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2. An order requiring defendants, and each of
them, to make whole by appropriate back pay and related
employee benefits, and damages to plaintiff because of
being adversely affected by discrimination on account
of race in the part of defendants;
3. For general damages to compensate plaintiff
for the harm, humiliation, and discrimination suffered
in an amount according to proof;
4. An order granting plaintiff a preliminary and
permanent injunction restraining defendants, their
agents, successors, employees, attorneys, and all
others acting in concert with defendants or under
defendants’ direction from discriminating on the basis
of race or color, and requiring them to undertake
remedial action to eradicate any effects of past
discrimination;
5. An order awarding reasonable attorneys’ fees
and costs; and,
6. An order granting such further relief as the
court deems proper.
ON THE FOURTH COUNT
1. For general damages in the sum of $1,000,000.00
(One Million Dollars);
2. For medical, hospital and related expenses
according to proof;
3. For lost earnings and losses sustained in the
sum of $1,000,000.00 (One Million Dollars);
4. For exemplary and punitive damages in the sum
of $1,000,000.00 (One Million Dollars);
5. For costs of suit herein incurred:
6. For such other and further relief that the
court may deem just and proper.
ON THE FIFTH COUNT
1. For general damages to plaintiff’s reputation
in the sum of $1,000,000.00 (One Million Dollars);
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Last modified: May 25, 2011