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I FIRST CAUSE OF ACTION 2 RETALIATION IN VIOLATION OF LABOR CODE §1102.5 3 4 (Against All DEFENDANTS) 5 108. KACHHUSKY realleges Paragraphs 1 through 107 above and incorporates same as though 6 fully set forth herein. 7 109. KACHHUSKY, as described more fully above,reported/disclosed to a government agency 8 9 and/or law enforcement agency and/or a person with authority over her or to an employee with authority to 10 investigate,discover,or correct legal violations and/or noncompliance to DEFENDANTS. KACHIRISKY 11 had reasonable cause to believe that the information reported/disclosed a violation of state,or federal statute 12 and/or a violation of and/or noncompliance with a local, state and/or federal rule and/or regulation [i.e., 13 14 Penal Code §§186.22, 13670 and Assembly Bill 958 (prohibition of gangs among police officers); 15 Government Code §§12900-12999 (California Fair Employment and Housing Act; Government Code 16 §§12945.2 et seq.); The California Occupational Safety and Health Act of 1973; Labor Code §6310 17 (workplace safety); Penal Code §§ 118, 127, 136.1 (perjury, suborning perjury, witness 18 19 tampering);Government Code§§6250 et seq. (California Public Records Act);Penal Code§§ 832.5, 832.7 20 (police officer confidentiality, internal investigation mandates and public records act compliance)]. 21 110. In response to the disclosures and complaints initiated by KACHIRISKY,DEFENDANTS 22 retaliated against KACHIRISKY as more fully described herein. 23 24 111. Because of the retaliation that KACHIRISKY faced,KACHHUSKY was not promoted and 25 suffered other adverse employment actions. 26 112. DEFENDANTS' treatment of and response to the disclosures, complaints and grievances 27 filed by KACHHUSKY was in violation of Labor Code §1102.5. 28 as KACFIIRISKY v. CFTY OF SANTA ANA CASE No. COMPLAINT