.,2.. 8.•
.
Par1nershlp Corporation 0 A6113 Partnership and Corporate Govemanpe case 2.,8.
Governance(21) • ..
: Q,AS121 Clvll Harassment 2 .• 3 .. 9.
..
-:♦
0 A8123 Workplace Harassment"' 2 .• 3 .. 9 .

•·baiter PetiUons
0 A0124 Elder/Dependent Adult.Ab~ Case 2.,3.. 8.
(N.ot Spedlted Above) 0 A6190 ElecUon Contes(
...
~
(43)
. 0 A8110 Petition for Change or Name
2.
2.• 7•
Q A6170 Petition for ReUef from Late Clam Law 2.,3.. 4.,8.
Q A8100 Other CMI PeUUon 2., 9.
:
,;.,.- ~t ••I ,! ! ~I
·1r"1 ,ll"l'l,,,,1 1
1, I ~ ,~, "', r l'"'.lr11• '1 '' 1:1 ,.

CJV 109 03-04 CIVIL PASE COVER SHEET ADDENDUM LASC, rute 2.0
LASC App,ovec1 AND STATEMENT OF LOCATION Page3of4
I .

f Sllcm TIRE'
~illanuev~ v. LASO, et al.
• •
1-·-..
Item Ill, Statement of Location: Enter the address of the accident, party's residence or place of business, performance: or
other clrcumstan~ Indicated in Item II., Step 3 on Page 1, as the proper reason for filing In the court rocation you selected.

REASON· CHECI< THE NUMBER UNDEij COLUMN C ADDRESS.

WHICH APPLIES IN THIS CASE ·tc,s Angelos· C4'unty Sheriff's Depe1:tment.
•4?00 ~amona Blvd,
□1.□2.J;a3.Q4.Qs.Oe.01.8a.09.010.
I
CITY: sr-,re: ZIPCODE:
Monterey'Park CA
. 917S4
w
,

• Item IV. D!claration•o, Assignment I declare under penalty of petjury under the laws 6f the State of canfomla that lhe foregoing is
true ana correct and that the above-enUtred matter is properly filed for assignment to the
cent.1:a1
.Stanley MOsk oourthouse in UIO
"
District oflhe Los Angeles Superior Court (Code Civ. Proc.,§ 392 et seq., and LASC Local Rule 2.0.
subds. (b), (c) and (d)).

Dated: November 2, 2005

PLGASE ljAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO
PROPERLY COMMENCE YO\JR NEW COURT CASE:

1. Orig!nal Complaint or Petition.

2. If filing a Complaint. a completed Summons form for issuance by the Clerk.
3. Civil Case Cover Sheet form JC·j382.2(b)(1 ).
4. Complete Addendum to Civil Case Cover Sheet form CIV 109 _ ___..._ (eff. Date).
5. Payment in full of the filing fee. unless.. fees have been waived.
6. Signed order appofnHng the Guardian ad utem. JC fonn 982(a)(27), If the plaintiff or petitioner is a mrnor
un~er 18 years of ag~, or If required by Court.
7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum
must.beperved along with the summons and complaint. or other inltfating pleading fn the case.
..
.. •,

.....
I

crv 109 03-04 CIVIL CASE COVER•SHEET ADDENDUM LASC, rule 2.0
LASC Approved AND STATEMEN:r OF LOCATION Pag&4 of4