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118. Asaresi S result of the def i endants’ unconstitutional and unlawful conspi racy, the plaintiff Was repr 's Teprimanded and was threatened. intimidated, and i an Mmitting acts to which he objected because those acts were illegal and unethical, 119. The plainti iscipli Plaintiff was disciplined, and suffered damage to his job security, his reputation, and severe emotional distress, as a result of the defendants” outrageous conduct. WHEREFORE, the plaintiff asks that this Court order that his discipline be expunged, that the defendants issue an apology to him and to all of the members of the State Police who were forced to participate in this immoral scheme, and to award him compensatory damages, his costs, attorneys’ fees, and all other relief to which he is entitled by law. COUNT III Intentional Infliction of Emotional Distress All individual Defendants 120, The plaintiff repeats and re-alleges the preceding paragraphs as if fully set forth herein. 121. ‘The defendants intended to inflict emotional distress on the plaintiff and should have known that their conduct would inflict emotional distress on the plaintiff. 122, The defendants’ conduct was extreme and outrageous, beyond all bounds of decency and utterly intolerable in a civilized community: 123, The distress suffered by the plaintiffs was severe and of the nature that no reasonable person could be expected to endure it. 20

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