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(6) CGC breached its statutory duty to pay petitioner the
compensation due him under the employment agreement, (7) CGC, Mr.
Heller, Heller Seasonings, and Does 21 through 30 unlawfully
retained and converted to their own use petitioner’s personal
belongings, (8) CGC, Mr. Heller, Heller Seasonings, and Does 31
through 40 invaded petitioner’s privacy by inspecting and copying
his personal files, (9) the conduct of each defendant was
outrageous and pursued to inflict severe emotional distress upon
petitioner, (10) CGC, CG Merger, Mr. Heller, Heller Seasonings,
and the Heller Trust were alter egos of each other so that each
of them lost his or its individuality or separateness as to each
other, and (11) Mr. Heller, CGC, and Does 1 through 10 published
defamatory statements about petitioner.
With the exception of the first, second, sixth, and seventh
causes of action, petitioner did not allege in his first amended
complaint that he suffered any specific damages as a result of
the asserted conduct underlying a cause of action. The first
cause of action alleged that CGC’s breach of the employment
agreement caused petitioner to lose salary of approximately
$676,000, incentive compensation of approximately $1,250,000,
supplemental incentive compensation of approximately $500,000,
and an unspecified amount of other significant benefits. The
second cause of action alleged that the named defendants’
interference with the employment agreement caused petitioner to
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