Correspondence - CS Item No. 3 - Laserfiche WebLink

Home Browse Search

I DEFENDANTS. Said harm and injury includes,but is not limited to, special(economic)damages,general 2 (non-economic)damages,attorneys'fees[per Government Code§12965(b)],litigation costs,future damages 3 4 and past damages, lost economic earning capacity in future employment endeavors and such further relief 5 as shown at the time of Trial and in excess of the minimal jurisdictional of this Court. 6 197. In addition to the damages sought above, as a proximate result of DEFENDANTS' actions 7 as alleged above, MENENDEZ will also seek all damages allowed by the Code. Government Code, 8 9 §12965(c). 10 FOURTH CAUSE OF ACTION 11 FAILURE TO TAKE CORRECTIVE ACTION 12 IN VIOLATION OF FAIR EMPLOYMENT AND HOUSING ACT 13 14 (PLAINTIFF Against All DEFENDANTS) 15 198. MENENDEZ realleges Paragraphs 1 through 197 above and incorporates same as though 16 fully set forth herein. 17 199. DEFENDANTS are suffering/have suffered with a number of lawsuits and complaints 18 19 (including but not limited to the complaints from MENENDEZ) alleging discrimination, retaliation and 20 harassment and putting DEFENDANTS on notice and providing knowledge of the need to eliminate 21 discrimination, retaliation and harassment. 22 200. Under the law, as well as their own policies, DEFENDANTS had an obligation to take 23 24 corrective action to prevent further discrimination, retaliation and harassment of MENENDEZ but failed 25 to do so in violation of Section 12940, et. seq. of the California Government Code. DEFENDANTS failed 26 to conduct proper investigations, failed to turn over the results of these investigations, failed to implement 27 proper policies to prevent discrimination,retaliation and harassment and failed to properly punish those who 28 engaged in misconduct to deter further such future actions. 31 MENENDEZ V. CITY OF SANTA ANA CASENO. COMPLAINT