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1 proven at trial. <br /> 2 45. As a direct and proximate result of said wrongful acts by Defendants, Plaintiff has suffered and <br /> 3 will continue to suffer substantial losses in earnings and other employment benefits, along with other <br /> 4 incidental and consequential damages and losses, all in an amount to be proven at the time of trial. <br /> 5 Plaintiff claims such amount as damages together with prejudgment interest pursuant to Civil Code § <br /> 6 3287 and any other provision of law providing for prejudgment interest. <br /> 7 46. As direct and proximate result of Defendants' wrongful acts, Plaintiff has suffered and will <br /> 8 continue to suffer emotional distress, loss of earnings, future loss of earnings, loss of status and future <br /> 9 status, loss of other employment benefits and job opportunities all to her damage in a sum to be <br /> 10 established according to proof. <br /> U o <br /> p` z 11 47. As a direct and proximate result of said wrongful acts by Defendants, Plaintiff has incurred <br /> 06 <br /> o 12 attorneys' fees in an amount to be determined, for which Plaintiff claims a sum to be established <br /> Wo 13 according to proof. <br /> y 14 PRAYER FOR RELIEF <br /> O <br /> 15 WHEREFORE, Plaintiff prays as follows: <br /> W o 16 1. For an award of all actual,consequential, compensatory,and incidental financial losses suffered <br /> 0 Q 17 by Plaintiff, including lost wages, back pay, front pay, and lost employment benefits in an amount of <br /> U o <br /> 18 at least$250,000; <br /> 19 2. For an award of general and special damages, including from the emotional distress and mental <br /> 20 anguish suffered by Plaintiff in an amount of$250,000; <br /> 21 3. Penalties pursuant to Labor Code § 1102.5; <br /> 22 4. Penalties pursuant to the FEHA, <br /> 23 5. For an award of Plaintiff's attorneys' fees and costs under applicable statutory bases, including <br /> 24 California Labor Code section 1102.5(b), 12965 (b),and the FEHA,and for prejudgment interest under <br /> 25 Civil Code § 3287 or 3288, and other applicable statutory bases; <br /> 26 6. For declaratory relief against Defendants, their officers, agents, successors, employees, <br /> 27 representatives, and any and all persons acting in concert with theirs that engaging in each of the <br /> 28 practices complained of in this Complaint are unlawful; and <br /> PLAINTIFF PALOMA ORTIZ'S COMPLAINT <br /> 9 <br />