SECOND CAUSE OF ACTION
(Sexual Harassment in Violation of California Gov’t Code §12900 et seq. Against All Defendants and DOES 1-50)
25. Plaintiff repeats and realleges by reference each and every allegation contained in paragraphs 1 through 24 and incorporates the same herein as though fully set forth.
26. Defendants are employers in the State of California, as defined in the California Fair Employment and Housing Act (“FEHA”), California Government Code § 12926.
27. Defendants’ harassment of Plaintiff by Dan Black included inappropriate touching and sexual comments and sexual innuendo, on the basis of her gender constitutes a violation of the California Fair Employment and Housing Act, California Government Code § 12940 et seq. The sexual harassment Plaintiff endured was severe and/or pervasive, offensive and hostile. Further the work environment including lingerie parties and sexual-charged comments regarding customers and employees constitutes a sexually hostile work environment that Plaintiff was forced to endure.
28. Plaintiff is informed and believes, and based thereon alleges, that in addition to the practices enumerated above, Defendants may have engaged in other discriminatory practices against her which are not yet fully known. At such time as such discriminatory practices become known to her, Plaintiff will seek leave of Court to amend this Complaint in that regard.
29. On or about October 27, 2008, Plaintiff filed timely charges against Defendants with the California Department of Fair Employment and Housing (“DFEH”). True and correct copies of her charges are referenced herein. Within one year of the filing of this Complaint, the California Department of Fair Employment and Housing issued right to sue notices to Plaintiff authorizing this lawsuit. True and correct copies of the right to sue letters are referenced herein. Plaintiff has therefore exhausted her administrative remedies
30. As a direct and proximate result of Defendants’ willful, knowing and intentional discrimination against her, Plaintiff has suffered and will continue to suffer extreme and severe mental anguish and emotional distress. Plaintiff is thereby entitled to general and compensatory damages in amounts to be proven at trial. (See Part 7 of 8.)
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