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1 123. As a direct and legal result of the retaliation against VALDEZ due to her protected status, <br /> 2 <br /> VALDEZ suffered harm and injury that was legally(proximately)caused by the conduct of DEFENDANTS. <br /> 3 <br /> 4 Said harm and injury includes,but is not limited to, special(economic)damages, general(non-economic) <br /> 5 damages,attorneys' fees [per Government Code §12965(b)] and such further relief as shown at the time of <br /> 6 Trial and in excess of the minimal jurisdictional of this Court. <br /> 7 <br /> 124. In addition to the above damages,as a proximate result of DEFENDANTS'actions as alleged <br /> 8 <br /> 9 above,VALDEZ will also seek all damages allowed by the Code. Government Code, §12965(b), (c). <br /> 10 THIRD CAUSE OF ACTION <br /> 11 DISCRIMINATION IN VIOLATION OF FAIR EMPLOYMENT AND HOUSING ACT <br /> 12 <br /> (PLAINTIFF Against All DEFENDANT'S) <br /> 13 <br /> 14 125. VALDEZ realleges Paragraphs 1 through 124 above and incorporates same as though fully <br /> 15 set forth herein. <br /> 16 126. Section 12940,et.seq. ofthe California Government Code makes it unlawful for an employer <br /> 17 <br /> to discriminate against an employee in "terms, conditions or privileges of employment" because of the <br /> 18 <br /> 19 protected status. DEFENDANTS engaged in an action or a course and pattern or conduct that,taken as a <br /> 20 whole,materially and adversely affected the terns,conditions and/or privileges ofVALDEZ's employment. <br /> 21 127. VALDEZ was treated differently by DEFENDANTS because of her protected status [i.e., <br /> 22 <br /> sex/gender, association with a member of a protected class] and for engaging in protected activities <br /> 23 <br /> 24 (participating as a witness in a discrimination/harassment complaint, reporting/resisting <br /> 25 discrimination/retaliation). <br /> 26 11l <br /> 27 <br /> 11l <br /> 28 <br /> 19 <br /> VALDFZv, CrTYOFSANTAANA CASENO. <br /> COWLATNT <br />