Limousin says she also reported Greenia's "abuse of authority and violation of law" to the independent auditors.
"Greenia's selection of candidates was based upon prior personal relationships rather than qualifications. Despite the lack of requirement or need for a project specialist, Greenia insisted upon hiring his friend Galvan who was not qualified for any specific business need. In January 2011, Greenia decided that a communications director was necessary, over objection of other directors. Two highly qualified female candidates were interviewed and recommended by the panel. Greenia directed that his friend Lalich be hired for the position over the recommendation of the panel against his hire due to lack of qualifications in the business," according to the complaint.
Greenia, Galvan and Lalich openly derided gays and lesbians - at one time asking Sziklai if she "ate steak," which apparently was a code word for lesbians. They also made derogatory race-based comments and pejorative statements about handicapped people, according to the complaint.
Sziklai says she told auditors that Greenia ordered her to alter the results of Medi-Cal's auto-assignment rules, the process which assigns beneficiaries to clinics and physicians. When she refused, she says, Greenia threatened to fire her.
"PCP auto-assignment rules were not openly and accurately communicated to the commission or providers. After assignments were made, Greenia instructed Sziklai to alter the assignment results in violation of Medi-Cal laws. Sziklai refused to alter the results. Thereafter, Greenia threatened to fire her and instructed that she was not to provide the outcome of selection and assignment results to providers," Sziklai says in the complaint.
Greenia's harassment of Sziklai escalated the more she questioned, according to the complaint.
"Commencing in the beginning of August 2011, whenever Sziklai raised operations questions to Greenia, Galvan or Lalich, she would be told 'You need to talk less and smile more.' Such statements were not made to any male employees. Sziklai was also repeatedly informed by Greenia, Galvan and Lalich that 'loyalty is more important than competency.' Sziklai is informed and believes that those statements were not made to male employees. These refrains were further directed at Sziklai by Bower. Simultaneously, she was frequently told that she was doing a superior job as COO and that there were no performance issues," Sziklai says in the complaint.
Sziklai claims she also told investigators that Greenia kept a $250,000 slush fund and regularly altered organization charts, changed employee titles and unilaterally reallocated budgets.
"Financial accounting problems result[ed] in inability to reconcile accounts with between $500,000 and more than $1,000,000 remaining unaccounted for," Sziklai says in the complaint.
After the investigation by independent auditors, Greenia announced plans to bring in an investigator of his own from defendant - and county-run - Regional Government Services. According to the complaint, he said he wanted to explore rumors that Sziklai had "coached employees to tell the auditors everything that was wrong with GCHP."
Five days later - before any investigator interviewed them - Limousin and Sziklai, Bower fired them via telephone and email, providing with no reason for the termination. Neither received the company-standard progressive discipline or coaching before being fired, they say.
One week after firing Limousin and Sziklai, Greenia resigned, telling his bosses at the Ventura County Medi-Cal Managed Care Commission that "he made the decision with sadness but though it was best for him," according to the Ventura County Star.
Both women claim that after Greenia resigned, Bower begged them not to initiate wrongful termination proceedings, promising them that they would be rehired. They say that county and commission officials told them the same thing.
But that's not what happened, they say.
"Subsequent to Sziklai's and Limousin's termination of employment, Kapustay, health services director, made a false statement to the Ventura County Star newspaper, under color of authority as a director and as an employee of RGS and GCHP that Sziklai's and Limousin's terminations were 'justified.' Bower was requested to obtain a retraction and to address the apparently authorized false statements being made to the media by an RGS and GCHP employee. Bower refused to do so.
"Subsequent to the termination of Limousin and Sziklai, and on the eve of the commission meeting that Bower had represented she would recommend reinstatement, but instead recommended against reinstatement, Bower informed Sziklai and Limousin that an 'independent' investigation was being conducted into purported racial slurs allegedly made by Limousin and Sziklai. Bower expressly stated that if they did not voluntarily participate in the investigation that the findings would be publicly reported and they could read the results in the commission's minutes or in the newspaper.
"The purported claim[s] of racial slurs were made by Galvan and were completely without merit. Galvan himself engaged in repeated racial slurs against persons of his own ethnicity, made sexually inappropriate comments to Sziklai and about gays and lesbians, and was investigated for harassing two of his direct reports. Galvan, after making his purported claim of racial discrimination, was heard by several people stating that he has 'whistleblower' protection for making these claims. Limousin and Sziklai are informed and believe that the racial slur claims were trumped up by Galvan with the tacit approval of Bower and Greenia, at precisely the same time that Bower advised Limousin and Sziklai that she would recommend their reinstatement, but immediately thereafter informed the commission in closed session that she was against reinstatement," the women say in their complaint.
Closed-door discussions of employment status without giving Sziklai and Limousin notice violated California's Brown Act, the women say. After a four-month independent investigation, they say, both were cleared of Galvan's charges.
According to the complaint, Galvan claimed that Sziklai referred to Latinos as "Mixtecas," and "your people," and called Galvan "boy." He accused Limousin of stating that "Mexicans are nothing more than toilet bowl cleaners" and referring to him in staff meetings as "whatever his name is over there."
Limousin's husband, John Limousin, claims he lost a lucrative real estate deal because of his wife's wrongful termination. He says he entered into an agreement to sell the home of one of his wife's coworkers - nonparty Melanie Frampton - when his wife was fired.
"Plaintiffs are informed and believe that Melanie Frampton and [fiancé] James Alba were instructed by Bower to have no further contact with plaintiffs under threat of loss of Frampton's job with GCHP and RGS. This resulted in Frampton and Alba informing J. Limousin that they could not list their property for sale with him. The property listing with J. Limousin was then canceled and subsequently listed for sale with another real estate broker and recently sold," according to the complaint.
The plaintiffs seek compensatory, special, punitive and statutory damages. They are represented by Fern Nisen of Los Angeles.
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