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1 128. As a direct and legal result of the discrimination VALDEZ suffered due to her protected <br /> 2 <br /> status, VALDEZ suffered harm and injury that was legally (proximately) caused by the conduct of <br /> 3 <br /> 4 DEFENDANTS. Said harm and injury includes,but is not limited to,special(economic)damages,general <br /> 5 (non-economic)damages,attorneys'fees[per Government Code§12965(b)]and such further relief as shown <br /> 6 at the time of Trial and in excess of the minimal jurisdictional of this Court. <br /> 7 <br /> FOURTH CAUSE OF ACTION <br /> 8 <br /> 9 HARASSMENT IN VIOLATION OF FAIR EMPLOYMENT AND HOUSING ACT <br /> 10 (PLAINTIFF Against All DEFENDANTS) <br /> 11 129. VALDEZ realleges Paragraphs 1 through 128 above and incorporates same as though fully <br /> 12 <br /> set forth herein. <br /> 13 <br /> 14 130. The harassment included but was not limited to unwanted and unwelcome comments directly <br /> 15 to VALDEZ that were reported to and by VALDEZ, as further alleged herein above. As further alleged <br /> 1.6 herein above,DEFENDANTS entirely failed to respond as mandated by law. <br /> 17 <br /> 131. The harassing conduct from DEFENDANTS was so severe,widespread or persistent that a <br /> 18 <br /> 19 reasonable person in VALDEZ's circumstances would have considered the work environment to be hostile <br /> 20 and abusive. VALDEZ considered the work environment to be hostile or abusive. <br /> 21 132. DEFENDANTS whether or not named or designated as a Doe was/were a supervisor with <br /> 22 <br /> actual or reasonably perceived authority over VALDEZ and engaged in the harassing conduct against <br /> 23 <br /> 24 VALDEZ. <br /> 25 133. VALDEZ was harmed and DEFENDANTS' conduct was a substantial factor in causing <br /> 26 VALDEZ's harm. <br /> 27 <br /> Ill <br /> 28 <br /> 111 <br /> 20 <br /> VALD LV.Crry of SANTA ANA CASENO, <br /> COMPLAINT <br />