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Id t1

2

3

4

5

6

7

8

9

10

11

12

13

1 i

Q 2

U

i

'')

then handed Plaintiffan eleven-page document,

printed

from

the

Department's briefing room

printer,

which

detailed

more ridiculous and incredibly

anti-Semitic

propaganda, and

suggested

that Plaintiff should

learn

more about his religion.

21. Inor around December

of

2011, Plaintiffwasapproached in the parking

garage

of

the

station

by

a

fellow

officer

and asked, in front

of

supervising

officers, if

he

knew

why Jews

and

Arabs keep fighting

each other

like cats and dogs.

No supervising officers

intervened.

22. Inaddition to the confrontations above, throughout his time with the Department,

Plaintiffhas been scheduled and forced to work on Jewish holydays, despite repeated and prior

requests

to not be scheduled on

such days.

When Plaintiffmade these requests,

he

was told that

he

had

nochoice, and that adverse employment actionswould be takenagainst him if hedidn't

work the

days

as

scheduled.

Based

upon

information

and

belief,

the

Department

made

no

effort

to schedule around the holy days observed by Plaintiff.

23. Plaintiff also had particulardifficulty meeting his requiredfirearm range

qualifications, because

range managers,

including two

in

particular,

refused to

schedule Plaintiff

ondays that did

not

conflict with his

observed religious holidays

and

worship, despite

Plaintiffs

repeated

requests. Based upon information and belief, they did

this

with the

intent

to make it

difficult for Plaintiff to make his firearm qualifications.

24.

During

a

meeting

onor

about February

6,

2012, with

Sergeants

Eric

Gaunt

and

Lou

Warnick, Plaintiffagainmadea formal complaint about theanti-Semitic and racist

treatment

from fellow and superior officers.

When this

issue was brought up, Sergeant Gaunt replied let's

notgo there, making it clearthat

neither

henor the Department

had

any

concern

about the

treatment received by Plaintiff, and did not intend to do anything about it.

25. During thatsame meeting, Plaintiff

informed

his superiors ofothermisconduct

and unlawful behavior by fellowofficers that he had witnessed. Plaintiff was told that the

purpose

of themeeting was not to talkaboutthose

issues.

Immediately thereafter. Plaintiff

was

asked to leave for a few minutes as the others wanted to speak amongst themselves. He was also

asked if he had been tape recording the meeting, which he did not.

26 .

When Plain ti f fwas

asked back in to the room , he

was

to ld that h e

was

no t

COMPLAINT

5

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SHORT

TITLE.

Siounit v. City of Palos Verdes Estates

CASE

NUMBER

>

on

o

a

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c

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a>

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in

5=

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2

o

r...i

Y>

f> ;

A

Civil Case

Cover

Sheet

Category No.

B

Type of Action

(Check only one)

c

Applicable Reasons -

Se e

Step

3 Above

Asset

Forfeiture (05)

D

A6108 Asset Forfeiture Case

2. ,

6.

Petition re Arbitration (11)

O A6115 Pet it ion to Compel/ConfirmA/acate Arbit ration

2.,

5.

Writ of

Mandate

(02) '

A6151 Writ -

Administrative

Mandamus

A6152 Writ -

Mandamus on Limited

Court

Case

Matter

Q A6153

Writ-Other

Limited Court

Case

Review

2 , 8 .

2.

2.

Other

Judicial

Review

(39)

D A6150 Other Writ/Judicial Review

2. . 8.

Antitrust/Trade Regulation (03)

O A6003 Antitrust/TradeRegulation

1 2 8

Construction Defect (10)

D A6007 Cons t ruc ti on Defec t

1 .2 . , 3.

Claims Involving

Mass

Tort

(40)

D A6006 Claims InvolvingMass Tort

1 2.. 8.

Securities Litigation (28)

Q A6035 Securit ies LitigationCase

1., 2 , 8.

Toxic To rt

Environmental (30)

O

A6036

Toxic Tort/Environmental

1.. 2., 3., 8.

Insurance

Coverage

Claims

from

Complex Case

(41)

D A6014 Insurance Coverage/Subrogation (complex case only)

1., 2 ,

5. ,8.

Enforcemen t

of

Judgment

(20)

Q A6141

Sister State Judgment

a A6160 Abstract of Judgment

D A6107 Con fes siono f Judgment (non-domestic relations)

O A6140 AdministrativeAgency Award (not unpaid taxes)

O A6114 Petition/Certificate for Entry of Judgment on Unpaid Tax

D A6112 Other Enforcement of Judgment

Case

2 , 9 .

26.

29 .

2 . 8 .

2 . 8 .

2 . 8 , 9 .

RICO (27)

O A6033 Racketeer ing (RICO)

Case

1 .. 2 ., 8.

Other Complaints

(Not Specified Above) (42)

D A6030 Declaratory Relief Only

D A6040 Injunctive Relief Only (not domestic/harassment)

Q A6011 Other Commercial Complaint

Case

(non-tort/non-complex)

D A6000 Other CivilComplaint (non-tort/non-complex)

1..2..8.'

2,8 .

1 , 2 , 8 .

1 , 2 . 8 .

Partnership

Corporation

Governance

(21)

D A6113

Partnership and Corporate Governance Case

2 ,8

Other Peti t ions

(Nol Specified Above)

(43)

O A6121 Civil

Harassment

D A6123 Workplace Harassment

D A6124 Elder /Dependent Adul tAbuse

Case

D A6190 Election

Contes t

O A6110 Petition for Changeof Name

D A6170

Petition

for

Relief from

Late

Claim Law

O

A 61 00 O th er

Civil

Petition

2. . 3., 9.

2 , 3 . 9 .

2. . 3., 9.

2.

2

7.

2., 3 ., 4 , 8.

2 , 9 .

LASIV 109 (Rev. 03/11)

LASS Approved

03-04

CIVIL CASE COVER SHEET

ADDENDUM

AND STATEMENT

OF LOCATION

Local Ru le 2 .0

Page 3 of 4

7/26/2019 Benjamin Siounit v Palos Verdes Estates Police Department Complaint 01-28-2013

18/18

SHORT

TITLE:

Siounit v. City of

Palos Verdes Estates

CASE NUMBER

Item

III. Statement

ofLocation:

Enter

theaddress oftheaccident, party's residence or

place

ofbusiness,

performance,

or

other

circumstance

indicated

in Item II.,

Step 3 onPage

1,

as theproper reason

for

filing

in

the

court

location

you

selected.

REASON:

Check the appropriate

boxes

for

the numbers shown

under Column C for

the

type of action

that

you have

selected

for

th is c a s e .

1.

D2. 03 .

D4. D 5.

D 6. D 7.

D8.

Q9.

D10.

OTY:

Palos Verdes

STATE;

CA

ZIP

CODE:

90274

AOORESS:

City of

Palos Verdes

Estates

34 0

Palos

Verdes Dr West

Item

IV. Declaration

ofAssignment.

I

declare under penalty

ofperjury

under

the laws oftheStateofCalifornia thatthe foregoing is

true

and correct and

that the

above-entitled matter is

properly filed

for

assignment to

the

Stanley Mosk courthouse in

the

District of theSuperiorCourtof

California,

County of Los

Angeles

[Code

Civ.

Proa, 392 et seq., and Local

ent ra l

Rule 2.0, subds. (b), (c)

and

(d)J.

Dated: 01/28/2013

(SIGNATURE OF ATTORNY/FILIN