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Russell A. Robinson, SBN 163937 _
Law Office of Russell A. Robinson PPPREEB
345 Grove Street, 1* Floor Lod ean
San Francisco, CA 94102 ASSES
Phone: 418.861.4416 . ,
Fax: 415.431.4526 NAY 29 2019
Nawa4e@omallcom CLERK OF THE COURT
Counsel for Plaintiff BY ae BOWED LS
YULANDA WILLIAMS
SUPERIOR COURT OF THE STATE OF CALIFORNIA
CITY & COUNTY OF SAN FRANCISCO,
YULANDA WILLIAMS, caseNo. — CG0-19-576 323
Plaintiff, COMPLAINT FOR DAMAGES AND INJUNCTIVE
RELIEF
v. [Employment]
CITY & COUNTY OF SAN FRANCISCO, ~ [Jury Trial Demanded]
MARTIN HALLORAN, DENISE
FLAHERTY, and DOES 1-40,
Defendants.
J
COMES NOW PLAINTIFF YULANDA WILLIAMS AND STATES AS FOLLOWS:
JURISDICTION AND VENUE
1. This action arises in part under California Government Code §12940, et seq.
This Court thus has jurisdiction this matter, and Plaintiff therefore files this action in this Court,
2. Plaintiff's claims arose in and around the City & County of San Francisco. Thus,
venue is proper herein at the time this action is commenced.
PARTIES
3. Plaintiff Yulanda Williams is an adult female citizen of the United States residing
in the State of Califomia. She is of African ancestry (she is black; that is, African-American). At
all relevant times, Plaintiff has been over 40 years of age. At all times, Defendants were aware
of these facts. Williams has been employed by the City & County of San Francisco, and began
working as a peace officer in about 1990. At the present time, Williams is an acting captain
Williams v. City & County oF San Francisco, et af POOT
COMPLAINT FOR DAMAGES.
AND INJUNCTIVE RELIEFes
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Ve VY
having attained the rank of lieutenant through advances based on merit.
4. On information and belief, Defendant CITY & COUNTY OF SAN FRANCISCO is
a municipal entity organized and existing under the laws of the State of California. One of its
subdivisions, or agencies, is the San Francisco Police Nepartment (SFPD). On information and
belief, the SFPD may not sue and be sued. Thus, together these two entities ere referred to as
San Francisco or C&CSF unless otherwise noted
5. Oninformation and belief, Defendant MARTIN HALLORAN is (or was) an
employee of San Francisco at the SFPD. He was until recently the president of the SFPOA
(more fully described below).
6. Oninformation and belief, Defendant DENISE FLAHERTY is an employee of
San Francisco at the SFPD. At times relevant to this complaint, Flaherty was a police captain
7. Plaintiff is ignorant of the identities of Defendants DOES 1 though 40, and
therefore sues such defendants as fictiiously named persons/entities, whose true identities and
roles in the events which are the subject matter of this complaint are presently unknown
Piaintiff will amend this complaint to identify fictiiously named Defendants and to set forth facts
relating to each when same become known to Plaintiff. Plaintiff is informed anc believes and
thereon alleges that each DOE Defendant is legally responsible for events alleged herein which
caused injury and damage to Plaintiff
8. __Indoing acts or omissions alleged, Defendants and each of them were acting in
the course and scope of their employment with their respective agencies. In doing the acts or
omissions alleged, Defendants acted under color of authority andlor under color of law.
9. Indoing acts or omissions alleged, each Defendant acted as the agent, servant,
‘employee, and/or in concert with each of the other Defendants herein.
SPECIFIC FACTS
10. Plaintiff sets forth a series of acts and failures to act spanning more than
four years, continuing through April 2019.
11. On March 15, 2015, at a meeting as President of Officers For Justice
Peace Officers Association, Plaintiff was notified that her name was in several
Wiiams v. City & County of San Francisco, etal. POOT
COMPLAINT FOR DAMAGES.
‘AUD INJUNCTIVE RELIEF23
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rewspapers. Plaintiff had been singled out by active SFPD members engaged in racist
and homophobic texting.
12. On March 16, 2015, Commander Ann Mannix and Deputy Chief Garrett
Tom alone of all command staff members called ta apologize and to express concern
for Plaintiff as being named by those members involved in what became known as
“Text-Gate |." On March 17, 2015, Plaintiff filed a complaint with the EEO office and
spoke to Insp. Lloyd Lew; she also complained to then-Chief Greg Suhr.
13. On April 30,'2018, Plaintiff met Chief Suhr and the SFPOA to tell them
about Plaintiff's new PSA Message “Not On My Watch.” Her idea met with resistance
and delays, but on the day the website launched the Press Release falsely indicated
the idea and inception came from Harry Soulette.
14. On August 18, 2015, Plaintiff met with Chief Suhr and Marion Jackson in
the Chief's Office. They discussed Recruitment, Academy, FTO Program, and the
need for further diversity. Plaintiff indicated a desire to work in 1A Criminal Unit, but
Suhr stated that would be difficult with Plaintiff serving as the OF J President; she had
previously put herself through the Internal Affairs Class offered by POST. Plaintiff was
denied the position.
15. On September 11, 2015, Plaintiff again met with Chief Suhr and Marion
Jackson in the Chief's Office. The scope of conversation regarded Textgate, ‘Not On
My Watch," and the need for a Racial Harmony symposium to discuss the racial divide
in a non-threatening environment with mental health professionals, respected
‘community leaders, and members of the SFPD with every member allowed to
patticipate. Chief Suhr stopped the meeting and called Plaintiff out of the meeting to
advise her of a pending IA investigation. Plaintiff was told that she ‘just a witness.”
Plaintiff then shared a conversation with Lt. Valerie Matthews from long before and that
itwas her opinion Matthews was attempting to gossip. The Chief downplayed the
situation, therefore Plaintiff thought nothing further about the matter.
16. On December 10, 2015, Plaintiff met with Malia Cohen regerding the
Willams v_ City & County oF San Francisco, et al POOT
COMPLAINT FOR DAMAGES
‘AUD INJUNCTIVE RELIEF se