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17 <br />1963 Haw. Sess. Laws Act 180, § 1 at 224 (emphasis added) (predecessor to HRS § 378- <br />2(3)). In other words, the legislature plainly understood how to proscribe the conduct of <br />individual employees, and when it intended to do so, it did so explicitly and <br />unequivocally. <br />(Emphasis added). <br />114. As explained above, Adams, motivated by sexual attraction repeatedly hired and <br />placed 3 young attractive females absurdly less qualified than Plaintiff into the film commissioner <br />position since the last permanent film commissioner retired. <br />115. As a result, Adams aided and abetted discrimination against Plaintiff. <br />116. As a result, Plaintiff was discriminated against due to his age, sex and gender in <br />violation of HRS § 378-2 by all above named Defendants. <br />117. As a direct and proximate result of Defendants' wrongful conduct, Plaintiff has <br />sustained substantial damages, including, but not limited to economic loss and emotional distress <br />and is therefore entitled to recover special, general, and compensatory damages in such amounts <br />as shall be shown at a trial or hearing hereof. <br />118. Plaintiff has been damaged in an amount to be proven at trial. <br />119. Plaintiff is entitled to recover damages from Defendants, together with prejudgment <br />interest and attorneys' fees and costs. <br />COUNT 2: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS <br />(AGAINST ALL DEFENDANTS) <br />120. Plaintiff reiterates and incorporates by reference the preceding paragraphs of this <br />Complaint as though set forth fully herein. <br />121. Defendants' wrongful conduct was intentional. <br />122. Defendants' wrongful conduct was unreasonable and/or outrageous, committed <br />-17- <br />EXHIBIT "A" Pg17 <br />Page 17 of 25 <br />