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I attorneys' fees [per Government Code §12965(b)], litigation costs, future damages and past damages, lost 2 economic earning capacity in future employment endeavors and such further relief as shown at the time of 3 4 Trial and in excess of the minimal jurisdictional of this Court. 5 FIFTH CAUSE OF ACTION 6 FAILURE TO TAKE CORRECTIVE ACTION 7 IN VIOLATION OF FAIR EMPLOYMENT AND HOUSING ACT 8 9 (PLAINTIFF Against All DEFENDANTS) 10 144. RAMIREZ realleges Paragraphs 1 through 143 above and incorporates same as though fully 11 set forth herein. 12 145. DEFENDANTS are suffering/have suffered with a number of lawsuits and complaints 13 14 (including but not limited to the complaints from RAMIREZ) alleging discrimination, retaliation and 15 harassment and putting DEFENDANTS on notice and providing knowledge of the need to eliminate 16 discrimination, retaliation and harassment. 17 146. Under the law, as well as their own policies, DEFENDANTS had an obligation to take 18 19 corrective action to prevent further discrimination, retaliation and harassment of RAMIREZ but failed to 20 do so in violation of Section 12940,et. seq. of the California Government Code. DEFENDANTS failed to 21 conduct proper investigations, failed to turn over the results of these investigations, failed to implement 22 proper policies to prevent discrimination,retaliation and harassment and failed to properly punish those in 23 24 engaged in misconduct to deter further such future actions. 25 147. As a direct and legal result of the treatment RAMIREZ suffered due to her protected status, 26 RAMIREZ suffered harm and injury that was legally (proximately) caused by the conduct of 27 DEFENDANTS. Said harm and injury includes,but is not limited to, special(economic)damages,general 28 (non-economic)damages,attorneys'fees[per Government Code§12965(b)],litigation costs,future damages 21 RAminzv. CITYoFSANTAANA CASENo. COMPLAINT