SYRYRRL ERY SBRSRELEN SeaRESRE FILED 2022 NOV 01 03:23 PM KING COUNTY SUPERIOR COURT CLERK E-FILED CASE #t: 22-2-18053-6 SEA ‘THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN THE COUNTY OF KING MERCEDES WEDAA NO. Plaintiff, COMPLAINT FOR DAMAGES vs. JEFFREY PRESTON BEZOS, an individual, ZEFRAM, LLC, a Washington Limited Liability Company, and NORTHWESTERN, LLC, a Washington Limited Liability Company, Defendants. 1, NATURE OF ACTION 1.1 Mercedes Wedaa (hereinafter “Plaintiff"), by and through her attomeys of record, HKM Employment Attomeys LLP, requests damages, statutory damages, punitive damages, reasonable attomeys’ fees and costs, in addition to other relief, for the unlawful conduct of her employers, Jeffrey Preston Bezos, Zeftam, LLC, and Northwestem, LLC (hereinafter, “Employers” or “Defendants”, 1.2 Employers discriminated against Plaintiff because of her race, forced Plaintiff HKM EmpLoyMent ATTORNEYSLLP (600 Stewart Stret, Suite 901 COMPLAINT FOR DAMAGES - 1 Seattle, Washington 98101 (206) 838-2504BEL ERYSBRNRRREBRYBSRISTEGHE Sem vr sHeune Skassss sess to work long hours without rest or meal breaks, exposed Plaintiff to unsafe and unsanitary work conditions, retaliated against and wrongfully terminated Plaintiff's employment in violation of the Washington Law Against Discrimination, Washington Wage and Hour laws, ‘Washington Occupational health and safety laws, and other Washington employee protection laws. Il. PARTIES 2.1 Plaintiff Mercedes Wedaa is an individual residing in King County, Washington. At all times material hereto, Plaintiff was employed by Defendants. 2.2 Defendant Jeffrey Preston Bezos is an individual residing in King County, Washington, 2.3. Defendant Zefram, LLC, is a Washington State corporation duly registered and licensed to do business in Washington State and maintains its principal office in Seattle, Washington. 24 Defendant Northwestem, LLC, is a Washington State corporation duly registered and licensed to do business in Washington State and maintains its principal office in Seattle, Washington. IJ, JURISDICTION AND VENUE 3.1 The Court has jurisdiction because all or a substantial portion of the acts complained of herein occurred in King County, Washington. 3.2 Atall times material to this action, Jeffrey Preston Bezos resided in King County. HKM Emp ovMent ATTORNEYS LLP {600 Stewart Street, Suite 901 COMPLAINT FOR DAMAGES - 2 ‘Seattle, Washington 98101 (206) 838-2508SSRLRELERESBRBSRELBN SRLEBE 3.3 Atall times material to this action, Zefram, LLC, conducted business in King County, and maintains its principal office in King County. 3.4 Atal times material to this action, Northwestern, LLC, conducted business in King County, and maintains its principal office in King County. 3.5 This action has been filed within the applicable statutory time periods. 3.6 Venue and jurisdiction are proper in this Court, IV. FACTS 4.1 Plaintiffhas worked as a housekeeper for wealthy/high profile families for 18 years. During this time, Plaintiff was an exceptional employee who never had any performance issues. In many of the previous positions Plaintiff has held, she functioned as lead housekeeper and had supervisory responsibilities. 42 In September 2019, Plaintiff applied for a Lead Housekeeper position through EstateJobs.com, After completing her application and providing references, Plaintiff was interviewed by Leanne Pardo at the Queen Bee Café in Clyde Hill on September 10, 2019. At first, Ms. Pardo questioned Plaintiff about her previous employment. Then, Ms. Pardo asked Plaintiff if she was able to work around a family without being scen. Plaintiff replied in the affirmative. The following day, ‘Ms, Pardo emailed Plaintiffand said: “It was nice chatting with you last night about the job opening for which you interviewed. Thank you for giving me an opportunity to clear up confusion and better articulate the role. I have attached a job description for your review. Can you take a lock at it today and let Ronna (copied here) and me know if you are still interested? Thank you again (and for your patience)!” Attached was a document entitled Household Coordinator Job Description.” Leanne Pardo’s HKM EwrLovMent ATTORNEYSLLP (600 Stewart Street, Suite 901 COMPLAINT FOR DAMAGES - 3 Seattle, Washington 98101 (206) 838-2504BSSSRGEGH oS ems ausun— SRGSSHASSESREE SBE SBBIRBLOV email was Leanne@zeframllc.com and Ronna Crewse’s email was “Ronna@zeframllc.com.” 43° Plaintiffaccepted the position and later on September 11, received an email from Ronna Crewse that had five documents attached; a FCRA Disclosure, a FCRA. Authorization, a Credit Release, a BGI Application, and a WA DMV Release. These authorizations and releases permitted Plaintiff's new employers to obtain Plaintiff's private and confidential information, Ms. Crewse’s electronic signature stated her name, Zefram, LLC, her phone number, and email. 4.4 As House Coordinator, Plaintiff reported to the House Manager, Leanne Pardo. The same Leanne Pardo who interviewed Plaintiff and was part of the Zefram hiring team. Plaintiff was the only employee with a housekeeper role. In early 2020, Plaintiff was occasionally assisted by contractors whom she supervised. A year or so after starting another housekeeper was added. By late 2021, Plaintiffas Lead Housekeeper supervised a team of 5- 6 housekeepers. 45 Plaintiff believed that she was employed by Jeff Bezos. Plaintiff's understanding, and that of many of her coworkers, was that Jeff Bezos hired people to work for him through Zefram, LLC. Plaintiff mainly worked at Jeff Bezos's home/primary residence, however, she also occasionally worked at other residences owned by Jeff Bezos. 4.6 The housekeeping team were all Hispanic (except for Kristina Gach who was ‘Caucasian and did not join until ate 2020). There was no breakroom for the housekeepers. Even though Plaintiff worked 10, 12, and sometimes 14 hours a day, there was no designated area for her to sit down and rest. Plaintiff and other housekeepers would try and eat some HKM EnrLovMent ATTORNEYSLLP COMPLAINT FOR DAMAGES - 4 Geatnr Washingt 9510 (206) 838-2504SSGPSSASSESKELEBESBRIRRRORBSSIRREGHE Sear sneun— food in the upstairs laundry room, which was very small, only about 10 x 6 ft, and without seats or appliances like a microwave or fridge. No information from the Department of Labor ‘and Industries informing employees of their employee rights was posted anywhere in the workplace, 4.7 There was no reasonably accessible bathroom for the housekeepers. Next to the upstairs laundry room there was a very small security room. It had multiple security monitors and usually two security personne! present. For a short time, Plaintiff would get permission from the security staff to use the small toilet in the security room. This soon ‘stopped though because it was decided that housekeepers using the bathroom was a breach of security protocol. 4.8 The upstairs laundry room only had one door and it accessed the house where the Bezos family lived. When the Bezos family was home, the housekeepers were not permitted to access the home, unless to perform a cleaning assignment. For about 18 months, in order to use a bathroom, Plaintiff and other housekeepers were forced to climb out the laundry room window to the outside Then, run along the path to the mechanical room, through the mechanical room and downstairs to a bathroom. This toilet was used by both men and women, for example grounds staff used it too. 4.9 Because there was no readily accessible bathroom, Plaintiff and other housekeepers spend large parts of their day unable to use the toilet even though they needed to, Asa result of this, the housekeepers frequently developed Urinary Tract Infections (UTIs), Plaintiff and other housekeepers related the frequency of UTIs with not being able to use the toilet when they needed to, HKM EmrLovaenr ATTORNEYSLLP COMPLAINT FOR DAMAGES - 5 ‘Suni, Washnge S001 (206) 838.2504SRSPSSSESBYR LUBY SBRSRRRERLB 4.10 When Plaintiff was hired as Household Coordinator/Lead Housekeeper, she was provided a work computer to help her perform her duties, Plaintiff used the computer to create spreadsheets for keeping track of inventory and maintaining schedules. Plaintiff also stored employee identification documents, e.g., an employee driver's license. Plaintiff also used the computer for company email. Through the entirety of her employment with Defendants, Plaintiff's work email account was Mercedes@zeframlle.com. All staff email accounts, including management, were @zeframlle.com. Defendant Zefram, LLC, according to multiple media sources, including The Seattle Times, exclusively manages Defendant Jeff Bezos’s personal investments and is his primary family office. It is apparent that Jeff Bezos hires staff to work solely for him at his home and his other properties, through Defendants Zefram, LLC and Northwestern, LLC. 4.11 According to the Washington Secretary of State, Zefram, LLC, and Northwestern, LLC, are essentially one in the same. Defendant Zefram is a Washington limited liability company and its principal place of business is C/O Lawco Corporate Services, 1201 Third Avenue, Suite 4900, Seattle, WA, 98101. Zefram’s governor is Paul Dauber. Defendant Northwestem, LLG, is also a Washington limited liability company and its principal place of business is the same as Zefram’s, C/O Laweo Corporate Services, 1201 ‘Third Avenue, Suite 4900, Seattle, WA, 98101. Like Zefram, Northwestern’s governor is, Paul Dauber. 4,12. Plaintiff considered herself an employee of Jeff Bez0s, as did the other housekeepers, Sometimes when the Bezos family was home, Plaintiff interacted with them as HKM EarLovMENT ATTORNEYS LLP COMPLAINT FOR DAMAGES - 6 Sette Washingon 98101 (206) 838-2504SHGRSHASSSYRSLESSSSRSROLER her employer. Plaintiff followed onlers and directives from Jeff Bezos and his girlfriend Lauren Sanchez. 4.13 During her first 18 months when Plaintiff was the only employee housekeeper, shockingly, she did not get legally required rest breaks nor meal periods/lunch breaks. Plaintiff worked 10, 12, sometimes 14 hours per day without legally required breaks. ‘No one ever told Plaintiff she was entitled to breaks and no one ever told her to take a break. Plaintiff did not know she was legally entitled to rest and lunch breaks. Once additional housekeepers were hired and Plaintiff had permanent help, if the Bezos family was not “in residence” the housekeeping team were allowed to have a lunch break, but no rest breaks. If the family was “in residence,” the housekeeping team did not get rest breaks or lunch/meal breaks. Plaintiff would try and eat while she worked and sometimes the chef would give the housekeepers food while they were working, 4.14 By contrast, when Plaintiff worked for the late Paul Allen, there was a separate staff quarters where employees enjoyed rest breaks and lunch periods. There were also readily accessible bathrooms for the staff to use. Mr. Allen even provided food for the housekeepers and other employees. 4.15 During her almost three years of working for the Defendants, each of the three ‘House Managers Plaintiff reported to was Caucasian. Leanne Pardo was PlaintifP's first manager. For most of the 7-8 months Plaintiff reported to Ms. Pardo, Plaintiff was the only housekeeper. Plaintiff usually worked 10-12 hours per day without rest breaks or lunch breaks. HKM EwrLovtenT ATTORNEYSLLE COMPLAINT FOR DAMAGES - 7 Gecrte Wishinge sel0) (206) 838-2508SHGRSSSSELRSR ALES SBRYRRPERYBSESAREGHESearaueun— 4.16 When Ms. Pardo left her position, Christopher Hughes was promoted to House Manager and Jessica Zugarramunti became Assistant House Manager. Hughes and Zugarramurdi treated Plaintiff, and later the other Hispanic housekeepers who were hired, differently from Caucasian employees. Hughes and Zugarramurdi were demeaning and disrespectful to Plaintiff. They mocked and ridiculed Plaintiff. Hughes and Zugarramurdi, however, did not treat the only white housekeeper, Kristina Gach, in such ways. Similarly, ‘Hughes and Zugarramurdi were respectfuul and polite to the Caucasian grounds staff and ‘maintenance staff. Zugarramurdi also became aggressive and abusive — even threatening —when communicating with Plaintiff, Plaintiff complained to Hughes about Zugarramurdi’s abusive treatment and although he said he would speak to Zugarramurdi, about her (discriminatory) behavior, nothing changed. 4.17 Plaintiff found out that an undocumented worker, Patricia Cuellar, was hired. Plaintiff did not want to be involved in the Defendants’ use of an undocumented worker and ‘was very apprehensive about the prospect of supervising an undocumented worker. Plaintiff complained to Hughes about her legitimate concems. Initially, Hughes did nothing to remedy Defendants’ illegal actions, although Ms. Cuellar was eventually let go. Plaintiff also expressed concems to management about Green Cleaning — the company that provided some housekeeper help — providing many undocumented contract personnel. Plaintiff heard Estate Manager, J.P. Farrell, also expressed concem to Hughes and Zugarramurdi about Green Gleaning providing undocumented people to work at the Bezos residence. HKM EMLoyMent ATTORNEYSLLP COMPLAINT FOR DAMAGES - 8 Geae Weegee 95101 (206) 838-2504SKSPSSSELBYRALECESVBYRRRENEBSSSRATGS ES cmv sueen— 4.18 Plaintiff constantly complained to Hughes and Zugarramurdi about not getting rest breaks and meal periods and also about the unsafe and unhealthy work conditions, At times 5-6 housekeepers were working long hours and unable to take rest breaks. Sometimes, Plaintiff and other housekeepers crammed into the laundry room for a couple of minutes to stand, which Plaintiff found inhumane and unbearable. Many times, Plaintiff was assured by Hughes that these conditions would be remedied, but they never were. Instead, Defendants retaliated against Plaintiff. Defendants levelled false allegations of poor performance against Plaintiff and required her to review some coaching videos. Plaintiff was demoted from her supervisory role, and Zugarramurdi took over leading the housekeeping team. 4.19 Plaintiff went above Hughes and complained to the Property Manager, Francois Thomas-Botevy that she was being retaliated against because she had complained about no breaks, unsafe work conditions, and about undocumented workers. Mr. Thomas- Botevy assured Plaintiff that she was still the Lead Housekeeper and that he would speak to her managers about the retaliation, Mr, Thomas-Botevy, however, did not give any assurances about changing Plaintiff's working conditions. 4.20 As the discrimination and retaliation grew worse, Plaintiff requested a meeting with HR Manager, Ronna Crewse, Thomas-Botevy, and Hughes. At this meeting, Plaintiff complained to Ms, Crewse about the discriminatory treatment she was enduring, especially at the hands of Zugarramurdi. Plaintiff described how Zugarramurdi treated her and other Hispanic housekeepers differently from other personnel and about how Zugarramurdi, had undermined and taken over Plaintiff's lead housekeeper role. Plaintiff told Crewse about Zugarramurdi excluding her from HKM EnrLovatent ATroRvEYSLLP COMPLAINT FOR DAMAGES - 9 ‘Seats Wasaga 98101 (206) 838.2504BSSSSRSCBS See wauaune SRACEHASSEYR ALES SBBYRREBS meetings, and assigning Plaintiff's projects to other lower-level, younger employees, and about Zugarramurdi withholding critical information from Plaintiff that she needed to do her job, thereby, causing unnecessary issues. 4.21 After the meeting the discrimination and retaliation worsened. Zugarramurdi installed Kristina Gach, the only white housekeeper, as the new lead housekeeper. Gach, began to harass Plaintiff and although Plaintiff complained nothing was done. 4.22 Plaintiff was an excellent employee and the ultimate professional. Plaintiff ‘was never disciplined regarding her job performance, So, in retaliation for complaining about discrimination, retaliation, violations of wage and hour laws, violations of workplace health and safety laws, and laws against hiring undocumented workers, management terminated Plaintiff's employment. Defendants cited the ridiculously concocted reason that she appeared “unhappy” and that this was having a negative effect on the housekeeping. team. Plaintiff's termination letter said Northwestern LLC at the top and was signed by Ronna Crewse. V. CAUSES OF ACTION A FIRST CAUSE OF ACTION — RACE DISCRIMINATION IN VIOLATION OF THE WASHINGTON LAW AGAINST DISCRIMINATION CHAPTER. 49.60 RCW 5.1 Plaintiff realleges the allegations set forth in paragraph 1.1 through 4.22 and hereby incorporates the same by reference. 5.2 At all times relevant to this complaint, Defendants had eight or more employees. 5.3 Defendants violated Chapter 49.60 RCW by treating Plaintiff differently than HKM EMLovMent ATTORVEYS LLP 600 Stewart Street, Suite 901 COMPLAINT FOR DAMAGES - 10 Seattle, Washington 98101 206) 838-2504SRSREKASSSYR ALES SURBSRERER Caucasian employees and by terminating PlaintifF s employment because of her race. 54 The illegal acts committed by Defendants caused Plaintiff to suffer economic and non-economic damages, including but not limited to damages for past and future wage and benefits loss, emotional pain, suffering, inconvenience, mental anguish, loss of enjoyment of life and other nonpecuniary losses, and attorneys’ fees and costs. Damages amounts will be proved at trial, B. SECOND CAUSE OF ACTION — RETALIATION IN VIOLATION OF THE WASHINGTON LAW AGAINST DISCRIMINATION CHAPTER 49.60 RCW 6.1 Plaintiff realleges paragraphs 1.1 through 5.4 of the Complaint and hereby incorporates the same by reference. 6.2 At all times relevant to this complaint, Defendants had eight or more employees. 63 Defendants retaliated against Plaintiff because she complained about discrimination. 6.4 The illegal acts committed by Defendants caused Plaintiff to suffer economic and non-economic damages, including but not limited to damages for past and future wage and benefits loss, emotional pain, suffering, inconvenience, mental anguish, loss of enjoyment of life and other nonpecuniary losses, and attorneys’ fees and costs, Damages ‘amounts will be proved at trial. C. THIRD CAUSE OF ACTION - WONGFUL TERMINATION IN VIOLATION ‘OF PUBLIC POLICY 7.1 Plaintiffrealleges paragraphs 1.1 through 6.4 of the Complaint and hereby incorporates the same by reference. HKM EMPLOYMENT ATTORNEYSLLP COMPLAINT FOR DAMAGES - 11 ‘State, Weshingon 98101 (206) 838-2504SRGPSHLSSEYRALE RES EBYRRRERLBSRIAGEGS IS eer auaun- 7.2 Defendants discharged Plaintiff in retaliation for opposing discrimination prohibited by RCW 49.60.010 er sec. 7.3 Defendants discharged Plaintiff in retaliation for opposing wage and hour violations prohibited by RCW 49.46.010 et sec. and RCW 49.52.010 et sec. 7.4 Defendants discharged Plaintiff in retaliation for opposing workplace safety and health violations prohibited by RCW 49.17.010 et sec., WAC 296-800-230, and WAC 296-800-23040, 7.5 There was no overriding justification for Plaintiff's termination. 7.6 The illegal acts committed by Defendants caused Plaintiff to suffer economic and non-economic damages, including but not limited to damages for past and future wage and benefits loss, emotional pain, suffering, inconvenience, mental anguish, loss of ‘enjoyment of life and other nonpecuniary losses, and attorneys’ fees and costs. 7.7 Defendants’ wrongful termination of Plaintiff caused her damages in amounts to be proven at trial. D. _ FOURTH CAUSE OF ACTION ~ FAILURE TO PAY WAGES 8.1 Plaintiff realleges the allegations set forth in paragraphs 1.1 through 7.7 and hereby incorporates the same by reference. 8.2 Defendants" policies and practices of requiring Plaintiff to work through rest breaks and meal breaks deprived Plaintiff of pay for all regular and overtime hours in violation of Washington law, including RCW 49.46.020, RCW 49.46.090, RCW 49.46.130, and RCW 49.52,050, for which Plaintiff is entitled to compensatory damages, prejudgment interest, and reasonable attorneys” fees and costs. HKM EnrLoyMent ATTORNEYS LLP COMPLAINT FOR DAMAGES - 12 ‘Seats, Washingon 98101 (206) 838-2504SSESRIRRSEKSSBRYRALOHK Sears 83 Asa result of Defendants’ acts and omissions, Plaintiff has been damaged in amounts to be proven at trial. E, _ FIFTH CAUSE OF ACTION - RETALIATION IN VIOLATION OF RCW 49.46 9.1 Plaintiff realleges the allegations set forth in paragraphs 1.1 through 8.3 and hereby incorporates the same by reference. 9.2 Defendants retaliated against Plaintiff for exercising her right to be paid for all the hours she worked. 9.3 Defendants’ retaliation against Plaintiff was in violation of multiple employee protection statutes including RCW 49.46,100 and WAC 296-128-770. 9.4 — Asa result of Defendants’ retaliation against Plaintiff, Plaintiff is entitled to compensatory damages, prejudgment interest, and reasonable attomeys* fees and costs in amounts to be proven at trial. F. _ SIXTH CAUSE OF ACTION - WILLFUL WITHHOLDING OF WAGES IN VIOLATION OF RCW 49.52.070 10.1 Plaintiff realleges the allegations set forth in paragraphs 1.1 through 9.4 and hereby incorporates the same by reference. 10.2 Defendants conduct in failing to provide compensation for all hours worked by Plaintiff was willful. 10.3 As a result of Defendants’ willful withholding of wages, Plaintiffs entitled to compensatory damages, prejudgment interest, and reasonable attorneys’ fees and costs in amounts to be proven at trial. HKM EwLoyMent ArroRNEYSLLP COMPLAINT FOR DAMAGES - 13 ‘Ses, Washngon 38101, (206) 838-2504SSSRSSSESRYE REE RESRRSRRVENLBSSGRATGH IS cas susune F. SEVENTH CAUSE OF ACTION - FAILURE TO PROVIDE BATHROOM AND TOILET ACCESS 11.1 Plaintiff realleges the allegations set forth in paragraphs 1.1 through 10.3 and hereby incorporates the same by reference. 11.2 Defendants failed to provide reasonable and unobstructed access to bathroom and toilet facilities in violation of Department of Labor and Industries, Division of Occupational Safety and Health, Directive 5.98, WAC-800-23020, RCW 49.17.010; RCW 49.17.050, and RCW 49.17.060. 11.3 Defendant's willful violations of 5.98, WAC-800-23020, RCW 49.17.010; RCW 49.17.050, and RCW 49.17,060 caused Plaintiff damages in an amount to be proven at trial, G. EIGHTH CAUSE OF ACTION - FAILURE TO PROVIDE SAFE AREA TO EAT AND REST 11.1 Plaintiff realleges the allegations set forth in paragraphs 1.1 through 11.3 and hereby incorporates the same by reference. 11.2 Defendant failed to provide a place free from chemicals for the Plaintiff to rest and eat in violation of WAC 296-800-230, WAC 296-800-23040, RCW 49.17.010; RCW 49.17.050, and RCW 49.17.060. 11.3 Defendant's willful violations of 5.98, WAC-800-23020, RCW 49.17.010; RCW 49,17.050, and RCW 49.17.060 caused Plaintiff damages in an amount to be proven at trial, H. NINTH CAUSE OF ACTION ~ FAILURE TO DISPLAY WORKPLACE POSTERS REGARDING EMPLOYEE RIGHTS AS A WORKER HKM EwpLoyMeT ATTORVEYSLLP {20 Stewart Street, Suite 901 COMPLAINT FOR DAMAGES - 14 saat wisstagical atoll (206) 838.2504SRGSSHLSESSSRR VERE SRBYRRRES 12.1. Plaintiff realleges the allegations set forth in paragraphs 1.1 through 11.3 and hereby incorporates the same by reference. 12.2 Defendant failed to provide a place free from chemicals for the Plaintiff to rest and eat in violation of WAC 296-800-230, WAC 296-800-23040, RCW 49.17.010; RCW 49.17.050, and RCW 49.17.060. 12.3 Defendant's willful violations of 5.98, WAC-800-23020, RCW 49.17.010; RCW 49.17.50, and RCW 49.17.060 caused Plaintiff damages in an amount to be proven at ial. VI. PRAYER FOR RELIEF WHEREFORE Plaintiff Mercedes Wedaa prays for relief as follows: A. Damages for back pay and benefits lost and for future pay and benefits lost; B, Double damages for willful withholding of wages; C. Actual damages; D. Statutory damages; E. Liquidated damages; F. Damages for loss of enjoyment of life, pain and suffering, mental anguish, emotional distress, and humiliation; G. Punitive damages; H. Pre- and post-judgment interest in an amount to be proven after trial; 1. Compensation as tax relief associated with any recovery on claims herein; J, Reasonable attorneys’ fees and costs; K. Injunctive relief, and HKM Ewrcoyment Arrorveys LL? COMPLAINT FOR DAMAGES - 15 ‘Seats, Washington 38101 (206) 838-2504SELSCESBRYRRRBRLB SeGRSRLESBS L. Whatever further and additional relief this Court shall deem just and equitable. DATED: November 1, 2022 COMPLAINT FOR DAMAGES - 16 (s/ Patrick L. McGuigan Patrick L. McGuigan, WSBA No. 28897 HKM EmpcoyMent ATrorNeys LLP 600 Stewart Street, Suite 901 Seattle, WA 98101-1225 Telephone: (206) 838-2504 Facsimile: (206) 260-3055 E-mail: plmeguigan@hkm.com Attorneys for Plaintiff KM EMPLOYMENT ATTORNEYS LLP (600 Stewart Street, Suite 901 Seattle, Washington 98101 (206) 838-2504