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Correspondence - Non Agenda
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1 128. Section 12940,et.seq.of the California Government Code wakes it unlawful for an employer <br /> 2 <br /> to retaliate against an employee in "terms, conditions or privileges of employment" because of their <br /> 3 <br /> 4 protected status. The Fair Employment and Housing Act("FEHA")protects,not only employees who make <br /> 5 a FEHA claim, but also, those who oppose acts made unlawful by the statute and/or testify, assist or <br /> 6 participate in any manner in proceedings or hearings. <br /> 7 <br /> 129. As referenced above,DEFENDANTS retaliated against RAMIREZ:(1)for her"opposition", <br /> 8 <br /> 9 "assistance"and/or"participation"in the FEHA claim of others; and(2)for the making of her own FEHA <br /> 10 claim. <br /> 11 130. As detailed above,DEFENDANTS engaged in an action or a course and pattern or conduct <br /> 12 <br /> 13 that, taken as a whole, materially and adversely affected the terms, conditions and/or privileges of <br /> 14 RAMIREZ's employment. <br /> 15 131. As also.detailed above,RAMIREZ was treated differentlyby DEFENDANTS because ofher <br /> 16 protected status [i.e., sex/gender,disability(physical or mental), association with a member of a protected <br /> 17 <br /> class, family care or medical leave and for engaging in protected activities (participating as a witness in a <br /> 18 <br /> 19 discrimination/harassment complaint, reporting/resisting discrimination/retaliation, requesting/using a <br /> 20 disability related accommodation,requesting/using family care and medical leave]. <br /> 21 132. Asa direct and legal result of the retaliation against RAMIREZ due to her protected status, <br /> 22 <br /> RAMIREZ suffered harm and injury that was legally (proximately), caused by the conduct of <br /> 23 <br /> 24 DEFENDANTS. Said harm and injury includes,but is not limited to,special(economic)damages,general <br /> 25 (non economic)damages,attorneys'fees[per Government Come§12965(b)b litigation costs,future damages <br /> 26 and past damages, lost economic earning capacity in future employment endeavors and such further relief <br /> 27 <br /> 2$ as shown at the time of Trial and in excess of the minimal jurisdictional of this Court. <br /> 111 <br /> is <br /> RAM PEZ v.CITY or SMTA ANA CmE No. <br /> CoMP[, wr <br />
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