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l economic earning capacity in future employment endeavors and such further relief as shown at the time of <br /> 2 <br /> Trial and in excess of the minimal jurisdictional of this Court. <br /> 3 <br /> 4 123. In addition to the damages sought above,as a proximate result of DEFENDANTS'actions <br /> 5 as alleged above, CARDENAL will also seek all damages allowed by the Code. Government Code, <br /> 6 §12965(c). <br /> 7 <br /> THIRD CAUSE OF ACTION <br /> 8 ' <br /> 9 FAILURE TO TAKE CORRECTIVE ACTION <br /> 10 IN VIOLATION OF FAIR EMPLOYMENT AND HOUSING ACT <br /> 11 (PLAINTIFF Against All DEFENDANTS) <br /> 12 . <br /> 124. CARDENAL realleges Paragraphs 1 through 123 above and incorporates same as though <br /> 13 <br /> 14 fully set forth herein. <br /> 15 125. DEFENDANTS are suffering/have suffered with a number of lawsuits and complaints <br /> 16 (including but not limited to the complaints from CARDENAL) alleging discrimination, retaliation and <br /> 17 <br /> harassment and putting DEFENDANTS on notice and providing knowledge of the need to eliminate <br /> 18 <br /> 19 discrimination,retaliation and harassment. <br /> 20 126. Under the law, as well as their own policies, DEFENDANTS had an obligation to take <br /> 21 corrective action to prevent further discrimination,retaliation and harassment of CARDENAL but failed to <br /> 22 <br /> do so in violation of Section 12940,et.seq, of the California Government Code. DEFENDANTS failed to <br /> 23 <br /> 24 conduct proper investigations,failed to turn over the results of these investigations, failed to implement <br /> 25 `proper policies to prevent discrimination,retaliation and harassment and failed to properly punish those in <br /> 26 engaged in misconduct to deter finther such future actions. <br /> 27 <br /> 111 <br /> 2$ <br /> 111 <br /> 23 <br /> CARDMa v.On Y OP 3ANTAANA CABRNO. <br /> C.aMPI.AINF <br />