2325 COM Cover Letter re Zinnia Health Objection w Exs

-12- FOURTH COUNT (New Jersey Law Against Discrimination , N.J.S.A. 10:5-1 et seq. – Aiding and Abetting Liability) 66. Plaintiff repeats the allegations stated above as if set forth at length herein. 67. Defendants each aided and abetted each other’s wrongful acts and violations of the LAD. 68. Defendants each performed wrongful acts that caused Plaintiff injury and were in derogation of Plaintiff’s rights under the LAD as is set forth above. 69. Defendants were all generally aware of their roles as part of the overall illegality and violations of Plaintiff’s rights under the LAD as alleged above. 70. Defendants each knowingly and substantially assisted each other in the violation of Plaintiff’s rights under the LAD as alleged above. 71. Defendants’ 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. 72. Defendants’ conduct was egregious, willful, and wanton, in reckless disregard of Plaintiff’s rights and involved direct upper management participation. WHEREFORE, Plaintiff demands judgment against all Defendants named herein 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 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 12 of 13 Trans ID: LCV20232124530