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suffer emotional distress, loss of reputation, and consequential
damages of an unspecified amount. The sixth cause of action
alleged that CGC’s breach of its statutory duty made it liable to
petitioner for unpaid wages plus penalties. The seventh cause of
action alleged that petitioner was entitled to recover from the
named defendants both his personal belongings and damages.
Rule 2.5 of the San Diego Superior Court Local Rule Division
II requires that all plaintiffs and cross-complainants in an
action in superior court complete and serve a “Case Management
Conference Questionnaire” (questionnaire) on all parties 10 days
before the date set for case management conference. Among other
things, the questionnaire asks each plaintiff and cross-
complainant to list the amount of damages which he or she is
claiming for personal injuries vis-a-vis nonpersonal injuries.
In August 1992, petitioner filed a questionnaire with the
superior court. The questionnaire listed no claim for damages
for personal injury. The questionnaire listed only petitioner’s
claim for nonpersonal injuries in the amount of $2.5 million plus
general and punitive damages.
Following a jury trial, the jury returned a special verdict
finding among other things that: (1) CGC breached its employment
agreement with petitioner by terminating him contrary to the
terms thereof, (2) the Heller Group and Harris wrongfully induced
CGC to breach that agreement, (3) the Heller Group and Harris
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