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I §§12945.2 et seq.); Child Abuse and Neglect Reporting Act.lPenal Code, §§11164 et. seal) (police officers <br /> 2 <br /> are mandated reporters); Penal Code §§118, 127, 136.1 (perjury, suborning perjury, witness <br /> 3 <br /> 4 tamperinglintimidation); Government Code §§18500, et. seal (civil service laws); City of' Santa Ana <br /> 5 Municipal Code and Santa Ana Police Department Policies]. <br /> 6 110. In response to the disclosures and complaints initiated, by MORENO, DEFENDANTS <br /> 7 <br /> retaliated against MORENO as more fully described herein. <br /> 8 <br /> 9 111. Because of the retaliation that MORENO faced, MORENO was not promoted, denied <br /> 10 workplace opportunities and suffered other adverse employment actions. <br /> 11 112. DEFENDANTS' treatment of and response to the disclosures, complaints and grievances <br /> 12 <br /> filed by MORENO was in violation of Labor Code §1102.5. <br /> 13 <br /> 14 113. MORENO's reporting/disclosure of information was a contributing factor, in <br /> 15 EFENDANTS' causing MORENO not to promote, DEFENDANTS' denial of workplace opportunities <br /> 16 to MORENO and MORENO's suffering of other adverse employment actions. <br /> 17 <br /> 114. Asa direct result of DEFEND ANTS'actions as alleged above,MORENO suffered harm and <br /> 18 <br /> 19 injury that was legally (proximately) caused by the conduct of DEFENDANTS. Said harm and injury <br /> 20 includes, but is not limited to, special (economic) damages, general (non-economic) damages, litigation <br /> 21 costs,future damages and past damages, lost economic earning capacity in future employment endeavors <br /> 22 <br /> 23 and such further relief as shown at the time of Trial and in excess of the minimal jurisdictional of this Court. <br /> 24 115. Additionally,as a direct and proximate result of the above-described acts of DEFENDANTS, <br /> 25 MORE NO has necessarily incurred attorney's fees and costs and he is entitled,per,inter alia, Labor Code <br /> 26 §§98.6(b), §11015, 1102.5(f), Code of Civil Procedure §1021.5 and Assembly Bill 1947 to the reasonable <br /> 27 <br /> value of such attorney's fees and costs. <br /> 28 <br /> 111 <br /> MOREND V. CrrV OF SANTA ANA CASENO. <br /> ICOMAINT <br />