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291.
As a consequence of the conduct by BAM LLC (in consultation and collaboration 2 with BAM and BN), Raffaelli has suffered and will suffer harm, including lost past and future
3 wages, bonuses, LTIP awards (including “carried interest”), retirement and other benefits, and
4 additional amounts of money Raffaelli would have received had he not been wrongfully
5 terminated. As a result of such wrongful termination and its consequences, Raffaelli has suffered
6 additional economic harm and damages, to be stated according to proof at trial.
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292. The acts of BAM LLC (in consultation and collaboration with BAM and BN), as
8 alleged herein, have been reckless and/or intentional, in that BAM LLC (in consultation and
9 collaboration with BAM and BN), in conscious disregard of Raffaelli’s rights, acted so as to cause 10 Raffaelli to suffer a loss of employment benefits and to suffer the injury, humiliation,
11 embarrassment, emotional distress and hardship alleged herein. As a result, Raffaelli did suffer 12 and still does suffer emotional distress, anxiety, stress and worry because of the wrongful conduct 13 of BAM LLC. Accordingly, Raffaelli is entitled to recover general damages against BAM LLC in 14 a sum in excess of the minimum jurisdictional limits of this Court, in an amount to be stated 15 according to proof at trial.
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293. The aforementioned acts were committed by BAM LLC (in consultation and 17 collaboration with BAM and BN), and Does 1 through 100, and each of them, by and through 18 officers, directors, managing agents, agents and/or representatives and/or were known to, aided, 19 abetted, authorized by, ratified by and/or otherwise approved by BAM LLC’s officers, directors, 20 managing agents and/or representatives. The above acts of BAM LLC (in consultation and 21 collaboration with BAM and BN) were despicable and committed knowingly, willfully, 22 fraudulently, and/or maliciously, with the intent to harm, injure, vex, annoy, and oppress Plaintiff, 23 and with a conscious disregard of his rights. By reason thereof, Raffaelli seeks punitive and 24 exemplary damages from BAM LLC in an amount to be proven at trial.
SECOND CAUSE OF ACTION
(Wrongful Termination in Violation of Cal. Labor Code § 1102.5)
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Against Brookfield Asset Management LLC and Does 1 through 100, Inclusive 294. Raffaelli repeats and realleges Paragraphs 1 through 293 as if fully set forth herein.
78 COMPLAINT
