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146

At all times mentioned in this complaint, Defendants were subject to the

provisions of California Labor Code section 1102.5.

147

At all times mentioned in this complaint, Plaintiff was employed by the

Defendants as an employee and thus was protected by the provisions of section 1102.5 of the

California Labor Code.

148

Plaintiff TAYLOR disclosed information that he had reasonable cause to believe

were violations of state or federal statute, or violations of or noncompliance with a local, state, or

federal rule or regulation, including but not limited to: (a) disclosures of information to the

California Department of Fair Employment and Housing regarding defendants' retaliation and

discrimination in violation of FEHA; (b) disclosures of information to the Federal Emergency

Management Authority (FEMA), a federal government agency, regarding the defendants

violations of federal statutes or regulations as to their orders that Plaintiff and other CITY

employees falsify time records in order to obtain reimbursements from FEMA for the Camarillo

Springs Fire; and (c) disclosures of information regarding defendants' noncompliance with local

rules or regulations as to retaliation and harassment of Plaintiff as well as the creation of a

hostile working environment for Plaintiff.

149 As a result of Plaintiff TAYLOR having made the above-referenced disclosures,

he suffered acts of reprisal, retaliation, and termination.

150

In subjecting Plaintiff TAYLOR to the acts of reprisal, retaliation, termination or

similar acts, Defendants violated California Labor Code section 1102.5.

151

As a direct and proximate result of the Defendants' unlawful conduct as alleged

in the complaint, Plaintiff TAYLOR has suffered and continues to suffer substantial losses in

employment benefits with defendant employer, including loss of reputation, lost wages, bonuses,

incentives, and job benefits, and expenses incurred in the search for comparable employment in

an amount not less than the jurisdictional minimum of this court. The precise amount of the

damages is presently unknown and will be proven at trial.

152

As a further direct and proximate result of the Defendants' unlawful conduct,

Plaintiff TAYLOR has suffered and continues to suffer extreme and severe anguish, humiliation,

 34

COMPLAINT

TRON TRON

5010 STE. 210

 805) 388-1241

7/23/2019 Scott Taylor v City of Camarillo Lawsuit

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emotional distress, nervousness, tension, anxiety, and depression, the extent of which is not fully

known at this time, and the amount of damages caused by defendants' conduct is not yet fully

ascertained but in an amount in an amount not less than the jurisdictional minimum of this court.

The precise amount of the damages is presently unknown and will be proven at trial.

153

Plaintiff TAYLOR also claims all amounts thereunder together with prejudgment

interest pursuant to California vil ode §

3287 and pursuant to any other provision of law

providing for prejudgment interest.

154

Plaintiff TAYLOR pursuant to California

Labor ode section 1102.5(f) seeks

civil penalties against defendant CITY in the amount of $10,000 per violation of California

Labor ode

section 1102.5.

EIGHTH C USE OF CTION BY PL INTIFF T YLOR

AGAINST DEFEND ANTS CITY and DOES 1-20 inclusive

FOR BRE CH OF CONTR CT

155

Plaintiff TAYLOR realleges and incorporates herein by reference all other

paragraphs of this complaint, as though fully set forth in this Cause of Action.

156

On or about March 26, 2014, defendant CITY and Plaintiff TAYLOR and other

employees in the competitive service entered into an agreement which defined the obligations,

rights, privileges, and benefits of the parties. This agreement is hereinafter referred to as the

Personnel Rules. A true and correct copy of the relevant portions of the Personnel Rules is

attached hereto as Exhibit 1 and made a part hereof by this reference.

157

Chapter 14 of the Personnel Rules established the procedure for disciplinary

action against an effected employee. Section 14.5 of the Personnel Rules provided that the

employee was permitted to respond, either verbally or in writing, to a notice of intent to

discipline in a pre-disciplinary hearing. Thereafter, defendant CITY was obligated, pursuant to

Section 14.5.3 of the Personnel Rules, to within five working days after the later of the

employee's verbal or written response, the date of the pre-disciplinary meeting, or the expiration

of the employee's time to respond to the Notice of Intent, the Department Head will take one of

the following actions: (1) dismiss the Notice of Intent and take no disciplinary action against the

-35-

COMPLAINT

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 809) 388-1241

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