Free Motion for Miscellaneous Relief - District Court of Arizona - Arizona

AFFlD1\Vl`!` OF BETH ANN D'AGU.¢‘tNNO
STATE OF ARILONA l
_ lss
_ County of Maricopa l
· I, Beth Ann l.)`.r{\gl.1Bl1IlO, state that the following facts are true: l
“l. l am a forty--year·oId woman;
nlhis affidavit is based upon what I personally saw and heard when l worked at .
` U ‘ ABC Supply, Inc., at 7-15 West Broadway, in Mesa, Arizona;
· I 3. ` - I worked asa Purchasing Agent at ABC- Supply from approximately September
__ I 1-1,.2OOQ toi approximately February 2, 200t; ` I .
4. During the {ew months that l worked at ABC Supply, I was sublected to sexual
" harassment by my male supervisors and co-employees on almost a daily basis;
5. For example, the first day that l starting work at ABC Supply, most ol the
_ .1 ` z; _company'.s ·male employees starting staring at my chest and at my behind in a
= l ‘ _-‘very obvious, sexual way. This made me iael ve·y uncomfortable; .
6. A few days later, several of the male employees started to make comments
about my body, like "boy, you have a nice huttf "you have a great ass" and
other similar comments;
7. They also started to make comments about "what they would like to do with
‘ ` L _ my ass" and similar comments;
_ ` _ _ _ At least once when l walked into the front office, Assistant Manager Pedro
__ ` - ’ Santiago and Yard Foreman Roger Sole said "I srnell pussy"; _
_ ‘ ‘9,r.- _ Oo about_io‘ur·o_cc_asions,when I went into the.restroorn,.a yardworker named _
l ` . ` _ J l ‘ _ Brian‘C_hinava`r.'banged on the-tdoor? sohard that l thought that itwas going t_o‘· ‘ -
_¥ · ‘ come—offjth_e hinges: l - l ‘ ‘ ‘
T . ” On at two occasions, Brian Chinavar slapped me on the butt and said
llsorry, I just couIdn‘t resist" or “nice ass";
_ `l'l. On at least two occasions, Roger Sole grabbed his crotch in front of me;
. 1 .
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12. hir- Rich Toddey was the Dispatcher at AHC Supply and served as my
immediate suaervisor; -
l {E13. On more than one occasion, Rich Toddey, Brian Chinavar, and a truck driver
` named Marvin Ternik would also try to rub against my chest and my behind
when they walked past me in the hallway and would tell me that "the only thing
that wcmert vvere QOOEI lor was 10 please a mart";
i iiilit Hich loddey would also ask me to have sex with him and said that he wished
that his wile was my age hecause he had heard that women my age are in their
° ` prime sexually; -
.;.15. On one occasion, Rich Toddey also pinched my butt while he was walking ‘
i -.3 _ behind me in the hallway} ·
_ its · _ . - -
_ l ’i1`6_. Rich Toddey would- also tell me that his `wife did-a't sexually satisfy him and
i ` vvouldask me if I thought l could sexually satisfy. hirn;‘ -
17. Marvin `lernik would also ask me whether l had ever tried certain sexual
_ ` ` _ _ ‘ positions and would frequently ask rneto go out with 'nirn;
T _ ‘ - 18. On at le-ast two occasions, Pedro Santiago and Lance Patterson would- ask me _
‘ whether-l gaae "good head"; . _
19. Pedro Santiago, Lance Patterson, Flichard Oliver, and Roger Sole also frequently
. talked about "giving head" and oral sex in front of me;
20. Roger Sole, Brian Chinavar and Marvin `lernik would also push each other into
· ‘ i` me and try to rub against me; _
` _ ` 21 ._ All ot these men spoke this way on almost every single day; ·
_ - i} 22. At first I tried to ignore them, hoping that they would stop_when I didrft
· S` _`#_ ‘ prespond to· their offensive jokes and behavior; _- _ _ -_ . ._ _ __ . _ _ . _ _. `
. I also told t-l·m that I had a boylriendand that I wasnot in"terest_ecl in `tltm at ` " "
_ . _‘_. — their personallives. ‘ _
l _ 24. l watlld also tell them {and sornetimesyell at them] to stop anti to Sl}i.l·l¢U|3'§
l `25. When they continued to talk-this way, I finally complained to one of my
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supervisors about it, Center Manager Ms. Frankie 'I`*,:ree;
26. Although Ms. Iyree told them to stop sneaking to me that way, they just
i` laughed about it and none of them ever stopped;
- 27. l Moreover, although I was supposed to r_ecei—.·e on-tire-jotrtraining to do myjob
Q ,as a Purchasing Agent, I never recei·.¤ed.the training that I was required to-do
` rny job; l l l
I was terminated from ABC Supply on approxirnatefy February 2, 2001 by
" · Assistant Manager Pedro Santiago. illtltough I asked Mr- Santiago why I was
` being fired, he refused to tell rne;
` P A __.. 2-9. l I subsequently called John Sirnonetli, the ABC Regional Managery in-ordiertorask -
· him why I had been fired. and to tellhim that I was being sexuatty harassed;
l I: 30. l .Mr. Sirnonelti refused to Iistento meand simply told-me that Ms-. Tyree had told _
- him that I had--quit; ‘
31- During the entire time that I worked at ABC Supply, I never received any
r training regarding sexual harassment or job discrimination.
( s I ,rM»wO
I3eth Dhftguanno /’
`i‘ SUBSCRIBED ANU SWORN to before me this Y"` day of I\/larch 2002- . - _
.-•,__ APRIL ROLL
- F mmwnue-mm _ ‘ _
·i¢¤v¤C¤mcy .. ·
. ‘ ` Notary ubhc - ‘
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