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2. For special damages for lost profits and
losses sustained in the sum of $4,500,000.00 ($4.5
Million);
3. For medical, hospital, and related expenses
according to proof;
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 SIXTH COUNT
1. For general damages to plaintiff’s reputation
in the sum of $1,000,000.00 (One Million Dollars);
2. For special damages for lost profits and
losses sustained [in] the sum of $4,500,000.00 ($4.5
Million);
3. For medical, hospital, and related expenses
according to proof;
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 November 25, 1987, petitioner filed in the District Court
a second lawsuit (Banks II) against the DOE and others.
Petitioner alleged in Banks II violations under title VII and 42
U.S.C. sec. 1983 (1982). Banks II was consolidated with Banks I
(Banks cases) on January 19, 1989.
On September 22, 1989, the District Court issued a final
pretrial conference order in the Banks cases. The order states,
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