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10/07/2025 Regular & HA
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Correspondence - Non Agenda
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City Clerk
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10/7/2025
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I FIFTH CAUSE OF ACTION <br /> 2 9. A declaration of the Court that the Defendants violated Penal Code §832,5- <br /> 3 832.7 and/or Evidence Code §§1043-1046 and that Plaintiffs are entitled to the full <br /> 4 relief afforded under Penal Code §832.5-832.7 and/or Evidence Code §§1043-1046. <br /> 5 10. Any and all appropriate injunctive or other extraordinary relief afforded under <br /> 6 the law to remedy the violation and to prevent future violations of a like or similar <br /> 7 nature. <br /> 8 11. For those matters already identified in Plaintiffs' Government Tort Claims, <br /> 9 any and all damages and/or civil penalties afforded under the law. <br /> 10 SIXTH CAUSE OF ACTION <br /> 11 12. Any and all appropriate injunctive or other extraordinary relief afforded under <br /> 12 the law to remedy the violation and to prevent future violations of a like or similar <br /> 13 nature. <br /> 14 13. For those matters already identified in Plaintiffs' Government Tort Claims, <br /> 15 any and all damages and/or civil penalties afforded under the law. <br /> 16 ALL CAUSES OF ACTION <br /> 17 14. An award ancillary damages pursuant to C.C.P. §1090 and 1095. <br /> 18 15. For all matters covered by Plaintiffs' Government Tort Claim(s), all damages <br /> 19 which the Plaintiffs have sustained as a result of Defendants' conduct, including general <br /> 20 damages for pain, suffering, distress, and special damages for lost compensation, <br /> 21 including back, front pay, job benefits that he would have received but for the <br /> 22 discriminatory practices of Defendants, damages for anguish, fright, nervousness, grief, <br /> 23 anxiety, worry, shame, mortification, injured feelings, shock, humiliation and indignity, <br /> 24 as well as other unpleasant physical, mental, and emotional reactions ordinarily to be <br /> 25 expected, damages to reputation, and other non-economic damages, to the extent <br /> 26 permitted by law and in a sum to be ascertained according to proof; <br /> 27 16. For all matters covered by Plaintiffs' Government Tort Claim(s), other actual, <br /> 28 consequential, and/or incidental damages, and/or statutory penalties in a sum to be <br /> 45 <br /> COMPLAINT <br />
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