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15 <br />99. As a result, Plaintiff was discriminated against due to his age, gender and sex in <br />violation of HRS § 378 2. Plaintiff is 61 years old, obviously gay male. <br />100. All of the named above Defendants' actions have caused Plaintiff significant <br />general and special damages. Plaintiff was victim of Defendants' conspiracy to discriminate, as <br />described above and deny him prestigious employment he was most qualified for. Due to the all <br />of the above -named Defendants' actions, Plaintiff has suffered also severe emotional distress, <br />mental trauma and mental illness and many other special and general damages as proven at trial. <br />101. All of the named above Defendants' above -described actions have caused Plaintiff <br />a severe mental illness that is manifesting, itself in Plaintiff's daily severe stress levels, anxiety, <br />insomnia, increased heart rate and depression. <br />102. Plaintiff was damaged in an amount to be proven at trial. <br />IV. - CAUSES OF ACTIONS <br />COUNT 1 • VIOLATION OF THE HAWAII REVISED STATUTES ("HRS") §378-2 <br />(HAWAII'S AGE, GENDER AND SEX DISCRIMINATION STATUTE) <br />(AGAINST ALL DEFENDANTS) <br />103. Plaintiff reiterates and incorporates by reference the preceding paragraphs of this <br />Complaint as though set forth fully herein. <br />104. Plaintiff has exhausted his administrative remedies. <br />105. HRS § 378-2(1)(A) (Supp.1999) provides in relevant part: <br />It shall be an unlawful discriminatory practice: <br />(1) Because of race, sex, sexual orientation, age, religion, color, ancestry, disability, <br />marital status, or arrest and court record: <br />(A) For any employer to refuse to hire or employ or to bar or discharge from employment, <br />or otherwise to discriminate against any individual in compensation or in the terms, <br />conditions, or privileges of employment[.] <br />(Emphases added.) <br />-15- <br />EXHIBIT "A" Pg15 <br />Page 15 of 25 <br />