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Case 1 :06-cv—OOO55-GIVIS Document 177 Filed 05/O3/2007 Page 1 013
SCHEDULE G-3

Case 1 :06-cv—OOO55-GIVIS Document 177 Filed 05/03/2007 Page 2 of 3
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
TESLA INDUSTRIES, INC. a Delaware j
Corporation,
Plaintiff
l
v. C.A. No. 06-55-GMS
DAVID C. WALDMANN, LYNDOL W.
HOLLINGSWORTH, CHARLES MINNICK
a.k.a. CHUCK MINNICK, and NEW l
MILLENNIUM TOOLS, INC., an Oregon
Corporation, V
Defendants.
SCHEDULE G-3
DEFENDANT WALDMANN’S STATEMENT OF SPECIAL DAMAGES
AND PLAINTIFF’S OBJECTIONS THERETO
Waldmann seek recovery of the following categories of damages:
l. Attomeys' fees and costs as compensatory damages under Abuse of
Process, Wage Payment Law, ERISA, Federal Electronic Communications Privacy Act,
Delaware Electronic Surveillance and Interception of Communications Act and pursuant
to 6 Del. C. § 2004 (Attorneys’ Fees in Bad Faith Trade Secret Cases) in the amount to be
determined as costs after trial.
3. Compensatory damages for the harm to his reputation.
4. Compensatory damages for emotional distress.
5. Punitive damages for Abuse of Process, Delaware Electronic Surveillance
and Interception of Communications Act., Intrusion Upon Seclusion and Wage Payment
Law.

Case 1 :06-cv—OOO55-GIVIS Document 177 Filed 05/O3/2007 Page 3 of 3
6. Statutory damages under ERISA, the Federal Electronic Communications
Privacy Act, Delaware Electronic Surveillance and Interception of Communications Act,
and the Delaware Access to Personnel File Law.
. 7. Civil Penalties of 10% of unpaid wages for each and every day that wages
were not paid when due under the Wage Payment Law.
8. Restitution for unpaid medical expenses under ERISA to be detennined at
trial.
Plaintiffs Objections to Defendant Waldmann’s Statement of Special Damages
Plaintiff objects to Waldmann’s claims under the Wage Payment and Claim Act I I I I I I I I
("WPCA") for the reasons stated in Plaintiffs Trial Brief and in Schedule B (Statement
of Contested Issues of Law). Similar objection is lodged to Waldmann’s ERISA claims
for the reasons stated in that Brief and Schedule B. See Plaintiff s Trial Brief and
Schedule B on Plaintiffs position on all other claims.