Beverly T. Rutt-Hahn - Page 5

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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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