CACI No. 2743

(Lab. Code, § 1197.5(k))

[Name of plaintiff] claims that [name of defendant] retaliated against [him/

her/nonbinary pronoun] for [pursuing/assisting another in the enforcement

of] [his/her/ nonbinary pronoun] right to equal pay regardless of [sex/race/

ethnicity]. To establish this claim, [name of plaintiff] must prove all of the

following:

1. That [name of plaintiff] [specify acts taken by plaintiff to invoke,

enforce, or assist in the enforcement of the right to equal pay];

2. That [name of defendant] [discharged/[other adverse employment

action]] [name of plaintiff];

3. That [name of plaintiff]’s [pursuit of/assisting in the enforcement

of another’s right to] equal pay was a substantial motivating

reason for [name of defendant]’s [discharging/[other adverse

employment action]] [name of plaintiff];

4. That [name of plaintiff] was harmed; and

5. That [name of defendant]’s retaliatory conduct was a substantial

factor in causing [name of plaintiff]’s harm.

New May 2018; Revised May 2020, May 2024