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1 in the harassing and retaliatory actions described herein, which ultimately resulted in Plaintiff being <br /> 2 subjected to the actions detailed herein. <br /> 3 23. There was a causal connection between Plaintiff s protected activity and the harassing and <br /> 4 retaliatory actions described herein. <br /> 5 24. Defendants' conduct was a substantial factor in causing Plaintiff's harm. <br /> 6 25. As a direct and proximate result of the acts of Defendants, as alleged above, Plaintiff has <br /> 7 incurred and will continue to incur compensatory damages, including lost earnings and other economic <br /> 8 damages, in an amount according to proof at trial. <br /> 9 26. As a further direct and proximate result of the acts of Defendants, as alleged above, Plaintiff <br /> t } 10 has suffered and will continue to suffer emotional distress and has been generally damaged in an <br /> v a <br /> 11 amount to be ascertained at trial. <br /> o <br /> a �0 12 27. Defendants authorized and ratified the wrongful acts of their agents and employees, knew in <br /> H �= <br /> , 13 advance that their agents and employees were likely to commit such acts and employed them with <br /> tti 14 conscious disregard of the rights or safety of others, and/or their officers, directors,or managing agents <br /> x15 were themselves guilty of oppression, fraud, and malice. Those who retaliated against Plaintiff were <br /> rilW a G 16 managing agents who were vested with discretionary authority to make decisions affecting City <br /> 17 employee policy regarding significant aspects of the Defendants' business. These managing agents <br /> m 18 acted with malice in engaging in the actions detailed herein in that they retaliated against Plaintiff <br /> 19 because of the complained about California and federal statutory violations despite knowing it was <br /> 20 illegal to do so under California law, in conscious disregard of Plaintiffs rights. In engaging in the <br /> 21 aforementioned conduct, Defendants aided, abetted, incited, compelled, and/or coerced unlawful <br /> 22 employment practices in violation of Labor Code § 1102.5 (b). <br /> 23 28. As a further direct and proximate result of the above-described acts of Defendant, Plaintiff has <br /> 24 necessarily incurred attorneys' fees and costs. <br /> 25 // <br /> 26 ll <br /> 27 /! <br /> 28 // <br /> PLAINTIFF PALOMA ORTIVS COMPLAINT <br /> 6 <br />