Wilson v. The Birmingham Public Library Foundation et al

Filing 53

DAMAGE list of Barbara Ann Wilson filed.. (Morel, Adam)

FILED
2012 Mar-26 PM 07:35
U.S. DISTRICT COURT
N.D. OF ALABAMA

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ALABAMA
SOUTHERN DIVISION
BARBARA ANN WILSON,
Plaintiff,
v.
WELLS FARGO BANK, N.A.
Defendant.

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2:10-cv-02386-KOB

PLAINTIFF'S DAMAGES LIST
Plaintiff seeks an award of the following damages:
1. Back pay/consequential loss of past wages in the amount of $62,841.60,
plus interest.
($872.80/week x 72 weeks from 12/4/10-4/23/12)
2. Front pay and/or consequential loss of future wages in an amount to be
determined by the Court and/or jury (21 years x $45,385.60 increased by
the value of any and all raises, bonuses and other compensation such as
the value of benefits and pension the Plaintiff would have reasonably
been expected to earn in the future but for the Defendants’ unlawful acts,
reduced to present value)
3. Damages for mental anguish in an amount to be determined by the Jury.
4. Instatement into a suitable position for which the Plaintiff is qualified and
in which she will have limited to no contact with library patrons.
5. Injunctive or other affirmative relief as the Court determines fit and just.
6. Punitive damages (as against the Library Board) in an amount to be
determined by the jury.

02025707.1

7. Reasonable attorney’s fees in an amount to be determined by the Court
upon petition of counsel for the Plaintiff.
8. Costs, as determined by the Court.
Respectfully submitted,

/s/ Adam Morel
Adam Morel
Attorney for Plaintiff
OF COUNSEL:
Law Offices of Adam Morel, P.C.
517 Beacon Parkway West
Birmingham, Alabama 35209
Telephone: [phone]
Facsimile: [phone]

02025707.1

CERTIFICATE OF SERVICE
I hereby certify that I have served a copy of the foregoing on all counsel of
record by electronic filing.
This the 26th day of March, 2012.

s/ Adam P. Morel
OF COUNSEL

02025707.1