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19 <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 />COUNT 4: NEGLIGENT SUPERVISION <br />(AGAINST DEFENDANT HAWAII COUNTY) <br />133. Plaintiff reiterates and incorporates by reference the preceding paragraphs of this <br />Complaint. <br />134. Asset forth above, Defendant Hawaii County and/or their employees, agents and/or <br />representatives had a duty of care to Plaintiff in making sure that Adams was properly supervised <br />and managed in exercising and using his power and authority when performing his County job and <br />duties and engaging in hiring for County jobs. <br />135. As set forth above, Defendant Hawaii County and/or their employees, agents and/or <br />representatives knew, should have known and/or were aware that Adams was abusing, misusing <br />and was negligent in performance of his official duties by engaging in discriminatory hiring <br />practices as described above and Defendant Hawaii County did nothing to correct or prevent this <br />behavior by Adams. <br />136. Defendant Hawaii County and/or their employees, agents and/or representatives <br />breached their duties of care to Plaintiff. <br />137. As a direct, proximate and legal cause of the negligence, gross negligence or <br />recklessness of Defendant Hawaii County and/or their employees, agents and/or representatives, <br />Plaintiff sustained the special and general damages described herein in the amount to be proven <br />and shown at trial. <br />138. All of the named above Defendants' above -described actions have caused Plaintiff <br />-19- <br />EXHIBIT "A" Pg19 <br />Page 19 of 25 <br />