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1 190. In addition to the damages sought above, as a proximate result of DEFENDANTS' actions <br /> 2 <br /> as alleged above, MENENDEZ will also seek all damages allowed by the Code. Government Code, <br /> 3 <br /> 4 §12965(c). <br /> 5 THIRD CAUSE OF ACTION <br /> 6 HARASSMENT IN VIOLATION OF THE <br /> 7 <br /> FAIR EMPLOYMENT AND HOUSING ACT <br /> 8 <br /> 9 (Against All DEFENDANTS) <br /> 10 191. MENENDEZ realleges Paragraphs 1 through 190 above and incorporates same as though <br /> 11 fully set forth herein. <br /> 12 <br /> 192. Section 12940,et.seq. of the California Government Code makes it unlawful for an employer <br /> 13 <br /> 14 to harass an employee in"terms,conditions or privileges of employment"because of their protected status. <br /> 15 DEFENDANTS engaged in an action or a course and pattern or conduct that, taken as a whole,materially <br /> 16 and adversely affected the terms, conditions and/or privileges of MENENDEZ's employment. <br /> 17 <br /> 193. The harassment included but was not limited to unwanted and unwelcome comments directly <br /> 18 <br /> 19 to MENENDEZ that were reported to and by MENENDEZ,as further alleged above.As also alleged herein <br /> 20 above, DEFENDANTS entirely failed to respond as mandated by law. <br /> 21 194. The harassing conduct from DEFENDANTS was so severe,widespread or persistent that a <br /> 22 <br /> reasonable person in MENENDEZ's circumstances would have considered the work environment to be <br /> 23 <br /> 24 hostile and abusive. MENENDEZ considered the work environment to be hostile or abusive. <br /> 25 195. MENENDEZ was harmed and DEFENDANTS' conduct was a substantial factor in causing <br /> 26 MENENDEZ's harm. <br /> 27 <br /> 196. As a direct and legal result of the discrimination MENENDEZ suffered due to his protected <br /> 28 <br /> status, MENENDEZ suffered harm and injury that was legally (proximately) caused by the conduct of <br /> 30 <br /> MENENDEZ V. CITY OF SANTA ANA CASENO. <br /> COMPLAINT <br />