Personal Injury Lawyer Blog
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.)
FOURTH CAUSE OF ACTION BY ALL PLAINTIFFS AGAINST ALL DEFENDANTS BASED UPON INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
104. Plaintiffs incorporate herein by reference each and every allegation contained in paragraphs1 through 87 with full force and effect as though fully set forth herein.
105. As a direct and proximate result of Defendants’ conduct, Plaintiffs have suffered and continue to suffer severe emotional distress, humiliation, loss of sleep and mental anguish all to her damage.
106. Defendants’ conduct, as set forth above, was intentional and malicious and done for the purpose of causing Plaintiffs to suffer humiliation, mental anguish and emotional distress. Defendants’ conduct was done with knowledge that Plaintiffs’ emotional and physical distress would result and was done with wanton and reckless disregard of the consequences to Plaintiffs and was despicable, intentional and malicious and done for the purpose of causing Plaintiffs to suffer humiliation, mental anguish and severe emotional distress. Defendants’ conduct was done with the knowledge that Plaintiffs’ emotional and physical distress would as a result increase and was done with wanton and reckless disregard of the rights of Plaintiffs and the consequences to Plaintiffs. The aforementioned acts of Defendants were willful, wanton, malicious and oppressive and justify the awarding of exemplary and/or punitive damages according to proof.
107. The aforementioned acts of Defendants were willful, wanton, malicious and oppressive and justify the awarding of exemplary damages according to proof.
WHEREFORE, Plaintiffs pray for judgment on all four Causes of Action against all Defendants as follows:
1. Compensate and make Plaintiffs whole for all earnings, wages and other employment benefits she would have received but for the discrimination, harassment and retaliation by the Defendants.
2. For statutory damages;
3. For attorney fees;
4. Award of general damages in a sum of according to proof
5. Award exemplary and punitive damages against the Defendants.
6. Award costs and reasonable attorney fees and
7. Grant such other and further relief as the Court may deem proper and just.
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.