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Petitioner's complaint requested, in relevant part, the following
relief:
(4) Equitable relief to make [plaintiff] whole, including:
(a) Back pay and retroactive promotion as
justified by the evidence * * *.
(b) If plaintiff cannot be reinstated because of
the discriminatory work environment, payment for
training and education needed to place plaintiff in
work consistent with her handicap, at a level to earn
comparable wages outside the Postal Service to those
she could have earned but for the discrimination.
(c) Front pay and benefits until plaintiff
obtains comparable employment described in (b) above,
or until early retirement age if she cannot return to
work because of the residual effects of the
discrimination.
(d) Recomputation of retirement benefits to
reflect the retroactive promotions and pay.
(e) Publication of notices to all postal
employees as to plaintiff's quality work performance
and prevailing on issues of discrimination.
(f) Reasonable attorney fees and costs of suit
for the administrative and judicial proceedings in
these cases.
(g) Such other and further relief as the court
may award.
Petitioner's "First Amended Complaint For Damages And
Equitable Relief", filed in January 1988, was identical with
respect to the above quoted language and presented no relevant
changes.
Petitioner and the Postal Service settled petitioner's
lawsuit and entered into a written settlement agreement (the
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