WHEREFORE, PREMISES CONSIDERED, the Plaintiff respectfully requests this Court to award the following relief:
a. Placement in the position(s) in which he would have worked absent the Defendants’ retaliatory treatment; or, in lieu thereof, front pay;
b. Back pay;
c. Injunctive relief;
d. Pre-judgment interest;
e. Attorney’s fees;
g. Compensatory damages for loss of wages, loss of benefits, mental anguish, embarrassment, emotional distress;
h. Punitive damages against the individual Defendants to deter such conduct in the future; and
i. Such other legal or equitable relief to which Plaintiff may be entitled, including prospective injunctive relief.
PLAINTIFF DEMANDS TRIAL BY STRUCK JURY ON ALL CLAIMS SO TRIABLE.
/s John D. Saxon
John D. Saxon
Alabama State Bar No. ASB-3258-O71J
John D. Saxon, Jr.
Alabama State Bar No. ASB-5374-H63S
Attorneys for Plaintiff