brian mcnamara, utla

Summary adjudication is granted on the fifth cause of action for the same reasons stated below as to the seventh cause of action. WebSee the complete profile on LinkedIn and discover Brians connections and jobs at similar companies. Code ; 51 ;subd. Code ; 51 ; Civil Code section 51.7 (the Ralph Act) provides that all persons have the right to be free of violence, or intimidation by threat of violence, committed against their persons, committed because of their political affiliation or any characteristic defined in Civil Code section 51. Ultimately, the work environment and retaliation was so severe and unbearable that I was forced to resign from my employment (in November 2019), she said. I want to make sure the dates are accurate. The Gunman. Ramirez stand for the proposition that a party has to act with or threaten violence or to lead Plaintiff to believe there will be violent acts. (Motion, 23-24.) (Demurrer, 8-9.). Pursuant to Code Civ. at p. Plaintiffs Fifth Cause of Action for Violation of the Bane Act, Civ. Defendants assert that Plaintiffs Ralph Act claim fails because it is undisputed that Defendants did not threaten or commit violence against Plaintiff.

(Id.) The Cole court earlier noted that Plaintiffs verified DFEH Complaint did not name two of the individual defendants in the body of the charge. Civil Case Cover Sheet; Filed by: ASTINE SULEIMANYAN (Plaintiff); As to: UTLA dba UNITED TEACHERS LOS ANGELES, a California Organization (Defendant); BRIAN MCNAMARA (Defendant); CARL JOSEPH (Defendant) et al. Brian McNamara, UTLA's field and organizing director for field services, and Carl Joseph, the organization's representation coordinator/housed teachers App. (Swanson, 232 Cal.App.4th at p. (Motion, 25-27.) I), 59:18-22, 64:13-65:1.) UTLA retaliated against Suleimanyan for complaining by changing her job duties to administrative work, preventing any professional growth on her part, and by writing her up for unfounded accusations, she alleges. (Civ.

(Evidence Code ; 452, subds. As will be discussed below, summary adjudication is granted as to the seventh cause of action because there is no triable issue as to whether Plaintiff experienced threats of violence from McNamara, Joseph or UTLA. A person aggrieved under the Ralph Act may bring a civil action to recover damages, a civil penalty of $25,000, exemplary damages, and an award of attorney fees. (, The court agrees with Plaintiff. Code Red: The Rubicon Conspiracy. (DSS 47-48; Exhibit B (Plaintiff Depo, Vol. WebUTLA DBA UNITED TEACHERS LOS ANGELES A CALIFORNIA ORGANIZATION MCNAMARA BRIAN JOSEPH CARL Attorney/Law Firm Details Plaintiff Attorney

Webbrian mcnamara, utla. AmTrust Financial is part of the Insurance industry, and located in New York, United States. Thus, there are no triable issues of material fact as to Plaintiffs seventh cause of action. Thank you and feel free to call me if you have questions. The court also denied Plaintiffs motion for reconsideration of this ruling. Brian Michael McNamara, 18, of Alexandria, Virginia, passed away Thus, by successive steps of increasingly narrow focus, the test allows discrimination to be inferred from facts that create a reasonable likelihood of bias and are not satisfactorily explained. (Swanson, 232 Cal.App.4th at p. McNamara and Joseph (Individual Defendants) now demur to the fourth cause of action. (FAC 121.) WebA2E Average 2 Elite Sports Athletic Training. Civil Code ;;51.7, 52), (10) breach of employment contract against UTLA only. TOBIN M. LANZETTA VS RAUL HERNANDEZ PAULINO. Cancellation and Refund Policy, Privacy Policy, and (Holland, supra, 154 Cal.App.4th at 942.) Plaintiff testified that this took place around 2018. (Id.) According to Defendants, Plaintiffs claim is untimely because her verified Complaint was signed on April 19, 2019 and attests that the harassment occurred on or before October 12, 2017, which is beyond the one-year time limit allowed under FEHA. at 1453, fn. A judge Wednesday pared a lawsuit brought by the former political organizer for United Teachers Los Angeles against the organization, in which she says she was forced to resign in 2019 due to sexual harassment inflicted by two co-workers, removing both men as defendants in the case. Justin Chambers. Los Angeles Superior Court Judge Richard Burdge Jr. found that neither UTLA nor the two individual defendants Brian McNamara, UTLAs field and organizing director for field services, and Carl Joseph, the organizations representation coordinator/housed teachers representative for field services had violated plaintiff Astine Suleimanyans civil rights because she provided no evidence of any threat of physical violence. ), Third, with respect to Josephs sexually suggestive gestures, Plaintiff testified that it occurred when they were at a staff union retreat dinner. (Id. 4th 940, 946 (Holland) for the argument that equitable tolling applies when a Plaintiff is misled through inaccurate advice from the DFEH. WebWe found 13 records for Brian McNamara in Virginia Beach, Mc Lean and 10 other cities in Virginia. For these reasons, Defendants demurrer to the ninth cause of action is overruled. According to Defendants, Plaintiffs claim is untimely because her verified Complaint was signed on April 19, 2019 and attests that the harassment occurred on or before October 12, 2017, which is beyond the one-year time limit allowed under FEHA. AGE 50s Brian Patrick McNamara Holly, MI View Full Report Aliases Used To Live In Relatives Patrick Brian McNamara Patrick Mc Namara Brian Namara Brian P Mc (Attorney): Name Suffix: Esq. Required fields are marked *.

Further, Holland is inapplicable to this action because the DFEH in Holland made repeated assurances that Plaintiffs complaint would be timely. Defendants request is granted. (Separate Statement in Support of Opposition (PSS), 7-11.) (Id. A: Im not sure if its before, but we were, again, at a Tuesday meeting. Additionally, Plaintiff asserts that the Ralph Act claim is not time-barred because Plaintiff gave Defendants notice of her claims for several years by filing internal UTLA complaints in 2016 and 2017 and by going to the DFEH in 2017 intending to receive a right to sue letter. MyNewsLA.com wont sell your information and you can unsubscribe at any time. Throughout her UTLA employment, the 38-year-old Toluca Lake woman was subjected to severe, pervasive, sexual, derogatory, offensive, physically/verbally abusive and outrageous conduct by McNamara and Joseph, the suit alleges. He stood close behind her during a job-related dinner and often raised his voice in an aggressive, threatening and demeaning manner, toward her, the suit states. ), A breach of the implied covenant of good faith and fair dealing requires something more than breach of the contractual duty itself. .

For these reasons, Defendants demurrer to the fourth cause of action is sustained. In addition, the FAC alleges that Defendants, by and through their employees agents or representatives, particularly defendants JOSEPH and MCNAMARA, engaged in a continuous course of conduct in or around Fall 2015 which allegedly constituted a breach of the implied covenant of good faith and fair dealing contained in Plaintiffs employment contract. Webbrian mcnamara, utla.

First, the court agrees with Plaintiff that Defendants reliance on.

1, 2 AND 3, Cases involving wrongful termination of employees. Civil Code ;;51.7, 52), (10) breach of employment contract against UTLA only.

(Motion, 21-23.) Your email address will not be published. We are hard at work representing professionals The demurrer is otherwise overruled. Exhibit 2 is an email chain between Plaintiff and Mr. Sahota which indicates that on January 8, 2019, Plaintiff inquired into the edits for the complaint she sent a few months ago. In response, Mr. Sahota simply wrote I will give you a call today. (Id.) 1 To Exclude Me Too Evidence And Hostile Work Environment Harassment Evidence Other Than As Relevant To Plaintiffs Remaining Claims to Memorandum In Support Of Motion In Limine No. (Plaintiff Declaration 16.) (Doe v. City of Los Angeles(2007) 42 Cal.4th 531, 550.) The date is accurate, please sign and return. (a), (b).) Log In or Create new account California Courts Of Appeal | Other | Q: Okay. Sign up here for our free newsletters. Proc., ; 437c, subdivision (p)(2): A defendant or cross-defendant has met his or her burden of showing that a cause of action has no merit if the party has shown that one or more elements of the cause of action, even if not separately pleaded, cannot be established, or that there is a complete defense to the cause of action. Code, ; 52.1,subds. (Osten Decl., Exh. She did have evidence that he yelled at her and scolded her behavior in a way she felt inappropriate, but there was no violence or threats of violence proved. (Id. In addition, the Pre-Complaint Inquiry Plaintiff submitted in October 2017stated the form is not a filed complaint., Civil Code, section 52.1 (the Bane Act) allows an individual to sue for damages if a person or persons interferes by threat, intimidation, or coercion, or attempts to interfere by threat, intimidation, or coercion, with the exercise or enjoyment by any individual or individuals of rights secured by the Constitution or laws of the United States, or of the rights secured by the Constitution or laws of this state. (Civ. (DSS 50-63.) The ;Unruh ;Act provides that all persons are entitled to the full and equal accommodations, advantages, facilities, privileges, or services in all business establishments of every kind whatsoever, no matter what their sex . Although Plaintiff asserts that she reasonably relied on inaccurate information from Mr. Sahota and DFEH, Plaintiff has submitted no evidence that Mr. Sahota or DFEH made any inaccurate representations about the timeliness of her Complaint. V SB LAW; Th hng; Trch nhim x hi; Thnh vin; Dch v cung cp. Defendants are to give notice. Brian McNamara Work Experience and Education. (Attorney): Name Suffix: Esq. Mr. Sahota allegedly did not respond to Plaintiff for months. (Id.). Proc., ; 452; see alsoStevens v.Sup. Plaintiff has cited no other authority in support of this proposition. Defendants cite to, In opposition, Plaintiff contends that her Ralph Act claim does not fail because whether a reasonable person would have been intimidated by Defendants actions is a question of fact. Each of the material facts stated shall be followed by a reference to the supporting evidence. Specifically, triable issues exist with regard to whether Plaintiff experienced a threat of violence due to McNamara or Josephs actions.

(DSS 10-11. All that is required of a plaintiff, as a matter of pleading, even as against a special demurrer, is that his complaint set forth the essential facts of the case with reasonable precision and with sufficient particularity to acquaint the defendant with the nature, source and extent of his cause of action. (Rannard v. Lockheed Aircraft Corp. (1945) 26 Cal.2d 149, 156-157.) Pursuant to Code of Civil Procedure, section 437c, subdivision (a): A party may move for summary judgment in any action or proceeding if it is contended that the action has no merit or that there is no defense to the action or proceeding. ), Campbell v. Feld Entertainment, Inc. (N.D. Cal. Obituary, funeral and service information for Brian M. McNamara from Alexandria, Virginia.

Your start date will be September 29, 2015. MOVING PARTIES: Defendants, United Teachers Los Angeles, Carl Joseph and Brian McNamara, MOTION: Defendants Demurrer to the First Amended Complaint. The court agrees with Defendants that the tenth cause of action is insufficiently pled and that Exhibit 1 to the FAC does not contain many of the terms under which she was employed, including a collective bargaining agreement referred in Exhibit 1 to the FAC. . This review is from a person who hired this attorney. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); Check for a confirmation email, and then you're all set with MyNewsLA.com! Your email address will not be published.

at 25:19-26:4.) 210.). March 26, 2023 Posted by jarrel The court agrees. (d).) (a), (b).) Q: And folks like Mr. Sahota are trained that those statutory deadlines are necessary to be met in order to effectively comply with the various DFEH requirements to ultimately bring a a case in in civil court, right? WebTrang ch; Gii thiu.

A defendant or cross-defendant has met his or her burden of showing that a cause of action has no merit if the party has shown that one or more elements of the cause of action, even if not separately pleaded, cannot be established, or that there is a complete defense to the cause of action. (DSS 24-26; Depo Exhibit 210 at DFEH 00010-13. Richard J. Burdge, Jr. in Department 37 Stanley Mosk Courthouse.

Stamps specifically did not consider whether the Unruh Act applied to Civil Code section 51.9. WebREPRESENT ALL TEACHERS IN THE LOS ANGELES UNIFIED SCHOOL DISTRICT WITH THE DISTRICT.

There is no evidence that Mr. Sahota or anyone at DFEH ever represented to Plaintiff that her pre-Complaint inquiry constituted timely filing of her DFEH Complaint. Ninth Cause of Action: Violation of the Ralph Act, Civil Code section 51.7 (the Ralph Act) provides that all persons have the right to be free of violence, or intimidation by threat of violence, committed against their persons, committed because of their political affiliation or any characteristic defined in Civil Code section 51. A: It was maybe over a little bit over 30, I think. 2 TO PRECLUDE EVIDENCE OF TRIAL WITNESS CARL JOSEPH'S 33- YEAR-OLD CONVICTIONS AND RELATED CHARACTER EVIDENCE, Motion in Limine - MOTION IN LIMINE PLAINTIFF'S MOTION IN LIMINE NO.

Mr. Sahota again asked for this information on September 4, 2018. The essence of a contract is the meeting of minds on the essential features of the agreement. (Krasleyv. Superior Court(1980) 101 Cal.App.3d 425, 431.) 1 TO PRECLUDE REFERENCE TO CARLA BARBOZA'S TESTIMONY OR DOCUMENTS, Motion in Limine - MOTION IN LIMINE PLAINTIFF'S MOTION IN LIMINE NO. WebThe Legend of Tillamook's Gold. (DSS 7-11; Depo Exhibit 210 at DFEH 00096-00105.) (1990) 219 Cal.App.3d 1309, 1318. ), In opposition, Plaintiff contends that the tenth cause of action is sufficiently pled because Exhibit 1 to the FAC sufficiently alleges the terms of Plaintiffs employment, including salary, auto allowance, start date, and confirmation of employment related materials such as the employee handbooks and benefit packages. (Opposition, 8-9.). Tenth Cause of Action: Breach of Contract, A cause of action for breach of contract consists of the following elements: (1) the existence of a contract; (2) the plaintiffs performance or excuse for nonperformance; (3) the defendants breach; and (4) the resulting damages to the plaintiff.

An employer defendant may meet its initial burden on summary judgment and require the employee plaintiff to present evidence establishing a triable issue of material fact, by presenting evidence that either negates an element of the employee's prima facie case, or establishes a legitimate nondiscriminatory reason for taking the adverse employment action against the employee. (Id. Thus, the court will address the motion pertaining to the fourth, fifth and seventh causes of action. Ct. (1985) 164 Cal.App.3d 462, 475) or where the opposition is weak (Salasguevara v. Wyeth Labs., Inc. (1990) 222 Cal.App.3d 379, 384, 387). (p)(2).) March 22, 2023. brian mcnamara, utla. TENTATIVE: Defendants motion is granted as to the fourth, sixth and seventh causes of action against. (Civ. Our financial advisor will contact you directly regarding your investment options..

Brian Jude Mcnamaras response: Sylvia, thank you very much for the excellent review. Well send you the latest headlines every morning and every weekday afternoon. 0 Here, the FAC alleges that Plaintiff was employed with Defendants pursuant to a written employment contract, the duties and responsibilities of which was memorialized by a September 11, 2015 offer of employment. A demurrer is an objection to a pleading, the grounds for which are apparent from either the face of the complaint or a matter of which the court may take judicial notice.

965-966.) 1 TO EXCLUDE "ME TOO" EVIDENCE AND HOSTILE WORK ENVIRONMENT HARASSMENT EVIDENCE OTHER THAN AS RELEVANT TO PLAINTIFF'S, Reply - REPLY DEFENDANT UTLAS REPLY MEMORANDUM IN SUPPORT OF MOTION IN LIMINE NO. The trial court sustained the landlords demurrer without leave to amend, observing that the Complaint did not and cannot allege violence or threats of violence against plaintiffs or their property. Additionally, all defendants demur to the sixth, seventh, ninth and tenth causes of action. He also allegedly told her to come sit on big papas lap and asked her for her gum so that he could taste her, and allegedly made make sexual gestures with his tongue toward her. Here, there is no evidence of such assurances.

(b).) CASE NAME: Astine Suleimanyan v. UTLA dba United Teachers Los Angeles, a California Organization, et al. This paperwork includes the W-4 form for state and federal tax withholdings, the 1-9 form that requires documentation to establish your identity and eligibility to work in the U.S., and your emergency contact information form. The Court of Appeal upheld the ruling on the landlords demurrer, stating: [t]here can be no threat of violence without some expression of intent to injure or damage plaintiffs or their property, and there simply was none. (Id. (DSS 14.). 1 TO EXCLUDE ME TOO EVIDENCE AND HOSTILE WORK ENVIRONMENT HARASSMENT EVIDENCE OTHER THAN AS RELEVANT TO PLAINTIFFS REM, Opposition - OPPOSITION DEFENDANT UTLAS OPPOSITION TO PLAINTIFFS MOTION IN LIMINE NO. Defendants notice of motion does not comply with California Code of Civil Procedure, section 437c(f)(1). ; Civil Code section 51.9 provides that a person is liable for sexual harassment under this section if Plaintiff proves that a business, services, or professional relationship between the Plaintiff and Defendant. (Civ. ), Pursuant to California Code of Regulations Title 2, section 10009(d), The filing date of a complaint shall be the date a DFEH office receives a verified complaint, regardless of whether the complaint is verified by the complainant in the office or the complaint is verified elsewhere and transmitted to the office via United States (U.S.) mail, electronically, private carrier mail (e.g., FedEx), facsimile, or hand delivery. ), Awrittencontract must be pled verbatim in the body of the complaint, be attached to the complaint and incorporated by reference, or be pled according to its legal effect. First, the court agrees with Plaintiff that Defendants reliance on Campbell is misplaced, as Campbell discusses whether a motion for summary judgment was properly granted on a Ralph Act claim. Defendants contend that Plaintiffs fourth cause of action fails because Plaintiff failed to timely exhaust administrative remedies. 966.) Minute Order - MINUTE ORDER (FINAL STATUS CONFERENCE), Exhibit List - EXHIBIT LIST SECOND AMENDED JOINT, Witness List - WITNESS LIST SECOND AMENDED JOINT WITNESS LIST, Minute Order - MINUTE ORDER (JURY TRIAL), Notice of Case Reassignment and Order for Plaintiff to Give Notice, Opposition - OPPOSITION PLAINTIFF'S OPPOSITION TO DEFENDANT'S MOTION IN LIMINE NO. 9 (Exhibit 216). Plaintiff recalls that on one occasion, she told him it was disgusting and that he was old enough to be my grandfather. (Id., 22:3-8.

(a).) Code, ; 52.1, . 35.). (Code Civ. A party may move for summary judgment in any action or proceeding if it is contended that the action has no merit or that there is no defense to the action or proceeding. Specifically, Mr. Sahota asked Plaintiff on March 14, 2018 for a copy of her paystub or W-2 form. It is undisputed that Plaintiff did sign a DFEH Complaint until April 19, 2019. (DSS 47-48; Exhibit B (Plaintiff Depo, Vol. Your starting salary will be $7,086.83 per month and you will also receive a monthly auto allowance of $660. 1 To Exclude Me Too Evidence And Hostile Work Environment Harassment Evidence Other Than As Relevant To Plaintiffs Remaining Claims: Name Extension changed from Defendant UTLAs Reply Memorandum In Support Of Motion In Limine No. Public Records Policy. Plaintiff is granted 30 days leave to amend. McNamara allegedly told the plaintiff she was hired because she was pretty and followed her during a work conference, including to the restroom. The filing of the motion shall not extend the time within which a party must otherwise file a responsive pleading. ; Faculty Physicians and Surgeons of LLUSM v. The Superior Court; Pedro Baron et al. The exhaustion of an administrative remedy is a procedural prerequisite to an action at law, and the failure to exhaust it does not divest a trial court of subject matter jurisdiction. [emphasis original] (Holand v. Union Pacific Railroad Co. (2007) 154 Cal.App.4th 940, 945.).

ASTINE SULEIMANYAN VS UTLA DBA UNITED TEACHERS LOS ANGELES, A CALIFORNIA ORGANIZATION, ET AL.

(Gov. Q: Okay. 2 TO PRECLUDE EVIDENCE OF TRIAL WITNESS CARL JOSEPHS 33-YEAR-OLD CONVICTIONS AND RELATED CHARACTER EVIDENCE, 5/13/2022: Reply - REPLY DEFENDANT UTLAS REPLY MEMORANDUM IN SUPPORT OF MOTION IN LIMINE NO. 3-4.) (Id. Further, when Plaintiff was asked if there were any comments or gestures by Joseph after October 2017 that she alleges to be harassment, she testified as follows: After October of 2017, no, but only one time when I was walking down the stairs, I did see him look me up and down and check my behind out. (DSS 48.) The court treat[s] the demurrer as admitting all material facts properly pleaded, but not contentions, deductions or conclusions of fact or law. In particular, the letter sent to Plaintiff prior to the expiration of the filing period sent a draft complaint and advised that a complaint had to be filed within one year of the last act. . (Ibid., emphasis in original.) Why is this public record being published online? By continuing to use this website, you agree to UniCourts General Disclaimer, Terms of Service, at 1509.) (Opposition, 5-6.) On September 7, 2018, Mr. Sahota sent Plaintiff a draft complaint for signature.

at 1449-1456.)

Defendants allegedly breached this agreement by allowing Plaintiff to be discriminated against, sexually harassed, abused, retaliated against and ultimately discharged in November of 2019. (FAC 123.) The court agrees with Plaintiff. (DSS 7.) Caught in the Act. The covenant of good faith and fair dealing imposes a general duty upon each contracting party to perform faithfully and not to deprive the other party of the benefits of the contract. (Floystrupv. City of Berkeley Rent Stabilization Bd. (c). Q: And was he sitting in the chair that he rolled in front of you? Code ; 51 ;subd. ), Fourth Cause of Action: Breach of the Implied Covenant of Good Faith and Fair Dealing, In every contract there is an implied covenant of good faith and fair dealing. Defendants are to give notice. Brian McNamara has been working as a Field and Organizing Director at United Teachers Los Angeles for 6 years. (, Here, the FAC alleges that McNamara was the Field and Organizing Director for UTLA, while Joseph held the position of Representation/Coordinator/Housed Teachers Representative Field Services. (FAC. Civ. Plaintiffs Seventh Cause of Action for Violation of the Ralph Act, Civ. Specifically, Defendants assert that the allegations against Joseph are insufficient because they describe comments and one gesture only, which is insufficient to constitute a threat of physical violence. pimp daddy new orleans death; sculpting with copper wire. WebLynn@hawaiibac.com | Call Today 801-428-7210 . What opportunities were you denied. Code ; 51.9,subd. In addition, even where a complaint is in some respects uncertain, courts strictly construe a demurrer for uncertainty because ambiguities can be clarified under modern discovery procedures. (Khoury v. Malys of California, Inc. (1993) 14 Cal.App.4th 612, 616. The timely filing of an administrative complaint is a prerequisite to the bringing of a civil action for damages under the FEHA. (, Defendants contend that Plaintiffs fourth cause of action fails because Plaintiff failed to timely exhaust administrative remedies. ; ;The essence of a Bane Act claim is that the defendant, by the specified improper means (i.e., ;threat[], intimidation or coercion), tried to or did prevent the plaintiff from doing something he or she had the right to do under the law or to force the plaintiff to do something that he or she was not required to do under the law. ; (King v. State of Cal. UniCourt uses cookies to improve your online experience, for more information please see our Privacy Policy. at 40:20-23. Paparazzi. Select the best result to find their address, phone number, relatives, and public records. (Plaintiff Decl. Email: cruise planner celebrity Hours: 10am - 6pm EST ), Defendants contend that the sixth cause of action is insufficiently pled because the FAC does not allege that Defendants engaged in any actions which threatened Plaintiff and is instead only conclusory as to Defendants alleged threats, intimidation or coercion. (UTLA) Plaintiff also brings this action against Defendant, Brian McNamara (McNamara), who was allegedly the Field and Organizing Director for ULTA as well as Defendant, Carl Joseph. 1 To Exclude Me Too Evidence And Hostile Work Environment Harassment Evidence Other Than As Relevant To Plaintiffs Remaining Claims; As To Parties: removed, DocketUpdated -- Brian Mcnamara (Defendant): First Name changed from BRIAN to Brian; Last Name changed from MCNAMARA to Mcnamara, DocketUpdated -- Carl Joseph (Defendant): First Name changed from CARL to Carl; Last Name changed from JOSEPH to Joseph. For example, Plaintiff testified to the following incident in April or May 2017: Q: Okay. A contract is unenforceable if the parties fail to agree on a material term or if a material term is not reasonably certain. (Lindsay v. Lewandowski(2006) 139 Cal.App.4th 1618, 1623. On February 3, 2021, Plaintiff filed the operative Second Amended Complaint. Plaintiff testified to various incidences she perceived to be abuse from McNamara, beginning in 2015. 29, Exh. In Cole, the Court of Appeal rejected Plaintiffs argument that a letter he wrote to the DFEH prior to filing his administrative charge and in which he alleged discrimination was sufficient to provide the DFEH with information about his claims against each individual. (see SAC, 90-101. Code ; 52.1, subd. (DSS 4; Exh. The motion may be made at any time after 60 days have elapsed since the general appearance in the action or proceeding of each party against whom the motion is directed or at any earlier time after the general appearance that the court, with or without notice and upon good cause shown, may direct. You will be eligible to enroll in the benefits package that includes medical, dental, vision, psychological services and life insurance coverage for you and your eligible dependents. On January 4, 2021, Defendants UTLA, Joseph and McNamaras (Defendants) demurrer was sustained as to the fourth, seventh and tenth causes of action. (Opposition, 9-10.) Plaintiff only recalls this occurring on one occasion. Joseph told Suleimanyan that he wished he was the same age as her because there were things he wanted to do to her, the suit alleges. Q: And some of that training relates specifically to the various statutory deadlines that exists with respect to employees filing complaints with the FEH for discrimination, harassment, retaliation, correct? Ex. (UTLA) Plaintiff also brings this action against Defendant, Brian McNamara (McNamara), who was allegedly the Field and Organizing Director for ULTA as well as Defendant, Carl Joseph.