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1 118. Additionally,as a direct and proximate result ofthe above-described acts of DEFENDANTS, <br /> 2 <br /> VALDEZ has necessarily incurred attorney's fees and costs and she is entitled,per,inter alia,Labor Code <br /> 3 <br /> 4 §§98.b(b), §1105, 1102.5(f), Code of Civil Procedure §1021.5 and Assembly Bill 1947 to the reasonable <br /> 5 value of such attorney's fees and costs. <br /> 6 SECOND CAUSE OF ACTION <br /> 7 <br /> RETALIATION IN VIOLATION OF THE <br /> 8 <br /> 9 FAIR EMPLOYMENT AND DOUSING ACT <br /> 10 (Against All DEFENDANTS) <br /> 11 119. VALDEZ realleges Paragraphs 1 through 118 above and incorporates same as though fully <br /> 12 <br /> set forth herein. <br /> 13 <br /> 14 120. Section 12940,et.seq.ofthe California Government Code makes it unlawful for an employer <br /> 15 to retaliate against an employee in "terms, conditions or privileges of employment" because of their <br /> 16 protected status. The Fair Employment and.Housing Act("FEHA")protects,not only employees who make <br /> 17 <br /> a FEHA claim, but also, those who oppose acts made unlawful by the statute and/or testify, assist or <br /> 18 <br /> 19 participate in any manner in proceedings or hearings. <br /> 20 121. As referenced above, DEFENDANTS retaliated against VALDEZ because she: (1) <br /> 21 participated as a witness in a discrimination or harassment complaint; and/or (2) reported or resisted any <br /> 22 <br /> form of discrimination or harassment. As detailed above, VALDEZ was treated differently by <br /> 23 <br /> 24 DEFENDANTS (i.e.,retaliated against)because of same. <br /> 25 122. As detailed above,DEFENDANTS engaged in an action or a course and pattern of conduct <br /> 26 that, taken as a whole, materially and adversely affected the terms, conditions and/or privileges of <br /> 27 <br /> VALDEZ's employment. <br /> 28 <br /> Ill <br /> is <br /> VALDEZv.CI'ITYoFSANTAANA CASENO. <br /> COMPI.ATNT <br />