11-17-2025 Council Documents - Regular Meeting

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� h I suggests that gender was a substantial moving factor for any adverse employment action taken 2 against her. Plaintiff claims that individual Councilmembers acted "increasingly hostile and 3 irrational" and subjected her to "personal attacks" (Complaint at ¶ 31), without reference to any 4 specific examples of hostility indicating a gender -motivated animus towards her. Similarly, 5 Plaintiff claims she was subjected to gender discrimination because individual Councilmembers 6 "made their views clear through their words and actions that a woman cannot be City manager" 7 (Complaint at ¶ 33), without pointing to which words or actions suggested that she could not 8 serve as City Manager because of her gender. Plaintiff's allegations of the City Council's gender- 9 bias against her are undermined by the City Council's decision to appoint Janelle T. Cameron — a 10 woman — as City Manager, following Plaintiff's departure. (See RJN, Ex. I (June 3, 2024 City 11 Council Meeting Minutes.) Nothing in the Complaint suggests that the City's conduct alleged in 12 the Complaint was because of or motivated by Plaintiff's gender. Absent any such allegations and 0 0 o� P 13 supporting evidence, Plaintiff cannot prevail on her gender discrimination claim. Additionally, for T 14 the reasons discussed in Section IV(B)(1), supra, Plaintiff cannot demonstrate that she was the " 15 � U subject of a constructive termination, nor that she was terminated was because of her gender. All 16 told, Plaintiff cannot demonstrate any facts supporting her claim of gender discrimination. 17 V. CONCLUSION 18 Plaintiff's Complaint demonizes the City's Councilmembers for engaging in conduct that is quintessentially protected by the First Amendment. Plaintiff cannot identify a single example of 19 20 conduct taken outside of the Councilmembers' scope of official duties, and beyond their capacity 21 as elected officials advocating for their constituents' needs; nor can Plaintiff point to a single law, 22 statute, or ordinance proscribing the Councilmembers' conduct, beyond vague references to the 23 City Charter. Plaintiff advocates for a deeply unsettling precedent of punishing City officials for 24 conduct necessary to maintain a "modern representative democracy." (Levy, supra, 114 25 Cal.App.4th at p. 1261.) This action is the exact type of case the legislature sought to deter in 26 enacting the anti-SLAPP statute. For all of the above -stated reasons, the City respectfully requests 27 that this Court grant the instant anti-SLAPP motion, striking the entirety of Plaintiff's Complaint, 28 and granting the City's request for its reasonable attorneys' fees in bringing the instant motion. 2.0 Defendant's Special Motion to Strike Plaintiff's Complaint (Anti-SLAPP) 12976111.1 SA213-005