`
`
`
`DANIELLE OCHS, CA Bar No. 178677
`danielle.ochs@ogletree.com
`CARA F. BARRICK, CA Bar No. 303107
`cara.barrick@ogletree.com
`SHANNON R. CLAWSON, CA Bar No. 273699
`shannon.clawson@ogletree.com
`SEAN CHOI, CA Bar No. 312256
`sean.choi@ogletree.com
`OGLETREE, DEAKINS, NASH, SMOAK &
`STEWART, P.C.
`One Embarcadero Center, Suite 900
`San Francisco, CA 94111
`Telephone:
`415-442-4810
`Facsimile:
`415-442-4870
`
`Attorneys for Defendants
`META PLATFORMS, INC., ETHAN HILLEL
`LUBKA, and IAN ROBERT LAIKS
`
`
`ELECTRONICALLY
`F I L E D
`
`Superior Court of California,
`County of San Francisco
`03/05/2025
`Clerk of the Court
`BY: SANDRA SCHIRO
`Deputy Clerk
`
`SUPERIOR COURT OF THE STATE OF CALIFORNIA
`FOR THE COUNTY OF SAN FRANCISCO
`
`
`TALIA KENNEDY,
`Plaintiff,
`
`vs.
`META PLATFORMS, INC.; ETHAN HILLEL
`LUBKA; IAN ROBERT LAIKS; and
`DOES 1 to 100, inclusive,
`Defendants.
`
`
`
`
`
`
`
`
`
`
`
`
`Case No. CGC-23-604370
`REQUEST FOR JUDICIAL NOTICE IN
`SUPPORT OF DEFENDANTS META
`PLATFORMS, INC. ETHAN LUBKA AND
`IAN LAIKS’ MOTION FOR SUMMARY
`JUDGMENT, OR IN THE ALTERNATIVE,
`SUMMARY ADJUDICATION
`
`Date:
`May 29, 2025
`Time:
`9:00 a.m.
`Location: Dept. 302
`
`Action Filed: January 31, 2023
`Trial Date:
`June 30, 2025
`
`
`
`Case No. CGC-23-604370
`
`REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT,
`OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION
`
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`
`TO THE COURT, ALL PARTIES AND THEIR COUNSEL OF RECORD:
`NOTICE IS HEREBY GIVEN that Defendants Meta Platforms, Inc., Ethan Lubka and Ian
`Laiks (collectively, the “Defendants”) hereby respectfully request, pursuant to California Evidence
`Code sections 452 and 453 and California Rule of Court Rule 3.1306, that the Court take judicial
`notice of the following documents, true and correct copies of which are attached to this Request, in
`support of Defendants’ Motion for Summary Judgment Or, in the Alternative, Summary
`Adjudication as to Claims by Plaintiff Talia Kennedy (“Motion”):
`Exhibit A: Complaint of Discrimination against Meta Platforms, Inc. Ethan Lubka, Ian
`Laiks, et al, filed by, or on behalf of, Plaintiff Talia Kennedy (“Plaintiff”) with the California Civil
`Rights Department (“CRD”), CRD Matter Number 202301-19536130, on January 30, 2023.
`Exhibit B:
`CRD Notice of Case Closure and Right to Sue dated January 30, 2023 to
`Plaintiff in relation to CRD Matter Number 202301-19536130.
`Exhibit C: Amended Complaint of Discrimination against Meta Platforms, Inc. Ethan
`Lubka, and Ian Laiks, filed by, or on behalf of, Plaintiff with the CRD, CRD Matter Number 202301-
`19536130, on January 31, 2023.
`Exhibit D: CRD Notice to Complainant’s Attorney dated January 31, 2023 to Plaintiff in
`relation to CRD Matter Number 202301-19536130.
`Exhibit E:
`Complaint of Discrimination against Meta Platforms, Inc., filed by, or on
`behalf of, Plaintiff with the CRD and Equal Employment Opportunity Commission, EEOC Matter
`Number 550-2023-01405, on August 14, 2023.
`Exhibit F:
`EEOC and CRD Notice of Right to Sue dated August 15, 2023 to Plaintiff in
`relation to EEOC Matter Number 550-2023-01405.
`/ / /
`/ / /
`/ / /
`/ / /
`/ / /
`/ / /
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`Case No. CGC-23-604370
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`REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT,
`OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION
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`
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`These requests for judicial notice are made on the grounds that the Evidence Code authorizes
`this Court to take judicial notice of the materials offered by Defendants and that the materials are
`relevant to issues raised in Defendants’ Motion.
`
`DATED: March 5, 2025
`
`OGLETREE, DEAKINS, NASH, SMOAK &
`STEWART, P.C.
`
`By:
`
`
`
`
`
`DANIELLE OCHS
`CARA F. BARRICK
`SHANNON R. CLAWSON
`SEAN CHOI
`
`Attorneys for Defendants
`META PLATFORMS, INC., ETHAN HILLEL
`LUBKA, and IAN ROBERT LAIKS
`
`
`
`
`
`
`
`3
`Case No. CGC-23-604370
`
`88396088.v1-OGLETREE
`REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT,
`OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION
`
`
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`MEMORANDUM OF POINTS AND AUTHORITIES
`
`I.
`
`THE COURT SHOULD TAKE JUDICIAL OF EXHIBITS A THROUGH F
`BECAUSE THEY ARE OFFICIAL ACTS OF AN ADMINISTRATIVE AGENCY
`AND THERE CAN BE NO FACTUAL DISPUTE AS TO THEIR CONTENTS
`The Court may take judicial notice of “[o]fficial acts of the legislative, executive, and judicial
`departments of the United States and of any state of the United States.” Cal. Evid. Code § 452(c).
`These “official acts” include records, reports, and files of administrative agencies. SC Manufactured
`Homes, Inc. v. Liebert (2008) 162 Cal. App. 4th 68, 82, fn.8; Rodas v. Spiegel (2001) 87 Cal. App.
`4th 513, 518; Fowler v. Howell (1996) 42 Cal. App. 4th 1746, 1750. Exhibits A through F of this
`Request are records, reports, and files of administrative agencies, specifically, the CRD (previously
`known as the Department of Fair Employment and Housing [“DFEH”]) and EEOC, for which the
`Court may take judicial notice. See Auburn Woods I Homeowners Ass’n v. Fair Employment and
`Housing Com’n (2004) 121 Cal. App. 4th 1578, 1591 (taking judicial notice of DFEH records).
`Copies of these records were obtained on behalf of Defendants through the submission of a
`Public Records Request to the CRD and EEOC and were also served upon Defendants by Plaintiff.
`The CRD and EEOC Complaints (attached as Exhibits A, C and E) were executed by or on behalf
`of Plaintiff on January 30, 2023, January 31, 2023 and August 14, 2023, and the Right to Sue Notices
`(attached as Exhibits B, D and F) were sent to Plaintiff or her attorneys on January 30, 2023, January
`31, 2023 and August 15, 2023, respectively. Accordingly, Defendants respectfully request that the
`Court take judicial notice of the documents. Cal. Evid. Code § 452(c); Cal. Evid. Code § 452(h)
`(Judicial notice may be taken of “facts and propositions that are not reasonably subject to dispute
`and are capable of immediate and accurate determination by resort to sources of reasonably
`indisputable accuracy”); Cal. Evid. Code § 453 (“The trial court shall take judicial notice of any
`matter specified in Section 452 if a party request it and (a) [g]ives each adverse party sufficient notice
`of the request, through the pleadings or otherwise, to enable such adverse party to prepare to meet
`the request; and (b) [f]urnishes the court with sufficient information to enable it to take judicial notice
`of the matter.”).
`
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`Case No. CGC-23-604370
`
`REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT,
`OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION
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`
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`II.
`
`CONCLUSION
`For the foregoing reasons, Defendants respectfully request that this Court take judicial notice
`of the documents attached hereto as Exhibits A to F.
`
`DATED: March 5, 2025
`
`OGLETREE, DEAKINS, NASH, SMOAK &
`STEWART, P.C.
`
`By:
`
`
`
`
`
`DANIELLE OCHS
`CARA F. BARRICK
`SHANNON R. CLAWSON
`SEAN CHOI
`
`Attorneys for Defendants
`META PLATFORMS, INC., ETHAN HILLEL
`LUBKA, and IAN ROBERT LAIKS
`
`
`
`
`
`5
`Case No. CGC-23-604370
`
`REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT,
`OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION
`
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`EXHIBIT A
`EXHIBIT A
`
`

`

`COMPLAINT OF EMPLOYMENT DISCRIMINATION
`BEFORE THE STATE OF CALIFORNIA
`Civil Rights Department
`Under the California Fair Employment and Housing Act
`(Gov. Code, § 12900 et seq.)
`
`In the Matter of the Complaint of
`Talia Kennedy
`
`CRD No. 202301-19536130
`
`Complainant,
`
`vs.
`
`Meta Platforms, Inc.
`1 Hacker Way
`Menlo Park, CA 94025
`
`Meta Platforms, Inc.
`1601 Willow Road
`Menlo Park, CA 94025
`
`Meta
`1 Hacker Way
`Menlo Park, CA 94025
`
`Ethan Lubka
`1 Hacker Way
`Menlo Park, CA 94025
`
`Ian Laiks
`1 Hacker Way
`Menlo Park, CA 94025
`
`-1-
`Complaint – CRD No. 202301-19536130
`
`Date Filed: January 30, 2023
`
`CRD-ENF 80 RS (Revised 12/22)
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`1
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`Complaint – CRD No. 202301-19536130
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`Date Filed: January 30, 2023
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`Complaint – CRD No. 202301-19536130
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`Date Filed: January 30, 2023
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`Complaint – CRD No. 202301-19536130
`
`Date Filed: January 30, 2023
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`-5-
`Complaint – CRD No. 202301-19536130
`
`Date Filed: January 30, 2023
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`-6-
`Complaint – CRD No. 202301-19536130
`
`Date Filed: January 30, 2023
`
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`

`oOONDODoOFFWNY=
`
`NODPPDPRNMPNNMNMNO|S|==>=]>>>>aoNODOoOFfWDY|FDOoODBNNDOOoFFWNY|OC
`
`Respondents
`
`1. Respondent Meta Platforms,Inc. is an employer subject to suit under the California Fair
`Employment and Housing Act (FEHA) (Gov. Code, § 12900 et seq.).
`
`
`
`
`
`2.Complainant is naming Meta Platforms, Inc. business as Co-Respondeni(s).
`Complainant is naming Meta business as Co-Respondeni(s).
`Complainant is naming Ethan Lubkaindividual as Co-Respondent(s).
`Complainantis naming lan Laiks individual as Co-Respondeni(s).
`Complainantis naming
`individual as Co-Respondent(s).
`Complainantis naming
`individual as Co-Respondenit(s).
`Complainantis naming
`individual as Co-Respondenit(s).
`Complainantis naming
`individual as Co-Respondeni(s).
`Complainantis naming
`individual as Co-Respondeni(s).
`Complainantis naming
`individual as Co-Respondeni(s).
`Complainant is naming
`individual as Co-Respondeni(s).
`
`Complainantis naming
`individual as Co-Respondeni(s).
`
`Complainantis naming
`individual as Co-Respondent(s).
`
`Complainantis naming
`individual as Co-Respondeni(s).
`
`Complainantis naming
`individual as Co-Respondeni(s).
`
`Complainantis naming
`individual as Co-Respondeni(s).
`Complainantis naming
`individual as Co-Respondeni(s).
`Complainantis naming
`individual as Co-Respondeni(s).
`
`Complainantis naming
`individual as Co-Respondenit(s).
`
`Complainant is naming
`individual as Co-Respondent(s).
`
`Complainantis naming
`individual as Co-Respondenit(s).
`Complainantis naming
`individual as Co-Respondeni(s).
`Complainantis naming
`individual as Co-Respondeni(s).
`
`Complainantis naming
`individual as Co-Respondent(s).
`
`Complainantis naming
`individual as Co-Respondenit(s).
`
`Complainantis naming
`individual as Co-Respondeni(s).
`
`Complainantis naming
`individual as Co-Respondeni(s).
`
`Complainantis naming
`individual as Co-Respondeni(s).
`
`Complainant is naming
`individual as Co-Respondeni(s).
`
`Complainantis naming
`individual as Co-Respondenit(s).
`
`Complainantis naming
`individual as Co-Respondeni(s).
`
`Complainantis naming
`individual as Co-Respondeni(s).
`-7-
`Complaint —- CRD No. 202301-19536130
`
`
`
`Date Filed: January 30, 2023
`
`CRD-ENF80 RS (Revised 12/22)
`
`

`

`oOONDODoOFFWNY=
`
`NODPPDPRNMPNNMNMNO|S|==>=]>>>>aoNODOoOFfWDY|FDOoODBNNDOOoFFWNY|OC
`
`Complainantis naming
`Complainantis naming
`Complainant is naming
`Complainant is naming
`Complainantis naming
`Complainantis naming
`Complainantis naming
`Complainantis naming
`Complainantis naming
`Complainantis naming
`Complainantis naming
`Complainant is naming
`Complainant is naming
`Complainantis naming
`Complainantis naming
`Complainantis naming
`Complainantis naming
`Complainantis naming
`Complainantis naming
`Complainantis naming
`Complainant is naming
`Complainant is naming
`Complainant is naming
`Complainantis naming
`Complainantis naming
`Complainantis naming
`Complainantis naming
`Complainantis naming
`Complainantis naming
`Complainantis naming
`Complainant is naming
`Complainant is naming
`Complainantis naming
`
`
`individual as Co-Respondeni(s).
`individual as Co-Respondeni(s).
`
`individual as Co-Respondeni(s).
`individual as Co-Respondeni(s).
`individual as Co-Respondent(s).
`
`individual as Co-Respondeni(s).
`
`individual as Co-Respondeni(s).
`
`individual as Co-Respondeni(s).
`individual as Co-Respondeni(s).
`individual as Co-Respondeni(s).
`
`individual as Co-Respondeni(s).
`
`individual as Co-Respondeni(s).
`individual as Co-Respondent(s).
`
`individual as Co-Respondent(s).
`individual as Co-Respondeni(s).
`
`individual as Co-Respondeni(s).
`individual as Co-Respondent(s).
`individual as Co-Respondeni(s).
`
`individual as Co-Respondeni(s).
`
`individual as Co-Respondeni(s).
`individual as Co-Respondeni(s).
`
`individual as Co-Respondeni(s).
`individual as Co-Respondeni(s).
`individual as Co-Respondenit(s).
`
`individual as Co-Respondeni(s).
`
`individual as Co-Respondent(s).
`individual as Co-Respondent(s).
`
`individual as Co-Respondent(s).
`individual as Co-Respondeni(s).
`individual as Co-Respondeni(s).
`
`individual as Co-Respondeni(s).
`individual as Co-Respondeni(s).
`
`individual as Co-Respondeni(s).
`
`
`
`3. Complainant Talia Kennedy,resides ini .
`
`4. Complainantalleges that on or about October 18, 2022, respondenttook the
`following adverse actions:
`
`Complainant was harassed because of complainant's sex/gender, genderidentity or
`expression, other, sexual harassment- hostile environment, pregnancy, childbirth, breast
`feeding, and/or related medical conditions, family care and medical leave (cfra) related to
`serious health condition of employee or family member, child bonding, or military exigencies.
`
`-8-
`Complaint — CRD No. 202301-19536130
`
`Date Filed: January 30, 2023
`
`CRD-ENF80 RS (Revised 12/22)
`
`

`

`Complainant was discriminated against because of complainant's sex/gender, gender
`identity or expression, other, pregnancy, childbirth, breast feeding, and/or related medical
`conditions, sexual harassment- hostile environment, family care and medical leave (cfra)
`related to serious health condition of employee or family member, child bonding, or military
`exigencies and as a result of the discrimination was terminated, denied hire or promotion,
`reprimanded, denied equal pay, demoted, denied any employment benefit or privilege,
`other, denied work opportunities or assignments.
`
`Complainant experienced retaliation because complainant reported or resisted any form
`of discrimination or harassment, requested or used a pregnancy-disability-related
`accommodation, requested or used family care and medical leave (cfra) related to serious
`health condition of employee or family member, child bonding, or military exigencies and as
`a result was terminated, denied hire or promotion, reprimanded, denied equal pay, demoted,
`denied any employment benefit or privilege, other, denied work opportunities or
`assignments.
`
`Additional Complaint Details: The facts include but are not limited to discrimination,
`harassment, and retaliation from management and coworkers based on protected
`categories, including but not limited to sex/gender, pregnancy, childbirth, breastfeeding or
`related medical conditions, sexual harassment - hostile environment, and pay inequity (Lab.
`Code § 1197.5). The above-identified unlawful conduct underpinned complainant’s wrongful
`termination and other adverse employment actions Meta imposed during her employment.
`
`Additional harms include but are not limited to failure to prevent discrimination, harassment,
`and/or retaliation, denied a work environment free of harassment, discrimination, and/or
`retaliation, failure to engage in a good faith interactive process, failure to offer reasonable
`accommodations, and retaliation for engaging in protected activity.
`
`-9-
`Complaint – CRD No. 202301-19536130
`
`Date Filed: January 30, 2023
`
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`

`VERIFICATION
`
`I, Carney Shegerian, am the Attorney in the above-entitled complaint. I have read
`the foregoing complaint and know the contents thereof. The matters alleged are
`based on information and belief, which I believe to be true.
`
`On January 30, 2023, I declare under penalty of perjury under the laws of the State of
`California that the foregoing is true and correct.
`
`Los Angeles, California
`
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`Date Filed: January 30, 2023
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`EXHIBIT B
`EXHIBIT B
`
`

`

`STATE OF CALIFORNIA | Business, Consumer Services and Housing Agency
`
`Civil Rights Department
`2218 Kausen Drive, Suite 100 | Elk Grove | CA | 95758
`800-884-1684 (voice) | 800-700-2320 (TTY) | California’s Relay Service at 711
`calcivilrights.ca.gov | contact.center@dfeh.ca.gov
`
`GAVIN NEWSOM, GOVERNOR
`
`KEVIN KISH, DIRECTOR
`
`January 30, 2023
`
`Talia Kennedy
`
`RE: Notice of Case Closure and Right to Sue
`CRD Matter Number: 202301-19536130
`Right to Sue: Kennedy / Meta Platforms, Inc. et al.
`
`Dear Talia Kennedy:
`
`This letter informs you that the above-referenced complaint filed with the Civil Rights
`Department (CRD) has been closed effective January 30, 2023 because an immediate
`Right to Sue notice was requested.
`
`This letter is also your Right to Sue notice. According to Government Code section
`12965, subdivision (b), a civil action may be brought under the provisions of the Fair
`Employment and Housing Act against the person, employer, labor organization or
`employment agency named in the above-referenced complaint. The civil action must be
`filed within one year from the date of this letter.
`
`This matter may qualify for CRD’s Small Employer Family Leave Mediation Pilot
`Program. Under this program, established under Government Code section
`12945.21, a small employer with 5 -19 employees, charged with violation of the
`California Family Rights Act, Government Code section 12945.2, has the right to
`participate in CRD’s free mediation program. Under this program both the
`employee requesting an immediate right to sue and the employer charged with
`the violation may request that all parties participate in CRD’s free mediation
`program. The employee is required to contact the Department’s Dispute
`Resolution Division prior to filing a civil action and must also indicate whether
`they are requesting mediation. The employee is prohibited from filing a civil
`action unless the Department does not initiate mediation within the time period
`specified in section 12945.21, subdivision (b) (4), or until the mediation is
`complete or is unsuccessful. The employee’s statute of limitations to file a civil
`action, including for all related claims not arising under section 12945.2, is tolled
`from the date the employee contacts the Department regarding the intent to
`pursue legal action until the mediation is complete or is unsuccessful. Contact
`CRD’s Small Employer Family Leave Mediation Pilot Program by emailing
`
`CRD - ENF 80 RS (Revised 12/22)
`
`

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`STATE OF CALIFORNIA | Business, Consumer Services and Housing Agency
`
`Civil Rights Department
`2218 Kausen Drive, Suite 100 | Elk Grove | CA | 95758
`800-884-1684 (voice) | 800-700-2320 (TTY) | California’s Relay Service at 711
`calcivilrights.ca.gov | contact.center@dfeh.ca.gov
`
`GAVIN NEWSOM, GOVERNOR
`
`KEVIN KISH, DIRECTOR
`
`DRDOnlinerequests@dfeh.ca.gov and include the CRD matter number indicated
`on the Right to Sue notice.
`
`To obtain a federal Right to Sue notice, you must contact the U.S. Equal Employment
`Opportunity Commission (EEOC) to file a complaint within 30 days of receipt of this
`CRD Notice of Case Closure or within 300 days of the alleged discriminatory act,
`whichever is earlier.
`
`Sincerely,
`
`Civil Rights Department
`
`CRD - ENF 80 RS (Revised 12/22)
`
`

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`EXHIBIT C
`EXHIBIT C
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`

`

`COMPLAINT OF EMPLOYMENT DISCRIMINATION
`BEFORE THE STATE OF CALIFORNIA
`Civil Rights Department
`Under the California Fair Employment and Housing Act
`(Gov. Code, § 12900 et seq.)
`
`In the Matter of the Complaint of
`Talia Kennedy
`
`vs.
`
`Complainant,
`
`CRD No. 202301-19536130
`
`Meta Platforms, Inc.
`1 Hacker Way
`Menlo Park, CA 94025
`
`Meta Platforms, Inc.
`1601 Willow Road
`Menlo Park, CA 94025
`
`Meta
`1 Hacker Way
`Menlo Park, CA 94025
`
`Ethan Lubka
`1 Hacker Way
`Menlo Park, CA 94025
`
`Ian Laiks
`1 Hacker Way
`Menlo Park, CA 94025
`
`Does 1-100
`1 Hacker Way
`Menlo Park, CA 94025
`
` Respondents
`
`1. Respondent Meta Platforms, Inc. is an employer subject to suit under the California Fair
`Employment and Housing Act (FEHA) (Gov. Code, § 12900 et seq.).
`
`2.Complainant is naming Meta Platforms, Inc. business as Co-Respondent(s).
`Complainant is naming Meta business as Co-Respondent(s).
`
`-1-
`Complaint – CRD No. 202301-19536130
`
`Date Filed: January 30, 2023
`Date Amended: January 31, 2023
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`CRD-ENF 80 RS (Revised 12/22)
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`Complainant is naming Ethan Lubka individual as Co-Respondent(s).
`Complainant is naming Ian Laiks individual as Co-Respondent(s).
`Complainant is naming Does 1-100 individual as Co-Respondent(s).
`
`3. Complainant Talia Kennedy, resides in
`
`.
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`4. Complainant alleges that on or about October 18, 2022, respondent took the
`following adverse actions:
`
`Complainant was harassed because of complainant's sex/gender, gender identity or
`expression, other, sexual harassment- hostile environment, pregnancy, childbirth, breast
`feeding, and/or related medical conditions, family care and medical leave (cfra) related to
`serious health condition of employee or family member, child bonding, or military exigencies.
`
`Complainant was discriminated against because of complainant's sex/gender, gender
`identity or expression, other, pregnancy, childbirth, breast feeding, and/or related medical
`conditions, sexual harassment- hostile environment, family care and medical leave (cfra)
`related to serious health condition of employee or family member, child bonding, or military
`exigencies and as a result of the discrimination was terminated, denied hire or promotion,
`reprimanded, denied equal pay, demoted, denied any employment benefit or privilege,
`other, denied work opportunities or assignments.
`
`Complainant experienced retaliation because complainant reported or resisted any form
`of discrimination or harassment, requested or used a pregnancy-disability-related
`accommodation, requested or used family care and medical leave (cfra) related to serious
`health condition of employee or family member, child bonding, or military exigencies and as
`a result was terminated, denied hire or promotion, reprimanded, denied equal pay, demoted,
`denied any employment benefit or privilege, other, denied work opportunities or
`assignments.
`
`Additional Complaint Details: The facts include but are not limited to discrimination,
`harassment, and retaliation from management and coworkers based on protected
`categories, including but not limited to sex/gender, pregnancy, childbirth, breastfeeding or
`related medical conditions, sexual harassment - hostile environment, and pay inequity (Lab.
`Code § 1197.5). The above-identified unlawful conduct underpinned complainant’s wrongful
`termination and other adverse employment actions Meta imposed during her employment.
`
`Additional harms include but are not limited to failure to prevent discrimination, harassment,
`and/or retaliation, denied a work environment free of harassment, discrimination, and/or
`retaliation, failure to engage in a good faith interactive process, failure to offer reasonable
`accommodations, and retaliation for engaging in protected activity.
`
`-2-
`Complaint – CRD No. 202301-19536130
`
`Date Filed: January 30, 2023
`Date Amended: January 31, 2023
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`VERIFICATION
`
`I, Carney Shegerian, am the Attorney in the above-entitled complaint. I have read
`the foregoing complaint and know the contents thereof. The matters alleged are
`based on information and belief, which I believe to be true.
`
`On January 30, 2023, I declare under penalty of perjury under the laws of the State of
`California that the foregoing is true and correct.
`
`Los Angeles, California
`
`-3-
`Complaint – CRD No. 202301-19536130
`
`Date Filed: January 30, 2023
`Date Amended: January 31, 2023
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`EXHIBIT D
`EXHIBIT D
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`

`

`STATE OF CALIFORNIA | Business, Consumer Services and Housing Agency
`
`Civil Rights Department
`2218 Kausen Drive, Suite 100 | Elk Grove | CA | 95758
`800-884-1684 (voice) | 800-700-2320 (TTY) | California’s Relay Service at 711
`calcivilrights.ca.gov | contact.center@dfeh.ca.gov
`
`GAVIN NEWSOM, GOVERNOR
`
`KEVIN KISH, DIRECTOR
`
`January 31, 2023
`
`Carney Shegerian
`11520 San Vicente Boulevard
`Los Angeles, CA 90049
`
`RE: Notice to Complainant’s Attorney
`CRD Matter Number: 202301-19536130
`Right to Sue: Kennedy / Meta Platforms, Inc. et al.
`
`Dear Carney Shegerian:
`
`Attached is a copy of your amended complaint of discrimination filed with the Civil
`Rights Department (CRD) pursuant to the California Fair Employment and Housing Act,
`Government Code section 12900 et seq.
`
`Pursuant to Government Code section 12962, CRD will not serve these documents on
`the employer. You or your client must serve the complaint.
`
`The amended complaint is deemed to have the same filing date of the original
`complaint. This is not a new Right to Sue letter. The original Notice of Case Closure
`and Right to Sue issued in this case remains the only such notice provided by the CRD.
`(Cal. Code Regs., tit. 2, § 10022.)
`
`Be advised that the CRD does not review or edit the complaint form to ensure that it
`meets procedural or statutory requirements.
`
`Sincerely,
`
`Civil Rights Department
`
`CRD - ENF 80 RS (Revised 12/22)
`
`

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`EXHIBIT E
`EXHIBIT E
`
`

`

`rn::oc roon 5 (06/22)
`
`Chnrgc Prcsc nlcd To:
`
`A gcncy(ics) C hnrgc No(s):
`
`(tnd eizo
`
`Ycnr orn1nh
`1987
`
`C HARGE OF D ISCRIMINATION
`Tius fonn 1s nfTcc1cd by 1hc Pnvncy Acl or 1974 Sec cnclo!IC<I Pnvncy Ac1
`Siorancnl nnd 01.hcr infonnohon before complc1i11g 11111 fonn
`
`550-2023-01405
`California Department of Fair Employment & Housing
`Su,rc or locnl A11mcy, I/ w1y
`
`Nnmc (mtllrorc Air , Al•. Mrs. M/55, Mr , l)r , //<NI , Re,•., <te}
`Talia Ke1U1edy
`S1rcc1 Addrcs.. c ,1y SIAIC nnd ZIP Code
`
`I lomo Phone
`(3 I 0) 860-0770
`
`clo 11 520 San Vicente Boulevard, Los Angeles, California 90049
`
`Nnmed is the Employer, Loba r Orgunizotlon, l;mployment Agency, Apprenticeship Committee, or Srn1c or Locnl Oovcmmcnt Agency Thot I Ocllcvc Discrnnlnutcd
`Against Mc or 0 1hcrs. (If more titan two. //st 1111der PAIITICUlA/IS below.)
`Nome
`Meta Platforms, Inc.
`
`No l'mployec,. Ma nbcr•
`
`Unknown
`
`Phone No
`
`NIA
`
`S1rcc1 Addrcs,, C11y S1n1c nnd Zll' Code
`
`I Hacker Way, Menlo Park., Cali forn ia 94025
`Nrune
`Meta Platforms, Inc.
`S1rcc1 Address, C11y, S1n1e nnd lJP Code
`
`160 1 Willow Road, Menlo Park, Cali fornia 94025
`
`No Employees, Members
`Unknown
`
`Phone No
`NIA
`
`OISCRIMINA TION IJASEO ON
`sex/gender. gender identity/expression. sexual harassment. prcgJ1ancy, child birth, breastfeeding.
`fan1ily care/medical leave (Cl'IWFMtA) rclutcd to serious hcnltl1 condition of employee/
`family. child bonding, Title VII (Equal Poy Acl/CompcnsntioJ1). nnd otl1cr.
`
`DATE(S) DISCRIMTNATION TOOK PLACU
`l,atltcsl
`-----------------
`
`LnlcSI
`10.25.2022
`
`11 lu PARTICULARS ARE (ljotl,Mo110/ pope, t., 11u,lcd, atrach w ro sheet(.•))·
`CLAIMS ARE ALLEGED ON AN INDIVIDUAL. BASIS ANO ON BEIIAI..F OF SIMILARY SITUATED EMPL.OYEUS ON CLASS/REPIUiSENTATlV(l nASIS
`
`The focis include but ore not limited to scxunl hnrassmcn~ d1scnmination. and rctnlintion from management nnd coworkers on tl1c basl!l of the rollowing proU,'Clcd cntcgones, which
`include but l\l'C not limited 10: sex/gender. gender identity or expression. sexual harassmenl - hostile environment, pregnancy, childb,nh, breastfeed in&, and/or rclalcd medical
`cond1t1ons. fnmily cnro and/or medical leave (CFRA/FMLA) related to serious health condition or employee or family member. child bondin&, T,1lc VI I (llqunl Pay Acl/
`Compensa1ion). and otl,er. Thai. among otl,er lhings, fonncd tl1e underlying b:ls1s for complninnnl's tcnninnt1on and/or subjected co111plainan1 to add,uonnl adverse employmenl
`net.mos.
`
`Please nolc the discnmina11on claims descnbcd. listed, and enumcrnlcd herein ore nllcged under bolh 1hc disparate treatment and d1spam1e impact theories of hab1hty So there can be
`no amb1gu11y, liability in a d1sp.1rn1e-trc11tment cnsc depends on whctl1er tl1c protected trait actually mo1iva1cd the employc(s decision On the other hand. d tSpnnuc impact nnscs when
`some employment prnet,ccs, usually foctnlly neulrnl, adopled without a dclibcrn1cly discrim1nn1-0,y motive, may 10 opcrnlion be functionally cquivlllcnt to intentional d1scnm1nnt1on
`
`Mela subjects female employees lo a pouem and practice or systematic unlawful disparate trcatmenl nnd unlawful d1spam1c impact d1scnm1nn11on by poym& female employee., Jen
`Uurn their male counterparts and denying fomlllc employees development, promo1ion, and ndvnnccmcnt opportunilics, These problems stcm from common employmcnl pol 1c1cs,
`pmc1iccs, nnd procedures, llS well as a predom,nantly mole senior leadership team lha1 approves systcma1ic unlawful trcntmcnt of females. mcluding d1sporntc leveling nt tl1c 1,mc of
`hire, development, cnrccr progression, promotions, cvnlunt1ons. personnel management. nnd compen53Uon Such pohc,cs, pract1ccs, and proccdun.'S ore not vnhd, JOb-rela1cd, or
`JUSllficd by bus mess necessity.
`
`Additional hanns include bul arc no! limited to failure to prevent d tsenmma1ion. harassment, and/or rcialia1ion, dented a work cnv1ronmen1 free ofharu.ument. d1SCnmma11on a.nd/or
`rc1aliat1on. and retnllauon for engaging in prolccted ac11v11y.
`
`I want this charge filed with both tl1e EEOC Md tJ,e State or local Agency, if any. I will NOTARY - Whm 11ecenory for Su,re and /,oco/ Al(e11cy R,qulrcmcnt,
`advise the agencies if I change my address or phone number Md I will cooperate fully
`with tl1em in the processing of my charge in accordance with their procedures.
`
`I declare under penalty of perjury that tl1c above is true and oorrccL
`
`t b4 \2 3 A(A 01\ ~ .I 1' 'J\ ,A ,AA -
`
`/)Ole
`
`Cho,g111g /'{Jf'I)' S1w1a1ure
`
`(I
`
`I swear or affirm that I hove read the above charge and tlrnt 11 is true to tile best
`of my knowledge, information and belief
`SIGNATURE OF COMPLAINANT
`
`SUOSCRllleDANO SWORN 10 llliFOlllJ Mll TIIIS OATB(mon1/1, day, J•ear)
`
`U.S. Equal Employment Opportunity Commission
`San Francisco District Office
`Received On: August 15, 2023
`
`

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`EXHIBIT F
`EXHIBIT F
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`

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`STATE. OF CAL IF"ORN I A I 8u.s 1nass, Consumer Suvicu 1nd Hou.sine A11ney
`
`Civil Rights Department
`2218 Kausen Drive, Suite 100 I Elk Grove I CA 195758
`800-884•1684 (voice) I 800· 700"2320 ITTYI I Ca lifornia' s Relay Serv ice at 711
`www.ca lciv1lri1hti .ca .,0v I con1act.cen1er@dfeh .ca .1ov
`
`GAV IN NEWSOM, GOVERNOR
`
`KEVIN KISH, DIRECTOR
`
`
`
`EEOC Number:
`
`550-2023-01405
`
`Case Name:
`
`Filing Date:
`
`Ms. Talia Kennedy v. Meta Platforms, Inc.
`
`August 15, 2023
`
`NOTICE TO COMPLAINANT AND RESPONDENT
`
`
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`
`
`
`
`This is to advise you that the above-referenced complaint is being dual filed with the
`California Civil Rights Department (CRD) by the U.S. Equal Employment Opportunity
`Commission (EEOC). The complaint will be filed in accordance with California
`Government Code section 12960. This notice constitutes service pursuant to
`Government Code section 12962.
`
`The EEOC is respons