- 5 -
to:
1. Grant Plaintiff a preliminary injunction
requiring the Defendant to reinstate plaintiff as an
employee * * * and enjoining defendant * * * from
terminating Plaintiff and from harassing her or from
retaliating against her and the class she represents
for asserting their rights under Title VII;
2. Grant Plaintiff a permanent injunction enjoin-
ing the Defendant Company * * * from engaging in any
employment policy or practice which discriminates
against any employee or member or applicant for employ-
ment on the basis of sex;
3. Order defendant to make whole the Plaintiff
herein by providing appropriate back pay and reimburse-
ment for lost sick leave pay, health and disability
insurance benefits, pension, social security and other
benefits in an amount to be shown at trial, and other
affirmative relief including, but not limited to, an
affirmative action program designed to eliminate the
effects of the discriminatory practices complained of
herein;
* * * * * * *
6. Plaintiff prays for an award of actual damages
to compensate plaintiff for the humiliation and associ-
ated personal suffering caused by Defendant’s unlawful
treatment in the amount to be proven at the time of
trial of this matter but in an amount not less than
$100,000.00.
7. Plaintiff prays for an award of punitive
damages in an amount believed by the court to be appro-
priate to punish Defendant for the willful and mali-
cious misconduct and necessary to deter Defendant from
engaging in such misconduct in the future;
On January 19, 1998, Goer’s attorney conducted a deposition
(deposition) of Ms. Nield with respect to her complaint. Ms.
Nield testified during her deposition that
There was another occasion where there was a
bunch of –- in my area it was –- I was in the light
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011