United States: California Employment Law Notes - March 2015

Employee Who Was Working Elsewhere During Medical Leave Of Absence Was Properly Terminated

Richey v. AutoNation, Inc., 182 Cal. Rptr. 3d 644 (Cal. S. Ct. 2015)

Avery Richey worked for Power Toyota Cerritos, part of the AutoNation consortium of automobile dealerships, for approximately four years before allegedly injuring his back while moving furniture at his home. Following the injury, Richey applied for and was granted a medical leave of absence (which was extended on multiple occasions) under the California Family Rights Act ("CFRA") and the federal Family and Medical Leave Act. Approximately one month before Richey allegedly injured his back, he began working on plans to open his own seafood restaurant, and Richey's supervisors at Power Toyota had met with him to discuss his performance and attendance problems and their concern that he had become "distracted." Power Toyota had a written policy prohibiting employees from engaging in outside work while out on an approved CFRA leave of absence. After a Power Toyota employee observed Richey "sweeping, bending over, and hanging a sign using a hammer" at his restaurant while on leave, the company fired him. Richey exhausted his administrative remedies under the California Fair Employment and Housing Act and filed a civil action in court against his employer for racial discrimination, harassment, retaliation for taking CFRA leave and failure to reinstate him following CFRA leave. The civil action was compelled to arbitration, based upon the parties' express agreement to have all employment disputes arbitrated.

After an 11-day hearing, the arbitrator rejected all of Richey's claims and concluded that "Power Toyota [could legally] terminate Mr. Richey if it has an 'honest' belief that he is abusing his medical leave and/or not telling the company the truth about his outside employment." Richey sought to vacate the award on the ground that the arbitrator committed reversible legal error by accepting Power Toyota's honest belief defense. The trial court denied Richey's motion to vacate the award; the Court of Appeal reversed the trial court's judgment, concluding that the arbitrator violated Richey's right to reinstatement under the CFRA; and the California Supreme Court in this opinion reversed the Court of Appeal on the ground that any error that the arbitrator may have committed did not deprive Richey of an unwaivable statutory right to reinstatement because the arbitrator found that he was dismissed for violating his employer's written policy prohibiting outside employment while on medical leave.

Disability Discrimination Claims Were Properly Dismissed On Summary Judgment

Nealy v. City of Santa Monica, 2015 WL 632228 (Cal. Ct. App. 2015)

Tony Nealy worked as a solid waste equipment operator for the City of Santa Monica before injuring his knee in July 2003 while moving a large bin full of food waste. Nealy was temporarily totally disabled due to the injury until 2005 when he was released to do "light duty" work after which time he was reassigned to a groundskeeper position. A year later, Nealy again injured himself on the job (this time a lower back injury) and never returned to work again. Over the next several years, Nealy and the City had several "accommodations meetings," which did not result in an offer of a job for which Nealy could perform the essential functions with an accommodation. Finally, in 2010, Nealy submitted an application for a job as a city planning staff assistant, but the City determined that Nealy did not meet the necessary qualifications for the position. The City then sent Nealy a letter stating it was unable to provide him with reasonable accommodation into an alternative position because he was not minimally qualified for the only position available at the time that was not a promotion.

Nealy exhausted his administrative remedies and filed a lawsuit against the City, alleging disability discrimination, failure to reasonably accommodate a disability, failure to engage in the interactive process and retaliation. The trial court granted summary judgment in favor of the City, and the Court of Appeal affirmed. The Court first affirmed summary judgment based on the statute of limitations and the inapplicability of the "continuing violation doctrine." The Court also affirmed summary judgment based on evidence that Nealy could not perform some of the essential functions of the solid waste equipment operator, with or without reasonable accommodation, and that the City was not required to eliminate essential functions of the job (e.g., heavy lifting and kneeling) as part of a reasonable accommodation. The City also was not required to "provide an indefinite leave of absence to await possible future vacancies" in jobs Nealy might be able to perform. The Court also affirmed summary adjudication of the claims for failure to engage in the interactive process (the City met with and informed Nealy about its vacant positions) and retaliation (Nealy's exercise of his right to request reasonable accommodation was not protected activity within the meaning of the statute). Compare Nigro v. Sears, Roebuck & Co., 2015 WL 774633 (9th Cir. 2015) (summary judgment in favor of employer in disability discrimination case reversed, based principally upon employee's own "self-serving" testimony

Applicant Could Proceed With Race Discrimination Claim Despite Undisclosed Criminal Conviction

Horne v. District Council 16 Int'l Union of Painters & Allied Trades, 2015 WL 681433 (Cal. Ct. App. 2015)

Raymond E. Horne was a glazier and a member of the glazier's union. He also served as an officer and a member of the council and of the executive board of the union. Horne, who is African American, twice applied for an organizer position with the council but both times the position was filled by whites. Horne sued the union for racial discrimination under the Fair Employment and Housing Act. During discovery, Horne admitted that he had been convicted of possession of narcotics for sale and that he had served a prison term for that conviction. He also admitted that his citizenship rights had been revoked as a result of the conviction, but denied that those rights had not been restored. When, during the course of the lawsuit, the union found out about the conviction, it asserted that under federal law (29 U.S.C. § 504(a)), Horne was barred from employment as a union organizer because of the criminal conviction. The trial court granted the union's motion for summary judgment, and the Court of Appeal initially affirmed, holding that Horne was disqualified for the organizer position due to the criminal conviction. However, following the California Supreme Court's opinion in Salas v. Sierra Chem. Co., 59 Cal. 4th 407 (2014), the case was remanded from the Supreme Court back to the Court of Appeal, and in this opinion, the Court of Appeal reversed the summary judgment that had been granted in favor of the union on the ground that while after-acquired evidence may limit the damages recoverable in an employment case, it cannot be used as "an absolute bar to a worker's FEHA claims." The Court also rejected the union's claim that Horne's claims are preempted by Section 504(a) of the federal Labor-Management Reporting and Disclosure Act.

Federal Air Marshal Could Proceed With Whistleblower Lawsuit

Department of Homeland Sec. v. MacLean, 574 U.S. ___, 135 S. Ct. 913 (2015)

Robert J. MacLean became a federal air marshal for the TSA in 2001. In that role, MacLean was assigned to protect passenger flights from potential hijackings. In July 2003, the Department of Homeland Security issued a confidential advisory about a potential hijacking plot by al Qaeda to be executed by the end of summer 2003. A few days later, MacLean received a text message from the TSA cancelling all overnight missions from Las Vegas (where MacLean was stationed) until early August. MacLean believed that cancelling those missions during a hijacking alert was dangerous and illegal insofar as federal law required the TSA to put an air marshal on every flight that "presents high security risks." After MacLean learned from a supervisor that the missions had been canceled due to budgetary restrictions and that "nothing could be done," he contacted an MSNBC reporter and told him about the canceled missions. Following publication of the MSNBC story, several Members of Congress criticized the cancellations and, within 24 hours, the TSA reversed its decision and put air marshals back on the flights. MacLean was subsequently fired for disclosing sensitive security information without authorization. The Merit Systems Protection Board held that MacLean did not qualify for protection because his disclosure was "specifically prohibited by law." However, the United States Court of Appeals for the Federal Circuit vacated the Board's decision, and the United States Supreme Court in this opinion affirmed the Court of Appeals, holding that MacLean's disclosure was not prohibited by the TSA regulations because regulations do not qualify as "law" under the applicable whistleblower statute.

San Quentin Correctional Officer Could Proceed With Civil Claim For Injury Suffered While On Prison Premises

Wright v. State of Cal., 183 Cal. Rptr. 3d 135 (Cal. Ct. App. 2015)

Monnie Wright was a correctional officer at San Quentin State Prison who lived on the premises of the prison in a unit he rented from the State of California. Wright was injured when he fell in the course of his walk from his home to his place of work at the prison. Following his injury, Wright sought and obtained workers' compensation benefits exceeding $137,000. Wright then filed a civil suit against the State, alleging premises liability for an allegedly defectively constructed and dangerously maintained stair that crumbled beneath him. The State moved for summary judgment on the ground that workers' compensation provided the exclusive remedy for Wright's claim because he was injured on the employer's premises (the "premises line rule"). The trial court granted the State's motion for summary judgment, but the Court of Appeal reversed, finding a triable issue of material fact as to whether Wright's injury arose out of and in the course of his employment. See also Schultz v. WCAB, 232 Cal. App. 4th 1126 (2015) (premises line rule applied and going-and-coming rule did not preclude award of workers' compensation benefits to employee injured in a traffic accident on a United States Air Force base not generally open to the public).

Security Guards Are Entitled To Compensation For All On-Call Hours Spent At Employer's Worksite

Mendiola v. CPS Sec. Solutions, Inc., 60 Cal. 4th 833 (2015)

CPS employed on-call guards to provide security at construction worksites. Part of each guard's day was spent on active patrol. Each evening, guards were required to remain on call and on premises at the worksite to respond to disturbances should the need arise. By written agreement, on-call guards were required to reside in a trailer at the worksite. An on-call guard had to notify a dispatcher and indicate where he or she would be and for how long. If another employee was not available to provide relief, the guard had to wait onsite until the reliever arrived. If relieved, guards had to be accessible by pager or radio phone and to stay close enough to the site to return within 30 minutes. The guards were paid hourly for the time spent patrolling the worksite, but received no compensation for on-call time unless an alarm or other circumstance required that they conduct an investigation or they were waiting for or had been denied a reliever. In this putative class action, both sides sought declaratory relief as to the lawfulness of CPS's on-call compensation policy. The trial court granted plaintiffs' motion for summary adjudication of their declaratory relief claim, concluding the on-call hours constituted compensable "hours worked" within the meaning of the applicable wage order. The Court of Appeal affirmed in part and reversed in part, and the California Supreme Court concluded in this opinion that plaintiffs' on-call hours constituted compensable hours worked and that CPS could not exclude "sleep time" from plaintiffs' 24-hour shifts.

$90 Million Judgment In Favor Of Security Guards Who Remained On Call During Rest Breaks Is Reversed

Augustus v. ABM Sec. Servs., Inc., 182 Cal. Rptr. 3d 676 (2015)

In this class action lawsuit, plaintiffs alleged that ABM did not provide rest periods to its security guard employees because it failed to relieve them of all duties and required them to remain on call during their breaks. The trial court certified the class and granted plaintiffs' motion for summary adjudication, concluding an employer must relieve its employees of all duties during rest breaks, including the obligation to remain on call. The trial court also granted plaintiffs' motion for summary judgment on the issue of damages, awarding plaintiffs more than $90 million in statutory damages, interest, penalties and attorney's fees. The Court of Appeal reversed the grant of summary adjudication and summary judgment, holding that "Labor Code § 226.7 prescribes only that an employee not be required to work during a rest break, not that he or she be relieved of all duties, such as the duty to remain on call. Remaining on call does not itself constitute performing work." However, the Court affirmed the trial court's order certifying the class, in light of evidence that ABM possessed a uniform policy of requiring its security guards to remain on call during their rest breaks. The fact that the policy may not have been uniformly applied "would go only to the issue of damages." Compare Mies v. Sephora USA, Inc., 2015 WL 798709 (Cal. Ct. App. 2015) (trial court properly denied certification to putative class of "Specialists" who manage 10 to 45 subordinate employees where evidence showed they "handled their time very differently" in performing a wide variety of tasks).

Employer Met Its Burden Of Proving At Least $5 Million Amount In Controversy For CAFA Removal

LaCross v. Knight Transp. Inc., 775 F.3d 1200 (9th Cir. 2015)

In this putative class action, plaintiffs alleged that Knight Transportation had misclassified them as independent contractors when in fact they were employees who were not reimbursed their lease-related and fuel costs as required by Labor Code § 2802. Knight removed the case from state to federal court under the Class Action Fairness Act ("CAFA"), estimating the amount in controversy for reimbursing the drivers' lease and fuel costs to be in excess of the $5 million minimum amount in controversy required for CAFA removal. Knight based its estimate on the actual fuel costs invoiced on Knight's fuel cards for the first quarter of 2014 and then multiplied that amount ($2.3 million) by the 16 quarters in the four-year class period for a total of $36.8 million. Knight had an alternative, lower estimate of $21 million. The United States Court of Appeals for the Ninth Circuit held that Knight's "chain of reasoning and its underlying assumption to extrapolate fuel costs... [is] reasonable" and that the employer had satisfied its obligation to prove that the amount in controversy exceeded $5 million. See also Ibarra v. Manheim Invs., Inc., 775 F.3d 1193 (9th Cir. 2015) (CAFA removal case remanded to district court so that both sides could submit evidence related to the contested amount in controversy).

Health Care Employees Should Not Have Been Permitted To Waive Their Second Meal Periods

Gerard v. Orange Coast Mem. Med. Ctr., 2015 WL 535730 (Cal. Ct. App. 2015)

In this putative class/Private Attorney General Act ("PAGA") action, Jazmina Gerard (and others) challenged a hospital policy that allowed health care employees who worked shifts longer than 10 hours to voluntarily waive one of their two meal periods, even if their shifts lasted longer than 12 hours. Plaintiffs alleged that they all signed second meal period waivers and occasionally worked longer than 12 hours without being provided a second meal period. The trial court granted summary judgment against Gerard and denied class certification to the other plaintiffs. The Court of Appeal reversed, holding
that Wage Order No. 5, Section 11(D), is partially invalid to the extent it permits employees in the health care industry to waive their second meal periods for shifts longer than 12 hours.

Ninth Circuit Submits Day Of Rest Questions To California Supreme Court

Mendoza v. Nordstrom, Inc., 2015 WL 691304 (9th Cir. 2015)

The United States Court of Appeals for the Ninth Circuit has certified three questions to the California Supreme Court: (1) Is the one day of rest in seven as required by Labor Code § 551 calculated by the workweek or on a rolling basis for any consecutive seven-day period?; (2) Does the exemption from Section 551 found in Labor Code § 556 (applicable when the total hours of employment do not exceed 30 hours in any week or six hours in any one day) apply when an employee works less than six hours in any one day of the applicable week or does it apply only when an employee works less than six hours in each day of the week?; (3) What does Labor Code § 552 mean when it says that an employer may not "cause his employees to work more than six days in seven?" Does "cause" mean "force, coerce, pressure, schedule, encourage, reward, permit, or something else?"

FLSA Claims Were Properly Dismissed At Pleadings Stage

Landers v. Quality Communications, Inc., 771 F.3d 638 (9th Cir. 2015)

Greg Landers, who was employed as a cable services installer, brought suit individually and on behalf of other similarly situated persons, alleging that Quality failed to pay him and the other employees minimum and overtime wages in violation of the Fair Labor Standards Act ("FLSA"). The district court granted Quality's motion to dismiss based on FRCP 8(a)(2) and 12(b)(6), concluding that the complaint did "not make any factual allegations providing an approximation of the overtime hours worked, plaintiff's hourly wage, or the amount of unpaid overtime wages..." Landers expressly declined an opportunity to amend his complaint, electing instead to stand on his claims as alleged. The United States Court of Appeals for the Ninth Circuit affirmed dismissal of the complaint, applying the United States Supreme Court's opinions in Twombly and Iqbal to the pleading in this case. The Court held that Landers failed to state a claim for unpaid minimum and overtime wages in that the complaint did not allege facts showing that
there was a given week in which Landers was entitled to but denied minimum or
overtime wages.

Second-Place Bidder On Public Works Contract Could Proceed With Tortious Interference Claim

Roy Allan Slurry Seal, Inc. v. American Asphalt South, Inc., 2015 WL 738675 (Cal. Ct. App. 2015)

Between 2009 and 2012, American Asphalt South, Inc. ("American") outbid Roy Allan Slurry Seal, Inc. ("Allan") or Doug Martin Contracting, Inc. ("Martin") on 23 public works contracts totaling more than $14.6 million to apply a slurry seal protective coating to various roadways throughout Southern California. Allan and Martin sued American in five counties, alleging intentional interference with prospective economic advantage and other torts, claiming that American had only been able to submit the lowest bids by paying its workers less than the statutorily required prevailing wage. The trial court sustained the demurrer to the interference claim, but the Court of Appeal reversed, holding that plaintiffs as the lawful and second lowest bidders had a reasonably probable economic expectancy that they would be awarded the contracts but for American's allegedly illegal acts in underpaying its employees. The appellate court affirmed dismissal of claims for predatory pricing under the Unfair Practices Act and for an injunction under the Unfair Competition Law.

California Employment Law Notes - March 2015

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

Authors
Similar Articles
Relevancy Powered by MondaqAI
 
In association with
Related Topics
 
Similar Articles
Relevancy Powered by MondaqAI
Related Articles
 
Related Video
Up-coming Events Search
Tools
Print
Font Size:
Translation
Channels
Mondaq on Twitter
 
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
 
Email Address
Company Name
Password
Confirm Password
Position
Mondaq Topics -- Select your Interests
 Accounting
 Anti-trust
 Commercial
 Compliance
 Consumer
 Criminal
 Employment
 Energy
 Environment
 Family
 Finance
 Government
 Healthcare
 Immigration
 Insolvency
 Insurance
 International
 IP
 Law Performance
 Law Practice
 Litigation
 Media & IT
 Privacy
 Real Estate
 Strategy
 Tax
 Technology
 Transport
 Wealth Mgt
Regions
Africa
Asia
Asia Pacific
Australasia
Canada
Caribbean
Europe
European Union
Latin America
Middle East
U.K.
United States
Worldwide Updates
Registration (you must scroll down to set your data preferences)

Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice):

  • To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
  • To enable features such as password reminder, news alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our content providers ("Contributors") who contribute Content for free for your use.

Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Mondaq has a "free to view" business model. Our services are paid for by Contributors in exchange for Mondaq providing them with access to information about who accesses their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.

Details of each Contributor to which your personal data will be transferred is clearly stated within the Content that you access. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.

Please indicate your preference below:

Yes, I am happy to support Mondaq in maintaining its free to view business model by agreeing to allow Mondaq to share my personal data with Contributors whose Content I access
No, I do not want Mondaq to share my personal data with Contributors

Also please let us know whether you are happy to receive communications promoting products and services offered by Mondaq:

Yes, I am happy to received promotional communications from Mondaq
No, please do not send me promotional communications from Mondaq
Terms & Conditions

Mondaq.com (the Website) is owned and managed by Mondaq Ltd (Mondaq). Mondaq grants you a non-exclusive, revocable licence to access the Website and associated services, such as the Mondaq News Alerts (Services), subject to and in consideration of your compliance with the following terms and conditions of use (Terms). Your use of the Website and/or Services constitutes your agreement to the Terms. Mondaq may terminate your use of the Website and Services if you are in breach of these Terms or if Mondaq decides to terminate the licence granted hereunder for any reason whatsoever.

Use of www.mondaq.com

To Use Mondaq.com you must be: eighteen (18) years old or over; legally capable of entering into binding contracts; and not in any way prohibited by the applicable law to enter into these Terms in the jurisdiction which you are currently located.

You may use the Website as an unregistered user, however, you are required to register as a user if you wish to read the full text of the Content or to receive the Services.

You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these Terms or with the prior written consent of Mondaq. You may not use electronic or other means to extract details or information from the Content. Nor shall you extract information about users or Contributors in order to offer them any services or products.

In your use of the Website and/or Services you shall: comply with all applicable laws, regulations, directives and legislations which apply to your Use of the Website and/or Services in whatever country you are physically located including without limitation any and all consumer law, export control laws and regulations; provide to us true, correct and accurate information and promptly inform us in the event that any information that you have provided to us changes or becomes inaccurate; notify Mondaq immediately of any circumstances where you have reason to believe that any Intellectual Property Rights or any other rights of any third party may have been infringed; co-operate with reasonable security or other checks or requests for information made by Mondaq from time to time; and at all times be fully liable for the breach of any of these Terms by a third party using your login details to access the Website and/or Services

however, you shall not: do anything likely to impair, interfere with or damage or cause harm or distress to any persons, or the network; do anything that will infringe any Intellectual Property Rights or other rights of Mondaq or any third party; or use the Website, Services and/or Content otherwise than in accordance with these Terms; use any trade marks or service marks of Mondaq or the Contributors, or do anything which may be seen to take unfair advantage of the reputation and goodwill of Mondaq or the Contributors, or the Website, Services and/or Content.

Mondaq reserves the right, in its sole discretion, to take any action that it deems necessary and appropriate in the event it considers that there is a breach or threatened breach of the Terms.

Mondaq’s Rights and Obligations

Unless otherwise expressly set out to the contrary, nothing in these Terms shall serve to transfer from Mondaq to you, any Intellectual Property Rights owned by and/or licensed to Mondaq and all rights, title and interest in and to such Intellectual Property Rights will remain exclusively with Mondaq and/or its licensors.

Mondaq shall use its reasonable endeavours to make the Website and Services available to you at all times, but we cannot guarantee an uninterrupted and fault free service.

Mondaq reserves the right to make changes to the services and/or the Website or part thereof, from time to time, and we may add, remove, modify and/or vary any elements of features and functionalities of the Website or the services.

Mondaq also reserves the right from time to time to monitor your Use of the Website and/or services.

Disclaimer

The Content is general information only. It is not intended to constitute legal advice or seek to be the complete and comprehensive statement of the law, nor is it intended to address your specific requirements or provide advice on which reliance should be placed. Mondaq and/or its Contributors and other suppliers make no representations about the suitability of the information contained in the Content for any purpose. All Content provided "as is" without warranty of any kind. Mondaq and/or its Contributors and other suppliers hereby exclude and disclaim all representations, warranties or guarantees with regard to the Content, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. To the maximum extent permitted by law, Mondaq expressly excludes all representations, warranties, obligations, and liabilities arising out of or in connection with all Content. In no event shall Mondaq and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use of the Content or performance of Mondaq’s Services.

General

Mondaq may alter or amend these Terms by amending them on the Website. By continuing to Use the Services and/or the Website after such amendment, you will be deemed to have accepted any amendment to these Terms.

These Terms shall be governed by and construed in accordance with the laws of England and Wales and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales to settle any dispute which may arise out of or in connection with these Terms. If you live outside the United Kingdom, English law shall apply only to the extent that English law shall not deprive you of any legal protection accorded in accordance with the law of the place where you are habitually resident ("Local Law"). In the event English law deprives you of any legal protection which is accorded to you under Local Law, then these terms shall be governed by Local Law and any dispute or claim arising out of or in connection with these Terms shall be subject to the non-exclusive jurisdiction of the courts where you are habitually resident.

You may print and keep a copy of these Terms, which form the entire agreement between you and Mondaq and supersede any other communications or advertising in respect of the Service and/or the Website.

No delay in exercising or non-exercise by you and/or Mondaq of any of its rights under or in connection with these Terms shall operate as a waiver or release of each of your or Mondaq’s right. Rather, any such waiver or release must be specifically granted in writing signed by the party granting it.

If any part of these Terms is held unenforceable, that part shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties, and the Terms shall continue in full force and effect.

Mondaq shall not incur any liability to you on account of any loss or damage resulting from any delay or failure to perform all or any part of these Terms if such delay or failure is caused, in whole or in part, by events, occurrences, or causes beyond the control of Mondaq. Such events, occurrences or causes will include, without limitation, acts of God, strikes, lockouts, server and network failure, riots, acts of war, earthquakes, fire and explosions.

By clicking Register you state you have read and agree to our Terms and Conditions