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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISON

FASCIA EDWARDS, )

 )

)

Plaintiff, )

) No. 12 CV 00371

v. ) Hon. Judge Aspen

)

ILLINOIS DEPARTMENT OF FINANCE )

PROFESSIONAL REGULATIONS, et al., )

)

)

)

)

Defendant. )

FOURTH AMENDED COMPLAINT

Plaintiff, FASCIA EDWARDS, by and through her attorneys the Barcla y 

Law Group, P.C., states for her Complaint against Defendant ILLINOIS

DEPARTMENT OF FINANCE AND PROFESIONAL REGULATION, et.al. as follows:

JURISDICTION AND VENUE

1. Plaintiff brings this action under the Americans with Disabilities Act of 1990, 42 

U.S.C. 12101 et seq. (hereafter "ADA") and the Americans with Disabilities Amendment Act 

of 2008 (hereafter “ADA Amendment Act”),Title VII of the Civil Rights Act of 1964, as 

amended, 42 U.S.C. §§ 2000e et seq. ("Title VII'), retaliation under Title VII enabling 

provisions of 703(a)1;2(b) and 704(a), 42 U.S.C 1983 and 1988; Sec 504 of the Rehabilitation 

Act of 1973 and Age Discrimination of 1988 as amended, 29 USC§ 629 633(c) contained 

within Fair Labor Standards Act of 1938 (U.S.C. 201-19 et.seq). Jurisdiction is conferred for 

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the Title VII claims by 28 U.S.C. § 1331, 28 U.S.C. § 1343(a)(3), and 42 U.S.C. §2000e5(f)(3). Jurisdiction for the Age Discrimination in Employment Act (“ADEA”) claim is 

conferred by 42 U.S.C. §12117. 

2. This Court has supplemental jurisdiction over Plaintiff's Illinois common 

law claims pursuant to 28 U.S.C.§1367.

3. Venue is proper in this judicial district under 28 U.S.C. § 1391 because the 

events that gave rise to this Complaint occurred in this district. 

4. On or about February 6, 2009 and amended on October 11, 2011, Plaintiff filed 

a timely charge of race, sex, disability, hostile work environment and retaliation in violation 

of the Title VII of the Civil Rights Act with the local district office of the EEOC against the

Illinois Department of Finance and Professional Regulation State of Illinois.

5. On October 18, 2011, the EEOC issued its Notice of Right to Sue regarding 

this charge, a copy of which is attached hereto as Exhibit “A”. 

 6. On September 29, 2011, Plaintiff filed another timely continuing action charge of

race, sex, and retaliation discrimination in violation of the ADA, Title VII of the Civil Rights

Act 1964 as amended and enabling provisions under Section 703(a)1; 2(b) and 704(a) with

the local district office of the EEOC against the Illinois Department of Finance and

Professional Regulation State of Illinois. On November 4, 2011, the EEOC issued its Notice

of Right to Sue regarding this charge, a copy of which is attached hereto as Exhibit “B”. 

7. On September 19, 2011, Plaintiff filed a charge of discrimination 

with the Illinois Department of Human Rights against the Illinois State 

Retirement System, in which Plaintiff alleged discrimination based on race, 

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retaliation, age and disability. On September 29, 2011, the EEOC sent 

Plaintiff a Notice of Right to Sue letter regarding this charge. (A copy of the 

Notice of Right to Sue letter regarding the charge against the Illinois State 

Retirement System is attached hereto as Exhibit “C”.) However, the Notice 

of Right to Sue letter was returned to the EEOC on October 4, 2011 and 

never resent to Plaintiff. (A copy of the envelope containing the Notice of 

Right to Sue letter regarding the charge against the Illinois State Retirement 

System is attached hereto as Exhibit “D” .)

8. This action was timely filed. 

PARTIES

9. Plaintiff, FASCIA EDWARDS (hereafter "Plaintiff or Plaintiff Edwards"), is

an African American female, born on December 3, 1951, and resided in City of Chicago,

Cook County, Illinois, at all times relevant to this action was a state certified full time

employee. 

10. Defendant, ILLINOIS DEPARTMENT OF FINANCE AND

PROFESIONAL REGULATION STATE OF ILLINOIS, et.al. IDFPR (hereafter "IDFPR"),

is and was at all relevant times a government agency and department of the State. IDFPR

created pursuant to Illinois statute 20 ILCS 5115 is a government agency and department

and that it is governed under the Illinois Department of Human Rights. The IDFPR has

continuously been a unit of government of the State of Illinois established pursuant to the

laws of the State of Illinois and at all times relevant has employed about 1000 employees,

and maintains a principal office in Springfield and Chicago, Illinois.

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11. Defendant, ILLINOIS S T A T E R E T I R E M E N T S Y S T E M (hereafter

"ISRS"), is and was at all relevant times a government agency and department of the State.

ISRS was created pursuant to Illinois statute 20 ILCS 5115 is a government agency and

department and that it is governed under the Illinois Department of Human Rights. The

ISRS has continuously been a unit of government of the State of Illinois established

pursuant to the laws of the State of Illinois and at all times relevant has employed about

1000 employees, and maintains a principal office in Springfield and Chicago, Illinois. 

FACTS COMMON TO ALL COUNTS

12. Plaintiff Edwards began her state employment with Department of Human 

Services on November 3, 2003. On December 1, 2008, Plaintiff Edwards was transferred in

lieu of layoff to the Department of Finance and Professional Regulations, State of Illinois.

13. Plaintiff's last position with IDFPR was Executive I within its Department of

Finance and Professional Regulation that began December 1, 2008 and ended July 9,

2009.

14. Plaintiff's job performance at all relevant times met or exceeded IDFPR's

legitimate expectations. Plaintiff Edwards received a Distinguished Service Award from her

work performed at the Department of Human Services for over five years.

15. On June 22, 2009, Plaintiff suffered a workplace back injury and

immediately sought emergency medical attention while at work.

16. Plaintiff timely reported her workplace injuries to her superiors.

17. After seeking medical care, Plaintiff Edwards’ initial diagnosis was a

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herniated lumbar disk and radiculopathy injury. Subsequent MRI lumbar spine diagnosis showed 

a musculoskeletal moderate-to-severe degenerative disk disease. Her Physician medical 

statement explains that Plaintiff's fibrous tissue that holds her disk in place has small tears in the

disk. It is an impermanent injury that lies between adjacent lumbar intravertebral disk in the

spine along with bilateral tingling in the lower extremities in the lower leg into the feet causing

significant limitation in lumbar spinal movement. Plaintiff is restricted from stooping,

lifting, climbing, bending, kneeling, crouching, crawling, and reaching functions.

18. This is a "disability" as defined within the meaning of ADA. Plaintiff is a

"qualified" individual with a musculoskeletal impairment that substantially limits one or

more of her major life activities that has a permanent long term impact and prevents her

from performing manual tasks that an average person can perform with little or no difficulty. 

19. On July 9, 2009, Plaintiff began a disability leave from work due to her back

injury. Treatment received at Northwestern Rehabilitation Institute of Chicago concluded on 

March 30, 2013.

20. On June 4, 2010, through her worker compensation attorneys, Plaintiff filed two

Applications for Adjustment of claim with the IDFPR Workers Compensation Commission

in connection with her workplace injury. On June 11, 2011, Industrial Commission 3-judge

panel on appeal from IDFPR, ruled unanimously that job duties not found under Plaintiff

position caused her to suffer a work related injury.

21. In October 2010, Plaintiff’s physician released her to return to work. Each

month physician statements were submitted to the IDFPR and A&R SHARED SERVICES

(Personnel arm of IDFPR) and continued beyond April 1, 2013 to be submitted. IDFPR has

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failed to interact with the Plaintiff for reassignment to work.

22. Plaintiff Edwards duly notified IDFPR of her release and her desire and ability

to return to work in any position that she was qualified to perform the essential functions

of with or without a reasonable accommodation.

23. Plaintiff' was offered a job described within the CMS#104 Office of Legal

Affairs, #13851-13-01-500-40-01, which did not include manual labor and heavy lifting. 

However, the job Plaintiff was assignedto by IDFPR was a file clerk. The job functions

Plaintiff was forced to perform involved manual labor and heavy lifting whichwere not advertised

by IDFPR nor approved by Illinois Central Management Services, Illinois A& R Shared

Services, orThe StateRetirement Systems, State of Illinois.

24. Plaintiff holds a B.A. from Northwestern University, MBA, Saint Xavier

University and is working on her doctorate in Education. Plaintiff applied for over 

thirty (30) positions within the Illinois A&R Shared Services (the personnel arm of

IDFPR) and also through the CMS Alternative Employment Program after Defendant

was promised assistance. Plaintiff Edwards was denied reassignment even though she

was qualified, met geographical area access and where she applied for jobs that

demanded similar training to be performed as her CMS 104 Office of Legal Affairs 

position.

25. To date, IDFPR has failed and refused to reinstate and/or recall Plaintiff back to

work, and by this retaliatory act has thereby effectively terminated her employment. The

action of her Defendant also constitutes reckless indifference toward Plaintiff's federally

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protected rights as a qualified individual with a disability when it refused to make

reasonable accommodations for Plaintiff’s known disability.

26. ISRS has wrongly denied Plaintiff medical and retirement benefits. 

COUNT I: DISCRIMINATION BASED ON DISABILITY

TITLE I OF THE ADA

 27. Plaintiff Edwards restates and fully incorporates into Count I her allegations set 

forth in Paragraphs 1 through 26, above.

 28. The ADA makes it unlawful for an employer to discriminate against a

qualified individual on the basis of a disability in regard to discharge of employees, employee

compensation, job training and other terms, conditions, and privileges of employment, including

not making reasonable accommodations to the known physical and mental limitations of an

employee who is otherwise a qualified individual with a disability, and denying employment

opportunities to such a person. See 42 U.S.C. § 12112(a) and (b)(5).

29. At all relevant times, Plaintiff was "disabled" as defined under the ADA and 

ADAAA, 42 U.S.C. § 12102(1); and under Section 504 of the Rehabilitation Act of 1973. She 

provided the employer with a record of a substantial limiting impairment but IDFPR 

discriminated against her because she was classified as having a disability. IDFPR under the 

ADAAA, regarded Plaintiff as having a disability but took retaliatory actions prohibited by the 

ADA. At all relevant times, Plaintiff was a "qualified individual" as defined under the ADA. 

See 42 U.S.C. § 12111(8) and under Section 504 of the Rehabilitation Act of 1973.

30. As described above, IDFPR failed to reasonably accommodate Plaintiff's return to 

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work, and has failed to engage in the interactive process with her in order to determine whether 

any reasonable accommodation can be made in order to return her to work.

31. IDFPR could have returned Plaintiff to work beginning in June 2010 and thereafter

without undue hardship.

32. IDFPR failed to reinstate and/or rehire Plaintiff because of her disability.

On information and belief, IDFPR reinstated and/or rehired other non-disabled similarly situated

employees.

33. As a direct and proximate result of the IDFPR's illegal conduct as described above,

Plaintiff has lost, and is expected to continue to lose, income in the form of wages and prospective

retirement benefits, social security and other benefits in a sum to be proven at trial, and has

suffered emotional pain, mental anguish, loss of enjoyment of life, and other non-pecuniary 

losses.

34. The IDFPR knew that its acts as described above were prohibited by the ADA and

ADAAA, or acted with reckless disregard to that possibility.

35. ISRS has wrongly denied Plaintiff medical and retirement benefits. 

WHEREFORE, Plaintiff, FASCIA EDWARDS, respectfully requests that this Court

enter judgment in her favor and against Defendants the ILLINOIS DEPARTMENT OF

FINANCE AND PROFESIONAL REGULATION and the ILLINOIS STATE RETIREMENT 

SYSTEM and grant the following relief:

A. Order Defendants to make Plaintiff whole by paying her appropriate back

pay and reimbursement for lost pension, social security and other benefits and out-ofCase: 1:12-cv-00371 Document #: 44 Filed: 07/29/13 Page 8 of 19 PageID #:235
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pocket expenses, plus pre-judgment interest in an amount to be shown at trial;

B. Order Defendants to immediately reinstate Plaintiff to her former position or

one comparable thereto; or, in the alternative, order IDFPR to pay her an appropriate amount

of front pay; purge any personnel file disciplinary items as required under two year

limitations of the CMS personnel policies and Union contract;

C. Order Defendants to pay her compensatory damages in the

maximum amount allowable under the law;

D. Order Defendants to pay Plaintiff Edwards punitive damages in the

maximum amount allowable under the law; and damages for intentional emotional

distress;

E. Order Defendants to pay her costs incurred in bringing this action,

including, but not limited to, expert witness fees and reasonable attorneys' fees;

F. Try all issues of fact to a jury; and,

G. Grant such other relief as the Court deems just.

COUNT II: AGE DISCRIMINATION IN VIOLATION OF THE ADEA

36. Plaintiff Edwards restates and fully incorporates into Count II her allegations set forth

in Paragraphs 1 through 26, above.

37. The ADEA makes it illegal for an employer such as the IDFPR to discriminate against

any individual with respect to her compensation, terms, conditions, or privileges of employment,

because of such individual's age. See 29 U.S.C. § 623(a).

38. The above-described acts and omissions by IDFPR were taken against Plaintiff

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Edwards because of her age in violation of the ADEA.

39. IDFPR treated similarly-situated, significantly younger employees more

favorably than Plaintiff. Her Executive I CMS #104 Office of Legal Affairs, #13851-13-

01-500-40-01 job functions were assigned to a younger worker while Plaintiff was given

the work of a file clerk. This position held no opportunity for raises, promotion or

advancement nor was the position change approved by CMS Personnel according to

policy.

40. As a direct and proximate result of IDFPR illegal age discrimination as

described above, Plaintiff has suffered mental and physical pain and anguish, a loss of wages,

including, but not limited to, salary, bonuses, a loss of employment benefits and other pecuniary

and non-pecuniary damages.

41. IDFPR knew that its acts as described above were prohibited by the ADEA, or acted 

with reckless disregard to that possibility.

42. ISRS has wrongly denied Plaintiff’s medical and retirement benefits. 

WHEREFORE, Plaintiff, FASCIA EDWARDS, respectfully requests that this Court

enter judgment in her favor and against Defendants the ILLNOIS DEPARTMENT OF

FINANCE AND PROFESIONAL REGULATION and the ILLINOIS STATE RETIREMENT 

SYSTEM and grant the following relief:

A. Order Defendants to make Plaintiff whole by paying her appropriate back pay

and reimbursement for lost pension, social security and other benefits and out-of-pocket

expenses, plus pre-judgment interest in an amount to be shown at trial;

B. Order Defendants to pay Plaintiff an equal amount to A, above, as and for

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liquidated damages under the ADEA;

C. Order Defendants to immediately reinstate Plaintiff to her former position or

one comparable thereto; or, in the alternative, order IDFPR to pay her an appropriate amount

of front pay; purge any personnel file disciplinary items as required under two year

limitations of the CMS personnel policies and Union contract.

D. Order Defendants to pay her compensatory damages in the

maximum amount allowable under the law;

E. Order Defendants to pay Plaintiff Edwards punitive damages in the

maximum amount allowable under the law; and damages for intentional emotional distress.

F. Order Defendants to pay her costs incurred in bringing this action, including,

but not limited to, expert witness fees and reasonable attorneys' fees;

G. Try all issues of fact to a jury; and,

H. Grant such other relief as the Court deems just.

COUNT III: RACE AND SEX DISCRIMINATION IN VIOLATION OF TITLE VII

43. Plaintiff Edwards restates and fully incorporates into Count III her allegations

set forth in Paragraph 1 through 26 above.

44. Title VII makes it illegal for an employer such as the IDFPR to discriminate or treat an

employee unfavorably because she is of certain race or sex. IDFPR discriminated against the

Plaintiff as an individual in the terms, conditions or privileges of employment on the basis of her

race and sex.

45. IDFPR terminated Plaintiff's employment, or failed to reinstate and/or rehire

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her because of her race in violation of Title VII. The violations became so frequent and

severe that it created a hostile, retaliatory and offensive work environment and resulted in

adverse employment acts such as threats to her life, demotion and docked wages.

 46. On information and belief, IDFPR reinstated and/or rehired other non-African

American, similarly-situated employees.

 47. On information and belief, IDFPR reinstated and/or rehired other male, similarlysituated employees.

 48. As a direct and proximate result of the IDFPR's illegal discrimination based on race 

and sex as described above, she has suffered mental and physical pain and anguish, a loss of

wages, including, but not limited to, salary, bonuses, a loss of employment benefits and other

pecuniary and non-pecuniary damages.

 49. IDFPR knew that its acts as described above were prohibited by Title VII, or acted

with reckless disregard to her protected rights.

 50. ISRS has wrongly denied Plaintiff medical and retirement benefits. 

WHEREFORE, Plaintiff, FASCIA EDWARDS, respectfully requests that this Court

enter judgment in her favor and against Defendants the ILLNOIS DEPARTMENT OF

FINANCE AND PROFESIONAL REGULATION and the ILLINOIS STATE RETIREMENT 

SYSTEM and grant the following relief:

A. Order Defendants to make Plaintiff whole by paying her appropriate back pay

and reimbursement for lost pension, social security and other benefits and out-of-pocket

expenses, plus pre-judgment interest in an amount to be shown at trial;

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B. Order Defendants to immediately reinstate Plaintiff to her former position or

one comparable thereto; or, in the alternative, order IDFPR to pay her an appropriate amount

of front pay; purge any personnel file disciplinary items as required under two year

limitations of the CMS personnel policies and Union contract.

C. Order Defendants to pay her compensatory damages in the

maximum amount allowable under the law;

D. Order Defendants to pay Plaintiff Edwards punitive damages in the

maximum amount allowable under the law; and damages for intentional emotional

distress;

E. Order Defendants to pay her costs incurred in bringing this action,

including, but not limited to, expert witness fees and reasonable attorneys' fees;

F. Try all issues of fact to a jury; and,

G. Grant such other relief as the Court deems just.

COUNT IV: RETALIATORY DISCRIMINATION UNDER SECTION 504

OF THE REHABILITATION ACT, OF 1973 29 U.S.C. § 794 (1994) AND

IDFPR ET.AL. COMMON LAW AND PUBLIC POLICY

51. Plaintiff restates and fully incorporates into Count IV her allegations set

forth in Paragraphs 1 through 26, above.

52. Sec 504 of the Rehabilitation Act of 1973 states that no otherwise qualified

individual with a disability in the United States, as defined in Section 705 (20) of this title,

shall, solely by reason of her or his disability, be excluded from the participation in, be

denied the benefits of, or be subjected to discrimination under any program or activity

receiving Federal financial assistance or under any program or activity conducted by any

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Executive agency responsible for regulatory operations for the State.

53. IDFPR, et.al., an Executive Agency of the State of Illinois and through The State

Plan, participates in interagency cooperation with, and utilization of the services and

facilities of, federal, state, and local agencies and programs.

54. IDFPR et.al. knew or should have known that its acts as described above were

prohibited by Sec 504 of the Rehabilitation Act but acted with reckless indifference toward

Plaintiff's federally protected rights when it took retaliatory acts against her instead of

affirmative actions to advance her employment to similarly situated positions.

55. IDFPR et.al., must make Plaintiff Edwards whole due to abrogation of her CMS

#104 Office of Legal Affairs job duties as defined in that position. Her subsequent

assignment to file room work duties was not approved and violated CMS Personnel Rules,

public policy and Sec 504 of the Rehabilitation Act. 

56. ISRS has wrongly denied Plaintiff medical and retirement benefits. 

WHEREFORE, Plaintiff, FASCIA EDWARDS, respectfully requests that this Court

enter judgment in her favor and against Defendants the ILLINOIS DEPARTMENT OF

FINANCE AND PROFESIONAL REGULATION and the ILLINOIS STATE RETIREMENT 

SYSTEM, and grant the following relief:

A. Order Defendants to make Plaintiff whole by paying her appropriate back pay

and reimbursement for lost pension, social security and other benefits and out-of-pocket

expenses, plus pre-judgment interest in an amount to be shown at trial;

B. Order Defendants to immediately reinstate Plaintiff to her former position or

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one comparable thereto; or, in the alternative, order IDFPR to pay her an appropriate amount

of front pay; purge any personnel file disciplinary items as required under two year

limitations of the CMS personnel policies and Union contract.

C. Order Defendants to pay her compensatory damages in the

maximum amount allowable under the law;

D. Order Defendants to pay Plaintiff Edwards punitive damages in the

maximum amount allowable under the law; and damages for intentional emotional

distress;

E. Order Defendants to pay her costs incurred in bringing this action,

including, but not limited to, expert witness fees and reasonable attorneys' fees;

F. Try all issues of fact to a jury; and,

G. Grant such other relief as the Court deems just.

COUNT V: RETALIATORY DISCHARGE IN VIOLATION OF

THE ILLINOIS WORKERS' COMPENSATION ACT,

COMMON LAW AND PUBLIC POLICY

57. Plaintiff Edwards restates and fully incorporates into Count IV her allegations

set forth in Paragraphs 1 through 2 6 , above.

58. Plaintiff's f i lin g o f h er W o rk e rs ’ Com p ens a tio n c la im a ga i nst 

IDFPR, and all activities she performed related to and in conjunction with 

filing the claim were activities protected by the Worker's Compensation Act, 820

ILCS 305/1 et seq. (the "Act").

59. IDFPR was aware of each of these aforementioned activities within a short

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time after they occurred but took retaliatory actions against her because she filed for

medical recovery under the Act.

60. Plaintiff suffered several threats to her life and safety. The violations became

so frequent and severe that it created a hostile, retaliatory and offensive work

environment and resulted in adverse employment acts such as threats to her life,

demotion and docked wages.

61. Plaintiff’s protected activities under the Act were a motivating factor behind

IDFPR' decision to terminate her employment, or refusal to reinstate and/or rehire

her.

62. As such, the IDFPR' termination of her employment, or refusal to reinstate

and/or rehire her was causally related to her protected activities under the Act.

63. Defendant’s termination of Plaintiff Edwards’ employment, or refusal to reinstate

and/or rehire her was therefore an illegal retaliatory discharge in contravention of public policy

as set forth in the Act.

64. As a direct and proximate result of Defendant’s illegal termination of her

employment, or refusal to reinstate and/or rehire, Plaintiff has suffered a loss of income in

the form of wages and prospective retirement and medical benefits, social security and

other employment benefits, emotional pain, mental anguish, loss of enjoyment of life, and

other non-pecuniary losses, and she is expected to incur future damages.

65. The above-described conduct by Defendant was willful and wanton, and with

reckless disregard and indifference to the law and the public policy of Illinois, and to Plaintiff

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Edwards’ protected rights. Defendant should therefore be subject to punitive damages as an

example to deter others from engaging in conduct of this kind.

WHEREFORE, Plaintiff, FASCIA EDWARDS, respectfully requests that this Court

enter judgment in her favor and against Defendant the ILLNOIS DEPARTMENT OF

FINANCE AND PROFESIONAL REGULATION, and grant the following relief:

A. Order Defendant to make Plaintiff whole by paying her appropriate back

pay and reimbursement for lost pension, social security and other benefits and out-ofpocket expenses, plus pre-judgment interest in an amount to be shown at trial;

B. Order Defendant to immediately reinstate Plaintiff to her former position or

one comparable thereto; or, in the alternative, order IDFPR to pay her an appropriate amount

of front pay; purge any personnel file disciplinary items as required under two year

limitations of the CMS personnel policies and Union contract.

C. Order Defendant to pay her compensatory damages in the maximum

amount allowable under the law;

D. Order Defendant to pay Plaintiff Edwards punitive damages in the

maximum amount allowable under the law; and damages for intentional emotional

distress;

E. Order Defendant to pay her costs incurred in bringing this action,

including, but not limited to, expert witness fees and reasonable attorneys' fees;

F. Try all issues of fact to a jury; and,

G. Grant such other relief as the Court deems just. 

VI. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

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66. Plaintiff Edwards restates and fully incorporates into Count V her allegations

set forth in Paragraphs 1 through 2 6 , above.

67. Defendant’s conduct was extreme and outrageous.

68. Defendant intended to cause or recklessly or consciously disregarded the 

probability of causing emotional distress.

69. Plaintiff suffered severe or extreme emotional distress.

70. Defendant’s conduct actually and proximately caused Plaintiff’s emotional 

distress. 

WHEREFORE, Plaintiff, FASCIA EDWARDS, respectfully requests that this Court

enter judgment in her favor and against Defendant the ILLNOIS DEPARTMENT OF

FINANCE AND PROFESIONAL REGULATION, and grant the following relief:

A. Order Defendant to make Plaintiff whole by paying her appropriate

back pay and reimbursement for lost pension, social security and other benefits and out-ofpocket expenses, plus pre-judgment interest in an amount to be shown at trial;

B. Order Defendant to immediately reinstate Plaintiff to her former

position or one comparable thereto; or, in the alternative, order IDFPR to pay her an

appropriate amount of front pay; purge any personnel file disciplinary items as required

under two year limitations of the CMS personnel policies and Union contract.

C. Order Defendant to pay her compensatory damages in the maximum

amount allowable under the law;

D. Order Defendant to pay Plaintiff Edwards punitive damages in the

maximum amount allowable under the law; and damages for intentional emotional distress;

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E. Order Defendant to pay her costs incurred in bringing this action,

including, but not limited to, expert witness fees and reasonable attorneys' fees;

F. Try all issues of fact to a jury; and,

G. Grant such other relief as the Court deems just.

Respectfully submitted,

FASCIA EDWARDS

By:_s/Terri Blanchard_

 One of her Attorneys

Terri Blanchard

The Barclay Law Group, P.C.

39 S. LaSalle, Suite 900

Chicago, IL 60603

(312)553-0123

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