In this lawsuit, Plaintiff alleges, on an individual basis, that The Permanente Medical Group (“Permanente” or “Defendant”) discriminated against and harassed Plaintiff on the basis of her sex in violation of California Government Code sections §12940, subdivisions (a) & (j) by engaging in a course of conduct intentionally designed to discriminate and harass Plaintiff on the basis of her sex and mental disability; (2) discriminated against Plaintiff on the basis of her religion, in violation of California Government Code section 12940, subdivision (a); (3) failed to take all reasonable steps to prevent discrimination and harassment in the workplace, in violation of California Government Code section 12940, subdivision (k); (4) retaliated against Plaintiff on the basis of her religion, mental disability, and for complaining about religious and sexual discrimination and harassment in violation of California Government Code section 12940, subdivision (h), by, among other things, terminating Plaintiff; and, (5) wrongfully terminated Plaintiff on the basis of her religion, mental disability, and/or in retaliation for making complaints about religious and sexual discrimination and harassment in violation of public policy embodied in Article I, section 8, of the California Constitution and/or California Government Code section 12904, et. seq. Said discharge was unlawful and in violation of public policy, article I, section 8, of the California Constitution, and California Government Code section 12940 because said discharge was in retaliation for Plaintiff complaining about discriminatory and harassing actions.