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(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.)
25. At all times during the employment relationship, PLAINTIFFS performed their duties in a highly satisfactory, competent and diligent manner.
26. PLAINTIFFS have filed Charges of Discrimination with the California Department of Fair Employment & Housing ( DFE ), copies of which are incorporated herein by reference. Within one year of filing this complaint, the DFEH has issued a Right to Sue Notices authorizing this lawsuit, copies of which are incorporated herein by reference. PLAINTIFFS have exhausted their administrative remedies.
27. As a direct and proximate result of Defendants’ willful, knowing and intentional discrimination against them, PLAINTIFFS have suffered and will continue to suffer pain and suffering, and extreme and severe mental anguish and emotional distress; PLAINTIFFS have suffered and will continue to suffer a loss of earnings and other employment benefits and job opportunities. PLAINTIFFS are thereby entitled to general and compensatory damages in amounts to be proven at trial.
28. As a further, direct and proximate result of Defendants’ violation of California Government Code section 12900 et seq., PLAINTIFFS have been compelled to retain the services of counsel in an effort to enforce the terms and conditions of their employment relationship with Defendants, and have thereby incurred and will continue to incur legal fees and costs, the full nature and extent of which are presently unknown to them. PLAINTIFFS therefore request that attorneys’ fees be awarded pursuant to California Government Code section 12965.
29. PLAINTIFFS are informed and believe and based thereon allege that the outrageous conduct of Defendants described above was done with malice, fraud and oppression and with conscious disregard for their rights and with the intent, design and purpose of injuring PLAINTIFFS. DEFENDANTS, and each of them, through their officers, managing agents and/or supervisors, authorized, condoned and/or ratified the unlawful conduct of all of the other Defendants named in this cause of action. By reason thereof, PLAINTIFFS are entitled to punitive or exemplary damages from all Defendants in a sum according to proof at trial. (See Part 5 of 7.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins