oOCO~DWABBWHHN
`
`RBBPONOKOKRKOKRDORDRDikekkhmemooNYDBAFSPWDYPNDBOoOO4HBvAF&FWHNH—&§OS
`
`Karen M. Goodman, SBN: 117423
`Shirley Yang, SBN: 334856
`GOODMAN LAW CORPORATION
`3840 Watt Avenue, Building A
`Sacramento, CA 95821
`Telephone No: (916) 643-0600
`Facsimile No: (916) 643-0605
`
`kgoodman@goodman-law.com
`
`Attorneys for Plaintiff ANGELA SORENSON
`
`F
`|
`L
`E
`D
`By
`
`Superior Court of California
`
`County of Butte
`
`07/29/2021
`
`Kimberly Flener, Clerk
`
`Electronically FILED
`
`F
`|
`L
`E
`D
`Deputy
`
`SUPERIOR COURT OF CALIFORNIA
`
`COUNTY OF BUTTE
`
`ANGELA SORENSON,
`
`Plaintiff,
`
`vs.
`
`CHICO IMMEDIATE CARE MEDICAL
`CENTER,INC., a California Corporation;
`
`
`
`Case No. 20CV02333
`
`REQUEST FOR JUDICIAL NOTICE IN
`SUPPORT OF MOTION FOR
`PRELIMINARY INJUNCTIONTO:(1)
`ENJOIN DEFENDANT SMITH FROM
`ANY AND ALL ATTEMPTSTO EVICT
`PLAINTIFF;(2) TO ENJOIN
`
`DOES1 through 50,inclusive.
`
`TRANSFERRING ASSETS
`
`Defendants.
`
`Date: August 25, 2021
`Time: 9:00 a.m.
`Location: Dept. 6
`Judge: Hon. Stephen E. Benson
`
`Complaint Filed: November 25, 2020
`
`Plaintiff ANGELA SORENSONhereby requests that this Court take judicial notice of
`
`the following evidence in support of Defendant’s Opposition to Plaintiff's Motion for Summary
`
`Judgment, pursuant to California Evidence Code Sections 452 and 453 and California Rules of
`
`Court, Rule 3.1306:
`1,
`| Plaintiffs Complaint filed with the above captioned Court on November 25,
`2020, a true and correct copy of which is attached hereto as RJN 1.
`
`
`
`
`
`
`
`
`
`RJN ISO Motion for Preliminary
`Injunction to Enjoin Defendant from 1)
`Attempts to Evict Plaintiff; 2)
`Transferring Assets
`
`Page - 1
`
`Sorenson v Smith, et al.
`Case No.: 20CV02333
`
`
`
`
`
`

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`2.
`2.
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`Governor's Executive Order N-28-20, Covid-19 Eviction Moratorium, a true and
`Governor's Executive Order N-28-20, Covid-19 Eviction Moratorium, a true and
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`correct copy of which is attached hereto as RJN 2.
`correct copy of which is attached hereto as RJN 2.
`
`3.
`3.
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`Plumas County Complaint filed against Defendant Smith on May 7, 2021, a true
`Plumas County Complaint filed against Defendant Smith. on May 7, 2021, a true
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`and correct copy of which is attached hereto as RJN 3.
`and correct copy of which is attached hereto as RJN 3.
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`4.
`4.
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`The Court's July 1, 2021 Order Staying The Current Civil Matter Pending The
`The Court's July 1, 2021 Order Staying The Current Civil Matter Pending The
`
`Completion Of The Plumas County Criminal Case, a true and correct copy of which is attached
`Completion Of The Plumas County Criminal Case, a true and correct copy of which is attached
`
`7 '
`7
`
`hereto as RJN 4.
`hereto as RJN 4.
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`5.
`5.
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`The June 9, 2021 Supplemental Brief In Support Of Defendant's Ex Parte
`The June 9, 2021 Supplemental Brief In Support Of Defendant's Ex Parte
`
`Application To Stay Civil Action Pending Resolution Of Criminal Proceedings Against
`Application To Stay Civil Action Pending Resolution Of Criminal Proceedings Against
`
`Defendant Smith, a true and correct copy of which is attached hereto as RJN 5.
`Defendant Smith, a true and correct copy of which is attached hereto as RJN 5.
`
`6.
`6.
`
`Defendant's July 22, 2021 Status Report Regarding Related Criminal
`Defendant's July 22, 2021 Status Report Regarding Related Criminal
`
`Proceedings, a true and correct copy of which is attached hereto as RJN 6.
`Proceedings, a true and correct copy of which is attached hereto as RJN 6.
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`DATED: July 29, 2021
`~ DATED: July 29, 2021
`
`GOODMAN LAW CORPORATION
`GOODMAN LAW CORPORATION
`
`BY (cid:9)
`
`f e ~
`
`r
`
`Karen M. Goodman, Esq.
`Karen M. Goodman, Esq.
`Shirley Yang, Esq.
`Shirley Yang, Esq.
`
`
`
`Attorneys for Plaintiff
`Attorneys for Plaintiff
`ANGELA SORENSON
`ANGELA SORENSON
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`RJN ISO Motion for Preliminary
`RJN ISO Motion for Preliminary
`Injunction to Enjoin Defendant from 1)
`Injunction to Enjoin Defendant from 1)
`Attempts to Evict Plaintiff; 2)
`Attempts to Evict Plaintiff; 2)
`Transferring Assets
`Transferring Assets
`
`Page - 2 (cid:9)
`Page - 2
`
`Sorenson v Smith, et ul.
`Sorenson v Smith, et al.
`Case No.: 20CV02333
`Case No.: 20CV02333
`
`(cid:9)
`

`

`RJN1RJN1RJN 1
`RJ N 1
`
`

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`Karen M. Goodman, SBI'~I: 117423
`Karen M. Goodman, SBN: 117423
`GUODMAN LAW CURPURATIUN
`GOODMAN LAW CORPORATION
`3840 Watt Avenue, Building A
`3840 Watt Avenue, Building A
`Sacramento, CA 95821
`Sacramento, CA 95821
`Telephone No: (91b) 643-0600
`Telephone No: (916) 643-0600
`Facsimile No: (916) 643-0605
`Facsimile No: (916) 643-0605
`k aodznan cti,~oadinan-la~v.co3n
`kgoodman@goodman-law.corn
`
`Attorneys for Plaintiff ANGELA SC~RENSCIN
`Attorneys for Plaintiff ANGELA SORENSON
`
`s s s sus
`
`...ounty of But
`11 /25/2020
`11/25/2020
`
`L
`E
`
`L
`L
`~.
`
`; ,
`
`,
`
`
`FILED
`
`StTPERIOR COURT OF CALIFORNIA
`SUPERIOR COURT OF CALIFORNIA
`
`CQUNTY OF BUTTE
`COUNTY OF BUTTE
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`ANGELA SORENSON,
`ANGELA SORENSON,
`
`Plaintiff,
`Plaintiff,
`
`vs.
`vs.
`
`CHICO IMMEI7IA.TE CARE MEDICAL
`CHICO IMMEDIATE CARE MEDICAL
`CENTER, INC., a California Corporation;
`CENTER, INC., a California Corporation;
`BRADLEY M. SMITH, an individual; and
`BRADLEY M. SMITH, an individual; and
`DOES 1 through 50, inclusive.
`DOES 1 through 50, inclusive.
`
`(Defendants.
`Defendants.
`
`Case No. 20CV02333
`Case No. 20CV02333
`
`COMPLAINT FOR DAMAGES
`COMPLAINT FOR DAMAGES
`
`1. Sexual Harassment
`1. Sexual Harassment
`Z. SexJGender Discrimination
`2. Sex/Gender Discrimination
`3. FEHA Retaliation
`3. FEHA Retaliation
`4. Failure to Prevent Harassment,
`4. Failure to Prevent Harassment,
`Discrimination, and Retaliation
`Discrimination, and Retaliation
`5, Negligence
`5. Negligence
`5. Sexual Battery
`6. Sexual Battery
`7. Gender Violence
`7. Gender Violence
`8. Assault
`8. Assault
`9. Battery
`9. Battery
`10. Interference with Exercise of Civil
`10. Interference with Exercise of Civil
`Rights
`Rights
`11. Promissory Fraud
`11. Promissory Fraud
`
`Plaintiff ANGELA SORENSON (°`Plaintiff') for her ctsmplaint against Defendant
`Plaintiff ANGELA SORENSON ("Plaintiff') for her complaint against Defendant
`
`BRAT3LEY M. SMITH ("Smith") and Defendant CHICO IMMEDIATE CARE MEDICAL
`BRADLEY M. SMITH ("Smith") and Defendant CHICO IMMEDIATE CARE MEDICAL
`CENTER, INC. ("ICMC") alleges as follows:
`CENTER, INC. ("ICMC") alleges as follows:
`
`NATURE QF THE ACTION
`NATURE OF THE ACTION
`
`1.
`1. (cid:9)
`
`This matter stems from the sexual harassment that Defendant Smith p+erpefirated an
`This matter stems from the sexual harassment that Defendant Smith perpetrated on
`
`Plaintiff over a long period of time, culminating in a sexual assault on July 4, 2020. Defendant
`Plaintiff over a long period of time, culminating in a sexual assault on July 4, 2020. Defendant
`
`Complaint for Damages
`Complaint for Damages
`
`Page - I (cid:9)
`Page - 1
`
`Sorenson v Smzth, et al.
`Sorenson v Smith, et al.
`
`(cid:9)
`(cid:9)
`

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`Smith created an abusive workplace environment where he made Plaintiff entirely dependent on
`Smith created. an abusive workplace environment where he made Plaintiff entirely dependent on
`
`him and then overstepped his bounds as Plaintiff's physician, "partner" in a real property
`him and then overstepped his bounds as Plaintiffs physician, "partner" in a real property
`
`investment and landlord in the home that Plaintiff currently resides.
`investment and landlord in the home that Plaintiff currently resides.
`
`2.
`2.
`
`After Plaintiff complained to ICMC about the sexual assault and requested an
`After Plaintiff complained to ICMC about the sexual assault and requested an
`
`', (investigation as well as protection from Defendant Smith, the Defendants collectively retaliated
`investigation as well as protection from Defendant Smith, the Defendants collectively retaliated
`
`by placing Plaintiff on unpaid leave, disconnecting her from the Company email system, shutting
`by placing Plaintiff on unpaid leave, disconnecting her from the Company email system, shutting
`
`off Plaintiff's Internet service, giving her office away to another employee and instructing other
`off Plaintiffs internet service, giving her office away to another employee and instructing other
`
`ICMC employees to not speak to Plaintiff.
`ICMC employees to not speak to Plaintiff.
`
`3.
`3.
`
`As a direct result of Defendants' conduct, Plaintiff has suffered and continues to
`As a direct result of Defendants' conduct, Plaintiff has suffered and continues to
`
`suffer from wage loss, major depression, post-traumatic stress disorder, severe anxiety disorder,
`suffer from wage loss, major depression, post-traumatic stress disorder, severe anxiety disorder,
`
`panic attacks, and other injuries and losses as described in this Complaint.
`panic attacks, and other injuries and losses as described in this Complaint.
`
`PARTIES, JURISDICTION AND VENUE
`PARTIES. JURISDICTION AND VENUE
`
`Plaintiff is an individual residing in Butte County, California.
`Plaintiff is an individual residing in Butte County, California.
`
`Defendant Smith is an individual residing in Butte County, California.
`Defendant Smith is an individual residing in Butte County, California.
`
`Defendant ICMC is a California corporation and a private medical practice with a
`Defendant ICMC is a California corporation and a private medical practice with a
`
`4.
`4.
`
`5.
`5.
`
`6.
`b.
`
`principal place of business located in Chico, Butte County, California. Upon information and
`principal place of business located in Chico, Butte Coun#y, California. Upon informarion and
`
`belief, Defendant Smith is the sole shareholder of ICMC.
`belief, Defendant Smith is the sole shareholder of ICMC.
`
`7.
`7,
`
`Plaintiff is unaware of the true names and capacities of Does 1 through 50 and sues
`Plaintiff is unaware of the true names and capacities of Does 1 through 50 and sues ~
`
`such individuals by fictitious names. Plaintiff will amend this complaint to show the true names
`such individuals by fictitious names. Plaintiff will amend this complaint to show the true names
`
`and capacities of these individuals when ascertained. Plaintiff is informed and believes that each
`and capacities of these individuals when ascertained. Plaintiffis informed and believes that each
`
`of the named defendants, including each fictitiously named defendant, is liable in some manner
`of the named defendants, including each fictitiously named defendant, is liable in some manner
`
`for the events referred to in this Complaint.
`for the events refereed to in this Complaint.
`
`8.
`S.
`
`Plaintiff is informed and believes that Defendant Smith, at certain times relevant to
`Plaintiff is informed and believes that Defendant Smith, at certain times relevant to
`
`this action, was the agent, employee, shareholder, officer, joint venturer, or joint tartfeasor of
`this action, was the agent, employee, shareholder, officer, joint venturer, or joint tortfeasor of
`
`Defendant ICMC, and that Defendant Smith was acting within the course and scope of such
`Defendant ICMC, and that Defendant Smith was acting within the course and scope of such
`
`agency, employment, partnership, and/or joint venture during those relevant times. Plaintiff
`agency, employment, partnership, and/or joint venture during those relevant times, Plaintiff
`
`further alleges that each of the named defendants, including each fictitiously named defendant, is
`further alleges that each of the named defendants, including each fictitiously named defendant, is
`
`liable in same manner for the events referred to in this Complaint.
`liable in some manner for the events referred to in this Complaint.
`
`Complaint for Damages
`Complaint for Damages
`
`Page - 2 (cid:9)
`Page - 2
`
`Sorenson v Smith, et al.
`Sorenson v Smith, et al.
`
`

`

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`9.
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`Plaintiff is informed and believes and thereon alleges that Defendant Smith and
`Plaintiff is informed and believes and thereon alleges that Defendant Smith and
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`Defendant ICMC are alter egos of each other so that there exists and existed a unity of ownership
`Defendant ICMC are alter egos of each other so that there exists and existed a unity of ownership
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`and interest between the entity and the individual Defendant, such that any individuality and
`and interest between the entity and the individual Defendant, such that any individuality and
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`separateness between them has ceased, and that each such Defendant is the alter ega of the other.
`separateness between them has ceased, and that each such Defendant is the alter ego of the other.
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`The entity Defendant {ICMC) is a mere shell, instrumentality and conduit through which
`The entity Defendant (ICMC) is a mere shell, instrumentality and conduit through which
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`Defendant Smith carried on business, exercising complete control and dominance of such
`Defendant Smith carried on business, exercising complete control and dominance of such
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`business to the extent that any individuality or separateness of the Defendants does nat, and did
`business to the extent that any individuality or separateness of the Defendants does not, and did
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`nat, exist. Adherence to the fiction of the separate existence of the entity Defendant as an entity
`not, exist. Adherence to the fiction of the separate existence of the entity Defendant as an entity
`
`disrinct from Defendant Smith would permit an abuse of the corporate immunities and privileges
`distinct from Defendant Smith would permit an abuse of the corporate immunities and privileges
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`and would sanction fraud and promote injustice and bad faith.
`and would sanction fraud and promote injustice and bad faith.
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`10.
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`Jurisdiction is proper in the State of California because it has general subject
`Jurisdiction is proper in the State of California because it has general subject
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`matter jurisdiction over Plaintiff s claims and no statutory exceptions to jurisdiction eacist.
`matter jurisdiction over Plaintiff's claims and no statutory exceptions to jurisdiction exist.
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`11.
`Venue is proper in Butte County, California because the sexual harassment (except
`11. Venue is proper in Butte County, California because the sexual harassment (except
`
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`for the July 2020 incidents which occurred in Plumas County) occurred there, Defendant Smith is
`for the July 2020 incidents which occurred in Plumas County) occurred there, Defendant Smith is
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`a resident of Butte County and Defendant ICMC's principal place of business is Butte County.
`a resident of Butte County and Defendant ICMC's principal place of business is Butte County.
`
`12.
`12.
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`This matter is timely filed, and Plaintiffhas e~chausted her adnninistrative
`This matter is timely filed, and Plaintiff has exhausted her administrative
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`requirements by obtaining a right to sue letter from the California Department of Fair
`requirements by obtaining a right to sue letter from the California Department of Fair
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`1$
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`Employment and Housing on October 21, 2020. A true and correct cflpy of the Department of
`Employment and Housing on October 21, 2020. A true and correct copy of the Department of
`
`Fair Employment and Housing's right to sue letter is attached as Exhibit A to this Complaint and
`Fair Employment and Housing's right to sue letter is attached as Exhibit A to this Complaint and
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`incorporated herein by reference.
`incorporated herein by reference.
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`GENERAL ALLEGATIONS
`GENERAL ALLEGATIONS
`
`13.
`13.
`
`In August 201 b, Defendant Smith recruited Plaintiff for Defendant ICMC's
`In August 2016, Defendant Smith recruited Plaintiff for Defendant ICMC's
`
`marketing manager position. Defendant Smith is the President, CEO, and Chief Medical Officer
`marketing manager position. Defendant Smith is the President, CEO, and Chief Medical Officer
`
`of Defendant ICMC. Initially, Defendants claimed Plaintiff was working as an "independent
`of Defendant ICMC. Initially, Defendants claimed Plaintiff was working as an "independent
`
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`contractor" but Plaintiff formally became an employee of Defendant ICMC in January 2417.
`contractor" but Plaintiff formally became an employee of Defendant ICMC in January 2017.
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`When Defendant Smith recnzited Plaintiff, she had revealed that she had difficulty enrolling in
`When Defendant Smith recruited Plaintiff, she had revealed that she had difficulty enrolling in
`
`law school because she needed a few college units as a condition for admission to law school.
`law school because she needed a few college units as a condition for admission to law school.
`
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`Defendant Smith offered to pay far Plaintiff's tuition to complete these units. Defendant Smith
`Defendant Smith offered to pay for Plaintiff's tuition to complete these units. Defendant Smith
`
`Complaint for Damages
`Complaint for Damages (cid:9)
`
`Page - 3
`Page - 3 (cid:9)
`
`Sorenson v Smith, et at.
`Sorenson v Smith, et al.
`
`

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`paid approximately $3,000 to Northern Arizona University so that Plaintiff could complete the
`paid approximately $3,000 to Northern Arizona University so that Plaintiff could complete the
`
`required undergraduate courses required for admission into law school. Initially, this payment
`required undergraduate courses required far admission into law school. Initially, this payment
`
`was to be a loan, but later Defendant Smith informed Plaintiff she didn't need to pay it back.
`was to be a loan, but later Defendant Smith informed Plaintiff she didn't need to pay it back.
`
`14.
`14. Commencing in the fall of 2016, Defendants provided Plaintiff with an ICMC-
`Commencing in the fall of 2Q16, Defendants provided Plaintiffwith an ICMC-
`
`owned Dodge Durango for markering meetings. Defendants allowed her to usethe company-
`owned Dodge Durango for marketing meetings. Defendants allowed her to use the company-
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`owned vehicle for personal use in lieu of a car stipend or reimbursing Plaintiff for business-related
`owned vehicle for personal use in lieu of a car stipend or reimbursing Plaintiff for business-related
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`mileage. Defendants approved Plaintiff to use the Durango for ICMC business as well as her
`mileage. Defendants approved Plaintiff to use the Durango for ICMC business as well as her
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`persanat needs. However, Defendant Smith later retaliated against Plaintiff when he saw a
`personal needs. However, Defendant Smith later retaliated against Plaintiff when he saw a
`
`Facebook post where Plaintii~persted photos of a road trip she had taken with a male friend using
`Facebook post where Plaintiff posted photos of a road trip she had taken with a male friend using
`
`the Durango. Suddenly, Defendant Smith insisted that he needed the Durango "back" and that
`the Durango. Suddenly, Defendant Smith insisted that he needed the Durango "back" and that
`
`Plainriff was "welcome" to purchase the Durango, stating that she may be able to afford it with
`Plaintiff was "welcome" to purchase the Durango, stating that she may be able to afford it with
`
`the help of the male friend in the pictures. Plaintiff had even paid $1,000 to replace the tires in
`the help ofthe male friend in the pictures. Plaintiff had even paid $1,Q00 to replace the tires in
`
`this Durango so she was very surprised by this move.
`this Durango so she was very surprised by this move.
`
`15. Defendant Smith was fully aware that Plaintiff was involved in a heated custody
`Defendant Smith was fully aware that Plaintiff was involved in a heated custody
`15.
`
`dispute with her ex-husband, Mark, and needed money to pay far legal bills. In August 2017,
`dispute with her ex-husband, Mark, and needed money to pay for legal bills. In August 2017,
`
`Defendant Smith offered to pay Plaintiff s legal bills as a form of additional eompensarion far the
`Defendant Smith offered to pay Plaintiffs legal bills as a form of additional compensation for the
`
`markering services that Plaintiff was providing. After Defendan# Smith assaulted Plaintiff in July
`marketing services that Plaintiff was providing. After Defendant Smith assaulted Plaintiff in July
`
`2020 and Plaintiff complained about his conduct, he quit paying the bills from Downey Brand
`2020 and Plaintiff complained about his conduct, he quit paying the bills from Downey Brand
`
`LLP (Plaintiffs lawyers). As a result, the Downey Brand law firm has withdrawn from
`LLP (Plaintii~s lawyers). As a result, the Doumey Brand law firm has withdrawn from
`
`representing Plaintiff in her custody case.
`representing Plaintiff in her custody case.
`
`16.
`16.
`
`Foltawing commencement of employment with Defendants, Plaintiff learned that
`Following commencement of employment with Defendants, Plaintiff learned that
`
`ICMC was falling apart in late 2016. Defendant Smith represented to Plaintiff that he needed her
`ICMC was falling apart in late 2016. Defendant Smith represented to Plaintiffthat he needed her
`
`to become his Executive Assistant to reverse the course that ICMC was on. When Defendant
`to become his Executive Assistant to reverse the course that ICMC was on. When Defendant
`
`ICMC' s Office Administrator resigned in April 2017, Defendant Smith asked that Plaintiff
`ICMC's t~i~`ice Administrator resigned in Apri12017, Defendant Smith asked that Plaintiff
`
`expand her duties. Flaintiffundertoak her new duties and managed the office despite Defendant
`expand her duties. Plaintiff undertook her new duties and managed the office despite Defendant
`
`Smith being AWOL for days at a time. (Defendant Smith is a "recovering" alcoholic but has had a
`Smith being AWtJL for days at a time. {Defendant Smith is a "recovering" alcoholic but has had a
`
`difficult time maintaining his sobriety, even ending up with a DUI in 2018, followed by a month's
`difficult time maintaining his sobriety, even ending up with a DLJI in 201$, followed by a month's
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`rehab, and a subsequent arrest for non-compliance, followed by house arrest). Plaintiff found the
`rehab, and a subsequent arrest for non-compliance, followed by house arrest). Plaintiff found the
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`Complaint for Damages
`Complaint for Damages
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`Page - 4 (cid:9)
`Page - 4
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`Sorenson v Smith, et al.
`Sorenson v Smith, et al.
`
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`increased workload demands placed on her at IGMC by Defendant Smith to conflict with her
`increased workload demands placed on her at ICMC by Defendant Smith to conflict with her
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`study demands in Law School. Defendant Smith represented that he would pay for Plaintiff to
`study demands in Law School. Defendant Smith represented that he would pay for Plaintiff to
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`complete her Law School studies later if she took an extended break from schooling to get ICMC
`complete her Law School studies later if she took an extended break from schooling to get ICMC
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`back an track. Plaintiff relied an Defendant Smith's promises in taking an extended leave of
`back on track. Plaintiff relied on Defendant Smith's promises in taking an extended leave of
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`absence from Law School in the spring of 201'7.
`absence from Law School in the spring of 2017.
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`17,
`17.
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`Plaintiff recognized that she didn't have the necessary experience to run Defendant
`Plaintiff recognized that she didn't have the necessary experience to run Defendant
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`ICMC and convinced Defendant Smith to hire a COO. Ultimately, Defendants hired Gregg
`ICMC and convinced Defendant Smith to hire a COO. Ultimately, Defendants hired Gregg
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`Florentin, who despite his professed expertise, clearly was in over his head from the beginning.
`Florentin, who despite his professed expertise, clearly was in over his head from the beginning.
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`Mr. Florentin commenced verbally abusing employees and harassed Plaintiff concerning her
`Mr. Florentin commenced verbally abusing employees and harassed Plaintiff concerning her
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`religious beliefs (she previously was a member of the Latter-Day Saints church, while Mr.
`religious beliefs (she previously was a member of the Latter-Day Saints church, while Mr.
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`Florentin apparently rernains an active member of LDS). Mr. Florentin improperly initiated a
`Florentin apparently remains an active member of LDS). Mr. Florentin improperly initiated a
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`number of personal conversations about Plaintiff's sexual practices, her dating life and touched
`number of personal conversations about Plaintiff's sexual practices, her dating life and touched
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`her inappropriately. When Plaintiff complained to Defendant Smith about Mr. Florentin's
`her inappropriately. When Plaintiff complained to Defendant Smith about Mr. Florentin's
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`conduct, Defendant Smith had a verbal fig11t with ium, and Mr. Florentin suddenly abandoned his
`conduct, Defendant Smith had a verbal fight with him, and Mr. Florentin suddenly abandoned his
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`position.
`position.
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`18. When Plaintiff first started working for Defendant ICMC in 2016, it did not offer
`18. When Plaintiff first started working for Defendant ICMC in 2016, it did not offer
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`sexual harassment training to its employees. It was not until 201$, with Plaintiff's encouragement,
`sexual harassment training to its employees. It was not until 2018, with Plaintiffs encouragement,
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`was there any sexual harassment training offered to ICMC managers and then it was clear by
`was there any sexual harassment training offered to ICMC managers and then it was clear by
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`conduct and words that Defendant Smith did not take the harassment training seriously.
`conduct and words that Defendant Smith did not take the harassment training seriously.
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`19.
`19.
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`Following Mr. Florentin's departure, Defendant Smith advised Plaintiff that she
`Following Mr. Florentin's departure, Defendant Smith advised Plaintiff that she
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`was the only person who could help him run ICMC. Defendant Smith revealed that he eventually
`was the only person who could help him run ICMC. Defendant Smith revealed that he eventually
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`intended to sell the practice but needy to get the practice in good operating shape to do so.
`intended to sell the practice but needed to get the practice in good operating shape to do so.
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`Defendant Smith revealed that he planned on {or already had) naming Plaintiff as a beneficiary in
`Defendant Smith revealed that he planned on (or already had) naming Plaintiff as a beneficiary in
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`his will and represented she would "always be taken care of." He also claimed to have named
`his will and represented she would "always be taken care of" He also claimed to have named
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`Plaintiff s son in his will and claimed to have a college fund set up for him. However, Defendant
`Plaintiff's son in his will and claimed to have a college fund set up for him. However, Defendant
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`Smith said that he canld not officially give Plaintiff a salary increase because that would damage
`Smith said that he could not officially give Plaintiff a salary increase because that would damage
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`the morale of other ICMC staffmembers who would accuse him of favoritism. As a result,
`the morale of other ICMC staff members who would accuse him of favoritism. As a result,
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`Plaintii~s salary was considerably below market rates far her skills and experience, Instead,
`Plaintiff's salary was considerably below market rates for her skills and experience. Instead,
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`Complaint for Damages
`Complaint for Damages
`
`Page - 5 (cid:9)
`Page - 5
`
`Sorenson v Smith, et al.
`Sorenson v Smith, et al.
`
`

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`Defendant Smith devised a scheme of providing additional compensation in the form of
`Defendant Smith devised a scheme of providing additional compensation in the form of
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`Defendants paying for living expenses for Plaintiff in exchange far the additional responsibilities
`Defendants paying for living expenses for Plaintiff in exchange for the additional responsibilities
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`she undertook to run the company. Following Defendant Smith's assault and Plainriff's
`she undertook to run the company. Following Defendant Smith's assault and Plaintiff's
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`complaint about the physical attack, Defendants have cut-off the payment of this additional
`complaint about the physical attack, Defendants have cut-off the payment of this additional
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`compensation in retaliation for Plaintiff's complaints about Defendant Smith's assault.
`compensation in retaliation for Plaintiff's complaints about Defendant Smith's assault.
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`At the time she began working for ICMC, Plaintiff was renting a house in a run-
`20.
`20. At the time she began working for ICMC, Plaintiff was renting a house in a run-
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`down neighborhood and the landlord refiused to do anything about protecting her and her young
`down neighborhood and the landlord refused to do anything about protecting her and her young
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`son from a neighbor who was a registered sex offender. Defendant Smith offered to find and pay
`son from a neighbor who was a registered sex offender. Defendant Smith offered to find and pay
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`for a better living environment as additional compensation for Plaintiffs role as the Chief
`for a better living environment as additional compensation for Plaintiff's role as the Chief
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`Operating Officer. In November 201?, Defendant Smith located a house in a nice neighborhood
`Operating Officer. In November 2017, Defendant Smith located a house in a nice neighborhood
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`and had Plaintiff look at it. Defendant Smith had already completed a rental application. Plaintiff
`and had Plaintiff look at it. Defendant Smith had already completed a rental application. Plaintiff
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`had made it clear that while Defendant Smith could stare his bike there, she didn't want
`had made it clear that while Defendant Smith could store his bike there, she didn't want
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`Defendant Smith to assume he had the right to stay there. Plaintiff expressed concern that the
`Defendant Smith to assume he had the right to stay there. Plaintiff expressed concern that the
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`home was "too much" but Defendant Smith assured her that he would pay far it and that she
`home was "too much" but Defendant Smith assured her that he would pay for it and that she
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`"deserved it" for all the great work she was doing for ICMC. Reluctantly, Plaintiff agreed since
`"deserved it" for all the great work she was doing for ICMC. Reluctantly, Plaintiff agreed since
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`she knew she needed. to be out of the rental home she was in. Defendant Smith signed the lease
`she knew she needed to be out of the rental home she was in. Defendant Smith signed the lease
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`agreement far 468 Southbury Lane with Plaintiff on I'~overnber 13, 2017. Plaintiff did not want
`agreement for 468 Southbury Lane with Plaintiff on November 13, 2017. Plaintiff did not want
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`Defendant Smith's name on the lease since she was concerned that it would hurt her custody and
`Defendant Smith's name on the lease since she was concerned that it would hurt her custody and
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`support litigation with. her ex-husband. Defendant Smith ignored Plaintiff's concerns {even
`support litigation with her ex-husband. Defendant Smith ignored Plaintiff's concerns (even
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`though it resulted in Plainriff having to repay to her ex-husband substantial back child support).
`though it resulted in Plaintiff having to repay to her ex-husband substantial back child support).
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`Defendants paid the rent at 468 Southbury Lane as additional compensation far Plaintiffls work
`Defendants paid the rent at 468 Southbury Lane as additional compensation for Plaintiff's work
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`for ICMC.
`for ICMC.
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`As further "additional compensation," Defendant Smith gave Plaintiffhis personal
`21. As further "additional compensation," Defendant Smith