Cathy Kirkwood v. HCA Healthcare, Inc.

I. BACKGROUND

On April 3, 2025, Plaintiff Cathy Kirkwood (“Plaintiff’ or “Kirkwood”) filed this workplace retaliation and discrimination case against Defendants Los Robles Regional Medical Center, Los Robles Hospital & Medical Center, HCA Healthcare, Inc., and Does 1-50 (collectively, “Defendants”) in Ventura County Superior Court. ECF 1-1 (Compl.). The Complaint alleges as follows: Kirkwood was employed as a per diem Cytologist in the Anatomic Pathology Department at Los Robles Medical Center (the “Hospital”) between October 10, 2022, until her termination on December 20, 2024. Jd. 9] 1, 2. Kirkwood’s employment was governed by a Collective Bargaining Agreement (“CBA”), and Plaintiff was represented by SEIU United Health Care Workers — West. ECF 1-13 (Gardner Decl.) § 2, Ex. L (“CBA”). In or about June 2023, Kirkwood complained to her direct supervisor, Zin Htway (“Htway”), about her breast tissue being exposed to radiation because the employer-provided lead apron was not custom fitted. Compl. Jf 2,6. Htway ignored her repeated complaints. Jd. Despite escalating her complaints to Htway’s supervisor, she continued to…