- 6 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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