Laserfiche WebLink
1 113. KACHIRISKY's reporting/disclosure of information was a contributing factor in <br /> 2 <br /> KACHIRISKY's lack of promotion and suffering of other adverse employment actions. <br /> 3 <br /> 4 114. Asa direct result ofDEFENDANTS'actions as alleged above,KACHIRISKY suffered harm <br /> 5 and injury that was legally(proximately)caused by the conduct of DEFENDANTS. Said harm and injury <br /> 6 includes, but is not limited to, special (economic) damages, general (non-economic) damages, litigation <br /> 7 <br /> costs, future damages and past damages, lost economic earning capacity in future employment endeavors <br /> 8 <br /> 9 and such further relief as shown at the time of Trial and in excess of the minimal jurisdictional of this Court. <br /> 10 115. Additionally,as a direct and proximate result of the above-described acts of DEFENDANTS, <br /> 11 KACHIRISKY has necessarily incurred attorney's fees and costs and he is entitled, per, inter alia,Labor <br /> 12 <br /> Code §§98.6(b), §1105, 1102.5(f), Code of Civil Procedure §1021.5 and Assembly Bill 1947 to the <br /> 13 <br /> 14 reasonable value of such attorney's fees and costs. <br /> 15 <br /> 16 WHEREFORE, KACHIRISKY prays for Judgment against DEFENDANTS, and each of them, as <br /> 17 <br /> follows: <br /> 18 <br /> 19 1. For compensatory damages, including loss of earnings, deferred compensation, bonuses, <br /> 20 vacation and other employment perquisites and other special and general damages according to proof, <br /> 21 2. Damages for pain and suffering and emotional distress; <br /> 22 <br /> 3. Interest, including pre judgment interest, at the prevailing legal rate; <br /> 23 <br /> 24 4. Attorneys' fees and costs incurred herein; and <br /> 25 5. Costs of suit; and <br /> 26 6. Such further and other relief as the Court deems just and proper. <br /> 27 <br /> 28 <br /> 29 <br /> KACAIRISKY v. CFFY OF SANTA ANA CASE No. <br /> COMPLAINT <br />