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1 196. As a proximate result of Defendants' willful, knowing, and intentional <br /> 2 discrimination/harassment/retaliation against Plaintiff, Plaintiff has sustained and <br /> 3 continues to sustain damages, humiliation, distress, pain and anguish, all to his <br /> 4 damage in a sum according to proof. <br /> 5 197. Plaintiffs have incurred and continues to incur legal expenses and <br /> 6 attorneys' fees. Pursuant to Government Code section 12965(b), plaintiffs are entitled <br /> 7 to recover reasonable attorneys' fees and costs (including expert costs) in an amount <br /> 8 according to proof. <br /> 9 198. Plaintiffs further request that the Court render appropriate injunctive or <br /> 10 other extraordinary relief to remedy these violations and to prevent future violations of a <br /> 11 like or similar nature, including, but not limited to, the granting of a permanent injunction <br /> 12 requiring the Defendants, upon receiving notification of conduct which may violate the <br /> 13 California Department of Fair Employment and Housing regulations or California <br /> 14 whistleblower statutes, to promptly conduct a fair and thorough investigation into the <br /> 15 allegations and not allow retaliatory actions to be taken against the employees. <br /> 16 199. Plaintiff requests this court to award ancillary damages pursuant to C.C.P. <br /> 17 §1090 and 1095. <br /> 18 200. The actions of defendants, and each of them, were arbitrary and capricious <br /> 19 and, therefore, Plaintiff is entitled to recover attorneys' fees pursuant to Government <br /> 20 Code §800. <br /> 21 201. The success of Plaintiff in this action will result in the enforcement of an <br /> 22 important right affecting the public interest in that a significant benefit will be conferred <br /> 23 on a large class of persons, that is, public employees, and the necessity and financial <br /> 24 burden of private enforcement of said benefit are such as to make appropriate the <br /> 25 award of attorney fees pursuant to California Code of Civil Procedure §1021.5 <br /> 26 202. Plaintiff obtained a Right to Sue letter from the DFEH, and served the <br /> 27 same on defendants via the City Clerk's office. <br /> 28 WHEREFORE, Plaintiff prays for judgment against Defendants and each of them <br /> 43 <br /> COMPLAINT <br />