2325 COM Cover Letter re Zinnia Health Objection w Exs

-10- litigation pursuant to N.J.S.A. 34:19-13(d); and such other relief as the Court may deem just and appropriate under the circumstances. SECOND COUNT (Pierce v. Ortho Pharm. Corp., 84 N.J. 58 (1980) – Wrongful Termination) 54. Plaintiff repeats the allegations stated above as if set forth at length herein. 55. Defendants’ wrongful conduct, as set forth above, violated “clear mandate[s] of public policy” and/or constituted illegal activities and unconscionable practices, as set forth in Pierce v. Ortho Pharm. Corp., 84 N.J. 58 (1980). 56. Plaintiff’s objections to such wrongful conduct, as set forth above, constituted “protected activities” under Pierce. 57. Defendants’ termination of Plaintiff was premised, in whole or part, upon Plaintiff’s exercise of protected activities and thus constituted a wrongful termination within the meaning of Pierce. 58. Defendants’ wrongful termination of Plaintiff has inflicted, and will continue to inflict, substantial injury upon Plaintiff, including without limitation economic damages including loss of income and benefits as well as emotional distress damages. WHEREFORE, Plaintiff demands judgment against all Defendants awarding her compensatory damages, including but not limited to front pay; back pay; the value of health insurance and other benefits, commissions, bonuses and vacation; damages for emotional distress; punitive damages; pre- and post-judgment interest; counsel fees and costs of litigation; and such other relief as the Court may deem just and appropriate under the circumstances. THIRD COUNT (New Jersey Law Against Discrimination, N.J.S.A. 10:5-1 et seq. – Age)ESX-L-004622-23 07/19/2023 2:53:48 PM Pg 10 of 13 Trans ID: LCV20232124530