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I Penal Code §§186.22, 13670 and Assembly Bill 958 (prohibition of gangs among police officers); <br /> 2 <br /> Government Code §§12900-12999 (California Fair Employment and Housing Act; Government Code <br /> 3 <br /> 4 §§12945.2 et seq.); Child Abuse and Neglect Reporting Act.lPenal Code §§11164 et. seq) (police officers <br /> 5 are mandated reporters); Penal Code §§118, 127, 136.1 (perjury, suborning perjury, witness <br /> 6 tampering/intimidation);Penal Code §§ 832.5, 832.7 (police officer confidentiality, internal investigation <br /> 7 <br /> mandates and public records act compliance); Government Code §§18500, et. seq(civil service laws); City <br /> 8 <br /> 9 of Santa Ana Municipal Code and Santa Ana Police Department Policies.) <br /> 10 180. In response to the disclosures and complaints initiated by MENENDEZ, DEFENDANTS <br /> 11 retaliated against MENENDEZ as more fully described herein. <br /> 12 <br /> 181. Because of the retaliation that MENENDEZ faced,MENENDEZ was not promoted,denied <br /> 13 <br /> 14 workplace opportunities and suffered other adverse employment actions. <br /> 15 182. DEFENDANTS' treatment of and response to the disclosures, complaints and grievances <br /> 16 filed by MENENDEZ was in violation of Labor Code §1102.5. <br /> 17 <br /> 183. MENENDEZ's reporting/disclosure of information was a contributing factor in <br /> 18 <br /> 19 DEFENDANTS'causing MENENDEZ not to promote,DEFENDANTS'denial ofworkplace opportunities <br /> 20 to MENENDEZ and MENENDEZ's suffering of other adverse employment actions. <br /> 21 184. Asa direct result of DEFENDANTS' actions as alleged above,MENENDEZ suffered harm <br /> 22 <br /> and injury that was legally(proximately) caused by the conduct of DEFENDANTS. Said harm and injury <br /> 23 <br /> 24 includes, but is not limited to, special (economic) damages, general (non-economic) damages, litigation <br /> 25 costs, future damages and past damages, lost economic earning capacity in future employment endeavors <br /> 26 and such further relief as shown at the time of Trial and in excess of the minimal jurisdictional of this Court. <br /> 27 <br /> 28 <br /> 28 <br /> MENENDEZ V. CITY OF SANTA ANA CASENO. <br /> COMPLAINT <br />