Wilson v. The Birmingham Public Library Foundation et al

Filing 53

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

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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. ) ) ) ) ) ) ) ) ) 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: (205) 252-8841 Facsimile: (205) 252-3727 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

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