Howe

BACKGROUND

18 The three plaintiffs – Barbara Howe, Jani Sheppard, and Carol Morgan – are former and 19 current employees of Mendocino County’s Health and Human Services Agency (“HHSA”). Dkt. 20 No. 31 ⁋⁋ 24-26. Their original complaint was filed on April 15, 2020. Dkt. No. 1. Defendants 21 filed a motion to dismiss the original complaint which was granted in part and denied in part. Dkt. 22 No. 28. 23 Allegations re Plaintiff Barbara Howe. Plaintiff Barbara Howe is a former employee at 24 HHSA where she worked from October 2017 – May 30, 2019. Ms. Howe alleges she was 25 “forcefully terminated” through compelled speech when she signed a resignation letter under duress 26 and threat of termination. FAC ¶¶ 285–308. Ms. Howe alleges she made comments on May 15, 27 Program (PHEPP). Specifically, Ms. Howe stated ambulances likely would not be available during the next major disaster like a wildfire because “Carmel Angelo . . . by and through [defendant Tammy Moss Chandler] had disrupted a flexible, multi-company ambulance system to divert the contract to a favored provider.” FAC ¶¶ 215–220. Ms. Howe and co-plaintiff Jani Sheppard also gave HHSA…