2325 COM Cover Letter re Zinnia Health Objection w Exs

-11- 59. Plaintiff repeats the allegations stated above as if set forth at length herein. 60. Plaintiff was 63 years old and, upon information and belief, was the oldest therapist working at Endeavor House. 61. Plaintiff was terminated by Zinnia, in whole or in part, because of her advanced age. 62. Upon information and belief, Zinnia replaced at least a substantial portion of Plaintiff’s job duties by hiring and assigning them to one or more persons significantly younger than Plaintiff. 63. Zinnia wrongfully terminated Plaintiff and has thereby caused, and continue to cause, Plaintiff substantial and foreseeable injury. 64. Zinnia’s conduct has caused, and continues to cause, Plaintiff substantial and foreseeable injury, including without limitation economic damages including loss of income and benefits as well as emotional distress. 65. Zinnia’s conduct was egregious, willful and wanton and in reckless disregard of Plaintiff’s rights and involved extensive upper management participation. WHEREFORE Plaintiff demands judgment against Zinnia awarding her compensatory damages, including but not limited to front pay, back pay, and 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 pursuant to N.J.S.A. 10:5-27.1; and such other relief as the Court may deem just and appropriate under the circumstances.ESX-L-004622-23 07/19/2023 2:53:48 PM Pg 11 of 13 Trans ID: LCV20232124530