Complaint Unlimited Fee AppliesCal. Super. - 6th Dist.November 23, 2020COSTANZO LAW FIRM, APC 111 W. ST. JOHN STREET, #700 SAN JOSE, CA 95113 KOOONOUI-PUJNr-t NNNNNNNNNHb-‘h-Ah-‘r-Awwh-Ah-kr- OONONM-bUJNi-‘OKDOONONM-PWNHO E-FILED 11/23/2020 3:25 PM Clerk of Court Lori J. Costanzo (SBN 142633) SUPerior Court of CA, lori(a3costanzo-law.com County Of Santa Clara Mallory A. Barr (SBN 3 1723 1) 20Cy373934 I mallorv.barr@costanzo-law.c0m REVIGWGd By: R. Tlen COSTANZO LAW FIRM, APC 111 West Saint John Street, #700 San Jose, CA 951 13 Phone: 408.993.8493 Fax: 408.993.8496 Attorneysfor PlaintiffErick Raich SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA CLARA ERICK RAICH, an individual, Case No.: 20CV373934 Plaintiff, COMPLAINT FOR DAMAGES: VS. 1. Disability Discrimination in Violation 0f Gov’t Code § 12940(a) FOOTHILL-DE ANZA COMMUNITY 2. Failure to Engage in the Interactive Process COLLEGE DISTRICT, a California public in Violation of Cal. Gov’t Code § 12490(n) entity and DOES 1-25, inclusive. 3. Failure t0 Accommodate in Violation of Gov’t Code § 12940(m) Defendants. UNLIMITED JURISDICTION DEMAND FOR JURY TRIAL COMES NOW PlaintiffERICK RAICH (“Plaintiff’ or “Coach Raich”), by and through his attorneys of record herein, Who bring this Complaint against the above-named Defendants, and in support thereof, alleges the following: JURISDICTION AND VENUE 1. This Court has jurisdiction over this action pursuant t0 California Code 0f Civil Procedure (“CCP”) § 410.10 and California Constitution Article VI, Section 5. The amount in 1 Complaint for Damages COSTANZO LAW FIRM, APC 111 W. ST. JOHN STREET, #700 SAN JOSE, CA 95113 \OOONO‘NUILUJNr-t NNNNNNNNNHHh-kr-kr-AHHh-kh-r-A OONONM-PUJNF-‘OKOOONO‘NM-PWNF-‘O controversy, exclusive 0f interest and costs, exceeds the sum of $25,000.00. 2. Plaintiff Erik Raich (“Coach Raich”), at all relevant times, was and is a resident 0f the County 0f Santa Clara. Coach Raich was a part-time faculty member 0f FHDA at its De Anza Community College campus. 3. Coach Raich is informed and believes that the named Defendant FOOTHILL-DE ANZA COMMUNITY COLLEGE DISTRICT (“FHDA”) is a public educational entity based in, and conducting business in, the County 0f Santa Clara. 4. Coach Raich alleges on information and beliefthat Does 1-25 were and are California entities or individuals authorized to d0, and who did business in the County of Santa Clara. 5. Venue is proper pursuant t0 CCP § 395(a) in that the obligations herein sued upon arose, occurred, happened and were and now are due, owing and payable from Defendants t0 Coach Raich in the above-entitled judicial district, in the County 0f Santa Clara, State 0f California. 6. The wrongful acts alleged herein occurred in San Jose, California, and venue is proper in Santa Clara County, State of California. PARTIES 7. PlaintiffERICK RAICH is a thirty-eight (38) year-old man who, at all times alleged in this Complaint, was and is a resident 0f the County 0f Santa Clara, State of California. Coach Raich was an employee, and part-time faculty member, 0fFHDA at its De Anza Community College campus, primarily as the Men’s Baseball Coach. 8. Coach Raich is informed and believes that Defendant FOOTHILL-DE ANZA COMMUNITY COLLEGE DISTRICT (“FHDA”) is a public educational entity based and conducting business in the County 0f Santa Clara. FHDA’S De Anza Community College (“De Anza”) is one of two colleges in FHDA and is located at 21250 Stevens Creek Blvd. in Cupertino, California. 9. Coach Raich is informed and believes and thereon alleges that Defendants, and each ofthem, are “employers” as that term is defined in the California Fair Employment and Housing Act, and under the California Labor Code. 10. At all times mentioned in the causes 0f action into Which this paragraph is incorporated 2 Complaint for Damages COSTANZO LAW FIRM, APC 111 W. ST. JOHN STREET, #700 SAN JOSE, CA 95113 \OOONO‘NUILUJNr-t NNNNNNNNNHHh-kr-kr-AHHh-kh-r-A OONONM-PUJNF-‘OKOOONO‘NM-PWNF-‘O by reference, each and every Defendant was the agent or employee of each and every other Defendant. In doing the things alleged in the causes 0f action into which this paragraph is incorporated by reference, each and every Defendant was acting within the course and scope of this agency or employment, and was acting with the consent, permission, and authorization 0f the remaining Defendants. A11 actions 0f each Defendant alleged in the causes of action into Which this paragraph is incorporated by reference, were ratified and approved by officers and managing agents 0f every other Defendant. 11. Does 1 through 25, inclusive, are sued herein under fictitious names. Their true names and capacities are unknown to Plaintiff. When their true names and capacities are ascertained, Plaintiff Will amend this Complaint by asserting their true names and capacities herein. Plaintiff is informed and believe, that thereon allege, that each of the fictitiously named Defendants is responsible in some manner for the occurrences herein alleged, and that Plaintiff’ s damages as herein alleged were proximately caused by those Defendants. Each reference in this complaint to “Defendant,” “Defendants” or specifically named Defendant refers to all Defendants sued under fictitious names. EXHAUSTION OF ADMINISTRATIVE REMEDIES 12. Plaintiff Erick Raich has exhausted all administrative remedies necessary by filing a charge of discrimination with the Department of Fair Employment and Housing (“DFEH”) and receiving a right-to-sue letter 0n March 23, 2019. The parties agreed t0 toll the statute through November 23, 2020. True and correct copies of Plaintiff s DFEH complaint, right-to-sue notice, and EEOC charge are attached hereto collectively as Exhibit A. FACTS APPLICABLE TO ALL CAUSES Coach Erick Raich turned De Anza’s losing baseball team into a repeat playoff team. 13. In early 2015, De Anza’s baseball team was the lowest-ranked in the entire state of California, With a Win-loss record 0f 3-31 for the 2013-2014 season- the worst in De Anza history. De Anza’s Athletic Director, Kulwant Singh, and Dean of Physical Education Coleen Lee-Wheat, 3 Complaint for Damages COSTANZO LAW FIRM, APC 111 W. ST. JOHN STREET, #700 SAN JOSE, CA 95113 \OOONO‘NUILUJNr-t NNNNNNNNNHHh-kr-kr-AHHh-kh-r-A OONONM-PUJNF-‘OKOOONO‘NM-PWNF-‘O were considering terminating De Anza’s baseball program altogether. Coach Raich was brought in t0 manage this failing and ready-to-be-scrapped program. 14. Despite the odds against him} due to Coach Raich’s drive and talent, he led De Anza’s bottom of the barrel team t0 repeat playoff appearances. In Coach Raich’s first two years, (2014- 2015, 2015-2016, he coached the baseball team in back-to-back playoff appearances and t0 be in play-off contention in his third year With the program (2016-2017), achieving a record of 22-17 (overall average of .564) for the 20 1 6-20 1 7 season. In Coach Raich’s three years managing De Anza’s Men’s Baseball team, nine (9) 0f his players were recruited to Division I college baseball programs, thirteen (13) were recruited t0 Division II, and one player to Division III. 15. In addition to bringing out the best from his athletes on the field, Coach Raich ensured his student-athletes also performed well in the classroom. Throughout his tenure, Coach Raich’s Men’s Baseball Teams” collective academic performance was among the best in De Anza’s entire athletic department. Two of his student-athletes were recognized as Scholar Athletes of the Year. During both the 2016-2017 and the 2017-2018 seasons, his teams earned national accolades from the American Baseball Coaches Association (“ABCA”) When they received the ABCA Team Academic Excellence Award. 16. While under his mentorship and direction, Coach Raich’s players transferred t0 4-year institutions at commendable rates. His dedication to the team and its players was unwavering. Coach Raich was instrumental in reviving De Anza’s struggling program and championing his students. He sacrificed countless hours, along With his own health, t0 make these improvements happen. Coach Raich injured his back While coaching and was denied reasonable accommodations. 17. As part 0f his job duties, Coach Raich was responsible for driving the baseball team to away games in a large bus. This required him t0 hold a Class B License. These roundtrip drives took anywhere from four (4) to ten (10) hours. In between these extended drives, Coach Raich was 1 The team’s Win/loss ratio had been consistently below .500, averaging just .269 overall percentage in the seasons prior t0 Coach Raich’s arrival for the 2014-2015 season. See CCCAA Baseball Archives, California Community Athletic Association (NOV. 20, 2020), https://www.cccaasports.org/sports/bsb/Archives. 4 Complaint for Damages COSTANZO LAW FIRM, APC 111 W. ST. JOHN STREET, #700 SAN JOSE, CA 95113 \OOONO‘NUILUJNr-t NNNNNNNNNHHh-kr-kr-AHHh-kh-r-A OONONM-PUJNF-‘OKOOONO‘NM-PWNF-‘O also required t0 coach, including some double-header matches, resulting in sometimes having 20- hour days of driving and coaching. 18. In January 2016, Coach Raich injured his back while doing field work on De Anza’s baseball field. Consequently, Coach Raich experienced extreme pain in his lower back that radiated down his left leg. Coach Raich was unable t0 walk or sit Without severe pain and discomfort. The pain became so bad he had t0 go t0 the emergency room 0n January 21, 2016. There, he was diagnosed With a herniated lumbar disc. 19. On or around January 25, 2016, Coach Raich notified the Dean of Physical Education and Coach Raich’s direct supervisor, Coleen Lee-Wheat, of his injury. Coach Raich gave Dean Lee- Wheat a doctor’s report. However, Dean Lee-Wheat failed to notify Coach Raich of his right to file a workers’ compensation claim for this workplace injury. Nor did Dean Lee-Wheat initiate a discussion With Coach Raich about how this injury may need t0 be accommodated so that he could return t0 work. 20. With his herniated disc, the baseball team’s hours-long drives became agonizing for Coach Raich. 21. A week after notifying Dean Lee-Wheat 0f his back injury, 0n 0r around February 1, 2016, Coach Raich met With Dean Lee-Wheat. In that meeting, Coach Raich explained how painful it was for him t0 drive the team to and from their away games because ofhis injury. After explaining his injury and the limitations it placed on his driving ability, Coach Raich requested another coach drive the team bus. Dean Lee-Wheat denied his request, claiming Coach Raich was the only baseball coach With a Class B Driver’s License Who could drive the team bus. Coach Raich then requested either: (1) a charter bus, not unlike those used by many other California Community College athletic programs; 0r (2) that his assistant coaches drive the school’s smaller passenger vans instead 0fCoach Raich driving one large bus. Either ofthese requests would have accommodated Coach Raich without requiring another coach t0 have a Class B Driver’s License. Alternatively, Coach Raich requested that either Dean Lee-Wheat 0r the Athletic Director Singh help With the driving responsibilities until another solution could be facilitated. 22. Rather than working t0 find reasonable accommodations 0r accept any 0f Coach 5 Complaint for Damages COSTANZO LAW FIRM, APC 111 W. ST. JOHN STREET, #700 SAN JOSE, CA 95113 \OOONO‘NUILUJNr-t NNNNNNNNNHHh-kr-kr-AHHh-kh-r-A OONONM-PUJNF-‘OKOOONO‘NM-PWNF-‘O Raich’s proposals, Dean Lee-Wheat again refused Coach Raich any accommodation and failed to offer any alternatives. Instead, Dean Lee-Wheat concluded the meeting by telling Coach Raich, “You know, this job doesn’t pay very much and if you don’t think you’re up for the job, you can quit.” Worse, Dean Lee-Wheat failed again t0 notify Coach Raich 0f his right to file a worker’s compensation claim for his injury. 23. De Anza failed t0 take any steps t0 provide reasonable accommodations for Coach Raich’s physical limitations. On notice 0fCoach Raich’s disability due t0 his injury, Defendants had an obligation to engage in the interactive process. They failed t0 do so in a reasonable manner. Instead, Defendants denied Mr. Raich’s repeated requests for reasonable accommodations and failed to make any good-faith attempts to engage in the interactive process t0 determine What measures could be taken to alleviate his pain and discomfort When working. Dean Lee-Wheat’s meetings with Coach Raich failed to notify him of his worker’s compensation rights and demonstrated a refiJsal t0 make any reasonable accommodations, suggesting Coach Raich quit rather than be accommodated. 24. After being refused any accommodation for his back injury to manage his driving responsibilities, Coach Raich developed severe anxiety over his work environment and the unabated pain he experienced When driving t0 away games. He dreaded having t0 sit for extended periods 0f driving and could not take pain pills While he was driving Without jeopardizing the safety 0f his players. In addition t0 his physical pain, Coach Raich endured the added stress of either being responsible for his player’s safe travels while he was in increasing pain or cancelling their amazing season because he could not drive them. 25. On or around February 4, 2016, Coach Raich again told Dean Lee-Wheat that he was in extreme pain due to his back injury. He pleaded with her to have someone else drive the team bus t0 games. Once again, however, Dean Lee-Wheat denied Coach Raich an accommodation. 26. In fact, Dean Lee-Wheat excluded Coach Raich from a walk-through of De Anza’s newly remodeled baseball field because she did not want him “Whining about his needs.” 27. Nonetheless, Coach Raich was fully committed to his team and his coaching job. Accordingly, he endured severe pain and discomfort every time he was forced t0 drive the team bus throughout the 4-month, 30+ game season, each season for the remainder 0f his tenure as De Anza’s 6 Complaint for Damages COSTANZO LAW FIRM, APC 111 W. ST. JOHN STREET, #700 SAN JOSE, CA 95113 \OOONO‘NUILUJNr-t NNNNNNNNNHHh-kr-kr-AHHh-kh-r-A OONONM-PUJNF-‘OKOOONO‘NM-PWNF-‘O Men’s Baseball coach. 28. Coach Raich continues to have back pain t0 this day, along with nerve pain down his left leg, and his left calf is now much smaller than his right calf due t0 atrophy. 29. On or around December 4, 2017, Coach Raich began experiencing an irregular heartbeat With an increased heart rate. He thought he was having a heart attack and immediately drove himself t0 Good Samaritan Hospital Where he was admitted. The doctor told him that he was experiencing heart palpitations due t0 a panic attack. Coach Raich’s panic attack was brought 0n by his stressful working environment. 30. Coach Raich continued to have panic attacks through December 2017 and January 2018 as a result 0f his stressful work environment. Coach Raich endured these panic attacks on his own, fearful of speaking up because ofhow his prior reasonable accommodation requests for his back injury were summarily denied. 3 1. On 0r around May 8, 2019, Coach Raich re-injured his back while lifting chain drags for De Anza’s baseball field. This time, rather than raising the issue with Dean Lee-Wheat, Coach Raich notified De Anza’s Dean 0f Instruction, Eric Mendoza, 0f his injury. Coach Raich then went to the De Anza Health Services Where he was told for the very first time he could file a workers’ compensation claim for his injury. Had Coach Raich known 0f this Coach Raich would have filed this immediately after his first injury t0 his back which occurred two years prior, 0n or about January, 20 1 6 had he known about such remedy, but De Anza failed to notify him 0f this legal rights and failed t0 ever engage in any discussions With him about his injuries. 32. Coach Raich was instrumental in revitalizing a once stagnant baseball program, elevating the team’s standings and championing his players to be successfiJI both on and off the field. Yet, When Coach Raich notified Defendants 0fhis back injury beginning in 20 1 6, instead 0f engaging in the interactive process and/or granting him reasonable accommodations, he was ignored and encouraged to quit a job he loved. For over two years, De Anza failed t0 take any positive steps t0 accommodate Coach Raich’s physical limitations. Indeed, Dean Lee-Wheat excluded Coach Raich from certain activities and failed to notify him 0f his worker’s compensation rights. /// 7 Complaint for Damages COSTANZO LAW FIRM, APC 111 W. ST. JOHN STREET, #700 SAN JOSE, CA 95113 \OOONO‘NUILUJNr-t NNNNNNNNNHHh-kr-kr-AHHh-kh-r-A OONONM-PUJNF-‘OKOOONO‘NM-PWNF-‘O FIRST CAUSE OF ACTION DISABILITY DISCRIMINATION IN VIOLATION OF CALIFORNIA GOV’T CODE §12940(a) (Against All Defendants) Coach Raich re-alleges and incorporates herein by reference all previous allegations set forth in this Complaint as though fully set forth herein. 33. At all times relevant t0 this Complaint, California Government Code section 12900, et seq., and its implementing regulations were in full force and effect. 34. Pursuant t0 California Government Code section 12940(a), it is unlawful for an employer t0 discriminate against an employee because of that employee’s physical or mental disability. 35. Pursuant to California Government Code section 12940(a), Coach Raich’s medical condition qualifies as a disability. 36. At all times relevant to this Complaint, Coach Raich was qualified for and could perform the essential functions 0f his position With Defendants, with reasonable accommodation. Defendants were motivated by discrimination against Coach Raich on the basis of his disability and subjected him to disparate and unfavorable treatment compared to similarly situated employees who did not have disabilities. 37. As a direct and proximate result 0f Defendants’ wrongful conduct, Coach Raich suffered damages including, but not limited t0, loss 0f income and benefits, an exacerbation 0f his medical conditions, emotional distress, and other general damages. 38. As a proximate result ofthe wrongful acts ofDefendants, Coach Raich has been forced t0 hire attorneys to prosecute his claims herein and has incurred and is expected t0 continue t0 incur attorneys’ fees and costs in connection therewith. Coach Raich is entitled t0 recover attorneys’ fees and costs under California Government Code section 12965(b). WHEREFORE, Coach Raich prays for relief set forth below. /// /// /// 8 Complaint for Damages COSTANZO LAW FIRM, APC 111 W. ST. JOHN STREET, #700 SAN JOSE, CA 95113 \OOONO‘NUILUJNr-t NNNNNNNNNHHh-kr-kr-AHHh-kh-r-A OONONM-PUJNF-‘OKOOONO‘NM-PWNF-‘O SECOND CAUSE OF ACTION FAILURE TO ENGAGE IN THE INTERACTIVE PROCESS IN VIOLATION OF CALIFORNIA GOV’T CODE §12490(n) (Against All Defendants) Coach Raich re-alleges and incorporates herein by reference, all previous allegations set forth in this Complaint as though fully set forth herein. 39. At all times relevant t0 this Complaint, California Government Code section 12900, et seq., and its implementing regulations was in full force and effect. 40. Pursuant to California Government Code section 12940(n) it is unlawful for an employer t0 fail to engage in a timely, good faith, interactive process With the employee or applicant to determine effective reasonable accommodations, if any, in response to a request for reasonable accommodation by an employee or applicant with a known physical or mental disability or known medical condition. 41. Pursuant t0 California Government Code section 12926(m), Plaintiff s medical conditions all qualify as physical and mental disabilities. In addition, the Defendants regarded 0r treated Plaintiff as though he had a disability as defined by these sections. 42. At all times relevant to this Complaint, Plaintiff was qualified for, and could perform the essential functions of his position with the Defendants, With reasonable accommodation. 43. The Defendants violated California Government Code section 12940(n) by, among other things, failing to engage in a timely, good faith interactive process and failing to provide reasonable accommodations. Defendants continuously refused t0 engage in the interactive process despite Plaintiff” s requests for reasonable accommodations. 44. As a direct and proximate result 0f Defendant’s wrongful conduct, Plaintiff has suffered damages including, but not limited t0, a loss 0f income and benefits, and has further suffered emotional distress, and other general damages. WHEREFORE, Coach Raich prays for relief set forth below. /// /// /// 9 Complaint for Damages COSTANZO LAW FIRM, APC 111 W. ST. JOHN STREET, #700 SAN JOSE, CA 95113 \OOONO‘NUILUJNr-t NNNNNNNNNHHh-kr-kr-AHHh-kh-r-A OONONM-PUJNF-‘OKOOONO‘NM-PWNF-‘O THIRD CAUSE OF ACTION FAILURE TO ACCOMMODATE IN VIOLATION OF CALIFORNIA GOV’T CODE §12940(m) (Against Defendants) Plaintiff re-alleges and incorporates herein by reference, all previous allegations set forth in this Complaint as though fully set forth herein. 45. At all times relevant to this Complaint, California Government Code section 12900 et seq. and its implementing regulations was in filll force and effect. 46. Pursuant t0 California Government Code section 12940(m) it is unlawful for an employer to fail 0r refuse to provide a reasonable accommodation to an employee with a physical or mental disability. 47. Pursuant t0 California Government Code section 12926(m), Plaintiff‘s medical condition qualifies as a physical disability. In addition, the Defendants regarded 0r treated Plaintiff as though he had a disability as defined by these sections. 48. At all times relevant to this Complaint, Plaintiff was qualified for, and could perform the essential functions of his position with the Defendants, With reasonable accommodation. 49. Defendants failed t0 accommodate Plaintiff When it forced Plaintiff t0 drive the baseball team t0 games and failed to provide alternative drivers or charter a bus, despite Plaintiff’s requests. 50. As a direct and proximate result of Defendant’s wrongful conduct, Plaintiff has suffered damages including, but not limited to, a loss of income and benefits, and has further suffered emotional distress, and other general damages. WHEREFORE, Plaintiff prays for relief as set forth below. /// /// /// /// /// /// 10 Complaint for Damages COSTANZO LAW FIRM, APC 111 W. ST. JOHN STREET, #700 SAN JOSE, CA 95113 KOOOQQUl-PUJNr-t NNNNNNNNNHb-‘h-Ah-‘r-Ab-Hh-Ah-kr- OOQQM-PUJNi-‘OKDOONQM-PWNHO PRAYER . For general damages, according to proof, on each cause 0f action for Which such damages are available; . For special damages, according to proof, on each cause of action for which such damages are available; . For declaratory relief t0 declare Defendants” conduct to be in Violation 0f Coach Raich’s rights; . For pre-judgment and post-judgment interests according to law; . For reasonable attorney’s fees incurred in this action on those causes of action for which such fees are recoverable under applicable law; . For costs of suit incurred in this action; and, . For such other and further relief as the court deems just and proper. DEMAND FOR JURY TRIAL Coach Raich hereby demands a trial by jury on all causes of action alleged herein in the Complaint for Damages. Dated: November 23, 2020 Respectfully submitted, [’flm/fi Loriq. Costanzo Mallory A. Barr Attorneys for Plaintiff ERICK RAICH 1 1 Complaint for Damages EXHIBITA &gm GAVIN NEWSOM GOVERNOR DEPARTMENT 0F FAIR EMPLOYMENT & HOUSING KEVINKISHDIRECTOR 2218 Kausen Drive, Suite 100 | Elk Grove | CA | 95758 (800) 884-1684 (Voice) | (800) 700-2320 ('I'I'Y) | California’s Relay Service at 711 http://www.dfeh.ca.gov | Email: contact.center@dfeh.ca.gov March 23, 2019 Erick Raich 2310 Samaritan Place #1 San Jose, California 951 24 RE: Notice to Complainant DFEH Matter Number: 201903-05559224 Right to Sue: Raich / FoothiII-De Anza Community College District Dear Erick Raich: Attached is a copy of your complaint of discrimination filed with the Department of Fair Employment and Housing (DFEH) pursuant to the California Fair Employment and Housing Act, Government Code section 12900 et seq. Also attached is a copy of your Notice of Case Closure and Right to Sue. Pursuant to Government Code section 12962, DFEH will not serve these documents on the employer. You must serve the complaint separately, to all named respondents. If you do not have an attorney, you must serve the complaint yourself. Please refer to the attached Notice of Case Closure and Right to Sue for information regarding filing a private lawsuit in the State of California. A courtesy "Notice of Filing of Discrimination Complaint" is attached for your convenience. Be advised that the DFEH does not review or edit the complaint form to ensure that it meets procedural or statutory requirements. Sincerely, Department of Fair Employment and Housing J3? _ §TATE QF QALIFQRNIA | ngingg; anggmgr §§rvig§§ gng Hgg§ing Aggncv GAVIN NEWSOM GOVERNOR gig)? DEPARTMENT 0F FAIR EMPLOYMENT & HOUSING KEV'NK'SH'D'RECTOR 1! Tue 8/18/2020 6:18 PM To: Jayne Chipman Cc: Carmen Plaza de Jennings ; Chelsea Hill ; Judy Pham Great, thank you. From: Jayne Chipman Sent: Tuesday, August 18, 2020 5:32 PM To: Lori Costanzo <|ori@costanzo-Iaw.com>; Chelsea Hill Cc: Carmen Plaza de Jennings ; Judy Pham Subject: FW: Erick Raich v De Anza Lori: Chelsea: The District is willing to toll the statute of limitations for filing FEHA claims until November 23, 2020 as requested. Regards, Carmen and Jayne Jayne Benz Chipman | Partner Bug Plaza de Jennings & Chipman LLP 1000 Marina Village Parkway, Suite 110 “Alameda, CA 94501 '3' ‘ I“ ""‘=-‘ Email: ijfilm@pjclflyers.com "I W’ Mam; 510-319-7080 Sent: Monday, August 17, 2020 1:15 PM To: Chelsea Hill Cc: Carmen Plaza de Jennings ; Judy Pham ; Lori Costanzo <|o_ri@costanzo-|aw.com> Subject: RE: Erick Raich v De Anza Hi Chelsea: Thanks for following up. We wi|| have an answer for you tomorrow. Carmen and Jayne Jayne Benz Chipman | Partner Plaza de Jennings & Chipman LLP 1000 Marina Village Parkway, Suite 110 °Alarneda, CA 94501 Email: jc_hipman@pjclawyers.com 'I"' ‘l'l" Mam: 510-319-7080 https://outlook.office.Com/mai|/inboxlid/AAQkADVmOWRmNzA1 LWQONjltNDExNCOSMDIZLWYXYdeZjCSOTZjNgAQAK8ip1 oerVbjDiujv%2F%2BBd . .. 1/4