John W. Banks, III - Page 5




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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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