Complaint Template.DOC (COMPLA~1.DOC;1)

12345678910111213141516171819202122232425262728

12345678910111213141516171819202122232425262728

SECOND AMMENDED COMPLAINT Page __ of __

MICHAEL MOORE15811 Raymond Ave.Gardena, Ca. 90247Telephone: (562) 448-8698Email: mrmdmoore@ymail.com

MICHAEL MOORE, IN PRO PER

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES

MICHAEL MOORE, an Individual,

Plaintiff,vs.SONY PICTURES ENTERTAINMENT INC., a Delaware Corporation, SONY CORPORATION OF AMERICA, a New York Corporation, TOKIO MARINE AMERICA INSURANCE COMPANY, a New York Corporation, AMY PASCAL, an Individual, MICHAEL LYNTON, an Individual, LEAH WEIL, an Individual, JEFF GROVER, an Individual, TOM ROTHMAN, an Individual, CYNTHIA HUBBARD, an Individual, MICHAEL GROE, an Individual, Dr. MICHAEL ZONA, an Individual, LEONARD VENGER, an Individual, DANIEL FISCHER, an Individual, DAVID HANDLER, an Individual, DOUG BELGRAD, an Individual, DWIGHT CAINES, an Individual, FERDINAND FATTORINI, an Individual, JUNE ROSALES, an Individual, GAUDENICO ROBLEDO, an Individual, MIKE ORNEOLAS, an Individual, MARK PACHECO, an Individual, RUTH OLLIE-WRIGHT, an Individual, CAROLYN HARDIMAN, an Individual, PAULA ASKANSAS, an Individual, PETER JORDAN, an Individual, STEVEN MOSKO, an Individual, STUART ZIMMERMAN, an Individual, THERESA SAPORITO, an Individual, MARY BURKE, an Individual, GEORGE ROSE, an Individual, GASTON BITAR, an Individual, MARCELO RODRIGUEZ, an Individual, DONNIE HARRIS, an Individual, ESIS INC., a Pennsylvania Corporation, DOES Defendants1 through 1,000,000

)))))))))))))))))))))) ) ))))))))

Case No.: BC582200Honorable Lisa Hart ColeDept. O

SECOND AMENDED COMPLAINT

1. HARASSMENT2. FRAUD 3. BREACH OF CONTRACT4. ABUSE OF THE PROCESS5. CONSPIRACY6. LIBAL OR FALSE STATEMENTS7. EMPLOYER NEGLIGENCE8. MENTAL ANGUISH9. HOSTILE WORK ENVIRONMENT10. CONSTRUCTIVE DISCHARGE11. INTENTIONAL INFLICTION OF EMONITIONAL DISTRESS12. FIDUCARY DUTY FAILURES13. UNJUST ENRICHMENT

Complaint Filed: May 19, 2015 Trial Pending

JURISDICTION AND VENUE

1. Plaintiff, Michael Moore, (hereinafter Plaintiff) is a Resident of Los Angeles County, and

Herein does make the following allegations against all Herein Named Defendants and Defendant

named as DOES 1 through 1,000,000.

2. This Court has Jurisdiction over all Causes of Action asserted herein pursuant to the

California Constitution, Article VI, Section 10, because this case is a cause not given by Statute to

any other Trial Courts.

3. This Court has Jurisdiction over all herein named Defendants because all are and/or were

Residents of Los Angeles County, and are and/or were living in California at all times relevant.

4. Venue is Proper because the Causes of Action herein stated arose in this Judicial District.

P A R T I E S

5. Michael Moore, an Individual (hereinafter plaintiff) is a resident of Los Angeles County,

was a union member IBEW Local 40, and was a sub-contracted Employee of Sony Pictures

Entertainment Inc.

6. Based upon information and belief Defendant, Sony Pictures Entertainment, Inc.,

(hereinafter SPE) is a Delaware corporation with its primary place of business in Culver

City, California, and DOES 1 through 1,000,000 are collectedly referred to herein as SPE. 7. Based on information and belief Defendant, SONY CORPORATION OF AMERICA, (hereinafter SCOA), is a New York corporation and does business in California, and DOES 1 through 1,000,000 are collectedly referred to herein as SCOA. 8. Based on information and belief Defendant, TOKIO MARINE AMERICA INSURANCE COMPANY (hereinafter TOKIO) is a corporation formed under the laws of New York, and does business in California, and DOES 1 through 10,000 are collectedly referred to herein as TOKIO. 9. Based on information and belief Defendant, Michael Lynton, (hereinafter Lynton) is of Los Angeles County, at all times relevant Chairman & CEO, of Defendants SPOA and SPE, and DOES 1 through 10,000 are collectedly referred to herein as Lynton. 10. Based on information and belief Defendant, Amy Pascal, (hereinafter Pascal) at all times relevant was Co-Chairman of SPE, Chairman of the Motion Pictures Group of Sony Pictures Entertainment and Co including Sony Pictures Television, and DOES 1 through 10,000 are collectedly referred to herein as Pascal. 11. Based on information and belief Defendant, Leah Weil, ESQ., (hereinafter Weil) at all times relevant is Senior Executive Vice President and General Counsel of Sony Pictures Entertainment (SPE). Weil is the Company's most senior legal adviser and the head of its law department, and DOES 1 through 1,000,000 are collectedly referred to herein as Weil. 12. Based on information and belief Defendant, Jeff Grover, (hereinafter Grover) was the Executive Director of the SPE Telecommunications Department. Grover on or about July 2014 was reinstated as a member of IBEW LOCAL 40 and employed as a SPE Telecommunications technician, and DOES 1 through 1,000,000 are collectedly referred to herein as Grover. 13. Based on information and belief Defendant, Tom Rothman, (hereinafter Rothman) is Chairman of Sony Picture Entertainments Motion Pictures Group, and DOES 1 through 1,000,000 are collectedly referred to herein as Rothman. 14. Based on information and belief Defendant, Cynthia Hubbard, (hereinafter Hubbard) is a former employee of the SPE Human Resources Department, and DOES 1 through 10,000 are collectedly referred to herein as Hubbard. 15. Based on information and belief Defendant, Michael Groe, (hereinafter Groe) is a Union Member of IBEW LOCAL 40 and Shop Foreman of the Defendant SPE Telecommunications Department, and DOES 1 through 1,000,000 are herein collectedly referred to here in as Groe. 16. Based on information and belief Defendant, Dr. Michael Zona, (hereinafter Zona) is a

DOCTOR of Psychiatric Medicine and was an Independent Consultant for Human Resources. and

DOES 1 through 10,000 are collectedly referred to herein as Zona.

17. Based on information and belief Defendant, Leonard Venger, ESQ., (hereinafter Venger)

an Attorney employee of Defendant SPE, and DOES 1 through 1,000,000 are collectedly referred to

herein as Venger. 18. Based on information and belief Defendant, Carolyn Hardiman, (hereinafter Hardiman) is a SPE Telecommunications Department Employee. and DOES 1 through 1,000,000 are collectedly referred to herein as Hardiman. 19. Based on information and belief Defendant, Daniel Fischer, (hereinafter Fischer) is a Union Member of IBEW LOCAL 40 and a Sub-Contractor Employee of Defendant SPE. and DOES 1 through 1,000,000 are collectedly referred to herein as Fischer. 20. Based on information and belief Defendant, David Handler, (hereinafter Handler) is the Chief Financial Officer and a Senior Executive Vice President of Defendant SPE. and DOES 1 through 1,000,000 are collectedly referred to herein as Handler. 21. Based on information and belief Defendant, Doug Belgrad, (hereinafter Belgrad) is the President of Sony Pictures Motion Picture Group and DOES 1 through 1,000,000 are collectedly referred to herein as Belgrad.. 22. Based on information and belief Defendant, Dwight Caines, (hereinafter Caines) is the President of Theatrical Marketing for the Columbia TriStar Motion Picture Group and DOES 1 through 1,000,000 are herein collectedly referred to herein as Caines. 23. Based on information and belief Defendant, Ferdinand Fattorini, (hereinafter Fattorini) is Senior Vice-President of Enterprise Infrastructure Services, Sony Pictures Entertainment Inc., and DOES 1 through 1,000,000 are collectedly referred to herein as Fattorini. 24. Based on information and belief Defendant, Gaudenico Robledo, (hereinafter Gaudenico) is a Union Member of IBEW LOCAL 40 and a Sub-contractor Employee of Defendant SPE and DOES 1 through 1,000,000 are collectedly referred to herein as Robledo. 25. Based on information and belief Defendant, June Rosales, (hereinafter Rosales) is a Telecommunications Department Employee of Defendant SPE and DOES 1 through 1,000,000 collectedly referred to herein as Rosales. 26. Based on information and belief Defendant, Mike Ornelas, (hereinafter Ornelas) is a Vice-President in the SPE Security Department and DOES 1 through 1,000,000 are collectedly referred to herein as Ornelas 27. Based on information and belief Defendant, Marcelo Rodriguez, (hereinafter Rodriguez) is a Vice-President in the SPE Security Department and DOES 1 through 1,000,000 are collectedly referred to herein as Rodriguez. 28. Based on information and belief Defendant, Mark Pacheco, (hereinafter Pacheco) is a Union Member of IBEW LOCAL 40, a Sub-contractor Employee in the SPE Telecommunications Department and DOES 1 through 100,000 are collectedly referred to herein as Pacheco. 29. Based on information and belief Defendant, Paula Askansas (hereinafter Askansas) is a SPE Vice-President and DOES 1 through 1,000,000 are collectedly referred to herein as Askansa. 30. Based on information and belief Defendant, Peter Jordan (hereinafter Jordan) is a SPE Telecommunications Department Employee and DOES 1 through 1,000,000 are collectedly referred to herein as Jordan. 31. Based on information and belief Defendant, Ruth Ollie-Wright (hereinafter Ollie-Wright) is the Manager of the SPE Telecommunications Department and DOES 1 through 1,000,000 are collectedly referred to herein as Ollie-Wright 32. Based on information and belief Defendant, Steven Mosko, (hereinafter Mosko) is the Chairman of the SPE Television Department and DOES 1 through 1,000,000 are collectedly referred to herein as Mosko. 33. Based on information and belief Defendant, Stuart Zimmerman, (hereinafter Zimmerman) is a SPE Executive Vice-President and DOES 1 through 1,000,000 are collectedly referred to herein as Zimmerman. 34. Based on information and belief Defendant, Theresa Saporito, (hereinafter Saporito') is a SPE Executive Director Nurse of the Medical Department, and DOES 1 through 1,000,000 are collectedly referred to herein as Saporito. 35. Based on information and belief Defendant, Mary Burke, ESQ. is a SPE Legal Department Vice-President and DOES 1 through 1,000,000 are collectedly referred to herein as Burke.36. Based on information and belief Defendant, Donny Harris, (hereinafter Harris) is a Union Member of IBEW LOCAL 40 and a Sub-contractor Employee in the SPE Telecommunications Department and DOES 1 through 1,000,000 are collectedly referred to herein as Harris. 37. Based on information and belief Defendant, Gaston Bitar, (hereinafter Bitar) was a SVP in the Human Resources Department and DOES 1 through 1,000,000 are collectedly referred to herein as Bitar 38. Based on information and belief Defendant, ESIS Inc. (hereinafter ESIS) was the SPE Third Party Workers Compensation Administrator and DOES 1 through 1,000,000 are collectedly referred to herein as ESIS. 39. Based on information and belief Defendant George Rose, (hereinafter Rose) is a SPE Senior Executive Vice-President and the Department Head of the SPE Human Resources Department and DOES 1 through 1,000,000 are collectedly referred to herein as Rose. 40. Plaintiff is ignorant of the true names and capacities of the Defendants sued herein

as DOES 1 through 1,000,000 and, therefore, sues these Defendants by such fictitious names.

Plaintiff will amend this complaint to allege their true names and capacities when ascertained. 41. Defendants sued herein as DOES 1 through 1,000,000 are contractually, strictly,

negligently, intentionally, vicariously liable and or otherwise legally responsible in some manner

for each and every act, omission, obligation, event or happening set forth in this Complaint, and

that each of said fictitiously named Defendants is indebted to Plaintiff as hereinafter alleged. 42. The use of the term Defendants in any of the allegations in this Complaint, unless specifically otherwise set forth, is intended to include and charge both jointly and severely, not only named Defendants, but all Defendants Does 1 through 1,000,000 designated as as well. 43. Plaintiff is informed and believe and thereon alleges that, at all times mentioned

herein, Defendants were agents, servants, employees, alter egos, superiors, successors in interest,

joint ventures and/ or co-conspirators of each of their co-defendants and in doing the things

herein after mentioned, or acting within the course and scope of their authority of such agents,

servants, employees, alter egos, superiors, successors in interest, joint ventures and/ or

co conspirators with the permission and consent of their co-defendants and, consequently, each

Defendant named herein, and those Defendants named herein as DOES 1 through 1,000,000

inclusive, are jointly and severely liable to Plaintiff for the damages and harm sustained as a result

of their wrongful conduct. 44. Defendants, and each of them, aided and abetted, encouraged, and rendered

substantial assistance to the other Defendants in breaching their obligations to Plaintiff, as

alleged herein. In taking action, as alleged herein, to aid and abet and substantially assist the

commissions of these wrongful acts and other wrongdoings complained of, each of the

Defendants acted with an awareness of its primary wrongdoing and realized that its conduct

would substantially assist the accomplishment of the wrongful conduct, wrongful goals, and

wrongdoing. 44. Defendants, and each of them, knowingly and willfully conspired, engaged in a

common enterprise, and engaged in a common course of conduct to accomplish the wrongs

complained of herein. The purpose and effect of the conspiracy, common enterprise, and

common course of conduct complained of was, inter alia, to financially benefit Defendants at the

expense of Plaintiff by engaging in fraudulent activities. Defendants accomplished their

conspiracy, common enterprise, and common course of conduct by misrepresenting and

concealing material information regarding the servicing of loans, and by taking steps and

making statements in furtherance of their wrongdoing as specified herein. Each Defendant was

a direct, necessary and substantial participant in the conspiracy, common enterprise and common

course of conduct complained of herein, and was aware of its overall contribution to and

furtherance thereof. Defendants wrongful acts include, inter alia, all of the acts that each of

them are alleged to have committed in furtherance of the wrongful conduct of complained of

herein. 46. Any applicable statutes of limitations have been tolled by the Defendants

continuing, knowing, and active concealment of the facts alleged herein. Despite exercising

reasonable diligence, Plaintiff could not have discovered, did not discover, and was prevented

from discovering, the wrongdoing complained of herein.

47. In the alternative, Defendants should be es-stoppled from relying on any statutes of

limitations. Defendants have been under a continuing duty to disclose the true character, nature,

and quality of their financial services and debt collection practices. Defendants owed Plaintiff

an affirmative duty of full and fair disclosure, but knowingly failed to honor and discharge such

duty.

I N T R O D U C T I O N

48. This Action brought by Plaintiff before this Honorable Court arises out of a Workers

Compensation Claim Plaintiff filed against Defendant SPE, for a work related stress injury. Plaintiff

had Suffered Psychological & Mental Abuse and was subjected to work in a very HOSTILE

Environment that had been created by the Executive Director of the SPE Telecommunications

Department, Defendant Grover. 49. August 3, 2009, Plaintiff, was suffering from a SEVERE Nervous Psychological, Emotional, Mental Condition & was having a Nervous Break Down. Plaintiff on the advice of Retired SPE President Mr. Arnie Schupack went to the Medical Department & HR Department on the advice of Retired SPE President Mr. Arnie Schupack 50. Plaintiff went to the Medical Department of Defendant SPE, where Plaintiff told the Executive Director Nurse of SPE Medical Department, Defendant Saporito, Plaintiff wanted and needed to be put off work, for a Workers Compensation Work Related Stress Injury. 51. Defendant Saporito, contacted Human Resources Employee, Defendant Felder, HR Rep for Plaintiff's Department and Saporito made a phone call to the Sony Pictures Medical Doctor, Dr. Steven Witlin at his private practice office. 52. Defendant Saporito, assessed the seriousness of Plaintiff's Psychological & Mental State of Mind, and Plaintiff's Medical Condition, at the time, did warrant, that she, accompany Plaintiff to the SPE HR Department Office of Defendant Felder. 53. Defendant Saporito informed Defendant Felder, she would accompany Plaintiff to Defendant Felder office. Saporito, said to Plaintiff, she was concerned, Plaintiff, could possibly have a Heart Attack or a Stroke, and she would remain with Plaintiff. STATEMENT OF FACTS 54. Plaintiff, Thursday July 30, 2009, place a phone call to Defendant, Brickmeyer, Plaintiff's Union Business Agent of IBEW LOCAL 40, Defendant 40. Plaintiff asked, Defendant Brickmeyer to file a grievance, on Plaintiff's behave, against Defendant SPE, because the SPE Executive Director, in charge of the SPE Telecommunications Department, Executive Director, Defendant Grover, had Harassed and Caused Plaintiff to Suffer, in a Very Hostile Work Environment, for nearly 20 years. 55. Plaintiff informed, Brickmeyer, Grover had not only harassed plaintiff, Grover, in fact harassed most of plaintiff's peers. Brickmeyer; was informed Grover routinely used very Offensive Language which included, IE; Derogatory remarks about GAYS Plaintiff is a Gay Male, Grover would routinely Swear at plaintiff & peers, made Derogatory Racial & Racist comments about African Americans, Hispanic Americans, Asian Americans. Plaintiff, told Brickmeyer, the conduct of Grover, has caused all of his PEERS IN THE SPE TELECOMMUNICATIONS DEPARTMENT TO SUFFER UNNECESSARY AND UNHEALTHFUL STRESS. 56. Brickmeyer; said; He Valued His Working Relationship, with SPE Executive Director, Defendant Grover, he would not risk damaging his working relationship by filing a Grievance Jeff Grover. Brickmeyer said he certainly would not get into a Legal Battle with Defendant SPE, and with its' Unlimited Funds. Under no circumstances would he, risk the Financial Solvency, or Bankrupt IBEW LOCAL 40, and Jeopardize the welfare of its' 500 plus MEMBERS. For a Half Dozen Phone Men at Sony Pictures, Plaintiff reminded Brickmeyer, the Half Dozen Phone Men at Sony Pictures are, also DUES PAYING MEMBERS of IBEW LOCAL 40. 57. Plaintiff told Brickmeyer, if you will not deal with Mr. Grover, then Plaintiff will deal with Grover, since after all, Plaintiff is responsible for Jeff Grover even having a Job at Sony Pictures. Plaintiff gave Grover his job at the Studio in the first place. Plaintiff told Brickmeyer, he would do so by going to the HR and filing a complaint against Executive Director Jeff Grover. I told; Defendant Brickmeyer, if Sony Pictures ever gets sued because of Grover, it will put Sony Corporation out of business, once their Insurance had to FOOT THE BILL for that man. 58. Defendant Brickmeyer told Plaintiff he was not only a fool, but a trouble maker. Plaintiff told Brickmeyer, the reason he thinks I am trouble maker, is Plaintiff, just like Local 40 Union Member, brother Jerry Green, expects the Union Contract to be FOLLOWED. Plaintiff said to Brickmeyer, I will fight for my own job and when I return to my job at Sony Pictures, do not send me another bill for DUES for Membership in IBEW LOCAL 40. If I ever receive a DUES BILL for so much as a Plugged Nickel, I will report this incident to the National Labor Relations Board. 59. Plaintiff is of the belief, his position on UNION DUES, was taken to heart. It was not until, late afternoon, November 18, 2014, Defendant Groe, received a phone call from someone at IBEW LOCAL 40. Defendant Groe was informed, Plaintiff had not been a member of IBEW LOCAL 40, for several years. Plaintiff, is of the belief, this could not have been a clerical error on the part of Local 40. Defendant Rosales, faxes or emails to IBEW LOCAL 40, a quarterly list with the Names, of the LOCAL 40 Union MEMBERS, employed in the SPE LOCAL 40 Telecommunications Shop. The propose of this list, to send a UNION DUES BILL to the working members. 60. Plaintiff on Friday July 31, 2009 at or about 4:00 PM, placed a phone call to the Palm Desert home of retired SPE President Mr. Arnie Shupack. The phone call was sent to Voice Mail, Plaintiff ask Mr. Shupack, to call him, as he needed ask his advise about a situation at SPE. Mr. Shupack was the Metro-Goldyn-Meyer Studios Manager, who had, Interviewed & Hired Plaintiff for the newly created MGM Telecommunications Department in May if 1982. 61. Mr. Shupack, on Friday July 31, 2009, approximately 7 & hours later returned a phone call to Plaintiff, at or about, 11:35 PM, over the next 1 & hours. Plaintiff informed Mr Shupack of the years of ABUSE, he had suffered, at the hands of Defendant Grover. Plaintiff and Plaintiff's Peers, were all aware and did hear Defendant Grover's ANTI-SEMITIC SLURS directed at People of the Jewish Faith, his RACIST SLURS & COMMENTS directed at African Americans, his RACIST SLURS & COMMENTS directed at Hispanic Americans, his RACIST SLURS & COMMENTS directed at Asian Americans. 62. Plaintiff; told Mr. Shupack that it was common knowledge among the SPE back-lot employees. If they were to file and/or make a complaint in the SPE Human Resources Department, against an SPE Manager or SPE Department Head. It would result in the complaining employee, losing his or her employment at SPE, Not the SPE Manager or SPE Department Head.

63. Plaintiff told Mr. Shupack if he did not do something about Defendant Grover, he would have to give up his job at SPE. Plaintiff said; the combination his HIV-Positive Status & the Stress caused by Defendant Grover's Harassment would end up causing Plaintiff death. Plaintiff asked Mr. Shupack, if he filed a Workers Compensation Claim, could it protect and keep Plaintiff from risking his job at SPE. Mr. Shupack; instructed Plaintiff, to go to Dr. Steven Witlin on Monday August 3, 2009 and ask to be put out for a Work Related Stress Injury. This way the SPE, Third Party Workers Compensation Administrator would be Documenting Plaintiff''s complaint against defendant Grover outside the company. 64. On August 3, 2009 Plaintiff filed a Work Related Stress Injury, against Defendant SPE the Mental State of Mind of Plaintiff was Extremely Severe. Plaintiff was in Danger of Suffering a Complete Nervous Breakdown. Due to Plaintiffs Fragile Mental State, and for approximately 1 &1/2 hours The Executive Director Nurse of the SPE Medical Department; Defendant Saporito sat at the side of Plaintiff, and she monitored both the Heart Rate and Blood Pressure of Plaintiff. Saporito recorded Plaintiff's Heart rate & Blood Pressure. 65. Plaintiff; INFORMED SPE Human Resources Department Employee, Defendant Felder how for 21 years, the Executive Director of SPE's Telecommunications Department, Defendant Grover had been the cause of & take pleasure, in creating for Plaintiff, a Hostile Work Environment. 66. Plaintiff told Felder; The Studio Back Lot Employees have very little faith in the SPE Human Resources Department and they are reluctant to come anyone in the Human Resources Department to file a complaint about an abusing SPE Manager. The non-management Employees have witnessed time and again, when an employee comes to Human Resources with a complaint about their Boss or Manager. The complaining employee 9 times out of 10 is no longer an employee of SPE. The non-management Employees are routinely told in department meetings, if former Employee so & so attempts to contact you, do not talk to him or her, if you do, you might suffer, that former employee's fate. Grover has said this to the Employees in his department many times. 67. Plaintiff told Felder; SPE Human Resources Department needs to send a clear message to the non-management Employees on the back lot. The SPE HR Department, wants all employees to know, they do not need to FEAR, reporting any harassers, abusers, racist, or bigots, no matter what their TITLE. The welfare of all SPE employees, depends on HR Department being Informed, of any Unprofessional or Incompetent, Department Head or Manager. Plaintiff advised Felder, for the first SPE Human Resources Department needs to make the right decision, TERMANATE and get rid of an ABUSIVE, Harassing, Racist & Bigoted Management EMPLOYEE. 68. Felder asked; Plaintiff if he thought, his co-workers would support him and confirm, Plaintiff's allegations. Plaintiff told; Felder, he could not say whether his co-workers would or would not support him and confirm his allegations. Plaintiff said; if his co-workers knew for a fact or were assured, they could speak freely, and they did not have to fear any sort of retribution. There would be no telling what HR, would find out about Grover. 69. Plaintiff said, Grover had harassed every single person in his department. Plaintiff told Felder, there is not one person in his department, that he had not violated their Privacy. Plaintiff told Felder, there is not one person in his department, that does not know the FACT THAT HE IS A RACIST BIGOT. Plaintiff told Felder, there was not one person in his department, that does not know, Grover is Antisemitic. Plaintiff told Felder, to ask Ollie-Wright, an African American Woman, how many times she had asked Grover, why he had never hired an African American Technician, and what he had told, to her, every time, he answered the question. 70. Plaintiff told Felder, Donny Harris, the only African American Technician, in the SPE Telecommunications 40 Shop crew, had been hired by Plaintiff. When Gerald Brown had been promoted to Shop Foreman, at the time Grover was promoted to SPE Management. Brown did not know the procedure, for hiring personnel from the 40 Union Hall. Grover told Plaintiff, to put in a call to the Union Hall, for a Technician, to replace Brown. Plaintiff went to Ollie-Wright's office and asked her for the telephone number of Donny Harris. Ollie-Wright asked Plaintiff, why did he want the telephone number for Donny Harris? Plaintiff told Ollie-Wright, Grover had just slipped up, and he doesn't realize what he has opened himself up too!, but he will find out real soon! Plaintiff told Olllie-Wright, she will not have to ask Grover again, why there is not an African American Technician in the Telecomm crew, Plaintiff told Ollie-Wright; he had been told to call the 40, Union Hall for a Technician to fill the position, vacated by Gerald Brown, when he was promoted to Foreman. Ollie-Wright commented; won't he be surprised, Plaintiff responded; you betcha, he is not only going to be surprised, he will be shocked too! 71. Plaintiff called Harris, and asked him, if he would consider making a job change, and come to work for Sony Pictures. Harris said; he would love having a job at Sony Pictures. Harris asked, Plaintiff why he had thought of him. Plaintiff said, he needed to be up front, he thought of Harris for two reasons. First because your a very good technician, second you're an African American. 72. Plaintiff told Harris, unfortunately Grover the Department Head, Ruth. [Ollie-Wright] has asked him, many times, why has there never been an African American Technician. Harris was told if he accepts the offer, I had just made, Ollie-Wright, will not have to ask again. Plaintiff asked Harris, if still wants a job with SPE and if so when could he start? Harris said; yes he still wanted the job, and could start the next day. Plaintiff told Harris, he would have to drive to the Union Hall in North Hollywood, to pay a work permit, Plaintiff would see him the next day. 73. Plaintiff called Brickmeyer, the 40 business agent, and told Brickmeyer, Donny Harris, a retired NFL Football Player, who had play for the New York Giants, & the Washington Redskins. An African American Gentleman, hired by Plaintiff, because he did not want a Law Suit filed against SPE, because of Racism, due to the fact there has never been, an African American Telephone technician, dispatched by 40, to SPE. 74. Plaintiff gave Felder three separate incidents for each one of his co-workers had suffered by Grover, which Plaintiff had personally witnessed, or had knowledge. Plaintiff told Felder to be sure to, ask each one of peers about the incidents, and find out just what is confirmed, Plaintiff guaranteed HR, would get more than enough conformation. Felder had filled several pages in the legal tablet, she writing on for over an hour and a half, page after page after page. Plaintiffs allegations covered 21 years, of abuse Plaintiff and his peers. 75. Plaintiff told Felder, he come to HR for EVERY SINGLE EMPLOYEE of SONY CORPORCATION. Felder asked Plaintiff what did he mean, he came to HR for every Employee of Sony Corporation. Plaintiff said he has warned his peers, and Grover hundreds of times over the years, the RACIST language which Grover routinely uses, how constantly harasses & degrades, the employees in his department. Plaintiff had told his peers if anyone were to realize the hundreds of Millions, how easy it would be for an Attorney to file and win a Law Suit. That it could SPE could not possibly defend a Grover, Law Suit. If Sony's Insurance Company having to foot that bill, because of what that man does every single day of the week, to his employees, it will put Sony Corporation out of Business. 76. Plaintiff; told Felder, as an example of how Evil, Cruel, Callas, and Hardhearted Grover completely lacking of empathy or compassion, for another Human Being. November 2, 1994 at 2:45 AM, Plaintiff received phone call, and was told his Sister Kathleen Elizabeth had put a, 38 caliber Pistol, into her mouth, and blew her brains, out the top of her head. Plaintiff, is also at the same time, trying to care for his partner Terrence Ricci, who terminally ill, suffering dementia and dying of HIV/AIDS. Plaintiff is forced to leave his partner alone, with out anyone to help or assist him, in their Redondo Beach home. 77. Plaintiff the on the day he returns to work, not five minutes after Plaintiff walked, into the office, Says hello to his peers. Not a word single word of condolence from any of his peers. What takes place next, hears, Grover, laughing to the point of tears rolling down his cheeks. Grover is telling, Plaintiff's, peers, his comedic story version of former co-worker, who had years earlier, committed suicide, by hanging himself. To keep from becoming violate, and doing to Grover, what Plaintiff, a nearly had an overwhelming urge to do, to Grover, at that very moment, Plaintiff had to walk out of the office, clock out, and go home. 78. Plaintiff; told Felder, at the time his late partner, Terrence Ricci, was DYING of HIV/AIDS, at their home in Redondo Beach. Plaintiff would routinely hear Grover's remarks, as well as his jokes, about dying Fagots & AIDS. June of 1995 took a leave of absence to care for Terry, in August 6 hours before Terry past away, Plaintiff received a phone call from his Doctor, and was informed he had tested positive for HIV. Before Plaintiff return to work from his leave of absence Plaintiff had approached the Department Manager at the time Kim Cahill, Grover, and all of his co-workers and told each one of them. He was HIV-Positive, then asked each one of them, if they would be uncomfortable working with Plaintiff. Plaintiff also told each one of them, there would come a time, when the HIV will cause Plaintiff, to be absent and miss work, and they would have to cover his work load. Plaintiff was assured by each of his co-workers, at the time, this would not become an issue for any of them. Plaintiff leave of absence was extended until January of 1996 so he could visit with his family and decide whether or not to retire, as Plaintiff was given that option. Plaintiff in January 1996 asked Grover for and was granted a one month extension to the leave of absence, because it was going to mid February before he would see a HIV Specialist. When Plaintiff did return to work, Grover told Plaintiff, that Kim Cahill had told Grover to fire Plaintiff. Grover said he had advised Cahill, Plaintiff was Protected by the Americans with Disabilities Act, because he is being HIV-Positive. Plaintiff told Grover, he should probally go ahead and retire, because he did not want or need to be stress anymore then he already was about his being HIV-Positive, nor did he to become a problem for Cahill, Grover or SPE. Plaintiff was assured by Grover there would never an issue in regard to his HIV-Positive status. Plaintiff told Felder; when he did started to miss work because of his health, it did become and has been an ISSUE, with Grover and a few of Plaintiff's Peers, that ISSUE has caused Plaintiff major amount of STRESS over the years. 79. As Saporito and Plaintiff were leaving her office to go see Dr. Steven Witlin the SPE Company Pshiation , Ms. Felder told me. While you are home recovering write in a notebook any other incidents you recall, when you have 4 or 5 call me. I told her that is not a good idea, because what you are asking me to do is going to set me up to look like a disgruntled employee who is trying to get his boss. She told me no it would not the more information they have, will help with the investigation of Mr. Grover. I told her I still think it a bad idea. 80. I called Abby Felder August 4, 2009 with ten to fifteen more incidences. On August 6, 2009 I called with two more pages, this time she tells I do not need to keep calling her. I reminded her I was doing as she had instructed. Then she asked if I could come in to HR at 4:00 PM to see a Doctor. I responded, what kind of Doctor a Psychiatrist? She said yes. I told her yes I will come in if that would help. 81. I met with Dr. Michael Zona Thursday August 6, 2009 in a HR conference room. Dr. Zona had in his hand Abby Felders legal pad with all my accusations against Mr. Grover. He told me; he was hired by Sony Pictures as an independent consultant, to determine. If what I had said was true, or I am angry disgruntled employee. Who is trying to cause trouble for his boss. He said you know; you have made a lot of very serious accusations any one of which, if proved to be true would result in an automatic termination of Executive Director Jeff Grover. I responded, I know there serious and if one of my co-workers confirms just one, it will cost Mr. Grover his job. 82. Dr. Zona and I sat down at the conference table, he said, I want to reintegrate to you, that I am here only as a consultant and I have no interest in the out come of this investigation. I am only here to form an opinion as to whether you are telling the truth or if you are just a disgruntled employee trying to get Mr. Grover in trouble. He said, I want you to know Sony Pictures is very concerned about your health, and Sony Pictures wants you to talk with me as long as you want to talk to me. If on Monday morning we are still in this room talking at 9:00 AM, when they return to work. It will be okay, because thats how concerned Sony Pictures is for you.

83. Within fifteen minutes Dr. Zona knew everything that I had accused Jeff Grover of havingdone to me and my co-workers was true. He knew I was not only concerned about my welfare; I was concerned for the welfare of my co-workers. And he knew I was very concerned what could happen if Sony Pictures was sued because of Jeff Grover. After talking with him for 3 hours and 45 minutes, I said Dr. Zona you know I am telling the truth. I said to him I have no idea what you are getting paid for this, I am sure it is costing, this company quite a bit of money, Sony Pictures does not need to waste any more money to find out if I have told the truth about Jeff Grover. I said its Friday night we both have to get on the 405, I have to drive to Long Beach, and you have to drive to Newport Beach. So we should end this and go home.

84. Dr. Zona told me he was going to write in his report; he believed every thing I said aboutJeff Grover is true. That I am genuinely concerned for the welfare of my co-workers, and Sony Pictures. In no way are you a threat to the safety of the Sony Pictures and the Employees.

85. Dr. Zona; then told me, Michael do not wait for your Workers Compensation medicalbenefits to start because it could take a week or more. In my professional opinion as a Medical Doctor, your condition is so severe; I believe you are one thread away from a Complete Nervous Breakdown. If that thread breaks, I do not know if you will ever come back from it. Michael, I urge you to find yourself a Doctor tomorrow you need to begin treatment immediately. I asked Dr. Zona if he would take me as a patient, he told me he couldnt that it would be a conflict of interest. He referred me to a friend of his in Newport Beach.

86. As we were walking towards the door, he blocked the doorway, and then said; I can notlet you leave here, until I get your answer to one last question. Human Resources needs to know your answer to this question. What if everything you have alleged is proven to be true by your co-workers, and for some reason Jeff Grover doesnt loose his job. Zona said: God I cant imagine that could happen with all of this, you have accused him of, but say there is a technicality. And, Mr. Grover gets to keep his job, could you come back and work for Sony Pictures, and could you work for Jeff Grover again. I said let me think a minute before I answer. It took me about a one second; I answered him with this, after having to put up with his crap for twenty years. If he knows he will not get a second. Yes I could come back to work for Sony Pictures and yes I could work for Jeff Grover again. But the question thats needs an answer is this, can Jeff Grover, after finding out I am the person that went to HR and filed the complaint against him. Can Jeff Grover handle Michael Moore working for him?

87. Saturday August 7, 2009 my partner Dale Swope, his sister Rebecca Swope, businesspartner Robin Merrill and I went see Herbie Hancock at the Hollywood Bowl. I saw Mr. Morgan Freeman, and we had a conversation, Plaintiff asked Mr. Freeman how he was getting along?, Mr. Freeman was recovering from the injuries he had sustained from a car wreck he had been in a year earlier. During our conversation I told him, I had went out on workers compensation disability for a long overdue mental health rest. I said; Morgan you being an African American Actor, I doubt this will be a surprise to you. After twenty years I went to HR Monday and reported the racist bigot in charge of Sony Pictures Telecommunications Department. Morgan responded; Im not surprised there are a lot of racist bigots running the entertainment industry. I told him yesterday HR had me come in to the studio to meet with a Psychiatrist, and his last question. I have a bad feeling how this is going to turn out for me. 88. When Morgan was honored by AFI June 10, 2011 the show was taped on stage 15 at SonyPictures, we talked about Herbie Hancocks' new music. The only reference I made about the conversation at the Hollywood Bowl was I still have my job here at Sony Pictures. I thought this is Morgan Freemans night, not the time for saying, Sony still has racist bigot, my boss Executive Director Grover.

89. Saturday August 8, 2009 Plaintiff had a Nervous Breakdown while taking a shower,Recbecca Swope & Dale Swope transported Plaintiff to Long Beach Community Hospital. Plaintiff was Admitted to the Psychiatric Ward. August 10, 2009 Plaintiff is discharged from Hospital. [see attachment 3A]

90. Plaintiff received a letter from Mr. Robert Thompson, a claims specialist employed byDefendant ESIS, the SPE Third Party Workers Compensation Administrator, Informing Plaintiff of his August 18, 2009 appointment with Dr.Ismail Yassai, a Psychologist. Plaintiff is suing Defendant ESIS merely as an unknowing co-conspirator profiteer, and for no other reason. 91. Mr. Thompson on or about August 21, 2009 received the report of Plaintiffs' appointmentwith Dr. Ismail Yassai, he was shocked at what he has read in the Doctors report. Mr. Thompson contacts the SPE Human Resources rep Felder. Mr. Thompson informs Felder, never in his career, has he ever read a more disgusting report from a doctor as the report he received on claimant Michael David Moore. 92. Thompson demands that SPE HR provides to him a written report every 2 days of the progress and details of the HR investigation, of Defendant Grover, what are Plaintiffs peers telling the HR Investigator about Executive Director, Defendant Grover.

93. On or about August 31, 2009 Mr. Thompson phones Plaintiff and informs him about hisdemand for a written report. Thompson tells plaintiff he has not yet received any written reports from HR investigator, Thompson asked Plaintiff if he knows or has heard anything about the HR investigation or what is going on, in the SPE HR Department? Thompson is very perturbed, he had made three calls to Defendant Felder and has only been given excuses why, he has not yet received any written reports, as he demanded. I said to Thompson, there are a lot of people to interview, please give them time. Thompson said okay he would, but he does not like what he believes, HR is doing. I knew what Mr. Thompson was insinuating, that thought there was a cover-up taking place or in the works.

94. Plaintiff immediately phoned Defendant Felder, and told Felder, that I had just gotten offof the telephone with Mr. Thompson. I told Felder, Thompson had informed me, that he had demanded, HR to provide him written reports, I told Felder, Thompson is vary perturbed with the SPE HR department.

95. I told Felder, Thompson knows Grover has not been suspended, he is not happy at allabout either. I told Felder to get Grover out of the Studio, pickup the telephone, and call Mr. Thompson. let him know Grover has been either Suspended or Terminated. Felder told me they know what, they are doing, and for me not to tell them, how to conduct they're Investigation of Defendant Grover. I reminded her, this was Sony's Insurance Company not mine. 96. Plaintiff about a week later Mr. Thompson called again this time he is furious, said he hadmade two or three more calls. HR was still making excuses, he said he could not believe what going on. Mr. Thompson said, he was going to have to report this to Risk Management. I talked him out of taking any action, Plaintiff said he would HR, and talk to someone above Felder. I calledFelder, and told her I wanted to talk to someone above Her. She said my phone calls are getting to be harassing, if I did not stop calling them how to do their job, it could determine if I was going have a job at Sony Picture. I told Felder what they were doing was driving a nail into the lid of Sonys coffin, every time Bob Thompson calls and is given excuses. I said what you people are doing is going to make sure no one has a job at Sony. I made a couple more phone calls to HR, the last call I was told outright if I called one more time I would not have a job at Sony Pictures.

97. September 23, 2009, Bob Thompson, call me around 10:00 am, he said; Michael, I been aclaims administrator nearly twenty years, and nothing like this has ever happened. He told me that he works in a room with 50 or 75 other claims administrators, and he had asked about half of his peers in the room. If they had ever heard of any thing like this happening, he said he told them, he notified the Risk Management Department at ACE American Insurance Company. The Vice-President of the Department informed the Parent, ACE LIMITED, the Chairman Mr. Evan Greenberg called an emergency meeting. Mr. Greenberg and all of the Senior Executives will be flying during the night aboard a company aircraft, from Zurich to New York City. And there will be people flying from all over the world to New York City to attend this Meeting as well. He said all he could tell Plaintiff, was that he was told to inform Plaintiff of the Meeting and to tell Plaintiff to make sure Dale Swope and Plaintiff are home in the evening. We will be receiving a phone call from New York in the late evening, and it was important that we are both home when the call comes. That it is important for both of us to be home when the phone call comes.

98. I could not sleep that night, all I did for the next 34 hours was worry and pace, I would gofor walks around the block. I went to a neighbors house, Sgt. Jason Davies, a Culver City Police Officer, sat on his porch and told him, I was afraid HR had done it this time. I told him; there is a meeting taking place in New York City now, and when I get a phone call. Their going to tell me, Sony Corporation is going to be put out of business, because of Jeff Grover and the SPE Human Resources Department. Plaintiff told Jason Davies, He could not understand how the People in the Human Resources Department could be so stupid & foolish, as to St0ne WALL Sony's Insurance Company. 99. Plaintiff received the phone call from Bob Thompson at or about 8:30 PM PST, he said, Ihave here with me, Mr. Robert Cusumano, Chief Legal Council of ACE LIMITED and he wants to speak with you. I do not recall his name. The gentleman said; Mr. Moore Sir, I am speaking with you, as the representative, of our Company's Chairman, Mr. Evan Greenberg. He has asked me to apologize to you, for Him not to being, the first person to speak with me. He said; Mr. Greenberg and the other attendees, were were finishing some business, of todays meeting and Mr. Greenberg will be talking to me in about 20 minutes. In the mean time, there is something that we need to do and we would like to tape record what I am about to tell you. Then he asked, Plaintiff, do I have your permission to record this conversation, and is it alright with you for Mr. Greenberg the others in the conference room listen in, on telephones and hear what we are going to be recording? I said it is okay to record this phone call and I do not mind if they listen.

100. Mr. Thompson, asked Plaintiff to bare with him, he had never done anything like thisbefore. Mr. Thompson said; I will ask you some questions, that are written on a sheet of paper, like a script and I need you to answer each one. Then, he said; we are now recording and he begins with the questions: Thompson: Is your name Michael David Moore? Plaintiff: Yes my name is Michael David Moore. Thompson: Are you an employee of Sony Pictures Entertainment Inc., in Culver City California? Plaintiff: Yes, I am, an employee of Sony Pictures Entertainment Inc., in Culver City, California. Thompson: Do you have a Workers Compensation Claim Filed against your employer Sony Pictures Entertainment Inc.? Plaintiff: Yes I have a Workers Compensation Claim Filed against my employer Sony Pictures Entertainment Inc. Thompson: Are you represented an Attorney? Plaintiff: No I am not represented by an Attorney. Mr. Thompson said, we were finished, then turn the phone back to the Chief Legal Council, he told Plaintiff, Mr. Greenberg is now ready to talk with you.

101. Mr. Greenberg; Says to Plaintiff, Mr. Moore, Sir it is Truly, an Honor and a Privilege,for me, to Speak with a Human Being, such as yourself. A person who is as Caring for the welfare of others as You are for the welfare of your peers, your peers who do not care for your welfare. A person who is as compassionate for his peers, the same peers who show no compassion to you.A person who is as forgiving of his peers, the same peers who have repeatedly betrayed you. You have no grudges against your peers, even though your peers do begrudge you. You wish no ILL WILL to your peers, while your peers have ILL WILL for You. 102. Mr. Greenberg said, we know, you do not have an Attorney and we know why you do nothave an Attorney. You told, Dr. Yassai, if you had involved an Attorney, he would seek damages for your Injury. You told, Dr. Yassai if that were to happen, you could not protect Sony Pictures, you could not protect Sony Corporation. You told, Dr. Yassai, you would not be able to protect the jobs of your peers, your friends and your co-workers at the Studio, that you LOVE. You told Dr. Yassai, you could not protect ACE LIMITED, and it's shareholders, you told, Dr. Yassai, you were afraid if my company had to pay a claim, for your injury, you were afraid it would put, Sony Corporation out of Business. You told Dr. Yassai, you were afraid one Law Suit would cost my company $400 to $600 Million Dollars. You told Dr. Yassai, you did not want $1.00 Dollar. Mr. Greenberg said, we know Mr. Thompson in 2007 administered a Workers Compensation Claim for an injury to your elbow. When it was time to settle that claim, Mr. Thompson told you he was going to issue you a check for $9,200.00 and you told Mr. Thompson to keep the money for someone who needs it. You said, the disability checks received allowed you to pay your bills and your medical bills were paid by the Insurance company, and that was all the money you needed, from the Insurance company.

103. Mr. Greenberg said, Plaintiff was absolutely correct to be worried about the Risk,Defendant Grover had put the SONY Corporation, Mr. Greenberg said, we are amazed the Senior Executive Management Team of Sony Pictures Entertainment Inc., did not concern themselves of how Executive Director Jeff Grover had Jeopardized the Sony Corporation. Plaintiff was told the ACE LIMITED, Board of Directors, are all Senior Executives of Fortune 500 Companies. They had been scratching their heads, asking themselves and each other, where in the WORLD could they find ONE EMPLOYEE as LOYAL, FAITHFUL AND DEDICATED to their Companies, as Plaintiff is Defendant SPE, A COMPANY THAT, DOES NOT DESERVE TO HAVE HIM.

104. Mr. Greenberg said, he regrets to inform Plaintiff, he has no other choice than to dropDefendant SPE as a client, the Executive Management Team of Defendant SPE had Violated several Federal and State Labor Laws & Statutes and had Violated several Statutes of the Securities and Exchange Commission Act of 1934. Greenberg said; the SPE Executive Management had entered into a Conspiracy to Conceal the Crimes that they had committed against Plaintiff and in doing so, his company (ACE LIMITED) had become an unknowing co-conspirator profiteer and they had made the financial industry an unknowing co-conspirator profiteer. Mr. Greenberg said, Defendant SPE, Defendant Lynton, Defendant Pascal, Defendant Weil, Defendant Felder, Defendant Stringer, had Violated, (Cal Civil Code 1871.4. (a) It is unlawful to do any of the \following: (text omitted), sec. 1, sec.2, sec.3, sec.4), and committed FELONY INSURANCE FRAUD, and entered into a CONSPRIACY to CONCEAL

104. Mr. Greenberg said, If it became, Public Knowledge, ACE LIMITED, insured a ClientWho's Senior Executive Management Team, had involved them selfs in a conspiracy. To cover up the fact that one of they're, Executive Directors is a RACIST BIGOT. Who had violated the rights of one of their employees, as did, Defendant Grover, violate Plaintiff's. It would put ACE LIMITED at risk, of having its' investors lose faith and sell off their shares of ACE LIMITED. Which in turn could harm the Fortune 500 Companys, ACE LIMITED insures and if that where to happen it could have a detrimental effect on the Global Economy, for this reason ACE LIMITED can no longer Insurance Defendant SPE.

106. Mr. Greenberg, told Plaintiff; a Press Release had been the final business details of theday's emergency meeting, and it would be released to the News Wire, and would inform the World what the SPE Executives had involved themselves. Mr. Greenberg told Plaintiff, Sony Corporation and the Subsidiaries of Sony Corporation would never again be able to purchase Insurance from another Insurance Company in the World, as a result of the Numerous Violations of Laws and Statutes, the Crimes of SPE's Senior Executive Management Team. Press Release. Sony Corporation was getting it's doors closed. 107. The Financial Companys that had given loans and lines of credit to Sony Corporation and it's Subsidiaries had been made unknowing co-conspirator profiteers. The financial company's will at 9:00 AM EST recall all the outstanding Loans and Lines of Credit extended to Sony Corporation and Subsidiaries of Sony Corporation. He says the Sony Corporation will fall on top of the heap of failed companies, as would any company fall if it had installed a Senior Executive Management Team as Dirty, Immoral, Unethical, Conniving, and Under-Handed at one its' Subsidiary Companies. As is the one Sony Corporation has installed at its' American Subsidiary Sony Pictures Entertainment Inc., in Culver City, California.

108. Plaintiff had Defended the SPE Senior Executive's, Plaintiff; said he could not believe they had any knowledge, that it had to have been, a few Rogue Employees in the Human Resources Department who had to have taken it upon themselves. Plaintiff said, the SPE Senior Executives could not possibly be so stupid or foolish to involve them selves in something like a Criminal Conspiracy. Plaintiff was told by Mr. Greenberg, because they had not returned any of Mr. Thompson's phone calls, it was clear they were involved. Mr. Greenberg, said it was suspected the Criminal Conspiracy involved the highest level of Executive Management at Sony Corporation in Tokyo, Greenberg said it was highly suspected the Chairman of Sony Corporation might be involved in or had of knowledge of the Conspiracy, but without the evidence to prove his involvement, they would not say this in the Press Release that had been written and was going to be sent to the NEWSWIRE, Greenberg said that it would be up to Law Enforcement in Japan to investigate the Senior Executives in Tokyo. agreed to a Settlement. Plaintiff was told, if he hung up the phone, without agreeing to settle, there would not be $1.00 dollar available to Plaintiff for the injuries he has suffered because at 9:00 AM, EST, Tomorrow Morning, there will not be a Sony Corporation.

109. Plaintiff was in Tears, he was Pleading & Begging Greenberg, not to put SonyCorporation out of business because of a Workers Compensation Claim had filed against SPE, due to the Mouth and Actions of One Racist & Bigoted Man. Plaintiff told Mr. Greenberg he did not have an Attorney involve on his behave just for this reason, because Plaintiff had known and had been warning his Peers & Grover for years, all it would take was, Just One Person Filing a Law Suit against SPE because of the Mouth & Actions of Executive Director Jeffery James Grover. Plaintiff told Greenberg; his friends and co-workers would blame & despise him for being the responsible for Sony Corporation being put out of business. Mr. Greenberg told Plaintiff, he was not to blame or responsible for what was going to happen to Sony Corporation. Greenberg said; itwas the Unconscionable Decision of SPE Senior Executive Management, for attempting to conceal and cover up the Injuries and Suffering Intentionally Inflicted on Plaintiff by an SPE Executive Director. Plaintiff realized, if he with-drew the Worker Compensation Claim, he had filed against SPE, and if he did not take one dollar for his injury. Then ACE AMERICAN INSURANCE COMPANY and it's Shareholders would not SUFFER a LOSE. Plaintiff could prevent ACE LIMITED using against Sony Corporation, any information it had learned because of Plaintiffs' Workers Compensation Claim. Plaintiff asked Mr. Greenberg, if he was correct?

110. There was silence for nearly 2 minutes, then Mr. Greenberg said; who am I talking too, on the other end of this phone? Plaintiff said; I am right, aren't I, you will not be able to put SONY Corporation out of Business, will you? Mr. Greenberg, said no we can not do a thing to SONY CORPORATION. Plaintiff, asked if he sent a FAX to Mr. Thompson right now, stating I wish to with-draw my Workers Compensation Claim at this time, will that be good enough to put an end to this? Plaintiff was told yes it would end their plan of putting SONY out of business. Plaintiff then asked for a phone number to send a fax. Mr. Greenberg advised Plaintiff, before he sent a fax withdrawing his claim, Plaintiff should consider the fact, Plaintiff did not know if he would have a job to go back too. Mr. Greenberg told Plaintiff that if he did have a job to go back too, Mr. Greenberg said he was sure Plaintiff would find out that Grover would still be employed by SPE and in all likely hood Plaintiff would find himself in a much worse Work Environment, then Plaintiff had been in, the previous 21 years. Plaintiff told Mr. Greenberg, he did not need to consider if he would have a job to go back too. Plaintiff said, he knew his company would do the right thing, Defendant SPE, would terminate Defendant Grover, and Plaintiff would have a job to go back too. Plaintiff was then given a phone number to send his fax, and said he would have to hang up to send the fax and asked Mr. Greenberg to call him back after the fax was received.

111. When Mr. Greenberg called back, he asked Plaintiff, if he realize, that Plaintiff had just put Hand Cuffs on to the Wrists, of the TITIANS, who are, the Drivers of the Worlds Economy. Mr. Greenberg said, YOU HAVE JUST STOPPED US IN OUR TRACKS. Mr. Moore, I want you to know, WE HAD BEEN ASSURED ALL DAY LONG, BY SOME OF THE BEST IVY LEGUE ATTORNEYS. THERE WAS NOTHING IN THE WORLD, THAT COULD STOP US FROM PUTTING SONY CORPORATION OUT OF BUSINESS, He said, You, SIR, a Phone Man with a High School 11th Grade GED Education, just out LAWYERED, the best Attorneys, Money can hire.

112. In the presence of Mr. Robert Hernandez, Mr. Michael P. Connors, Ms. Mary Cirillo-Goldberg, Mr. Olivier Steimer, Mr. Leo F. Mullin, Mr. Michael G. Atieh, Mr. Peter Menikoff, Mr. John A. Krol, and many others. Mr. Greenberg said, Plaintiff is the most Loyal and Faithful Employee in the World. Mr. Greenberg said, Plaintiff had locked away a vast fortune from himself when he with-drew his Workers Compensation Claim. Mr. Greenberg said, the Story of how Plaintiff saved Sony Corporation has a World-Wide value of between 4 and 8 Billion Dollars. Mr. Greenberg said this story is the property right of Michael David Moore, and Plaintiff needs to put his name to his story. Mr. Greenberg said, when Plaintiff puts his name to his story, he will also take his place in History as the Person who ended Golden Parachutes for the Executive Management Failures of the Entertainment Industry. Plaintiff will become the MEGA Super Star of the Global Financial Industry & the Global Insurance Industry. Mr. Evan Greenberg told Plaintiff he had locked away the title of Mega Super Star, from himself, when he with-drew his Workers Compensation Claim. Mr. Greenberg told Plaintiff the Executive Management Failures of the Global Entertainment Industries Public owned Companies had since the time of the first public owned company, taken from the Share Holders Trillions and Trillions of Dollars. Mr. Greenberg told Plaintiff when he claims his story he will end this practice, and in doing so Plaintiff will be responsible for putting that money into the hands of the share holders, and ultimately that will result in Trillions of Dollars going into the Worlds Economy. Mr. Greenberg, told Plaintiff and Dale Swope would become the Two Richest Men in the World, and this would put their Family Members at risk of being Kidnapped and held for Ransom. Mr. Greenberg told Plaintiff that the United States Department of Homeland Security, had agents and a van within a few blocks of every member of Plaintiff's & Dale Swope's Families was ready to gather every member of his and Dale Swope's Family. For this reason Plaintiff never wanted any of this to be made Public. Plaintiff realizes this sounds like he is living a life delusions of grandeur, But this is what Mr. Evan Greenberg told Plaintiff in the Presence of Person Who Attended the ACE LIMITED Emergency Meeting, Mr. Evan Greenberg had CALLED.

113. Mr. Greenberg and Plaintiff talked for over an hour after he save Sony Corporation, the worst case scenario, Mr. Greenberg said once Plaintiff told the Executive Management Team what had almost happened that night. How the Executive Management Team could ever allow Michael Moore v. Sony Pictures, but if it ever does happen. If his company is served with a complaint and a summons. ACE LIMITED would settle immediately with Plaintiff and Sony would be on it's own. Plaintiff told Mr. Greenberg and others, when Plaintiff returns to work, Plaintiff will tell the Executive Management what almost happened. Plaintiff will call Mr. Greenberg, and settle his pending Workers Compensation Claim for $1.00. Mr. Greenberg, will know Grover is no longer an Employee of SPE, Plaintiff can claim his Story/Property Right and Plaintiff will share the value of his Story with SPE 50/50. Plaintiff jokingly told the Bankers on the ACE LIMITED Board of Directors, his Studio would not be coming to them looking for Financing for their Movies anymore.

114. Plaintiff told Mr. Greenberg if it did come too, Michael Moore v. Sony Pictures, he would try not to take money from his company, Plaintiff would take the money of the Defendants who are responsible, ie the Executives of SPE & their Accomplices. Plaintiff said he wouldnegotiate a fair settlement for Dale F. Swope, since Plaintiff had denied Mr. Swope a settlement when he with-drew his Workers Compensation Claim

115. Mr. Greenberg said; he had made phone calls to, President Obama, Prime Minster Gordon Brown, Prime Minster Yukio Hatoyama, and many others. Mr. Greenberg, informed them, that an Unnamed Multi-Billion Dollar Corporation would be removed from the trading boards, of the worlds stock exchanges, and would fall onto the Heap of failed companies. Mr. Greenberg said, he would have to call all of them back that night, and tell them, he had made a mistake. He had not counted on the injured Employee. Plaintiff, was told the United States Securities and Exchange Commission, the New York Stock Exchange, the London Stock Exchange, the Tokyo Stock Exchange, and many other Entities were informed of Sony Corporations Demise.

116. The next morning September 25, 2009, Plaintiff, placed a phone call to Felder and informed her, ACE LIMITED accepted his injury, and was going to settle his Workers Compensation Claim, and turn the Documents it had over to the EEOC, and the California Department of Fair Housing and Labor. Plaintiff told Felder he had with-drawn his Workers Compensation Claim to prevent ACE LIMITED from turning the Documents over for Investigation. Felder responded, Oh that's Good, said good bye and hung up the phone.

117. October 2009 Plaintiff begins receiving treatment from two Doctors, at Memorial Counseling Associates, in Long Beach. Dr. William Clark, MD, a Doctor of Psychiatric Medicine, Dr. Clark advises Plaintiff to also see a Psychologist Dr. Frank Martinez, LCSW, Doctor of Psychology. When Dr. William Clark retired, Plaintiff's treatment is assigned to Dr. Dharmesh Sheth, MD.

118. Plaintiff had not yet received a phone call from Felder, on or about January 10, 2010, Plaintiff called Felder and asked when is the HR Investigation of Defendant Grover, going to end? Felder told Plaintiff, the HR Investigation of Grover, had ended 3&1/2 months earlier. Plaintiff; asked Felder why he had not contacted and informed of this fact, that the Investigation had been completed? Felder told, Plaintiff that it had SLIPPED HER MIND, TO CONTACT PLAINTIFF, Plaintiff; was shocked, he asked Felder, how could it be possible, that it Slipped Felders' Mind, to make a phone call to Plaintiff and let him know this?

119. Felder says to Plaintiff, she is happy to inform him, if Plaintiff wants to return to work at SPE, he has a job to return too. Felder told Plaintiff, how Fortunate SPE is to have such a concerned Employee, who is as Loyal, Faithful, Dedicated, an Employee who had somehow found the courage to have brought the matter of Executive Director Grover, to their attention, so HR could rectify the unhealthy environment in the SPE Telecommunications Department. Felder said SPE was so grateful to Plaintiff, there is a job at SPE for Plaintiff, until the day, Plaintiff chooses to leave SPE. Felder said if your HIV-Positive Status prevents you from working a full 8 hour day, Plaintiff could work how ever many hours in a day he could, this will never be an issue for Plaintiff again.

120. Plaintiff said to Felder, good my co-workers have confirmed the allegations, I made against Grover, and he has been terminated. Felder, was silent for a few moments, Felder then said, just what Zona, said what he COULD NOT POSSIBLY IMAGINE, how it COULD EVER HAPPEN. Felder said, there was a TECHNICALITY, and SPE did not TERMINATE Grover. Plaintiff said; what do you mean there was a technicality? Felder said; when Grover had been promoted to SPE MANAGEMENT, from the Union Ranks. Grover had fallen through the cracks, and had not received, SPE MANAGERIAL TRAINING. Felder said the Legal Department had determined if he were fired for what he had done to you, he could turn himself into a VICTIM. That he could file a Multimillion Dollar Law Suit against SONY PICTURES. The SPE LEGAL DEPARTMENT had made the decision, SPE would rather pay Grover through to his retirement, than allow Grover to become a millionaire at the Expense of SPE's Insurance Company.

121. Plaintiff asked Felder, who is the SPE Attorney, that thinks Grover, can turn himself into a victim? Plaintiff was told the head of the SPE legal department had determined, Grover could become a victim. Felder told Plaintiff, if he did not like it, he did not have to return to SPE. Felder said Executive Director Grover did not realize his language was offensive to anyone, that Grover was just a COLORFUL GUY. Plaintiff asked; Felder if SPE believes Grover's RACIAL SLURS about African Americans, His RACIAL SLURS about Hispanics Americans, His RACIAL SLURS about Asian Americans, and his DEROGATORY COMMENTS & SLURS about Gay Men & Gay Women, is just COLORFUL Language?, Felder had no comment.

122. Plaintiff; told Felder, it was obvious to Plaintiff, SPE, decided to cover up for Grover, August 6, 2009 as soon as Plaintiff had walked out of her office, Plaintiff told Felder, a Neanderthal Judge and a Jury of Twelve Neanderthals, could not find Grover a Victim. Plaintiff was reminded again, this is what the LEGAL DEPARTMENT had determined, and this is the way it is going to be. Felder told Plaintiff, Grover had been put on notice, if there was one complaint brought to HR, by anyone in his department, He would be terminated on the spot. Plaintiff was told Grover did not know who had reported him to HR and HR wanted to leave it that way. Plaintiff was told HR would need a Doctors release before he could return to work. SPE was informed of Plaintiff's Diagnosis and Treatment, in the release Dr. Clark filled out and signed so Plaintiff could return to work.

123. Plaintiff returned to work on February 1, 2010 at 7:00 am, his first job assignment, was to install a phone in the Rita Hayworth Dining Room for a Human Resources Training Class. Felder approached Plaintiff and asked; what does he think of the changes made in the Telecommunications Department. Plaintiff told Felder, she knew Plaintiff had just returned to work 15 minutes earlier, and it's a little to soon, for Felder, to be asking Plaintiff, what does he think about the changes made in his department. Plaintiff asked Felder, to call him in three or four days and then he would be able to tell her, what he thought of the changes, made in the Telecommunications Department. Felder told Plaintiff, she would call him on Friday, February 5, 2010.

124. Defendant Pacheco, said to Plaintiff Monday afternoon February 1, 2010, Defendant Grover is worse, than he ever was, because he knows he has gotten any with everything. Pacheco said Grover has become so arrogant, that he has walked through the Telecommunications Office, saying he, ie. Grover, is just a colorful guy! Pacheco told Plaintiff, Grover had accused everyone in the department of having gone to Human Resources and thrown him under the Bus. 125. Mr. Patrick Patchen told Plaintiff, in the parking lot of the Turner Building, that he and all of Plaintiffs co-workers are grateful & indebted to Plaintiff, for having gone to Human Resources about Defendant Grover, because all of them have benefited. Mr. Patchen said; had he known the chain of command on his first day, he would not have done to Plaintiff, what he had. When he told Plaintiff, he did not have to do the work, Plaintiff had to assigned him, his first day on the Job. Plaintiff asked Mr. Patchen, if he had asked by the Human Resources Investigator, about how Grover, had made Mr. Patchen beg him, ie: Grover, for his job back. Mr. Patchen, five years earlier had transferred to Sony Image Works, and when he was laid off from his Sony Image Works job, Mr. Patchen asked Grover, if he could have his job back in the Telecommunications Department. Mr. Grover, came to the 40 Telecommunications Shop, and told Mr. Gerald Brown, Pacheco, former co-workers Mr. Michael Souza, Mr. Carl Gollie, and Plaintiff. Mr. Patchen would be returning to work in the 40 Telecommunications Shop. Defendant Grover said, we should have seen Mr. Patchen in his office, crying like a baby and begging him, ie: Grover, for his job back. Grover said; it was the funniest thing, he had ever seen. Mr. Patchen said, he had not been asked about that incident, nor was he asked about any of Grover's Racist Slurs or Derogatory Comments, he had heard Grover in his presence.

126. Plaintiff asked; Defendant Gardity, if he had been asked by the Human Resources Investigator about, Grover's, use of the N word, in his presence at Grover's Big Bear Lake cabin?, Garity, told Plaintiff, he had not been asked. Garity said he was asked nothing about the Racist Slurs or the Derogatory Comments, he had heard Grover use in the past.

127. Plaintiff asked Defendant Ollie-Wright, if she had been asked by the Investigator, why and how many times did she ask, Defendant Grover, why there are no Africa American Technicians in the Defendant 40 Telecommunications shop. Defendant Ollie-Wright told Plaintiff, she had not been asked. Ollie-Wright said; she was asked nothing about Defendant Grover's Racist Slurs or Derogatory Comments

128. Plaintiff asked Defendant Pacheco if he had been asked by the Human Resources Investigator why he needed to vent for nearly 2 hours every day to his wife. When he got home from work, Defendant Pacheco said he was not asked. Pacheco said he was asked nothing about Defendant Grover's Racist Slurs or Derogatory Comments.

129. Plaintiff discovered on his first day back to work the Human Resources Investigator did not ask one question, that would have Confirmed Plaintiff's Accusations & Proved the Guilt of Defendant Grover. The Sony Pictures Entertainment Inc., Human Resources Department Investigation, of Defendant Grover was a complete SHAM. Plaintiff was assigned to do a job at the Turner Building, Plaintiff told Defendant Groe, some problems he was encountering on this job. Defendant Grover started right back with his Harassment of Plaintiff, Defendant Groe and Mr. Patchen, at one point are sent by, Defendant Grover, to give Plaintiff a message, not to come to Grover with any more problems with the Turner job. Plaintiff advised; Mr. Patchen & Defendant Groe, not to get themselves involved in the dispute between Plaintiff and Defendant Grover. Plaintiff told them did not have any idea, what they were getting themselves involved in.

130. On February 18, 2010 Plaintiff placed a telephone call to Mr. Schupack, and informed him Defendant Grover was more arrogant than before August 3,2009, and was right back at his habit of Harassing Plaintiff. Plaintiff told Mr. Schupack he was trying to figure out what to do to bring an end to Grover's Harassment. While talking with Mr. Schupack, Plaintiff saw Defendant Pascal walking to the entrance of the Thalberg Building, Plaintiff told Mr. Schupack, he had just seen the answer to his problem, walking towards the Thalberg Building. Plaintiff told Mr. Schupack, he would call him later and let him know if it was the answer to his situation and problem.

131. At 8:35 AM February 18, 2010, Plaintiff went to the 3rd floor office of Defendant Pascal. Pascal was in her office talking with an assistant, when Plaintiff knocked and was invited in by Pascal. Plaintiff; told Pascal although he had been in her office in the past and they had spoke a number of times in the past while working on her office telephones. Plaintiff wanted to officially introduce himself to Chairman Pascal, on this visit, because Plaintiff was going to inform Pascal about an Extremely Serious Situation, and Problem in her & Lynton's Human Resources Department, that they seriously needed to get fixed, they're broken HR Department. Plaintiff told Pascal; if it was not handled correctly it would result in the possibility of Pascal being removed from the Chair, she occupied as one of the Co-Chairman. I then told Pascal my name Michael David Moore and that I am an Employee in the Telecommunications Department, Pascal acknowledged she knew who I was. Pascal asked the assistant to exit her office and close the door behind her. Plaintiff told Pascal before I say what it is that I came to tell you, I want you Ms. Pascal to answer two questions for me before I say anything, Pascal agreed. I asked Pascal: when she and Lynton held an all hands meeting on stage 15 the year before, did they mean, what they had told the employees?, or had the employees been given, just another line of, {Pascal finished Plaintiffs' question saying Bull Sh t}, Plaintiff said yes those were the words I was going to use. Defendant Pascal pull her hands on Plaintiff shoulders and told Plaintiff; they meant everything they had said. Plaintiff told Defendant Pascal; he had hoped they had. Plaintiff asked Pascal; in the 15 to 18 months since that all hands meeting, how many employees in this Company, have said or used the word, CODE to either Lynton or her? Defendant Pascal with a grinning smile, patted Plaintiff on his back, and said: Michael, YOUR THE FIRST, Plaintiff told Pascal he thought he would be, the first, Pascal said, let's talk!

132. Plaintiff told Defendant Pascal, he had been harassed for 21 years by Executive Director Jeff Grover, that Grovers' constant Harassment, caused Plaintiffs' Mental State of Mind to be so Stressed, Plaintiff was near Suffering a Complete Psychological & Nervous Breakdown.When Plaintiff, went to the Human Resources Department August 3, 2009, and filed a Workers Compensation Claim against Sony Pictures. Plaintiff told Defendant Pascal, his condition was so serve, company nurse, Defendant Saporito, had stayed with him, in Defendant Felders office and checked Plaintiffs' blood pressure and heart rate. Plaintiff told Pascal he had followed Defendant Felders instructions, and he had called Felder 2 times from his home with additional incidents of harassment by, Defendant Grover. Defendant Pascal was told the second time Plaintiff called Defendant Felder on August 6, Plaintiff was asked to drive into the Studio, HR wanted Plaintiff to see a Doctor. Plaintiff told Pascal he had spent 3 hours and 45 minutes in a HR Conference Room with Dr. Michael Zona a Psychiatrist. Plaintiff told Defendant Pascal, Zona had warned Plaintiff that his condition was so Severe, he should not wait for the Workers Compensation Medical Benefits to start. Zona told Plaintiff; in his Professional Opinion as a Medical Doctor, Plaintiffs' Mental & Psychological Condition was so Severe & Serious, Zona, said he believed Plaintiff to be one thread away from having a complete nervous psychological & mental breakdown, and if the thread breaks, Zona said; he was not sure if, Plaintiff, could ever come back from it. Zona told; Plaintiff, he needs to find a Psychiatrist tomorrow, because Plaintiff needs to begin treatment immediately. Plaintiff started getting chocked up, and was having difficultly telling Pascal what he had been through, and to have had everything Covered Up by SPE, as if none of this mattered, compounded Plaintiff's Mental Anguish made it worse. Pascal told Plaintiff it was okay, take your time. Pascals said; she knew what he was going through, she had been there herself.

133. Plaintiff told Pascal; when Defendant Zona, asked Plaintiff his last question, Plaintiff knew everything he told Defendant Felder, was going to get covered up. How he and his peers had suffered at Grover's whim and for Grover's sheer pleasure. Plaintiff told Pascal; 5 days after he had been in Felder's office, the nurse, Defendant Saporito sitting next to him, checking his Blood Pressure and Heart Rate because Saporito was afraid Plaintiff might have a Heart Attack or Stroke, Plaintiff had a Nervous Breakdown and was lockup up in the Psychiatric Ward at Long Beach Community Hospital. Plaintiff waited 6 & months, for the HR Investigation to be completed, when Plaintiff called Felder, and she told Plaintiff, the Investigation ended 3 months earlier, the tells, Plaintiff, it slipped her mind to call Plaintiff, and inform him the HR Investigation had ended. He is told he needs a signed release from his Psychiatrist in order to return to work. Then fifteen minute into his first day back Felder asks him what he thinks about all the changes that HR has made in the Telecommunications Department, He tells Felder she has got to be kidding him Felder says she is sorry what could she have been thinking? Felder asking, him what he thought of the changes, Felder told Plaintiff; she will call Plaintiff on Friday February 5th and Felder did not call Plaintiff. Assigned Turner building demolition, through the course demoing the Turner Building, Grover, Harassed, and caused Plaintiff to Suffer, the very same Mental Anguish, he complained to Felder, August 3, 2009. Wiped out the Mental HEALTH Recovery, paid with CLAIM CHECKS ISSUED to MEDICAL PROVIDERS, by MOTION PICTURE HEALTH AND WELFARE FUND INSURANCE {MPHWFI}, and Bi-Weekly ISSUED STATE DISABILITY CHECKS, SDI TAX PAYERS {SDITP}, of CALIFORNIA. Plaintiff alleges the {SDITP} & {MPHWFI} were FRAUDULANTLY CHEATED, DENIED & SHORT CHANGED, by not RECEIVING the BENIFIT of WHAT THEY PAID. For HORRENDOUS PERSONAL FAILURES of EXECUTIVE FIDUCIARY DUTIES & and ORAL CONTRACT to Plaintiff, Defendant Grover & his FAMILY are REWARDED by way of a SECURED LIFE TIME RETIREMENT, {MPHWFI}, HEALTHCARE INSURANCE, Two Monthly Pension Checks {MPHWF} & {SSI}, PLUS a 401k with over [Five Hundred Thousand Dollars, $500.00.00] Invested. SECURE, having done this to him, because some Lawyer that is Ignorant of the Law says Grover can turn himself into a victim because he fell through the cracks and was not given Managerial Training he did not know he could not use Racial Slurs, already he gets locked up As well as every thing Plaintiff has been through since that was going to be COVERED UP.

134. Plaintiff told Pascal that Felder asked Him fifteen minutes after he return back to work after having been Plaintiff told Defendant Pascal, the HR Department had Stonewalled, Robert Thompson, the Defendant ESIS Claims Specialist and Mr. Thompson had notified the Risk Management Department of ACE AMERICAN INSURANCE COMPENY. ACE AMERICAN INSURANCE COMPANY notified its' Parent Company ACE LIMITED. Mr. Evan Greenberg the Chairman of ACE LIMITED held an emergency meeting, and at the end of that meeting, Plaintiff was informed by Mr. Greenberg, his company was no longer going to wait for Sony Pictures to accept or deny Plaintiffs' Workers Compensation Injury, ACE LIMITED had accepted the injury and was going to settle with Plaintiff. Once the claim was settled, ACE LIMITED was going to send a Press Release to the News Wire, then turn over all the documents it had to the U. S. EEOC, and California State Department of Fair Housing & Employment. So they could Investigate Sony Pictures and Prosecute for covering up the accusations Plaintiff had made against Executive Director Jeff Grover to Abby Felder. Plaintiff told Pascal, he had been told, the Attorney General of California, or the U.S. Attorney General would probably end up Prosecuting the SPE Executives for their Involvement in the cover up. Plaintiff told Pascal, when he with drew his Workers Compensation Claim against Sony Pictures, he had prevented ACE LIMITED from doing anything that could hurt Sony Pictures. Plaintiff had sealed the Documents in a File, that is now a Pending Workers Compensation Claim, that only Plaintiff can close it or have it reopened.

135. Plaintiff told Pascal he had wanted as a child to be a part of this Studio, and after he was discharged from the Navy. He stayed with his Parents, in their home in Kansas City Kansas for a year, then packed what he could in his car, then told his Parents he was going to California. That he was going to go to work at the M-G-M Studios. Where he intends to make movies, so he can make people laugh and forget about all their lifes troubles, for a couple hours. Six months later Plaintiff was working as a Telephone Man in the M-G-M Studios new Telecommunications Department. Six years later I had hired Executive Director Jeff Grover, who said he would be for ever grateful if I hired him. Plaintiff told; Defendant Grover, all he needed to do was to be, LOYAL, FAITHFUL, and HONORABLE to his co-workers, and Defendant Grover gave His Word of Honor to Plaintiff, that He will always live up to these Three Simple Expectations. Defendant Grover broke his word of HONOR the day he announced, to Carl Gollie, David Riveria and Plaintiff, that Studio Manager Defendant Garcia had made him the Foreman, and if he thought any of us threatened or jeopardized his job, he would launch our F---ing Aes out of the Studio. For 21 years that is just what he had tried to do to Plaintiff.

136. Defendant Pascal, said to Plaintiff, you intend to walk out of this Studio on your own terms, don't you, Plaintiff told Pascal, yes my terms, not Defendant Grovers. Defendant Pascal told Plaintiff, he has, Her Word of HONOR, as A BINDING CONTRACT, that as long as She is one the Co-Chairman at Sony Pictures Entertainment Inc. Plaintiff will leave, his Employment with Sony Pictures Studios, on His own TERMS and his own CONDITIONS. Plaintiff said; Thank You to Defendant Pascal, that he will hold Pascal, To Her Given Word of HONOR.

137. Defendant Pascal told Plaintiff, she was grateful, he had come to her with this information, rather then to Air the Companys Dirty Laundry in Public. Pascal said Plaintiff had Clearly Demonstrated and Proved to Her, She knows without a Doubt, at least at Least One Loyal Faithful Employee in the Entire Company, who she knows will go to the mat for her, and will do what ever it is he thinks he needs to protect Her and Sony Pictures. Plaintiff told Pascal, he would have her back along as She does Her Job & Keeps Her Fiduciary Duty to the Chair, that is Sony Pictures Studios. Plaintiff said, if she ever did lose Plaintiff's having her Back, then has failed this Company. Plaintiff also told Defendant Pascal that from the lowest paid Janitor Employee to the Highest Paid Executive Employee everyone in this needs to understand this is not an American Company, it is a Japanese Company, and I do not believe there is an American Executive that could bring themselves to do what a Japanese Executive has to do in Japan when they Failed in they're Fiduciary Duty to a Company in Japan.

138. Plaintiff told Pascal; if the information in this file gets outside the walls of the studio, it would be the Executives, who will be to blame. Plaintiff told Pascal; he intends to take its' secret to his grave. Plaintiff told Pascal; his pending WCC is a Pandoras Box, and if that box is opened for the wrong reason, it will, without a doubt be the SPE Senior Executive Management Team's worst nightmare, and it will be a nightmare for them, that will never end! Plaintiff told Pascal; he does expect Lynton, Weil, & Pascal, to do what should have already been done, to terminate Grover. Defendant Rose or one of his Subordinates, should have terminated him in August of 2009. After they have terminated Grover, all three of them need to come to Plaintiffs, Work Station in the Thalberg basement no later than 3:00pm today. Plaintiff, does expect to hear, Grover has finally been terminated, and is no longer an employee of Sony Pictures. Plaintiff told Pascal; when he knows, Grover has been terminated, Plaintiff will pick up the telephone, call Mr. Greenberg, and tell him, he is ready to Settle, his Pending Workers Compensation Claim, for ONE DOLLAR. Plaintiff told Pascal; if Mr. Greenberg does not get a phone call from Plaintiff. He will know, Grover is still the Executive Director of SPE's Telecommunications Department and still Plaintiff's Boss. Greenberg would also know they were correct about the SPE Senior Executive ManagementTeam. When 3:00 pm came and went, and Plaintiff and had not been visited by the three SPE Executives, Plaintiff knew what he had been told about the SPE Senior Executives September 24, 2009 was True.

139. February 23, 2010, Plaintiff received a phone call from Vice-President, Defendant Bitar who was Felders boss. Bitar asked, Plaintiff if it was convenient for him to come to HR, for a meeting in the HR conference room, so Bitar and SPE could understand, just what are Plaintiffs' problems at Sony Pictures. Bitar asked Plaintiff if it was all right with Plaintiff, if Bitar had a Psychologist in the meeting with us? Plaintiff told Bitar, he thought it would be a very good idea for a Psychologist to be in the meeting with us. Plaintiff said, maybe the Psychologist could explain to Bitar and SPE, why Grover's harassment has created a problem for Plaintiff, at SPE. The meeting with Bitar and the Psychologist was a little over 2 hours. Plaintiff told Bitar that he had a nervous break down, just as Zona had thought he would, and had been admitted to the Psychiatric Ward of Long Beach Community Hospital. Plaintiff told defendant Bitar, that if Grover is terminated, no one can sue SPE for a dollar, if SPE terminates him once they have been told and made aware of what he has done to the Employees who report to him. Plaintiff told defendant Bitar, that the SPE Legal Department's believe that Grover could somehow turn himself into a victim is DEAD WRONG. Plaintiff said; if Grover is not terminated like he should have been when Plaintiff first came to Felder about Grover. Plaintiff told Defendant Bitar, he knows that when Grover thinks he has gotten away with what he has done to Plaintiff, Grover will not be able to help himself, he will start right back where he left off, and the fact we are here having this meeting now, should be proof enough for SPE. Plaintiff was again told, if Plaintiff makes one more complaint about Grover HR, will terminated Grover on the Spot. This was said to Plaintiff by Bitar, with the Psychologist present. Plaintiff asked Bitat, why is this complaint not getting him fired on the spot? Since it had been, just a little more than five weeks ago that Felder told Plaintiff during our telephone conversation, when Plaintiff had called and talked with her in mid-January, When Felder said; just one complaint about Grover, from Plaintiff. Defendant Bitar, did not havean answer to that question, for Plaintiff. 140. In the presence of the Psychologist, Plaintiff was told, by Bitar, that he had made it crystal clear to Grover, and Grover understood completely without any doubt, he was never again to say a word about Plaintiff's Attendance, if he did Grover would find himself Terminated. In the presence of the Psychologist, Plaintiff was told, by Defendant Bitar, that he had made it Crystal Clear to Grover, and Grover understood completely without any doubt, he was never again to have a conversation or discussion about Plaintiff's Personal Business with anyone, if Grover did he would find himself Terminated. Plaintiff was told, the only person Grover was allowed to talk with, about work related issues, was the Foreman, Defendant Groe. Plaintiff was told by defenda