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1 113. VALDEZ,as described more fully above,reported/disclosed to a government agency and/or <br /> 2 <br /> law enforcement agency and/or a person with authority over her or to an employee with authority to <br /> 3 <br /> 4 investigate,discover,or correct legal violations and/or noncompliance to DEFENDANTS. VALDEZ had <br /> 5 reasonable cause to believe that the information reported/disclosed a violation of state, or federal statute <br /> 6 and/or a violation of and/or noncompliance with a local, state and/or federal rule and/or regulation [i.e., <br /> 7 <br /> Government Cade §§12900-12999 (California Fair Employment and Housing Act; Government Code <br /> 8 <br /> 9 §§12945.2 et seq.;Penal Code§§186.22, 13670 and Assembly Bill 958(prohibition of gangs among police <br /> 10 officers); Child Abuse and Neglect Reporting Act.IPenal Code §§11164 et. seq) (police officers are <br /> 11 mandated reporters); Penal Code §§118, 127, 136.1 (perjury, suborning perjury, witness <br /> 12 <br /> tampering/intimidation);City of Santa Ana.Municipal Code and Santa Ana Police Department Policies.]Tn <br /> 13 <br /> 14 response to the disclosures and complaints initiated by VALDEZ, DEFENDANTS retaliated against <br /> 15 VALDEZ as more fully described herein. <br /> 16 114. Because of the retaliation that VALDEZ faced, VALDEZ was wrongfully disciplined and <br /> 17 <br /> not promoted. <br /> 18 <br /> 19 115. DEFENDANTS' treatment of and response to the disclosures, complaints and grievances <br /> 20 filed by VALDEZ was in violation of Labor Code §1102.5. <br /> 21 116. VALDEZ's reporting/disclosure of information was a contributing factor in VALDEZ's <br /> 22 <br /> suffering of adverse employment actions. <br /> 23 <br /> 24 117. Asa direct result of DEFENDANTS'actions as alleged above,VALDEZ suffered harm and <br /> 25 injury that was legally (proximately) caused by the conduct of DEFENDANTS. Said harm and injury <br /> 26 includes, but is not limited to, special (economic) damages, general (non-economic) damages, litigation <br /> 27 <br /> 28 costs, future damages and past damages, lost economic earning capacity in future employment endeavors <br /> and such further relief as shown at the time of Trial and in excess of the minimal jurisdictional of this Count. <br /> 17 <br /> vAmRz v.CaY of SAN,A ANA CASH No. <br /> COMPLAW <br />