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NILESH CHOUDHARY, 219425 JOEL RAPAPORT, 248847 CHOUDHARY LAW OFFICE 4010 Foothills Blvd. Suite 103 PM Box 221 Roseville, CA 95747 Telephone (916) 526-2770 Attomeys for Plaintiffs

14-2011 =11474
SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SACRAMENTO

MECHELLE SHERLES; and ROBYN SHERLES Plaintiff, vs. RICH BOYD, et al. Defendant.

Case No.: 34-2011-00114745 DECLARATION OF SUSY DELLACASAMILLS IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANTS MOTION FOR SUMMARYJUDGMENT Date: Time: Dept.: Judge: November 1, 2013 2:00 p.m. 53 Hon. David I . Brown

I, Susy Delia Casa-Mills, Declare as follows: 1. I am over the age of eighteen. If called to testify, I would testify truthfully and

consistently with the foregoing and the following: 2. I am a former employee of SEIU Local 1000. I began employment on September 28,

D e c l a r a t i o n o f Susy D e l i a C a s a - M i l l s 1

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2008, and worked in the Legal Department as Paul Harris' Secretary until November 15, 2012, when I transferred to another department. 3. During my time working with Paul Harris he made statements to me such as... "gay

people make me sick to my stomach, and what is worse is inter-racial, gay couples." These comments were directed toward the relationship that Mechelle Sherles had with Robyn

Sherles.
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4.

I am a close friend of Robyn Sherles and when she and Mechelle Sherlesfileda lawsuit

against SEIU Local 1000, Mr. Harris told me that I could no longer befiiendswith Robyn Sherles. 5. He fiirther made the comment, which was in the context of me wearing a short sleeve

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top, that the following are things that he hates: 1) Women having exposed bra straps; 2) gay people; 3) fat people; and 4) tattoos. I believe that Mr. Harris is biased against women, and these statements illustrate that 6. I recall Paul Harris speaking of a meeting that Brian Schroeder and Paul Harris had

with Mechelle Sherles in Brian Schroeder's office shortly after she made a complaint regarding Richard Boyd. It was within a day or so of the meeting when Harris told me that it

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lasted a long time, and that they "kept Mechelle Sherles in Brian's office much longer than
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was necessary." Paul said... "this was a meeting she would remember for the rest of her life," and then he chuckled. 7. It was my experience with Harris that he would use his authority and position to try

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and intimidate people. He did this to me on many occasions as well. Working for Paul Harris made me feel like a 'puppet' instead of a valued employee, and because I was in fear of losing my job, I did as I was told
Declaration of Susy Delia Casa-Mills 2

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I declare under Penalty of Perjury under the laws of the State of Califomia that the above is true and correct. 17* day, of October, 2013, in Rio Linda, Califomia.

Susv Delia Casa-Mills

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D e c l a r a t i o n o f Susy D e l i a C a s a - M i l l s 3

If,) DROP BO.X

ri" OCT 18 "M
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