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The pleading alleges retaliation and multiple civil and labor-law violations, including alleged discrimination and wrongful adverse treatment, and demands a jury trial. It outlines jurisdiction and venue, describes the parties, and sets forth common facts, including Plaintiff’s career progression and alleged abusive conduct by a board member beginning in October 2018, plus conduct related to stipends and meeting practices.",{"@graph":63,"@context":118},[64,80,101],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/1-complaint-2-complaint-for-retaliation-and-related-claims/302847/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/1-complaint-2-complaint-for-retaliation-and-related-claims/302847.png","ImageObject",442,249,{"name":88,"@type":89},"Skyler","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-09-27","2026-09-19",true,{"@type":98,"interactionType":99,"userInteractionCount":47},"InteractionCounter",{"@type":100},"ViewAction",{"@type":102,"mainEntity":103},"FAQPage",[104,110,114],{"name":105,"@type":106,"acceptedAnswer":107},"Who is the plaintiff in this complaint?","Question",{"text":108,"@type":109},"The plaintiff is Carolina Manzano, identified as the “PLAINTIFF” in the pleading.","Answer",{"name":111,"@type":106,"acceptedAnswer":112},"Which court and venue are stated for the case?",{"text":113,"@type":109},"The complaint states jurisdiction in the U.S. District Court for the Southern District of California and provides venue based on where the events or omissions giving rise to the claims occurred.",{"name":115,"@type":106,"acceptedAnswer":116},"What kind of legal relief is requested?",{"text":117,"@type":109},"The document includes a “JURY TRIAL DEMANDED” request.","https://schema.org",{"og:url":78,"og:type":120,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":122,"canonical":78},"index,follow",{"doc_id":124,"site_id":56},302847,1790239169,{"code":4,"msg":5,"data":127},{"doc_id":124,"user_id":128,"nickname":88,"user_avatar":129,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":47,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":20,"language":135,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":136,"faqs":137,"seo_title":138,"seo_description":61,"update_tm":139,"read_time":47},2336464648746,"https://ap-avatar.wpscdn.com/davatar_276721f389ce27ea32af1340a28f341c","Case 3:20-cv-02130-BAS-BGS Document 1 Filed 10/30/20 PageID.1 Page 1 of 14  \n1 D . N . BRADY, Bar No . 118461 SAN DIEGO EMPLOYMENT LAW GROUP  \n2 3517 Camino del Rio South, Suite 400 San Diego, California 92108  \n3 Telephone: (619) 528-2530  \nEmail: [gradyfedonly@msn.com](gradyfedonly@msn.com)  \n4  \n5  \nAttorneys for Plaintiff, CAROLINA MANZANO 6  \n7 UNITED STATES DISTRICT COURT  \n8 SOUTHERN DISTRICT OF CALIFORNIA 9  \n10 CAROLINA MANZANO ) Case No . '20CV2130 JM BGS )  \n11 Plaintiff, ) COMPLAINT FOR)  \n12 v . ) (1) RETALIATION IN CIVIL  \n) VIOLATION OF THE FEDERAL AND  \n13 SOUTHERN INDIAN HEALTH COUNCIL, ) CALIFORNIA FALSE CLAIMS INC . ; and DOES 1-50, inclusive, ) ACTS;  \n14 ) (2) CIVIL VIOLATION OF) CALIFORNIA LABOR CODE  \n15 Defendants . ) § 1102 .5;  \n) (3) CIVIL VIOLATION OF  \n16 ) CALIFORNIA LABOR CODE) § 232 .5;  \n17 ) (4)DISCRIMINATION IN) VIOLATION OF THE UNIFORMED  \n18 ) SERVICES EMPLOYMENT AND) REEMPLOYMENT RIGHTS ACT OF  \n19 ) 1994; AND  \n) (5)WRONGFUL ADVERSE  \n20 ) TREATMENT INCLUDING WRONGFUL) DISCHARGE IN VIOLATION OF  \n21 ) PUBLIC POLICY .  \n)  \n22   ) JURY TRIAL DEMANDED  \n23  \n24  \n25  \n26  \n27  \n28  \n1  \nCOMPLAINT  \nCase 3:20-cv-02130-BAS-BGS Document 1 Filed 10/30/20 PageID.2 Page 2 of 14  \n1 PLAINTIFF, CAROLINA MANZANO, (“PLAINTIFF”) complains and  \n2 alleges as follows: 3  \n4  JURISDICTION  \n5 This court has jurisdiction under 28 U .S .C . § 1331 and  \n6 28 U .S .C § 1367.  \n7 VENUE  \n8 The events or omissions giving rise to Plaintiff's  \n9 claims occurred in this judicial district, thus venue is proper  \n10 here pursuant to 28 U .S .C . § 1391(b)(2) .  \n11  \n12  PARTIES  \n13 1. PLAINTIFF, at all times relevant hereto, was a resident  \n14 of the State of California, County of San Diego .  \n15  \n2. PLAINTIFF is informed and believes, and thereby 16  \nalleges, that DEFENDANT the SOUTHERN INDIAN HEALTH COUNCIL, 17  \nINC . (\"SIHC\") is a California organization with its principal 18  \nplace of business in California and qualified to do business in 19  \nthe State of California, at all times relevant to this lawsuit, 20  \n21 with business operations in San Diego County where PLAINTIFF  \n22 worked .  \n23  \n3. The true names and capacities of the DEFENDANTS named 24  \nherein as DOES 1 through 50, inclusive, whether individual, 25  \ncorporate, associate, or otherwise, are unknown to PLAINTIFF who 26  \ntherefore sues such DEFENDANTS by fictitious names pursuant to 27  \nCalifornia Code of Civil Procedure § 474. PLAINTIFF is informed 28  \n2  \nCOMPLAINT  \nCase 3:20-cv-02130-BAS-BGS Document 1 Filed 10/30/20 PageID.3 Page 3 of 14  \n1 and believes that DOE DEFENDANTS are California residents .  \n2 PLAINTIFF will amend this Complaint to show such true names and  \n3 capacities when they have been determined .  \n4  \n4. PLAINTIFF is informed and believes, and thereby 5  \nalleges, that at all relevant times, each of the DEFENDANTS acted 6  \nas a principal, agent, representative, or employee of each of the 7  \nother Defendants and acted, at least in part, within the course 8  \nand scope of said agency, representation or employment, and with 9  \nthe permission and ratification of each of the other Defendants . 10  \n11  \n12  FACTS COMMON TO ALL CLAIMS  \n13 5. In 2004, PLAINTIFF started her career as a Dental  \n14 office Manager at the SIHC . In 2005, she was promoted to Chief  \n15 Operations Officer . In 2011, PLAINTIFF was promoted to Chief  \n16 Executive Officer . PLAINTIFF has over 24 years of working  \n17 experience in the health care industry . She has an ability to  \n18  \nsuccessfully manage, support, maintain, and provide excellent 19  \nhealth services to any community clinic .  \n20  \n6. In October, 2018, PLAINTIFF became a victim of 21  \noutrageous abuse from Brian Connolly (“CONNOLLY”) , a member of 22  \nthe SIHC Board .  \n23  \n24 7. CONNOLLY frequently raised his voice in a demeaning way  \n25 to PLAINTIFF, a Hispanic, harassed her, stared at her, and made  \n26 fun of her Spanish accent .  \n27 8. In October , 2018 , the","cbCaiiw8wUC3DFq5","https://ap.wps.com/l/cbCaiiw8wUC3DFq5","pdf",233853,"English","# Jurisdiction\n# Venue\n# Parties\n## Plaintiff\n## Defendants\n# Facts Common to All Claims\n## Employment history and qualifications\n## Alleged abuse in October 2018\n## Board meeting conduct and stipend practices","[{\"question\":\"Who is the plaintiff in this complaint?\",\"answer\":\"The plaintiff is Carolina Manzano, identified as the “PLAINTIFF” in the pleading.\"},{\"question\":\"Which court and venue are stated for the case?\",\"answer\":\"The complaint states jurisdiction in the U.S. District Court for the Southern District of California and provides venue based on where the events or omissions giving rise to the claims occurred.\"},{\"question\":\"What kind of legal relief is requested?\",\"answer\":\"The document includes a “JURY TRIAL DEMANDED” request.\"}]","1-complaint-2 - Complaint for Retaliation and Related Claims | PDF",1789798157]