A defamation lawsuit filed by SEIU-UHW President Dave Regan in Riverside County Superior Court against a former SEIU-UHW organizer who was quoted in a news report about Regan's alleged sexual misconduct, drinking on the job, backroom deals with employers, illegal electioneering and other misconduct.
A defamation lawsuit filed by SEIU-UHW President Dave Regan in Riverside County Superior Court against a former SEIU-UHW organizer who was quoted in a news report about Regan's alleged sexual misconduct, drinking on the job, backroom deals with employers, illegal electioneering and other misconduct.
Original Title
SEIU-UHW Dave Regan's Lawsuit vs Former Union Staffer 03-21-2019
A defamation lawsuit filed by SEIU-UHW President Dave Regan in Riverside County Superior Court against a former SEIU-UHW organizer who was quoted in a news report about Regan's alleged sexual misconduct, drinking on the job, backroom deals with employers, illegal electioneering and other misconduct.
A defamation lawsuit filed by SEIU-UHW President Dave Regan in Riverside County Superior Court against a former SEIU-UHW organizer who was quoted in a news report about Regan's alleged sexual misconduct, drinking on the job, backroom deals with employers, illegal electioneering and other misconduct.
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BRUCE A, HARLAND, Bar No. 230477
WEINBERG, ROGER & ROSENFELD
A Professional Comporation
1001 Marina Village Parkway, Suite 200
Alameda, California 9450| FILED
Telephone (510) 337-1001 ‘APERER cou ox Rowan
Fax (510) 337-1023
E-Mail: [email protected] MAR 21 2019
Dbharland@unioncounsel net
MONICA T. GUIZAR, Bar No, 202480 1 SIRAGUSA
CHRISTINA L, ADAMS, Bar No. 325056
WEINBERG, ROGER & ROSENFELD
A Professional Corporation
800 Wilshire Blvd., Suite 1020
Los Angeles, Califomia 90017
‘Telephone (213) 380-2344
Fax (213) 443-5098
E-Mail: cadams@unioncounsel net
lacourtnotices@unfoncounsel net
Attomeys for SEIU-UHW and DAVE REGAN
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF RIVERSIDE
RIC 1902014
SERVICE EMPLOYEES INTERNATIONAL. ‘Case No.
UNION, UNITED HEALTHCARE
WORKERS - WEST; AND COMPLAINT FOR DEFAMATION
DAVE REGAN,
v
NJOKI WOODS, -
Defendant,
‘COMPLAINT FOR DEFAMATION
Case No.Plaintiffs, Service Employees Intemational Union- United Healthcare Workers West, and
Dave Regan hereby allege and complain as follows:
1. PARTIES
1. Plaintiff SEIU, United Healthcare Workers ~ West (‘SEIU-UUHW" orth “Union”)
{8a labor organization that represents approximately 95,000 healthcare workers in hospitals and
clinis throughout California, and at all relevant imes herein maintained an offic located in Los
Angeles County, California. SEIU-UHW also maintains ofices across Calfomia in Oakland,
Fresno, Sacramento, San Francisco, San Jose, and Stockton.
2. Plaintiff Dave Regan (“Regan”) is an employee and the elected President of SEIU-
UW; he resides in Contra Costa County, California. Regan brings this action as an individual
3. Defendant Njoki Woods (“Woods”) isa former employee of SEIU-UHW, and
upon information and belief, currently resides in Riverside County, California
I JURISDICTION AND VENUE
4. Woods, upon information and belie, is domiciled within Riverside County,
California. Therefore, Woods i subject tothe personal jurisdiction ofthis Court, and this Court
has the power to render an effective judgment against Woods.
5. Woods, upon information and belief, is an individual who is and has beea, at all
times mentioned herein, a resident of Riverside County, in the State of California.
MI, FACTUAL ALLEGATIONS
A. SEIU-URW IS AS A VOICE FOR HEALTHCARE WORKERS,
CONSUMERS, AND PATIENTS THROUGHOUT CALIFORNIA.
6. SEIU-UHW
workers in hospitals and clinics throughout Califomia; the Union is funded solely by the
« labor organization representing approximately 95,000 healthcare
‘voluntary, dues payments ofits members.
7. SEIU-UHW is committed to improving the working lives ofits members;
supporting their families; ensuring and providing “the best quality care to our patients,
consumers, and residents; and promoting quality, affordable health cae forall” To this end, the
tission of SEIU-UHW isto “build a workers’ organization dedicated to being a powerful force to
change workers’ lives and fight for social and economic justice.” In line with its mission, SEIU-
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‘COMPLAINT FOR DEFAMATION
Case No.eS iicva ceca
UHW’s “objective [is] to build a strong and more effective labor movement by organizing
unorganized workers, building an effective political voice for working people, and protecting all
workers from unacceptable or unjust actions by employers.”
8. ‘The highest leadership body of SEIU-UHW is the Executive Board, which consists
of elected rank and file members, a president, and vice-president.
9. Regan has served as president of SEIU-UHW since 2011. The membership re-
lected Regan in 2014 and, again, in 2017. In his role as president, Regan is responsible for
administerfing] the affairs of the Union and implement{ing] the policies ofthe Union on a day-
to-day basis." This includes, but is not limited to, “r}epresenting the Union in the community, in
the media and at meetings, conferences, or conventions of organizations that the Union is
affliated with; and generally acting asthe chief spokesperson for the Union.”
10. In furtherance of its mission, SEIU-UHW hires staff to assist in organizing and
recruiting non-union healthcare workers to join SEIU-UHW; to assist in organizing and recruiting
community members, who do not work ata hospital or clinic, to join the Union and support the
mission and objectives of SEIU-UHW; to assist in the administration ofits collective bargaining
agreements with employer-hospitals and clinics; and to assist inthe representation of its more
‘than 95,000 members in their respective workplaces.
11, InMay 2015, SEIU-UHW hired Woods as a Union organizer. As a Union
organizer, Woods was responsible for, among other things, reeating and organizing non-union
healthcare workers and community members, administering collective bargaining agreements
resenting healthcare workers employed at
ith SEIU-UHW.
‘covering SEIU-UHW members, and assisting and rep
hospitals or clinics that have a collective bargaining relationship wit
B. _ WHILE EMPLOYED WITH SEIU-UHW WOODS MAKES FALSE
STATEMENTS ABOUT SEIU-UHW AND ITS PRESIDENT TO MIKE
ELK, AN INTERENT BLOGGER.
12, OnMarch 1, 2019, at 12:23 am, Mike Elk (“EIk"), the Senior Labor Reporter
with PaydayReport.com, emailed Steve Trossman, a SEIU-UHW employee, asking fOr a response
from SEIU-UHW regarding various sta
Regan, Email Attached as Exhibit A, whic
ements that Woods had made about SEIU-UHW and
fais incorporated by reference as though fully set
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TS
COMPLAINT FOR DEFAMATION
Case No.