The suit names the City of El Segundo and Fire Chief Chris 多诺万 as defendants. Chief Bonfield contends that Chief 多诺万 has embarked on a campaign “to force older employees, particularly those over age 50, to leave the employ of the ESFD so 多诺万 can replace them with substantially younger employees.”
- Frustrated that his efforts to force Plaintiff to leave ESFD had not come to fruition, on February 19, 2020, 多诺万 demanded that Plaintiff retire. Plaintiff refused, advising 多诺万 that he had no intention of retiring until November 2021 at the earliest when he would be age 55. 多诺万 responded that Plaintiff would retire in December 2020. Plaintiff again refused.
- Due to Plaintiffs refusal to retire, 多诺万’本文所称对原告的年龄动机和普遍性待遇仍在继续。
- On March 27, 2020, 多诺万 and Plaintiff met privately at 多诺万’s request on the premises of ESFD. 多诺万 berated Plaintiff, telling Plaintiff that he was not meeting performance standards, was an ineffective leader and “把球丢在所有东西上。 ”
- As a result of 多诺万’由于不断遭受虐待，多年来，原告遭受了极大的情绪困扰，包括焦虑，失眠和惊恐发作以及相关的身体不适，所有这些都使他寻求医疗并导致了住院。
- After and because of the March 27, 2020 meeting with 多诺万, Plaintiffs emotional and physical maladies increased to such a level that he was forced to take medical leave.
- After Plaintiff commenced medical leave, 多诺万 placed into the Battalion Chief position that had been vacated by Plaintiff two substantially younger employees. Consistent with his age- related prejudice 多诺万 refused to place into that position a more qualified ESFD Captain who is over age 50.