What is the current state of the law on "protected activities" in civil litigation?

MultiRegion, United States of America

The following excerpt is from Donovan v. Woodbridge Maint. Ass'n, No. 2:14-cv-00995 JAM-EFB (E.D. Cal. 2015):

This section protects plaintiffs who were "engaged in [a] protected activity." Brown v. City of Tucson, 336 F.3d 1181, 1192 (9th Cir. 2003). Protected activities include "the request

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