Jared R. and Naylene M. Nield - Page 5




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                         b.  Defendant, acted in a discriminatory                     
               manner towards her because Defendant retaliated against                
               her by terminating her employment because she com-                     
               plained to management about the alleged sexual harass-                 
               ment, to wit:                                                          
                              i.  the supervisor about whom she com-                  
               plained had threatened to “get even” with her if she                   
               ever reported him to management again                                  
                         ii.  Plaintiff s [sic] supervisor was                        
               instrumental in the decision to terminate her                          
                         iii.  and was retaliating against her                        
               because she had reported his acts of sexual harassment                 
               to management.                                                         
                    12.  As a further result of the Defendant’s above-                
               stated actions, the Plaintiff has been and is being                    
               deprived of income in the form of wages and of prospec-                
               tive retirement benefits, social security and other                    
               benefits due to her as a worker solely because of her                  
               sex in the sum to be proven at the trial.                              
                  *       *       *       *       *       *       *                   
                    14.  Plaintiff invokes this court’s jurisdiction                  
               * * * [to] adjudicate claims arising out of the trans-                 
               actions set forth above that violate rights and duties                 
               established by the law of Utah, to wit:                                
                         a.  That the Plaintiff s [sic] termination                   
               was wrongful in that it violates of [sic] the public                   
               policy set forth in 42 U.S.C. � 2000e.                                 
                         b.  That the Plaintiff s [sic] termination                   
               was in violation of Title 35-9-11, Utah Code Annotated.                
                    15.  The treatment of Plaintiff by Defendant and                  
               by Supervisor were [sic] intentional and with the                      
               purpose and intent of causing Plaintiff severe and                     
               grievous mental and emotional harm which in turn re-                   
               sulted in severe physical consequences in violation of                 
               the common law of Utah.                                                
                                  PRAYER FOR RELIEF                                   
                    WHEREFORE, Plaintiff respectfully prays this Court                




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