ELECTRONICALLY
`F I L E D
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`Superior Court of California,
`County of San Francisco
`04/22/2024
`Clerk of the Court
`BY: AUSTIN LAM
`Deputy Clerk
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`CGC-24-614104
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`BBERRETHLAWGROUP
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`AttorneysandCounselorsatLaw
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`JURISDICTION
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`l.
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`This Court has original jurisdiction of the claimsarising from the California Fair
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`Employment and Housing Act, Cal. Govt. Code § 12900 et seq. (FEHA). Venueis proper
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`pursuant to California Code of Civil Procedure Code §394, as Plaintiff worked in and was
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`terminated in San Francisco County andall acts and omissionsgiving rise to liability are alleged
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`to have occurred in San Francisco County.
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`THE PARTIES
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`2.
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`Plaintiff, JESSLEY PENNINGTON,is andat all times relevant hereto was a
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`resident of the County of Contra Costa, State of California and was employed in San
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`Francisco County, California.
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`3.
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`Plaintiff is informed and believes, and based thereuponalleges,that at all times
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`relevant hereto Defendant CBRE GROUP,INC.a Delaware Corporation (hereinafter referred
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`to as (“CBRE”), doing business in the State of California, in the County of San Francisco.
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`4.
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`The true names and capacities of Defendant Does 1-10, inclusive, are unknown to
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`Plaintiff, who therefore sues said Defendant by suchfictitious names. Plaintiff is informed and
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`believes and thereon alleges that each Defendant designated herein asa fictitiously named
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`Defendantis in some mannerresponsible for the events and happeningsherein referred to, either
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`contractually or tortiously, and caused the damageto Plaintiff as herein alleged. When Plaintiff
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`ascertains the true names and capacities of Does 1-10, inclusive, Plaintiff with ask leave ofthis
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`Court to amend her Complaintby setting forth the same.
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`5.
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`Plaintiff is informed and believes and, on thatbasis, alleges, that at all times
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`mentioned herein, Defendant, and each of them, were the agents, servants and/or employees of
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`each of the other Defendant, and in doing the things alleged herein were acting within the course
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`and scope ofsaid agency and/or employment.
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`6.
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`Plaintiff is informed and believes and based thereonalleges, that at all times
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`herein mentioned, one or more of each named and/or unnamed Defendant was in some fashion
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`by contract or otherwise, the successors, or assigns of one or more of the remining names and/or
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`unnamed Defendant, and hereinafter alleged, was acting within that capacity.
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`2
`COMPLAINT FOR DAMAGES
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`BERRETHLAWGROUP
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`GENERAL ALLEGATIONS
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`7.
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`Plaintiff incorporates by reference all preceding paragraphs as thoughfully set
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`forth herein and further alleges the following:
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`8.
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`At all relevant times, Plaintiff was employed by CBRE GroupInc. and was
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`assigned to CBRE’s client, Cruz Automation (hereinafter “CRUZ”),. CRUZ had contracted with
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`Plaintiffs employer to provide personne! to run and managethefacility being leased by CRUZ.
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`9.
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`CBRE notified Plaintiff that he had to be vaccinated (COVID 19) to be onsite at
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`CRUZ.Plaintiff had filed a request for reasonable accommodation with respect to his sincerely
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`held religious beliefs regarding the requirement to be vaccinated. CBRE approvedhis request
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`yet CBRErequired Plaintiff to separately submit his request to CRUZ. CRUZ denied his request
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`on the grounds it was unduly burdensome. Plaintiff was locked out of his email accountandall
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`access was revoked. This was done without warning or explanation.
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`10.
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`CBRE thenplaced Plaintiff on a thirty (30) day leave of absence withoutpay.
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`CBRE theninstructed Plaintiff to apply to a different department. CBRE terminated Plaintiffs
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`position at CRUZ dueto the fact he wasnot fully vaccinated. CBRE expressly stated that it had
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`no other position available for Plaintiff. To make matters more confusing and despite
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`communicating to Plaintiff that no other positions were available, CBRE invited Plaintiff to
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`apply for other positions.
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`11.
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`Defendant CBRE hada facially neutral practice or policy, baring no manifest
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`relationship to job requirements which had a disproportionate adverse effect on membersof a
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`protected class.
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`In this case, CBRE required employeesto either be vaccinated with the COVID-
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`19 vaccine. CBRE had nopolicy which would allow employees to undergo weekly testing as an
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`alternative to receiving the vaccine. Plaintiff requested reasonable accommodationfor his
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`sincerely held religious beliefs. His request was to undergo weekly testing. Defendant CBRE’S
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`policy had a disproportionate effect on those seeking accommodation for their religious beliefs.
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`In fact, CBRE’S policy did not even allow for a discussion with Plaintiff about His beliefs and
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`whetherthere could be an accommodation. Plaintiff submitted his request and was simply
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`3
`COMPLAINT FOR DAMAGES
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`denied without explanation. This constituted a clear violation of FEHA and hadadisparate
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`impact on Plaintiff.
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`12.
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`In this case, Defendant CBRE wasusingthe practice as a mere pretext for
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`discrimination. The only individuals, including Plaintiff, that were terminated or adversely
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`affected were those requesting reasonable accommodation for religious beliefs. The policy of
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`the CBREhad an obvious disproportionate effect on those seeking accommodationsfor the
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`sincerely held religious beliefs and creed.
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`13.
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`As anemployee of Defendant CBRE,Plaintiff was harmed by CBRE’s policy
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`requiring employees receive the COVID-19 vaccineas it had a disproportionate effect on
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`employees withreligious beliefs that did not allow them to be vaccinated but would agree to
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`weekly testing. This policy was a substantial factor in causing Plaintiff's harm as she was
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`terminated for not meeting CBRE’s conditions of employmentthat conflicted with his religious
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`creed andbeliefs.
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`EXHAUSTION OF ADMINISTRATIVE REMEDIES
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`14.
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`Plaintiff filed a complaint with the California Department of Fair Employment
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`and Housing (DFEH). On August 9, 2023, the DFEH issued Plaintiff a Right to Sueletter.
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`FIRST CAUSE OF ACTION
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`For Discrimination in Violation of Gov’t Code §§12940 et seq.
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`Against all Defendants
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`15.
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`Plaintiff hereby incorporates and realleges the preceding paragraphs as though
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`fully set forth herein.
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`16.
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`At all times hereto, the FEHA wasin full force and effect and was binding upon
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`Defendants and each of them.
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`17.
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`As such term is used under FEHA,"on the basis enumerated in this part" means
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`or refers to discrimination on the basis of one or more of the protected characteristics under
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`FEHA.
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`COMPLAINT FOR DAMAGES
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`18.
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`FEHA requires Defendantsto refrain from discriminating against an employee on
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`the basis ofdisability, real and perceived, and religious creed, and to preventdiscrimination and
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`harassmentbased onthe protected class.
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`19.
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`Plaintiff was a memberof multiple protected classes based on his sincerely held
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`religious beliefs and religious creed and disability or perception that he was suffering from a
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`disability.
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`20.
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`‘At all times relevant hereto, Plaintiff was performing competently in the position
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`Plaintiff held with Defendant.
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`21.
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`Plaintiff suffered the adverse employmentactions of unlawful, discrimination,
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`failure to accommodate,failure to investigate, remedy, and/or prevent discrimination, failure to
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`reinstate and/or return to work, and termination, and was harmedthereby.
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`22.
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`Plaintiff is informed and believesthat Plaintiff's religious beliefs and disability,
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`and some combinationofthese protected characteristics under Government Code §12926(j) were
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`motivating reasons and/orfactors in the decisions to subject Plaintiff to the aforementioned
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`adverse employmentactions.
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`23.
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`Said conduct violates the FEHA, and such violations were a proximate cause
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`Plaintiff damageas stated below.
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`24.
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`The foregoing conduct of Defendant, or by andthroughits officers, directors
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`and/or managing agents, was intended by the Defendantsto cause injury to the Plaintiff or was
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`despicable conductcarried on by the Defendants with a willful and conscious disregard of the
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`rights of Plaintiff or subjected Plaintiff to cruel and unjust hardship in conscious disregard of
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`Plaintiff's rights such as to constitute malice, oppression, or fraud under Civil Code §3294,
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`thereby entitling Plaintiff to punitive damages in an amountappropriate to punish or make an
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`example of Defendants.
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`25.
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`As a result of Defendants’ actions, Plaintiff has suffered special damages such as
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`lost wages, benefits, and earning capacity. Plaintiff claims general damages for emotional and
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`mentaldistress and aggravation in a sum in excessofthe jurisdictional minimum of this Court.
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`5
`COMPLAINT FOR DAMAGES
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`30._—_—Plaintiff engaged in the protected activities of requesting accommodation,
`requesting disability leave, exercising plaintiff's rights to disability leave/ medical leave and
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`26.
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`Pursuant to Government Code §12965(b), Plaintiff requests a reasonable award of
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`attorney’s fees and costs, including expert fees.
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`SECOND CAUSE OF ACTION
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`Retaliation in Violation of Gov’t Code §§12940 et seq.
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`Againstall Defendants
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`27.
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`Plaintiff hereby incorporates and realleges the preceding paragraphs as though
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`fully set forth herein.
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`28.
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`At all times hereto, the FEHA wasin full force and effect and was binding upon
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`Defendants and each of them.
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`29.
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`These lawsset forth in the preceding paragraph required defendants to refrain
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`from retaliating against an employee for engaging in protected activity.
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`complaining about and protesting defendants discriminatory conduct towardsplaintiff based
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`uponplaintiffs disability, use of disability leave, and plaintiffs religious creed.
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`31.
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`Plaintiff suffered adverse employmentactions of unlawful discrimination,
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`retaliation, failure to accommodate, failure to reinstate and or return to work, and termination,
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`and was harmed thereby.
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`32.
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`Plaintiff is informed and believes that plaintiffs request for reasonable
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`accommodationofhis religious beliefs, requests for disability leave, and exercise ofhis rights,
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`and his complaints and protestations about defendants discriminatory andretaliatory conduct,
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`and or some combination of these factors, were motivating reasonsin the decisions to subject
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`plaintiff to the aforementioned adverse employmentactions.
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`33.
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`Defendants violated FEHAbyretaliating against Plaintiff and terminating
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`plaintiff for attempting to exercise his protected rights, as set forth herein.
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`34.
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`Plaintiff is informed and believes, and based thereonalleges, that the above acts
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`of retaliation committed by defendants were done with the knowledge, consent, and or
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`ratification of, or at the direction of, each other defendant and the other managers.
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`6
`COMPLAINT FOR DAMAGES
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`BBERRETHLAWGROUP
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`35.
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`The aboveset acts of defendants constitute violations of FEHA, and were the
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`proximate cause and Plaintiff's damagesas stated below.
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`36.
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`The foregoing conduct of Defendant, or by and throughits officers, directors
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`and/or managing agents, was intended by the Defendants to cause injury to the Plaintiff or was
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`despicable conduct carried on by the Defendants with a willful and conscious disregard ofthe
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`rights of Plaintiff or subjected Plaintiff to cruel and unjust hardship in conscious disregard of
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`Plaintiff's rights such as to constitute malice, oppression, or fraud under Civil Code §3294,
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`thereby entitling Plaintiff to punitive damages in an amount appropriate to punish or make an
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`example of Defendants.
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`37.
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`Asaresult of Defendants' actions, Plaintiff has suffered special damages such as
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`lost wages, benefits, and earning capacity. Plaintiff claims general damages for emotional and
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`mental distress and aggravation in a sum in excessofthe jurisdictional minimum ofthis Court.
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`38.
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`Pursuant to Government Code §12965(b), Plaintiff requests a reasonable award of
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`attorney’s fees and costs, including expert fees.
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`THIRD CAUSE OF ACTION
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`Discrimination - Failure to Provide Reasonable Accommodation in Violation of Gov’t
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`Code §§12940 et seq. against all Defendants
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`39.
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`Plaintiff hereby incorporates and realleges the preceding paragraphs as though
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`fully set forth herein.
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`40.
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`At all times hereto, the FEHA wasin full force and effect and was binding upon
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`Defendants and each of them.
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`4].
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`Plaintiff's bone fide religious beliefs conflicted with a condition of Plaintiff's
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`employmentthat required him to receive the COVID 19 vaccine. Plaintiff submitted his request
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`for reasonable accommodation whichincludedhis religious beliefs. Plaintiff's employer,
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`Defendant CBRE,was aware ofPlaintiff's religious beliefs.
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`42.
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`Plaintiff is informed and believes, and based thereonalleges, that Defendant
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`CBRE failed to maintain any grievance procedure or policy addressing religious discrimination
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`7
`COMPLAINT FOR DAMAGES
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`BBERRETHLAWGROUP
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`or accommodationof its employees’religious beliefs. This constitutes a failure to prevent
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`religious creed discrimination.
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`43.
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`CBRE failed to initiate a good faith effort to accommodate Plaintiff's religious
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`beliefs, which is a violation of FEHA. It is mandated that Defendant CBRE accommodate
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`Plaintiff's religious beliefs unless the employer can demonstrate that the accommodationis
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`unreasonable because it would impose an undue hardship. CBRE did not communicate any
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`unduehardship to Plaintiff. Simply put, Defendant CBRE did not explore any available
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`reasonable alternative means of accommodating the religious beliefs of Plaintiff as required.
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`44,
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`The abovesaid acts of Defendants constitute violations of FEHA, and were the
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`proximate cause of Plaintiff's damages as stated below.
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`45.
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`The foregoing conduct of Defendant, or by and throughits officers, directors
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`and/or managing agents, was intended by the Defendantsto cause injury to the Plaintiff or was
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`despicable conduct carried on by the Defendants with a willful and conscious disregard of the
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`rights of Plaintiff or subjected Plaintiff to cruel and unjust hardship in conscious disregard of
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`Plaintiff's rights such as to constitute malice, oppression, or fraud under Civil Code §3294,
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`thereby entitling Plaintiff to punitive damages in an amount appropriate to punish or make an
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`example of Defendants.
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`46.
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`Asaresult of Defendants’ actions, Plaintiff has suffered special damages such as
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`lost wages, benefits, and earning capacity. Plaintiff claims general damages for emotional and
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`mental distress and aggravation in a sum in excess of the jurisdictional minimum ofthis Court.
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`47.
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`Pursuant to Government Code §12965(b), Plaintiff requests a reasonable award of
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`attorney’s fees and costs, including expert fees.
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`FOURTH CAUSE OF ACTION
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`Disparate Impact in Violation of Gov’t Code §§12940 et seq. against all Defendants
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`48.
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`Plaintiff hereby incorporates and realleges the preceding paragraphs as though
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`fully set forth herein.
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`49,
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`Atall times hereto, the FEHA wasin full force and effect and was binding upon
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`Defendants and each of them.
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`8
`COMPLAINT FOR DAMAGES
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`BBERRETHLAWGROUP
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`50.
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`Disparate impact occurs when an employer has an employmentpractice that
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`appears neutral but has an adverse impact on membersof a protected group and cannot be
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`justified by business necessity. Plaintiff alleges that defendant CBRE had an employment
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`practice, requiring employeesto either be vaccinated (COVID 19) or undergo weeklytesting.
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`This practice appeared neutral as it seemingly applied to all employees. However, this employee
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`practice and policy had an adverse impact on a protected group — those employees with sincerely
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`held religious beliefs. Plaintiff was thus discriminated against becauseofhis religious beliefs
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`because CBRE’s policy had a disparate impact on Plaintiffs protected class.
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`51.
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`The abovesaid acts of Defendants constitute violations of FEHA, and were the
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`proximate cause of Plaintiff's damagesas stated below.
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`52.
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`The foregoing conduct of Defendant, or by and throughits officers, directors
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`and/or managing agents, was intended by the Defendantsto cause injury to the Plaintiff or was
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`despicable conduct carried on by the Defendants with a willful and conscious disregard of the
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`rights of Plaintiff or subjected Plaintiff to cruel and unjust hardship in conscious disregard of
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`Plaintiff's rights such as to constitute malice, oppression,or fraud under Civil Code §3294,
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`thereby entitling Plaintiff to punitive damages in an amount appropriate to punish or make an
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`example of Defendants.
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`53.
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`Asa result of Defendants' actions, Plaintiff has suffered special damages such as
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`lost wages, benefits, and earning capacity. Plaintiff claims general damages for emotional and
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`mentaldistress and aggravation in a sum in excess of the jurisdictional minimum ofthis Court.
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`54,
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`Pursuant to Government Code §12965(b), Plaintiff requests a reasonable award of
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`attorney’s fees and costs, including expert fees.
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`FIFTH CAUSE OF ACTION
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`Failure to Engage in Good Faith Interactive Process in Violation
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`of Gov’t Code §§12940 Et Seq. against all Defendants
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`55.
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`Plaintiff hereby incorporates and realleges the preceding paragraphs as though
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`fully set forth herein.
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`9
`COMPLAINT FOR DAMAGES
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`BBERRETHLAWGROUP
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`56.
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`Atall times hereto, the FEHA wasin full force and effect and was binding upon
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`Defendants and each of them,
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`57.
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`Plaintiff requested accommodation,triggering Defendant obligation to engage
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`in the interactive process with Plaintiff, but at all times herein, Defendant failed and refused
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`todo so. Thereafter, despite Defendant continuing obligation to engage in the interactive
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`process with Plaintiff, despite Plaintiff's desire to continue working by having weekly
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`testing, Defendant failed and refused to have any dialogue with Plaintiff whatsoever, on any
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`of these occasions, and Defendant violated, and continued to violate this obligation up to and
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`including the date of Plaintiffs termination or, if Defendant contends Plaintiff was never
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`terminated, through the present and ongoing. Defendant CBRE wasrequired to engage in a
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`good faith interactive process with Plaintiff with regard to his request for reasonable
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`accommodation. The purposeofthis interactive processis to determine if a reasonable
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`accommodation can be made. CBRE failed to engagein this required process.
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`58.
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`The abovesaid acts of Defendants constitute violations of FEHA, and were the
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`proximate cause of Plaintiff's damagesas stated below.
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`59.
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`The foregoing conduct of Defendant, or by and throughits officers, directors
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`and/or managing agents, was intended by the Defendants to cause injury to the Plaintiff or was
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`despicable conductcarried on by the Defendants with a willful and conscious disregard ofthe
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`rights of Plaintiff or subjected Plaintiffto cruel and unjust hardship in conscious disregard of
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`Plaintiff's rights such as to constitute malice, oppression, or fraud under Civil Code §3294,
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`thereby entitling Plaintiff to punitive damages in an amount appropriate to punish or make an
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`example of Defendants.
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`60.
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`As a result of Defendants’ actions, Plaintiff has suffered special damages such as
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`lost wages, benefits, and earning capacity. Plaintiff claims general damages for emotional and
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`mental distress and aggravation in a sum in excessofthe jurisdictional minimum ofthis Court.
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`61.
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`Pursuant to Government Code §12965(b), Plaintiff requests a reasonable award of
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`attorney’s fees and costs, including expert fees.
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`Ml
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`COMPLAINT FOR DAMAGES
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`SIXTH CAUSE OF ACTION
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`Wrongful Termination in Violation of Public Policy against all Defendants
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`62._Plaintiff hereby incorporates and realleges the preceding paragraphs as though
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`fully set forth herein.
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`63._—_Atall times hereto, the FEHA wasin full force and effect and was binding upon
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`Defendants and each of them. This law requires defendants to refrain, among other things, from
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`discriminating against any employee onthe basis of disability, medical condition, or religious
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`beliefs, and from retaliating against any employee who engagesin protected activity.
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`64.
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`At all mentioned in this complaint, it was a fundamental policyofthe state of
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`California that defendants cannot discriminate and or retaliate against any employee on the basis
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`of their protected class, IE, disability and or religious belief.
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`65.
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`Plaintiff believes in thereon alledges that Plaintiff's disability and religious beliefs
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`- his engagementin protected activity with respect to these protected classes, and/or some
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`combination thereof, were factors in defendants conduct as alleged herein.
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`66.
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`Such discrimination and retaliation, resulted in the wrongful termination of
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`Plaintiff's employmentonthe basis of his disability and sincerely held religious beliefs, Plaintiff
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`complaining of discrimination due to these protected classes, Plaintiff's engagement in protected
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`activity, and/or some combination of these factors, were a proximate cause and Plaintiff's
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`damagesasset forth below.
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`and the public policy ofthe state of California embodied therein as set forth above. Defendants
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`of violated these laws by discriminating andretaliating against plaintiff and terminating plaintiff
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`employmentandretaliation for exercise of protected rights.
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`68.
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`The foregoing conduct of Defendant, or by and throughits officers, directors
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`and/or managing agents, was intended by the Defendants to cause injury to the Plaintiff or was
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`despicable conduct carried on by the Defendants with a willful and conscious disregard of the
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`rights of Plaintiff or subjected Plaintiff to cruel and unjust hardship in conscious disregard of
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`Plaintiff's rights such as to constitute malice, oppression, or fraud under Civil Code §3294,
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`COMPLAINT FOR DAMAGES
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`67,|The abovesaid acts of defendants constitute violations of the government code
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`thereby entitling Plaintiff to punitive damages in an amount appropriate to punish or make an
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`example of Defendants.
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`69.
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`Asaresult of Defendants’ actions, Plaintiff has suffered special! damages such as
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`lost wages, benefits, and earning capacity. Plaintiff claims general damages for emotional and
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`mental distress and aggravation in a sum in excess of the jurisdictional minimum ofthis Court.
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`70.+Pursuant to Government Code §12965(b), Plaintiff requests a reasonable award of
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`BBERRETHLAWGROUP
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`attorney’s fees and costs, including expert fees.
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`PRAYER FOR RELIEF
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`WHEREFORE, PLAINTIFF JESSLEY PENNINGTON,respectfully prays this Court
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`grantrelief as follows:
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`As to DEFENDANT CBRE GROUP,INC.:
`. Award Plaintiff backpay, including past loss of wages and benefits, plus interest;
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`ZTS& . Award Plaintiff any additional special and general damages according to proof;
`aOo
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`. Award to Plaintiff his reasonable attorney’s fees and costs ofsuit;
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`. Declare that Defendant has violated FEHA;
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`oO. Punitive Damages
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`f. Grant Plaintiff such additional oralternative relief as the Court deemsjust and proper
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`Date: April 18, 2024
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`BERRETH LAW GROUP
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`LESS
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`KEVIN J. BERRETHAttorney for Plaintiff
`Jessley Pennington
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`DEMAND FOR JURY TRIAL
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`PLAINTIFF hereby demandsa trial by jury.
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`eoFeNIDnvA&F|]YH=
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`TSFe
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`Date: April 18, 2024
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`BERRETH LAW GROUP
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`KEVIN J. BERRETHAttorneyfor Plaintiff
`Jessley Pennington
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`12
`COMPLAINT FOR DAMAGES
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