John W. Banks, III - Page 4




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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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