Correspondence - CS Item No. 3 - Laserfiche WebLink

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I THIRD CAUSE OF ACTION 2 FAILURE TO TAKE CORRECTIVE ACTION 3 4 IN VIOLATION OF FAIR EMPLOYMENT AND HOUSING ACT 5 (PLAINTIFF Against All DEFENDANTS) 6 121. MORENO realleges Paragraphs I through 120 above and incorporates same as though fully 7 set forth herein. 8 9 122. DEFENDANTS are suffering/have suffered with a number of lawsuits and complaints, 10 (including but not limited to the complaints from MORENO) alleging discrimination, retaliation and I I harassment and putting DEFENDANTS on notice and providing knowledge of the need to eliminate 12 discrimination, retaliation and harassment. 13 14 123. Under the law, as well as their own policies, DEFENDANTS had an obligation to take 15 corrective action to prevent further discrimination, retaliation and harassment of MORENO but failed to do 16 so in violation of Section 12940, et- seq. of the California Government Code. DEFENDANTS failed to 17 18 conduct proper investigations, failed to turn over the results of these investigations, failed to implement 19 properpolicies to prevent discrimination,retaliation and harassmentand failed to properlypunish those who 20 engaged in misconduct to deter further such future actions. 21 124. Asa direct and legal result of the treatment MORENO, MORENO suffered harm and injury 22 23 that was legally(proximately),caused by the conduct of DEFENDANTS. Said harm and injury includes,but 24 is not limited to, special (economic) damages, general (non-economic) damages, attorneys' fees [per 25 Government Code §12965(b)], litigation costs, future damages and past damages, lost economic earning 26 capacity in future employment endeavors and such further relief as shown at the time of Trial and in excess 27 of the minimal jurisdictional of this Court. 28 fJJ 21 MO"M V. CfrVOFSMTAAIqA CASENO. COWAur