(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.)
82. Defendant UCC and/or its agents and employees, supervisors, managers, officers and/or directors knew or should have known of the harassing actions on the basis of verbal and/or written reports of such actions made by Plaintiff to Defendant UCC’s supervisors, managers, officers and/or directors. Despite Defendant UCC’s actual and/or constructive knowledge of such harassing actions, Defendant UCC failed to take immediate and/or appropriate corrective action to stop the harassment. Furthermore, before the unlawful discrimination, harassment and retaliation occurred, Defendant UCC failed to take all reasonable steps to prevent such unlawful actions from occurring.
83. Defendant UCC also subjected plaintiff to discriminatory enforcement of company rules, arbitrary enforcement of rules, arbitrary write-ups, racially hostile comments, innuendos, and offensive and insulting remarks, unfair performance evaluations, contrived terminations, demotions, punishments and retaliation against Plaintiff for engaging in protected activity.
84. As a proximate result and legal cause of Defendant UCC’s conduct as alleged herein above, Plaintiff has been damaged in that Plaintiff has suffered the loss of wages, salary, benefits, and promotion, in an amount to be proven at time of trial.
85. At all times herein mentioned, Plaintiff was an excellent employees with an outstanding record of dedication, loyalty and efficient service and contribution to Plaintiff’s employer’s goal.
86. Defendants and each of them knew or should have known, actually and/or constructively of the harassing actions as described herein above, on the basis that the actions and/or words described above were the actions and/or words of owners, directors, officers, managing agents, supervisors and/or employees of Defendants.
87. Despite Defendant UCC’s knowledge, actual and/or constructive, as described herein above, of the above described harassment, discrimination and retaliation, Defendant UCC failed and refused and continue to fail and refuse to stop the harassment and have failed and refused and continue to fail and refuse to take all reasonable steps to prevent such harassment, discrimination and retaliation from occurring. (See Part 15 of 18.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.