The Regents - University of California | Office of The President

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283. With knowledge of the unlawful purpose of the conduct of
WorldCom, Defendants, and each of them, entered into an agreement to
accomplish the aforesaid scheme, and by their actions took steps to further that
scheme.
284. As a result of the wrongful conduct of each of the Defendants,
Plaintiff has suffered and will continue to suffer economic losses and other general
and specific damages, all in an amount to be determined according to proof.
285. At all times herein alleged, Defendants acted with actual malice. At
all times herein alleged, Defendants acted willfully, wantonly, with oppression,
fraud and/or malice, and with a conscious disregard of the rights of others, such
that Plaintiff requests that the trier of fact, in the exercise of its sound discretion,
should award Plaintiff additional damages for the sake of example and in a
sufficient amount to punish the Defendants for their conduct, in an amount
reasonably related to Plaintiff’s actual damages and defendants’ wealth and
sufficiently large to be an example to others, and to deter plaintiffs and others
from engaging in similar conduct in the future.
WHEREFORE, Plaintiff prays for relief as set forth below.
PRAYER FOR RELIEF
1. Compensatory and general damages according to proof;
2. Special damages according to proof;
3. For an injunction ordering Defendants, and each of them, to cease and
desist from engaging in the unfair, unlawful, and/or fraudulent
practices alleged in the Complaint;
4. Prejudgment interest at the maximum rate;
5. Punitive and exemplary damages according to proof;
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COMPLAINT