The following excerpt is from De Markoff v. Superior Court of Cal., Case No. 1:11-CV-02017 AWI MJS (E.D. Cal. 2014):
748, 754 (9th Cir. 2006). Termination, dissemination of a negative employment reference, issuance of an undeserved negative performance review and refusal to consider for promotion are examples of adverse employment actions. Brooks v. City of San Mateo, 229 F.3d 917, 928 (9th Cir. 2000).
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