WHEREFORE, PLAINTIFF requests that this Court:
1. Permanently enjoin defendants and their agents, employees, successors, and all persons in active conduct or participation with defendants, from engaging unlawful and tortious conduct as alleged herein, paragraphs 1-79, including, but not limited to, the customs, patterns and practice resulting in the constructive termination of PLAINTIFF.
2. For an order directing defendants to take such affirmative steps as may be necessary and appropriate to correct the effect of their past unlawful acts and practices;
3. For an order for:
a. Compensatory damages including, but not limited to, PLAINTIFF'S economic losses, deprivation of civil rights, humiliation, mental anguish and emotional damages;
b. Other special and general damages as according to proof, the extent of which will be proven at trial.
4. For an award of interest, including pre-judgement interest, attorneys fees and costs.
5. For any other such order and further relief that the Court may deem proper.
Dated: _______________ LAW OFFICES OF LEO JAMES TERRELL
_______________________________
LEO JAMES TERRELL
Attorney for Plaintiff
Demand For a Jury Trial
Plaintiff herein demands a jury trial on all issues triable by jury.
Dated: _______________ LAW OFFICES OF LEO JAMES TERRELL
_______________________________
LEO JAMES TERRELL
Attorney for Plaintiff
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