John Bothe & Barbara Bothe - Page 7

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          petitioner filed an amended complaint (the amended complaint) in            
          the lawsuit and included two executives/employees of the                    
          Meadowlands as co-defendants.  The amended complaint advances               
          three causes of action:  (1) Employment discrimination; (2)                 
          reprisal against petitioner by the Meadowlands for filing the               
          lawsuit; and (3) violation of the New Jersey Conscientious                  
          Employee Protection Act, N.J. Stat. Ann. 34:19-1 through 34:19-8            
          (West 2000), by the two named executives/employees of the                   
          Meadowlands.                                                                
               With respect to the first two causes of action, petitioner             
          sought:  (1) Damages for lost earnings, including medical and               
          fringe benefits; (2) damages for mental and emotional distress;             
          (3) compensation for injury to petitioner’s professional stature            
          and loss of public esteem; (4) compensation for petitioner’s                
          reduced prospects of future employment; (5) reasonable attorney’s           
          fees and litigation costs; and (6) punitive damages.  Petitioner            
          also sought compensatory and punitive damages for mental and                
          emotional distress with respect to the third cause of action.               
          According to petitioner, “the whole basis of the lawsuit” was               
          that he “felt [he] was being discriminated because [he] was going           
          to Gamblers Anonymous.”                                                     
               Ultimately, the lawsuit was settled.  James H. Lockwood                
          (Mr. Lockwood), the Meadowlands’ associate counsel and longtime             







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