Correspondence - CS Item No. 3 - Laserfiche WebLink

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l SECOND CAUSE OF ACTION 2 RETALIATION IN VIOLATION OF THE 3 4 FAIR EMPLOYMENT AND HOUSING ACT 5 (Against All DEFENDANTS) 6 117. CARDENAL realleges Paragraphs l through 116 above and incorporates same as though 7 fully set forth herein. 8 9 118. Section 12940,et.seq.of the California Government Code makes itunlawful for an employer 10 to retaliate against an employee in "terms, conditions or privileges of employment" because of their . 11 protected status. The Fair Employment and Housing Act("FEHA")protects,not only employees who make 12 a FEHA claim, but also, those who oppose acts made unlawful by the statute and/or testify, assist or 13 14 participate in any manner in proceedings or hearings. 15 119. As referenced above,DEFENDANTS retaliated against CARDENAL for his"opposition", 16 "assistance"and/or"participation"in the FEHA claim of others. 17 120. As detailed above,DEFENDANTS engaged in an action or a course and pattern or conduct 18 19 that, taken as a whole, materially and adversely affected the terms, conditions and/or privileges of 20 CARDENAL's employment. 21 121. As also detailed above,CARDENAL was treated differently by DEFENDANTS because of 22 his protected status [i.e., engaging in protected activities (participating as a witness in a 23 24 discrimination/harassment complaint,reporting/resisting discrimination/retaliation.] 25 122. As a direct and legal result of the retaliation against CARDENAL,CARDENAL suffered 26 harm and injury that was legally(proximately)caused by the conduct of DEFENDANTS. Said harm and 27 28 injury includes, but is not limited to, special (economic) damages, general (non-economic) damages, attorneys' fees[per Government Code§12965(b)],litigation costs, future damages and past damages,lost 22 CARDS [.Y.CnYOFSMTAANA CmEM. COMer.AtNr