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Plaintiffs' economic advantage. All of the factual allegations
revolved around the Defendants' wrongdoing in violations of the
above-mentioned laws. There were no factual allegations
regarding any personal injury.
The Plaintiffs based their claims on four counts consisting
of two separate counts for RICO Act violations, one count for
unlawful interference with prospective economic advantage, and
one count for punitive damages. As required by the RICO Act, the
two counts for RICO Act violations alleged injury to the
Plaintiffs' business and property. Under the count for unlawful
interference with prospective economic advantage, the Plaintiffs
alleged that the Defendants' actions interfered with the rights
of the Plaintiffs to "enjoy the fruits and advantages of their
industries and efforts as employees". (Emphasis added.)3
Finally, by their count for punitive damages, the Plaintiffs
claimed that the Defendants' negligent conduct caused "severe
economic and financial harm as well as other damages" to the
Plaintiffs. No mention was made of any physical or emotional
injury under any of the four counts.
Pursuant to the class action, all AHP employees affected by
AHP's relocation to Guayama, Puerto Rico, received a legal notice
of class action. Petitioner was a member of this class action
3 Not relevant here, the class action also alleged
interference with the Union's right to receive dues income from
its members.
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