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1 (workplace safety); Penal Code §§ 118, 127, 136.1 (perjury, suborning perjury, witness <br /> 2 <br /> tampering);Government Code§§6250 et sect.(California Public Records Act);Penal Code§§ 832.5,832.7 <br /> 3 <br /> 4 (police officer confidentiality,internal investigation mandates and public records act compliance.) <br /> 5 111. In response to the disclosures and complaints initiated by CARDENAL, DEFENDANTS <br /> 6 retaliated against CARDENAL as more fully described herein. <br /> 7 <br /> 112. Because of the retaliation that CARDENAL faced,CARDENAL was demoted and suffered <br /> 8 ` <br /> other adverse employment actions. <br /> 10 113. DEFENDANTS' treatment of and response to the disclosures, complaints and grievances <br /> 11 filed by CARDENAL was in violation ofLabor Code §1102.5. <br /> 12 <br /> 114. CARDENAL's reporting/disclosure of information was a contributing factor in <br /> 13 <br /> 14 CARDENAL's demotion and suffering of other adverse employment actions. <br /> 15 115. Asa direct result of DEFENDANTS'actions as alleged above,CARDENAL suffered harm <br /> 16 and injury that was legally(proximately)caused by the conduct of DEFENDANTS. Said harm and injury <br /> 17 <br /> includes, but is not limited to, special (economic) damages, general (non-economic) damages, litigation <br /> 18 <br /> 19 costs, :future damages and past,damages, lost economic earning capacity in future employment endeavors <br /> 20 and such further relief as shown at the time of Trial and in excess of the minimal jurisdictional of this Court. <br /> 21 116. Additionally,as a direct and proximate result of the above-described acts ofDEFENDANTS, <br /> 22 <br /> CARDENALhas necessarily incurred attorney's fees and costs and he is entitled,per,interalia,Labor Code <br /> 23 <br /> 24 §§98.6(b), §1105, 1102.5(f), Code of Civil Procedure §1021.5 and Assembly Bill 1947 to the reasonable <br /> 25 value of such attorney's fees and costs. <br /> 26 Ill <br /> 27 <br /> 'llI <br /> 28 <br /> "lll <br /> 21 <br /> CARDwmv.C7YcwSmTAANA "ENO. <br /> COWL4W <br />