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Sixth Cause of Action (cont.)
73. The acts and failures to act as alleged herein also created a harassing, intolerable and retaliatory work environment for the PLAINTIFF. PLAINTIFF'S complaints were ignored, PLAINTIFF was ostracized from his co-workers, put in less favorable working conditions, and DEFENDANT'S failure to address PLAINTIFF'S complaints left PLAINTIFF with no other recourse than to resign.
74. PLAINTIFF believes that the defendants' acts as alleged herein, including, but not limited to, informally reprimanding PLAINTIFF regarding his reports, threatening the loss of PLAINTIFF'S job, leaving harassing notes on PLAINTIFF'S desk, failing to promote PLAINTIFF, ostracizing PLAINTIFF in the work place, ordering PLAINTIFF not to return to the Rampart Task Force, and subsequently reassigning PLAINTIFF to a less desirable position within the Robbery-Homicide, Bank Robbery Division, violated California Labor Code Section 1102.5.
75. California Labor Code Section 1102.5(b) provides, in relevant part, that "[N]o employer shall retaliate against an employee for disclosing information to a government or law enforcement agency, where the employee has reasonable cause to believe that the information discloses a violation of state or federal statute." Violation of Cal.Labor Code Section 1102.5 is a misdemeanor under Cal.Labor Code Section 1103.
76. Defendants failure to support PLAINTIFF, and the retaliatory response to PLAINTIFF'S efforts to report criminal and/or matters of public concern, was in violation of the anti-discriminatory statues.
77. The acts, omissions or failures to act as alleged herein, resulted in custom, policy, and practice with the deliberative intent of suppressing and retaliating the first amendment rights of PLAINTIFF on criminal matters and matters of public concern.
78. As a direct and proximate cause of the unlawful conducts and actions alleged herein, PLAINTIFF has suffered and will continue to suffer loss of his employment, loss of promotional opportunities, severe emotional distress, humiliation, anxiety, sleeplessness, lost wages, loss of employment benefits and loss of sick time, the exact amount of which will be determined at trial.
79. Defendants conduct as described above was willful, despicable, malicious, knowing, and intentional; accordingly, PLAINTIFF seeks an award of punitive and exemplary damages in an amount according to proof.
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