10 n 2 13 “4 6 6 "w 8 1» 20 a 2 23 4 26 26 20 28 ho rotaliated ageinst them, Regan atked a group of women if he could sniff their pantics. Bensaid observed this behavior and did nothing, though he ucknowlodged its potential legal consequences for UHW. 8. Regan made inappropriate and cexist remarks to UHW's Political Director, who reported him to the Deputy Chief of Staff and to Director Hatcher. x. B (Hatcher Dep., 20646, 13-14); Ex. F Gilton Dep., 10649 140:16-21) VP Stan Lyles sent photos of his penis to a UHW member, and cornered and propositioned her in a hotel room, Regan made lewd comments about women staff. (“The only way she is getting ‘a job is if she sucks my dick") Lyles groped a member's breast. + Bensnid propositioned a UHW organizor and when she turned him down, he called her a bitch and told her to "fuck off” + Regan and Lyles discussed picking up o's" while on business in Arizona, and waely * Lyles mado sexually inappropriate comments to a union organizer. Req, For Jud. Notice, Hx. 8 ‘commented that the “ho's in UHW's office “ws Regan is a notorious “boob gazor” who would comment to attractive women you've lucky I'm a married man’) Bonsai had inappropriate photos on his cell phone, and UHW General Counsel Bruce Harland, UHW's Chief of Staff, and UHW's Deputy Chief of Staff told him to ‘keep the photos “in case there will be asexual harassment case next time.” Ex. M, 9 2 + Bensaid referred to a woman co-worker asa “whore” and “biteh", stalked her, and caused hero resign from UHW. Id. p. 2 ‘Rogan tld taf that he would “go after” anyone who made allegations against25 6 2 28 the Union, UHIW hited and promoted men like Director Chokri Bensaid, despite a record of harassment ata sistor union, - UHW hired a man who soxually assaul ‘co-worker at his prior SEIU union. Hatcher was drunk, wildly dancing, and hanging on women at union events. Ex. $ out Dez, $9): Ex. 212-20Rx. 1 19622-1875; 187°7-13) - VP Lyles sent inappropriate and suggestive texts to women co-workers, CU look really nice in that blowse, mmm”). Bx." - Directors Bensaid and Hatcher texted lewd remarks about women co-workers (I think I might wane to fuck Georgette first Ex. B (Hatcher Dep, 1491928; 155:16-2D “Just like to spin her on my dick Io”) As the ccurt noted in Johnson, supra, evidence of how an employer sexually harassed other employees is “relative and probative of [its] general disrespect and sexual objectification of female employees. 1d. at 765. Here, there is plonty of such evidence. Gc. Bailu smont Is Not A Dofons ili UHW argues that Sturge’s harassment claim should be dismissed because she failed to report some of the harassment that ocurred prior to her assault. However, this argument, know as the “avoidable consequences” defense, is not a defense to liability and thus has no place on summary judgmont. As the California Supreme Court noted in McGinnis, 91 Cal, 4th at 1049, “An employee's failure to report SUHIW may claim it had no clue as to Bonsaid’s pas, but this ie untrue Bonsaid told UilWs Goneral Counce about the ercamistances surrounding his fermination, and told UW's Deputy Chit of Stat hed been fired. fx. {Bonaaid beps ti 12-15: 612562") Bensaid was outed on UW's own Instagram age az apredator” Ex. P- In any event, the knowledge of UHW's employees Enehuding Bonsai) is imputed to UHW. CACL 1012, 10