(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.)
THIRD CAUSE OF ACTION BY ALL PLAINTIFFS AGAINST
DEFENDANT UCC BASED UPON RETALIATION
99. 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.
100. The acts and words of Defendant as alleged herein above constitute adverse employment action and/or retaliation against Plaintiffs, and Defendants violated Government Code § 12940 by retaliating against Plaintiffs because they opposed Defendants’ practices as described herein above.
101. As a direct and proximate result of Defendants’ conduct, Plaintiffs suffered and continue to suffer general damages, including, but not limited to, severe emotional distress, as alleged herein in an amount according to proof.
102. 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. The aforementioned acts of Defendants were willful, wanton, malicious and oppressive and justify the awarding of exemplary and/or punitive damages according to proof.
103. As a result of Defendants’ violation of Government Code § 12940, as alleged herein, Plaintiffs are entitled to reasonable attorney’s fees and costs as provided by Government Code § 12965, et seq. (See Part 18 of 18.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.