(Violation of USERRA, 38 U.S.C. § 4311)   (Violation of USERRA, 38 U.S.C. § 4316)   (Violation of USERRA, 38 U.S.C. § 4312)   (Violation of USERRA, 38 U.S.C. § 4313)   66.  Plaintiff repeats and incorporates the allegations contained in the  foregoing paragraphs as if fully set forth herein.   67.  USERRA, 38 U.S.C. § 4311, prohibits an employer from discriminating  against any person who is a member of, applies to be a member of, performs, has  performed, applies to perform, or has an obligation to perform service in a uniformed  service with respect to, among other things, employment, reemployment, retention in  employment, promotion, or any benefit of employment by an employer on the basis of  that membership, application for membership, performance of service, application for  service, or obligation.   68.  Based on the admissions of Defendants’ employees, Defendants have a  policy of disciplining and/or terminating employees who use what Defendants or its  human resources employees deem to be excessive leave and/or leave without pay to  perform military service.      72.  Plaintiff repeats and incorporates the allegations contained in the  foregoing paragraphs as if fully set forth herein.   79.  Plaintiff repeats and incorporates the allegations contained in the  foregoing paragraphs as if fully set forth herein.   Plaintiff’s Background  