Harkins

FACTS

Plaintiff had a long-time career with the Angels, beginning in 1981 as a batboy and ending with his sudden firing in early 2020. During the last 10 years of his tenure, he worked as the visiting clubhouse manager. In that role he provided hospitality at Angels Stadium of Anaheim to visiting teams, which included fulfilling their requests for food, drinks, equipment and other items. In the first few days of March 2020, plaintiff was called to a meeting with the Angels’ general manager, Billy Eppler, and its attorney, Alex Winsberg. They advised him he was being terminated and provided two different explanations. According to plaintiff, they first said the team received “some non-descript complaints about [his] ‘communication skills’ which were affecting [his] management of the clubhouse.” Not believing what was said, plaintiff pushed for the true story. In response, Eppler provided plaintiff with a memorandum written by the senior vice-president of on-

1 All further statutory references are to the Code of Civil Procedure unless otherwise specified.

2 field operations and umpiring for Major League Baseball, Chris Young (the Young memo). The Young memo, dated three days…