Laserfiche WebLink
1 on a large class of persons, that is, public employees, and the necessity and financial <br /> 2 burden of private enforcement of said benefit are such as to make appropriate the <br /> 3 award of attorney fees pursuant to California Code of Civil Procedure §1021.5. <br /> 4 SIXTH CAUSE OF ACTION <br /> 5 (Violation of FEHA (Government Code $ 12900, et seq.) <br /> 6 Retaliation for Engaging in Protected Activity <br /> 7 (Against City of Santa Ana/Santa Ana Police Department) <br /> 8 191. The allegations set forth in paragraphs 1 through 190 are re-alleged and <br /> 9 incorporated herein by reference. <br /> 10 192. Plaintiffs filed complaints with the City of Santa Ana, via Defendant Ridge <br /> 11 and/or Motsick regarding allegations of gender discrimination and/or harassment. <br /> 12 Furthermore, Defendants Ridge, Motsick and Carvalho believed that Plaintiffs had or <br /> 13 would file complaints against Ridge for allegations of sexual harassment. In retaliations <br /> 14 for Plaintiffs filing complaints, and/or the fear that additional complaints would be made, <br /> 15 defendants engaged in actions such as issuing punitive action, causing Plaintiff Serrano <br /> 16 to be subject to improper Investigations, placed on administrative leave, and/or to <br /> 17 implement other adverse employment action against Plaintiff Serrano. <br /> 18 193. Plaintiffs complained to Defendants about the inappropriate actions <br /> 19 (discrimination, harassment and/or retaliation), but nothing was done and the retaliation <br /> 20 continued unabated. On the basis of the above, Plaintiffs believe and allege that <br /> 21 Defendants retaliated against them for their complaints of gender discrimination, sexual <br /> 22 harassment, and/or retaliation. <br /> 23 194. Plaintiffs reporting of unlawful actions were motivating factors in <br /> 24 Defendants' decision not to implement adverse employment actions against Plaintiff <br /> 25 Serrano. <br /> 26 195. Defendants' conduct, as alleged, violated the Fair Employment and <br /> 27 Housing Act, Government Code section 12900, et seq., and Defendants committed <br /> 28 unlawful employment practices. <br /> 42 <br /> COMPLAINT <br />