Garrett

I. BACKGROUND

1 Plaintiff Tavernier was employed by OUSD as the Financial Services Director of Budget. 2 Compl. ¶ 5. In that capacity, she oversaw a staff of 14-16 financial analysts. Id. ¶ 18. The 3 Complaint alleges that some of those financial analysts received stipends while four financial 4 analysts—three of whom were Black employees approximately sixty years old—did not. Id. 5 More specifically, the Complaint alleges that Defendant Tara Gard intentionally withheld the 6 stipends from Tavernier’s employees. Id. ¶ 20. Tavernier opposed this perceived discrimination 7 by processing the stipends herself without the approval of Human Resources. Id. As a result, 8 Tavernier was put on administrative leave. Id. ¶ 21. 9 Jenine Lindsey, OUSD’s Director of Labor Relations, investigated Tavernier’s alleged 10 misconduct. See id. ¶¶ 28-30. Plaintiff Tavernier alleges that, during this investigation, Jenine 11 Lindsey falsely represented herself as a neutral arbiter and attorney despite ultimately being the 12 prosecutor in Tavernier’s Skelly hearing. Id. Plaintiff Tavernier was ultimately terminated for 13 financial mismanagement. Id. ¶ 21. Based on these facts,…