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1 134. As a direct and legal result of the harassment VALDEZ suffered due to her protected status 2 [i.e., sex/gender, association with a member of a protected class and for engaging in protected activities 3 4 (participating as a witness in a discrimination/harassment complaint, reporting/resisting 5 discrimination/retaliation)],VALDEZ suffered harm and injury that was legally(proximately)eausedby the 6 conduct of DEFENDANTS. Said harm and injury includes, but is not limited to, special (economic) 7 damages, general(non-economic) damages, attorneys' fees [per Government Code §12965(b)] and such 8 9 further relief as shown at the time of Trial and in excess of the minimal jurisdictional of this Court. 10 FIFTH CAUSE OF ACTION 11 FAILURE TO TAKE CORRECTIVE ACTION 12 IN VIOLATION OF FAIR EMPLOYMENT AND HOUSING ACT 13 14 (PLAINTIFF Against All DEFENDANTS) 15 135. VALDEZ realleges Paragraphs 1 through 134 above and incorporates same as though fully 16 set forth herein. 17 136. DEFENDANTS are suffering/have suffered with a number of lawsuits and complaints 18 19 (including but not limited to the complaints from VALDEZ) alleging discrimination, retaliation and 20 harassment and putting DEFENDANTS on notice and providing knowledge of the need to eliminate 21 discrimination, retaliation and harassment. 22 137. Under the law, as well as their own policies, DEFENDANTS had an obligation to take 23 24 corrective action to prevent further discrimination,retaliation and harassment of VALDEZ but failed to do 25 so in violation of Section 12940, et. seq. of the California Government Code. DEFENDANTS failed to 26 conduct proper investigations, failed to turn over the results of these investigations, failed to implement 27 proper policies to prevent discrimination,retaliation and harassment and failed to properly punish those in 28 engaged in misconduct to deter further such future actions. 21 VALDEZ V. CITY OF SANTA ANA CASBNO.