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1 122. Because of the retaliation that RAMIREZ faced,RAMIREZ was constructively terminated <br /> 2 <br /> (i.e.,was forced to resign). <br /> 3 <br /> 4 123. DEFENDANTS' treatment of and response to the disclosures, complaints and grievances <br /> 5 filed by RAMIREZ was in violation of Labor Code §1102.5. <br /> 6 124. RAMIREZ's reporting/disclosure of information was a contributing factor in RAMIREZ's <br /> 7 <br /> constructive termination. <br /> 8 <br /> 9 125. Asa direct result of DEFENDANTS'actions as alleged above,RAMIREZ.suffered harm and <br /> 10 injury that was legally (proximately) caused by the conduct of DEFENDANTS. Said harm and injury <br /> 11 includes, but is not limited to, special (economic) damages, general (non-economic) damages, litigation <br /> 12 <br /> 13 costs, future damages and past damages, lost economic earning capacity in future employment endeavors <br /> 14 and such further relief as shown at the time of Trial and in excess of the minimal jurisdictional of this Court. <br /> 15 126. Additionally,as a direct andproximate result of the above-described acts of DEFENDANTS, <br /> 16 RAMIREZ has necessarily incurred attorney's fees and costs and she is entitled,per,inter alia,Labor Code <br /> 17 <br /> §§98.6(b), §1105, 1102.5(f), Code of Civil Procedure §1021.5 and Assembly Bill 1947 to the reasonable <br /> 18 <br /> 19 value of such attorney's fees and costs. <br /> 20 SECOND CAUSE OF ACTION <br /> 21 RETALIATION IN'VIOLATION OF THE <br /> 22 <br /> FAIR EMPLOYMENT AND HOUSING ACT <br /> 23 <br /> 24 (Against All DEFENDANTS) <br /> 25 127. RAMIREZ realleges Paragraphs 1 through 126 above and incorporates same as though filly <br /> 26 set forth herein. <br /> 27 <br /> 111 <br /> 28 <br /> Ill <br /> RAMumv.CmuSAN'rAANA CASIINo. <br /> CONII%AINT <br />