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1 133. In addition to the damages sought above, as a proximate result of DEFENDANTS' actions <br /> 2 <br /> as alleged above,RAMIREZ will also seek all damages allowed by the Code.Government Code,§12965(c). <br /> 3 <br /> 4 THIRD CAUSE OF ACTION <br /> 5 DISCRIMINATION IN VIOLATION OF FAIR.EMPLOYMENT AND HOUSING ACT <br /> 6 (PLAINTIFF Against All DEFENDANTS) <br /> 7 <br /> 134. RAMIREZ realleges Paragraphs I through 133 above and incorporates same as though fully <br /> 8 <br /> 9 set forth herein. <br /> )'10 135. Section 1,2940,et.seq.ofthe California Government Code makes it unlawful for an employer <br /> 11 to discriminate against an employee in "terms, conditions or privileges of employment" because of the <br /> 12 <br /> protected status. DEFENDANTS engaged in an action or a course and pattern or conduct that,taken as a <br /> 13 <br /> 14 whole, materially and adversely affected the terms, conditions and/or privileges of RAMIREZ's <br /> 15 employment. <br /> 16 136. RAMIREZ was treated differently by DEFENDANTS because of her protected status [i.e., <br /> 17 <br /> 18 sex/gender, disability(physical or mental), association with a member of a protected class,family care or <br /> 19 medical leave and for engaging in protected activities (participating as a witness in a <br /> 20 discriminationiharassment complaint, reporting/resisting discrimination/retaliation, requesting/using a <br /> 21 disability related accommodation,requesting/using family care and medical leave]. <br /> 22 <br /> 23 137. As a direct and legal result of the discrimination RAMIREZ suffered due to her protected <br /> 24 status, RAMIREZ suffered harm and injury that was legally. (proximately) caused by the conduct of <br /> 25 DEFENDANTS. Said harm and injury includes,but is not limited to,special(economic)damages,general <br /> 26 (non-economic)damages,attorneys'fees[per Government Code§12965(b)],litigation costs,future damages <br /> 27 <br /> and past damages, lost economic earning capacity in future employment endeavors and such further relief <br /> 28 <br /> as shown at the time of Trial and in excess of the minimal jurisdictional of this Court. <br /> RAMIREZ V.Cay or SANTA.ANA CASE No. <br /> COMPLAINT <br />