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1 FOURTH CAUSE OF ACTION 2 HARASSMENT IN VIOLATION OF FAIR EMPLOYMENT AND HOUSING ACT 3 4 (PLAINTIFF Against All DEFENDANTS) 5 138. RAMIREZ realleges Paragraphs 1 through 137 above and incorporates same as though fully 6 set forth herein. 7 139. The harassment included but was not limitedto unwanted and unwelcome comments directly 8 9 to RAMIREZ that were reported to and by RAMIREZ, as further alleged herein above.As finrther alleged "iF 10 herein above,DEFENDANTS entirely failed to respond as mandated by law. 11 140. The harassing conduct from DEFENDANTS was so severe,widespread or persistent that a 12 reasonable person.in RAMIREZ's circumstances would have considered the work environment to be hostile 13 14 and abusive. RAMIREZ considered the work environment to be hostile or abusive. 15 141. DEFENDANTS whether or not named or designated as a Doe'was/were a supervisor with 16 actual or reasonably perceived authority over RAMIREZ and engaged in the harassing conduct against 17 RAMIREZ. 18 19 142. RAMIREZ was harmed and DEFENDANTS' conduct was a substantial factor in causing 20 RAMIREZ's harm. 21 143. As a direct anal legal result of the harassment RAMIREZ suffered due to her protected status 22 [i.e.,sex/gender,disability(physical or mental),association with a member of a protected class,family care 23 24 or medical leave- and for engaging in protected activities (participating as a witness in a 25 discrimination/harassment complaint, reporting/resisting discrimination/retaliation, requesting/using a 26 disability related accommodation, requesting/using family care and medical leave], RAMIREZ suffered 27 28 harm and injury that was legally(proximately) caused by the conduct of DEFENDANTS. Said harm and injury includes, but is not limited to, special (economic) damages, general (non-economic) damages, 20 RAm RR7v.C[TYoFSANrAANA CAS19NO. COMPI AIPIT