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1 138. As a direct and legal result of the treatment VALDEZ suffered due to her protected.status, <br /> 2 <br /> VALDEZ suffered harm and injury that was legally(proximately)causedby 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 /> 8 <br /> 9 WHEREFORE,VALDEZ prays for Judgment against DEFENDANTS,and each ofthem,as follows: <br /> 10 1. For compensatory damages, including loss of earnings, deferred compensation,bonuses, <br /> 11 vacation and other employment perquisites and other special and general damages according to proof; <br /> 12 <br /> 2. Damages for pain and suffering and emotional distress; <br /> 13 <br /> 14 3. Interest, including pre judgment interest, at the prevailing legal rate; <br /> 15 4. Attorneys' fees and costs incurred herein; and <br /> 16 5. Costs of suit; and <br /> 17 <br /> 6. Such further and other relief as the Court deems just and proper. <br /> 18 <br /> 19 <br /> 20 REQUEST FOR TRIAL BY JURY <br /> 21 VALDEZ hereby demands a Trial by Jury. <br /> 22 <br /> 23 <br /> 24 DATED: October 24, 2023 LAW OFFICE OF LAWRENCE J. LENNEMANN <br /> 25 <br /> 26 By: Lawrence J. Lennemann <br /> 27 LAWRENCE J. LENNEMANN <br /> Attorneys for Plaintiff JUDITH VALDEZ <br /> 28 <br /> zz <br /> VALmz V,0TY of SANTAANA CA89NO. <br /> COMPLAINT <br />