Case 3:20-cv-08258-MMC Document 1 Filed 11/23/20 Page 1 of 25 Timothy B. Sottile, Esq. SBN: 127026 1 Michael F. Baltaxe, Esq. SBN: 129532 2 Payam I. Aframian, Esq. SBN: 299345 Victoria V. Felder, Esq. SBN: 304894 3 SOTTILE BALTAXE 4360 Park Terrace Drive, Suite 140 4 Westlake Village, California 91361 Telephone: (818) 889-0050; 5 Facsimile: (818) 889-6050 6 CHURCH STATE COUNCIL 7 Alan J. Reinach, SBN. 196899
[email protected] 8 2686 Townsgate Road Westlake Village, CA 91361 9 Tel: 805-413-7398 Fax: 805-497- 3828 10 Jonathon Cherne, SBN. 281548 11 Of counsel
[email protected] 12 Counsel for Plaintiff Peter Fretwell 13 UNITED STATES DISTRICT COURT 14 NORTHERN DISTRICT OF CALIFORNIA 15 16 Civ No. 20-8258 PETER FRETWELL, 17 COMPLAINT FOR ECONOMIC, Plaintiff, COMPENSATORY AND PUNITIVE 18 v. DAMAGES, AND INJUNCTIVE RELIEF 19 BOARD OF TRUSTEES OF THE 1. Harassment, Title VII 20 CALIFORNIA STATE UNIVERSITY 2. Discrimination, Title VII 3. Retaliation, Title VII 21 Defendants. 4. Violation of Gov. Code §8547 et seq. 5. Violation of Labor Code §§ 98.6 & 1102.5 22 6. Harassment, Gov. Code § 12940, et. seq. 7. Discrimination, Gov. Code § 12940 et. seq. 23 8. Retaliation, Gov. Code § 12940, et. seq. 24 9. Failure to Prevent Harassment and Discrimination, Gov. Code § 12940 et. seq. 25 JURY TRIAL DEMANDED 26 27 Peter Fretwell, by the undersigned, his attorneys, hereby files his complaint. 28 1 FRETWELL v. CSU COMPLAINT Case 3:20-cv-08258-MMC Document 1 Filed 11/23/20 Page 2 of 25 INTRODUCTION 1 Plaintiff Peter Fretwell was a seasoned radio management professional who was recruited to 2 take over a Humboldt State University (“HSU”) radio station, KHSU, that had been controlled by 3 volunteers and community leaders for as long as anyone could recall.