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1 185. Additionally,as a direct and proximate result ofthe above-described acts of DEFENDANTS, <br /> 2 <br /> MENENDEZ has necessarily incurred attorney's fees and costs and he is entitled,per,inter alia,Labor Code <br /> 3 <br /> 4 §§98.6(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 /> DISCRIMINATION IN VIOLATION OF THE <br /> 8 <br /> 9 FAIR EMPLOYMENT AND HOUSING ACT <br /> 10 (Against All DEFENDANTS) <br /> 11 186. MENENDEZ realleges Paragraphs 1 through 185 above and incorporates same as though <br /> 12 <br /> fully set forth herein. <br /> 13 <br /> 14 187. Section 12940,et.seq. of the California Government Code makes it unlawful for an employer <br /> 15 to discriminate against an employee in "terms, conditions or privileges of employment" because of their <br /> 16 protected status. DEFENDANTS engaged in an action or a course and pattern or conduct that, taken as a <br /> 17 <br /> whole, materially and adversely affected the terms, conditions and/or privileges of MENENDEZ's <br /> 18 <br /> 19 employment. <br /> 20 188. MENENDEZ was treated differently because of his protected status [sexual <br /> 21 orientation/perceived sexual orientation] by DEFENDANTS. <br /> 22 <br /> 189. As a direct and legal result of the discrimination MENENDEZ suffered due to his protected <br /> 23 <br /> 24 status, MENENDEZ suffered harm and injury that was legally (proximately) caused by the conduct of <br /> 25 DEFENDANTS. Said harm and injury includes,but is not limited to, special(economic)damages,general <br /> 26 (non-economic)damages,attorneys'fees[per Government Code§12965(b)],litigation costs,future damages <br /> 27 <br /> and past damages, lost economic earning capacity in future employment endeavors and such further relief <br /> 28 <br /> as shown at the time of Trial and in excess of the minimal jurisdictional of this Court. <br /> 29 <br /> MENENDEZ V. CITY OF SANTA ANA CASENO. <br /> COMPLAINT <br />