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1981 (1982). Petitioner filed two amended complaints, the last
of which (second amended complaint) was filed by the District
Court on January 15, 1985. The second amended complaint alleged
unlawful discrimination in employment practices under title VII
and 42 U.S.C. secs. 1981 and 1983 (1986). The second amended
complaint also alleged claims arising under California law,
including claims of intentional infliction of emotional distress
and slander. The second amended complaint sought the following
relief:
ON THE FIRST COUNT
1. For general damages for violation of
plaintiff’s constitutional rights, harassment,
humiliation, and embarrassment in an amount subject to
proof;
2. For medical and hospital expenses in an amount
subject to proof;
3. For future medical and hospital expenses in an
amount subject to proof;
4. For punitive and exemplary damages in an
amount determined by the trier of fact;
5. For reasonable attorneys fees incurred in the
prosecution of this action;
6. For costs of suit herein incurred;
7. For such other and further relief that the
Court may deem just and proper.
ON THE SECOND AND THIRD COUNTS
1. An order requiring defendants and each of them
to promote plaintiff to the position of Administrator
II, in the State Department of Education;
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