Set 10 12 13 “ 15 16 7 18 19 a 24 25 28 THE VAN VLECK LAW FIRM, LLP ‘Brian F. Van Vleck, State Bar No. 155250 Stuart H. Kiuft, Start Bar No. 315081 5737 Wilshire Blvd., Suite 535 Angeles, California 90036 eh ene: oR 520-0250 Attomeys ene, Njoki Woods FILED PERNT SE RE JUL 16 2019 A, Hemandez gS SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF RIVERSIDE SERVICE EMPLOYEES INTERNATIONAL UNION, UNITED HEALTHCARE WORKERS |- WEST; AND DAVE REGAN, Plaintiffs, INJOKI WOODS, Defendant, Case No. RIC1902014 ‘Assigned for All Pi Hon. Sunshine S. Dept. 06 DECLARATION OF YVONNE MELTON BECTARATION CAi wm soe Tt ine eG BB1, Yvonne Melton declare as follows: 1. The facts in this declaration ere within my personel knowledge, and if called on as a witness, I could competently testify thereto. 2. Twas hired on as @ full-time union organizer for SEIU-UHW (“Union”) on February 14, 2017 and had my employment terminated in November 9, 201% I have epproximately 22-23 years of experience as a labor representative in many capacities. "3. As a.union organizer for SETU-UHW, I was able to witness several employees get preferential treatment due to the sexnal relationships those individuels had with other employees of| cece rawnrun SETU-UHW. Jn particular, { was aware thet my team member Jennifer Saldana ("Seldana”) had & 10 | sexual relationship with our supervisor Grisell Rodriguez's (“Rodriguez”). 1 know this because 11 | Saldana made a public apology to our team about this relationship. 1 also made observations of| 12] Saldana and Rodriguez's relationship while working with them that Saldana's employment 13 | benefitted from this relationship, as Rodriquez would give her preferential treatment over all the 14 [other team members, despite the other team members, me included, outperforming her. 15 4, 1 was aware and have had conversations with members of SEIU-UHW that some 16 | other employees of SEIU-UHW including, Dave Regan, and Marcus Hatcher had sexual relations 17 | with members and staff of the Union. Also Stan Lyles, a Vice President of SEIU-UHW, made 18 | soxually inappropriate comments at work to me that made me very uncomfortable. 19 5. Lam aware that Mindy Sturge (“Sturge”) was a subordinate of Marcus Hatchér and 20 | Dave Regan while employed for SEIU-UHW, but now Sturge is suing the Union and Hatcher for 21 | the sexual harassment she received while employed for SETU-UHW. 22 6. Throughout my employment for SEIU-UHW I had personal knowledge that Dave 23 | Regan hed drank alcoho! while serving his duties as president of the Union. For example, I was 24 | present in Executive Board Meetings where President Dave Regan was drinking alcohol and 25 | exhibiting symptoms that he was intoxicated. 1 also went to a team building meeting in Burbank, 26 | CA where Dave Regan was present and I could smell alcoho! on his breath when } spoke with him. 1 also have had conversations with members of SEIU-UHW regarding Dave Regan Regan’s 28 | elcohol consumption while he was working in the capacity of a president for the Union, T was told TDRCTARATION OF YVONNE HELTON 8 nxn aoe aan een 10 12 3B 14 15 16 7 18 19 a fhe had a “reputation” of drinking and being violent, and getting into fights because he stands his ground on things, 7. 1 witnessed racism on several occasions while working for SEIU-UHW. Specifically, an instance I recall occurring in October 2017 where I was present and Judith Bustamente (“Bustamente”) had an altercation with Njoki Woods and had called her a “black bitch.” I then overheard Rodriguez speaking with Bustamente and Saldana that they “are going to got that black bitch fired” which I understood meant Njoki Woods. 1 told Njoki of their comment about getting her fired and calling her a black bitch, 8, I also witnessed further racism from Rodriguez when she would segregate the [African American team members and the Latino/Hispanic team members and made racist statements like “chingona” and statements like “go sit with your peers,” which I understood meant to apply to member's race. 9, T'was told by Rodriguez, Pearson Woods, and Ryn Schneider that I had no choice but to give money to COPE (“Campaign On Political Education”) and campaign on my personal time for the SEIU-UHW executive board elections because Thad to “hit my mumbers.” I declare under penalty of porjury under the laws of the State ‘of California that the foregoing is true and correct. Executed this July 9, 2019, at Downey, Californie. Yvonne Melton