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On February 8, 1999, petitioner filed a complaint against
the Meadowlands (the original complaint) in the Superior Court of
New Jersey, Morris County (the lawsuit). The original complaint
advances two causes of action: (1) Employment discrimination;
and (2) intentional infliction of emotional distress. Petitioner
sought the following relief with respect to the employment
discrimination: (1) Reinstatement of his previously-in-effect
employment conditions; (2) an injunction restraining the
Meadowlands from further violations of the New Jersey Law Against
Discrimination, N.J. Stat. Ann. 10:5-1 through 10:5-49 (West
2002); (3) damages for lost income and medical and fringe
benefits; (4) compensation for injury to petitioner’s
professional stature and loss of public esteem; (5) compensation
for petitioner’s reduced prospects for future employment; (6)
reasonable attorney’s fees and litigation costs; and (7) punitive
damages. With respect to the count alleging intentional
infliction of emotional distress, petitioner requested
compensatory and punitive damages. Petitioner remained employed
by the Meadowlands after he filed his complaint.
During March 1999, petitioner suffered severe migraines and
lost his voice. Sometime during or shortly before March 1999,
petitioner was placed on paid disability. On March 23, 1999,
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