20. 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.
21. As a direct and proximate result of Defendants’ willful, knowing and intentional retaliation against her, Plaintiff has suffered and will continue to suffer pain and suffering, and extreme and severe mental anguish and emotional distress. Plaintiff is thereby entitled to general and compensatory damages in amounts to be proven at trial.
22. As a direct and proximate result of Defendants’ willful, knowing and intentional retaliation against her, Plaintiff has further suffered and will continue to suffer a loss of earnings and other employment benefits and job opportunities. Plaintiff is thereby entitled to general and compensatory damages in amounts to be proven at trial.
23. As a further, direct and proximate result of Defendants’ violation of California Government Code § 12900, et. seq. , as heretofore described, Plaintiff has been compelled to retain the services of counsel in an effort to enforce the terms and conditions of her employment relationship with Defendants, and has thereby incurred, and will continue to incur, legal fees and costs, the full nature and extent of which are presently unknown to her.
Plaintiff will therefore seek leave of Court to amend this Complaint in that regard when the same shall be fully and finally ascertained. Plaintiff requests that attorney’s fees be awarded pursuant to California Government Code §12965.
24. Plaintiff is informed and believes, and based thereon alleges, that the outrageous conduct of Defendants described above was done with malice, fraud and oppression and with conscious disregard for her rights and with the intent, design and purpose of injuring her. Defendants, authorized, condoned, participated, and/or ratified the unlawful conduct. By reason thereof, Plaintiff is entitled to punitive or exemplary damages from Defendants in a sum according to proof at trial. (See Part 6 of 8.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.