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31. As a direct and proximate result of Defendants’ willful, knowing and intentional discrimination and sexual harassment against her, Plaintiff has further suffered and will continue to suffer a loss of earnings and/or other employment benefits and job opportunities. Plaintiff is thereby entitled to general and compensatory damages in amounts to be proven at trial.
32. 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 attorneys’ fees be awarded pursuant to California Government Code § 12965.
33. 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 participated, authorized, condoned and/or ratified the unlawful conduct of the other employees. By reason thereof, Plaintiff is entitled to punitive or exemplary damages from Defendants in a sum according to proof at trial.
THIRD CAUSE OF ACTION
(For Injunctive Relief Against All Defendants and DOES 1-50)
34. Plaintiff repeats and realleges the allegations set forth in paragraphs 1 through 33 and incorporates the same by reference as though fully set forth herein.
35. An actual controversy has arisen and now exists between Ms. Williams and Defendants concerning their respective rights and job duties relating to Plaintiff’s job and her ability to perform her work at the front bar directly interacting with the public. (See Part 8 of 8.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.