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this position, was of a nervous tendancy, did have problems with other employees immediately after filling this position. Was accepted in this position, only after all others, had refused, was attempted, beyond all truths, all reality, and at theexpense of the plaintiff and others to get ahead, look good in the companies eyes, to gain-Sfurther promotion. And that the company, UPS,did and was liable, for the acts of its employee's under " Master Servant"--Respondent Superior---. Plaintiff further charges that any and all incidents, which did and do now exist of a conspiracy against him, do, arise out of this incident and any and all that did follow, acts of which were committed against this plaintiff, of a continuing nature, that did and do lead up to this complaint, and as incorporated, Counts I,11I,III,IV,V, and this Vij are a direct and aneproximate result of this incident and this companies, pattern of continuing harassment, of this plaintiff, on the job, off the job, in acts of slander of a criminal nature, to obtain an 'ANIMUS INTENT" campaign , to further there ambitions, being as supervisors, Or as a company at whole, to deprive this plaintiff, of his civil rights, and did act in conspiracy, both in the cover-up of this 1964 assault, and all harassment and intimidation that did follow, by this company and its servant Supervisors, in acts of revenge, with "M6tive and Intent", to harass this plaintiff at any means available to’ them, on the job off the job, and to obtain for themselves as supervisors, extra stock in the company, promotions, and as a company @s a whole, a Corporation, to set out without just cause or any provocation, from this plaintiff to destroy his life at any means, to set an example to others, that "WE CAN DESTROY YOU". Plaintiff charges that this was the goal of this Corporation UPS, it did in 1964, through a promoticn cf its choosing, promote an employee to management, who did not have’ the skills required, and that whatever acts that did transpire from this promotion, and all others, and acts committed by all others that were promoted by this Corporation "UPS", are the acts of the company, being liable for its wrongs, under "MASTER Sérvant", to any third parties, and the plaintiff charges that he is athird party, wronged by the incompetent and malicious people that this C6rporation did and does employ, and that these employees, going in disguise, as wanton and vicicus slander of a criminal nature, did destroy the life of the plaintiff as charged in all counts this complaint. 32) Plaintiff further charges that from this 1964, incident, Sna for the remainder of his tenure as an employee, ending in dismissal on March 29th,1978, he was the subject of cruel and unusual=-narassment, intimidation, conspiracy, and that this Corporation did use its supervisor personel, its Corporate position, its aspiring drivers, to promote hate off the job, on the job, in slander, which @id result in further harass ment and intimidation, both on the job and off the job to this plaintiff. Plaintiff charges that this Corporation 1s solely responsible for all events that did transpire,did happen in the life of theplaintiff, up to and including this (74)