Scott Taylor v City of Camarillo Lawsuit
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Transcript of Scott Taylor v City of Camarillo Lawsuit
7/23/2019 Scott Taylor v City of Camarillo Lawsuit
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146
At all times mentioned in this complaint, Defendants were subject to the
provisions of California Labor Code section 1102.5.
147
At all times mentioned in this complaint, Plaintiff was employed by the
Defendants as an employee and thus was protected by the provisions of section 1102.5 of the
California Labor Code.
148
Plaintiff TAYLOR disclosed information that he had reasonable cause to believe
were violations of state or federal statute, or violations of or noncompliance with a local, state, or
federal rule or regulation, including but not limited to: (a) disclosures of information to the
California Department of Fair Employment and Housing regarding defendants' retaliation and
discrimination in violation of FEHA; (b) disclosures of information to the Federal Emergency
Management Authority (FEMA), a federal government agency, regarding the defendants
violations of federal statutes or regulations as to their orders that Plaintiff and other CITY
employees falsify time records in order to obtain reimbursements from FEMA for the Camarillo
Springs Fire; and (c) disclosures of information regarding defendants' noncompliance with local
rules or regulations as to retaliation and harassment of Plaintiff as well as the creation of a
hostile working environment for Plaintiff.
149 As a result of Plaintiff TAYLOR having made the above-referenced disclosures,
he suffered acts of reprisal, retaliation, and termination.
150
In subjecting Plaintiff TAYLOR to the acts of reprisal, retaliation, termination or
similar acts, Defendants violated California Labor Code section 1102.5.
151
As a direct and proximate result of the Defendants' unlawful conduct as alleged
in the complaint, Plaintiff TAYLOR has suffered and continues to suffer substantial losses in
employment benefits with defendant employer, including loss of reputation, lost wages, bonuses,
incentives, and job benefits, and expenses incurred in the search for comparable employment in
an amount not less than the jurisdictional minimum of this court. The precise amount of the
damages is presently unknown and will be proven at trial.
152
As a further direct and proximate result of the Defendants' unlawful conduct,
Plaintiff TAYLOR has suffered and continues to suffer extreme and severe anguish, humiliation,
34
COMPLAINT
TRON TRON
5010 STE. 210
805) 388-1241
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emotional distress, nervousness, tension, anxiety, and depression, the extent of which is not fully
known at this time, and the amount of damages caused by defendants' conduct is not yet fully
ascertained but in an amount in an amount not less than the jurisdictional minimum of this court.
The precise amount of the damages is presently unknown and will be proven at trial.
153
Plaintiff TAYLOR also claims all amounts thereunder together with prejudgment
interest pursuant to California vil ode §
3287 and pursuant to any other provision of law
providing for prejudgment interest.
154
Plaintiff TAYLOR pursuant to California
Labor ode section 1102.5(f) seeks
civil penalties against defendant CITY in the amount of $10,000 per violation of California
Labor ode
section 1102.5.
EIGHTH C USE OF CTION BY PL INTIFF T YLOR
AGAINST DEFEND ANTS CITY and DOES 1-20 inclusive
FOR BRE CH OF CONTR CT
155
Plaintiff TAYLOR realleges and incorporates herein by reference all other
paragraphs of this complaint, as though fully set forth in this Cause of Action.
156
On or about March 26, 2014, defendant CITY and Plaintiff TAYLOR and other
employees in the competitive service entered into an agreement which defined the obligations,
rights, privileges, and benefits of the parties. This agreement is hereinafter referred to as the
Personnel Rules. A true and correct copy of the relevant portions of the Personnel Rules is
attached hereto as Exhibit 1 and made a part hereof by this reference.
157
Chapter 14 of the Personnel Rules established the procedure for disciplinary
action against an effected employee. Section 14.5 of the Personnel Rules provided that the
employee was permitted to respond, either verbally or in writing, to a notice of intent to
discipline in a pre-disciplinary hearing. Thereafter, defendant CITY was obligated, pursuant to
Section 14.5.3 of the Personnel Rules, to within five working days after the later of the
employee's verbal or written response, the date of the pre-disciplinary meeting, or the expiration
of the employee's time to respond to the Notice of Intent, the Department Head will take one of
the following actions: (1) dismiss the Notice of Intent and take no disciplinary action against the
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COMPLAINT
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809) 388-1241
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