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THE KAUFMAN LAW FIRM, APC CONFORMED COPY ORIGINAL FILED Martin J. Kaufman, Esq. (SBN 155672) superna o cation 2300 Westwood Boulevard, Suite 200 “ Los Angeles, California 90064 OCT 22 2018 ‘Tel: (213) 239-94 Fax @ 735-9409 ‘Shot R Cat, Execuve OtiedClak of Cot Attomeys for Plaintiff, By: Kristina Vargas, Deputy SHANTI HINOJOS SUPERIOR COURT OF THE STATE OF CALIFORNIA, FOR THE COUNTY OF LOS ANGELES ~CENTRAL DISTRICT caseno: 18STCVO1751 PLAINTIFF'S VERIFIED COMPLAINT FOR DAMAGES SHANTI HINOIOS, an individual Plaintiff, 1. Sexual harassment based on gender in violation of the fair employment act and th Civil Rights Act of 1964, 2. Hostile Work environment in violatior California Fair Employment Act. 3. Violation of the interactive process unde the Fair Employment and Housing Act. 4. Violation of taking reasonable steps prevent Harassment and Discrimination it work place under Fair Employment an Housing Act. 5. Wrongful Termination, conspiracy and ion in Violation of Lab. Code § 1102.5, 6. Violation of Cal. Lab. Code §§ 510 an 1198 and Industrial Welfare Commissio: Order No. 12-2001 for Failure to Pay Wages. 7. Claim for Failure to Pay Wages Violation of Cal, Lab. Code §204 8. Claim for violation of California Labor Code Section 226 and Wage Order No, 12. 2001 9. (Penalties for Failure to Pay Overtime Violation of Cal. Lab. Code § 558) 10. (Penalties for Failure to Pay Wages at time of Discharge in Violation of Californi Labor Code Sections 201 and 202 an Penalties — Labor Code §203) 11, Intentional Infliction of Emotional Distress| vs. CROWN MEDIA UNITED STATES, LLC; (DBA “CROWN MEDIA FAMILY NETWORKS"), CROWN MEDIA. HOLDINGS, INC; (DBA “CROWN MEDIA” & “CROWN HOLDINGS”) H&F PRODUCTIONS, LLC; CITI TEEVEE, LLC; WOODY FRASER PRODUCTIONS, INC; (DBA “FRASER PRODUCTIONS”) EXTREME REACH CREW SERVICES, INC; (DBA “EXTREME”), are California Corporations; WOODY FRASER, an individual and DOES 1 through 100, inclusive: Defendants JURY TRIAL DEMANDED T COMPLAINT FOR DAMAGES 26 n 2 COMES NOW Plaintiff SHANTI HINOJOS, an individual, (hereinafter referred to as “Plaintiff” or “HINOJOS”) and hereby complains and alleges against Defendants, and each of them, as follows: PARTIES 1, Plaintiff SHANTI HINOJOS (“Plaintif®” or “Ms. Hinojos”) is, and at all times relevant ‘was, an individual residing in Los Angeles, California, Plaintiff was employed by Defendants, and each of them, from January 24, 2014 until her termination on December 18, 2017 2. On information and belief, Defendant CROWN MEDIA UNITED STATES, LLC is, and at all times relevant was, a corporation duly organized under the laws of the State of Kansas and doing business in the State of California. 3. Defendant CROWN MEDIA UNITED STA’ “Crown Media Family Networks” and maintains a business address at 12700 Ventura Boulevard LLC, is a corporation doing business as #200, Studio ‘ity, CA 91604. On information and belief, William Abbott is the Chief Executive Officer of Crown Media Family Networks. 4. On information and belief, Defendant CROWN MEDIA HOLDINGS, INC. is, and at all times relevant was, a corporation organized under the laws of the State of Delaware and doing business in the State of California. Defendant CROWN MEDIA HOLDINGS, INC. is a corporation doing business as “Crown Media” “Crown Holdings,” and H&F Productions, LLG and maintains its corporate headquarters at 12700 Ventura Boulevard #200, Studio City, C, 91604. On information and belief, William Abbott is the President and Chief Executive Offick of Crown Media/Crown Holdings. Defendants CROWN MEDIA UNITED STATES, LLC, CROWN MEDIA HOLDINGS, INC. and H&F PRODUCTIONS, LLC are hereinafter referred] to as the (“Crown Defendants”) 5. On information and belief, Defendant CITI TEEVEE, LLC (“Citi TeeVee”) is, and at all times relevant was, a corporation organized under the laws of the State of Delaware and doing business in the State of California. Defendant CITI TEEVEE, LLC maintains a business address 2 COMPLAINT FOR DAMAGES, | |Jat 12700 Ventura Boulevard #200, Studio City, CA 91604. On information and belief, Williar 2 || Abbott is the Principal Executive Officer of Citi TeeVee. * | 6. On information and belief, Defendant H&F PRODUCTIONS, LLC (“H&P”) is, and at all times relevant was, a corporation organized under the laws of the State of California and doing * |Ibusiness in the State of California. Defendant H&F maintains a business address at 1270 © || Ventura Boulevard #200, Studio City, CA 91604. On information and belief, William Abbott i the Principal Executive Officer of H&F. 7. On information and belief, Defendant WOODY FRASER (“Fraser”) is, and at all times relevant was, an individual, doing business in the State of California. Fraser resides in the City o| Los Angeles, County of Los Angeles. 8. On information and belief, Defendant WOODY FRASER PRODUCTIONS, INC. (“Fraser Productions”) is, and at all times relevant was, a corporation organized under the laws of the State of California and doing business in the State of California. Fraser Production: 5 ||maintains a business at 11827 Kearsarge Street, Los Angeles, CA 90049, 16 9. On information and belief, Defendant EXTREME REACH CREW SERVICES, INC} under the laws of the Statg \7 ||(Extreme”) is, and at all times relevant was, a corporation organi 8 |lof California and doing business in the State of California at 3601 W. Olive Ave. Suite 5 19 || Burbank, CA 91505. 2 10. The true names and capacities of DOES 1-100, inclusive, whether individual ot *" TT comporate, are presently unknown to Ms. Hinojos, who therefore sue these Defendants by such ® | fictitious names. Plaintiff will amend her complaint to allege her true names and capacities whert °° I! ascertained. Plaintiff is informed and believes, and thereon alleges, that each of the fictitious! * |! named Defendants is responsible for the alleged occurrences and injuries to Plaintiff . 11, Plaintiff is informed, believes, and alleges that, at all times relevant, Defendants, and , ||POES 1-100 named herein, were employees, agents, partners, employers, parents, subsidiaries, » predecessors, successors, assignors, assignees, associates, joint ventures, and/or co-conspirators 3 COMPLAINT FOR DAMAGES