(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.)
SECOND CAUSE OF ACTION BY ALL PLAINTIFFS AGAINST ALL DEFENDANTS BASED UPON HOSTILE WORK ENVIRONMENT HARASSMENT
93. Plaintiffs incorporate herein by reference each and every allegation contained in paragraphs1 through 87 with full force and effect as though fully set forth herein.
94. The acts and words of Defendants as alleged herein above constitutes harassment on account of Plaintiffs’ sex, race and/or national origin in the form of a hostile working environment and violated Government Code § 12940 by maintaining a hostile work place where such harassment occurred including harassment by Defendants’ officers, supervisors, managing agents, directors, and/or employees as evidenced by Defendants’ conduct and policies as herein above described.
95. As a direct and legal result of Defendants’ harassment of Plaintiffs, Plaintiffs suffered damages as alleged herein in an amount according to proof.
96. Defendants’ conduct, as set forth above, was intentional and malicious and done for the purpose of causing Plaintiffs to suffer humiliation, mental anguish and emotional distress. Defendants’ conduct was done with knowledge that Plaintiffs’ emotional and physical distress would result and was done with wanton and reckless disregard of the consequences to Plaintiffs and was despicable, intentional and malicious and done for the purpose of causing Plaintiffs to suffer humiliation, mental anguish and severe emotional distress. Defendants’ conduct was done with the knowledge that Plaintiffs’ emotional and physical distress would as a result increase and was done with wanton and reckless disregard of the rights of Plaintiffs and the consequences to Plaintiffs.
97. The conduct of Defendants as alleged herein above was despicable, willful, wanton, malicious and oppressive and justify the awarding of exemplary and/or punitive damages according to proof.
98. As a result of Defendants’ violation of Government Code § 12940 as alleged herein, Plaintiffs are entitled to reasonable attorney fees and costs as provided by Government Code § 12940 et seq. (See Part 17 of 18.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.