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UNITED STATES DISTRICT COURT

[courtDistrict], [courtDivision]

[plfName]	)	Case No (LT)
Plaintiff	)
)
v.	)
)
[defName]	)	Jury Trial Demanded
Defendant	)	Yes | No

COMPLAINT

COMES NOW, Plaintiff, [plfName], on this [d] day of [MMM] [YYYY], and hereby sues Defendant, [defName] and states the following:

NATURE OF THE CLAIM

This action is brought under {[29 USC §206, et. seq. (“EPA”)], [29 USC §621, et seq. (“ADEA”)], [42 USC §1981 The Civil Rights Act of 1886 (“§1981”)], [42 USC §1983 The Ku Klux Klan Act of 1871 (“§1983”)], [42 USC §2000e, et. seq. (“Title VII”)], [42 USC §2000ff, et. seq. (“GINA”)], [42 USC §12112, et seq. (“ADA”)]}, to redress Defendant’s unlawful employment practices towards Plaintiff (also see 28 USC §1331, §1343, and §1367).

Charges which include – but are not limited to – unlawful retaliation, unlawful interference, color discrimination, disability discrimination, genetic information discrimination, national origin discrimination, race discrimination, religion discrimination, and sex discrimination.

JURISDICTION: AMOUNT

Plaintiff seeks declaratory relief, injunctive relief, and damages in excess of thirty thousand dollars ($30,000) - exclusive of interest, costs, and attorney fees.

JURISDICTION: PARTIES

At all times material hereto, Plaintiff was a resident of [plfCity], FL ([plfCou] County). Thus, he was a “Person”, as described by Title VII.

At all times material hereto, Defendant (a Florida corporation), had its principal place of business in [defCity], FL ([defCou] County). Employing fifteen (15) or more employees at all times pertinent. As such, Defendant satisfies the definition of an “employer” – as contemplated by Title VII.

JURISDICTION: VENUE

Defendant’s unlawful conduct was committed within the jurisdiction of this Court. Thus, pursuant to 28 USC §1331 FS (and §1391), this venue is correct.

STATUTORY PREREQUISITES

All conditions precedent to bringing this action have been satisfied.

In accordance with §1981 provisions, Plaintiff has timely filed this complaint within four (4) years of the date that Defendant [adverseEmploymentAct] against [him/her].

Plus, pursuant to EEOC Regulations (see 29 CFR §1601.19, §1601.21, §1601.28, §1626.17, §1691.7, and/or §1691.9), Plaintiff has initiated this lawsuit within 90 days of receiving [his/her] right-to-sue letter. Thus, upon exhausting all administrative remedies, this cause of action is ripe for litigation.

STATEMENT OF THE FACTS

[para001]

[para002]

[para003]

[para004]

[para005]

[para006]

[para007]

[para008]

[para009]

[para010]

ULTIMATE FACTS

[ultF001]

COUNT I: COLOR DISCRIMINATION | TITLE VII, et. seq.

Plaintiff hereby restates and realleges each and every factual allegation contained in Section VI (Paragraphs 10 through 20).

[arg001]

[arg002]

COUNT II: DISABILITY DISCRIMINATION | ADA, et. seq.

Plaintiff hereby restates and realleges each and every factual allegation contained in Section VI (Paragraphs 10 through 20).

[arg003]

[arg004]

COUNT III: GENETIC INFORMATION DISCRIMINATION | GINA, et. seq.

Plaintiff hereby restates and realleges each and every factual allegation contained in Section VI (Paragraphs 10 through 20).

[arg005]

[arg006]

COUNT IV: NATIONAL ORIGIN DISCRIMINATION | TITLE VII, et. seq.

Plaintiff hereby restates and realleges each and every factual allegation contained in Section VI (Paragraphs 10 through 20).

[arg007]

[arg008]

COUNT V: RACE DISCRIMINATION | TITLE VII, et. seq.

Plaintiff hereby restates and realleges each and every factual allegation contained in Section VI (Paragraphs 10 through 20).

[arg009]

[arg010]

COUNT VI: RACE DISCRIMINATION | 42 USC §1981

Plaintiff hereby restates and realleges each and every factual allegation contained in Section VI (Paragraphs 10 through 20).

[arg011]

[arg012]

COUNT VII: RELIGION DISCRIMINATION | TITLE VII, et. seq.

Plaintiff hereby restates and realleges each and every factual allegation contained in Section VI (Paragraphs 10 through 20).

[arg013]

[arg014]

COUNT VIII: SEX DISCRIMINATION | TITLE VII, et. seq.

Plaintiff hereby restates and realleges each and every factual allegation contained in Section VI (Paragraphs 10 through 20).

[arg015]

[arg016]

COUNT IX: RETALIATION | TITLE VII, et. seq.

Plaintiff hereby restates and realleges each and every factual allegation contained in Section VI (Paragraphs 10 through 20).

[arg017]

[arg018]

COUNT X: CONSTITUTIONAL VIOLATIONS | 42 USC §1983

Plaintiff hereby restates and realleges each and every factual allegation contained in Section VI (Paragraphs 10 through 20).

[arg019]

[arg020]

COUNT XI: EQUAL PAY VIOLATIONS | EPA, et. seq.

Plaintiff hereby restates and realleges each and every factual allegation contained in Section VI (Paragraphs 10 through 20).

[arg021]

[arg022]

PRETEXT

[pre001].

[pre002]

[pre003]

DAMAGES

As a direct and proximate result of said acts, Plaintiff has suffered – and continues to suffer – loss of employment, loss of income, loss of other employment benefits, loss of earning capacity and has suffered and continues to suffer mental anguish, distress, pain, great expense, inconvenience, professional damage and other pecuniary and nonpecuniary losses.

As a further result of Defendant’s discrimination, Plaintiff has incurred legal fees and will continue to incur legal fees.

RESERVATION OF RIGHTS

Defendant’s acts, discriminatory patterns, and unlawful practices demonstrate a callous disregard and reckless indifference to Plaintiff that justifies an award of punitive damages at trial. Upon an evidentiary showing and hearing, Plaintiff reserves the right to amend his pleadings to assert a claim for punitive damages against Defendant.

Plaintiff may retain an attorney to represent him in prosecuting this action and if so will be obligated to pay them a reasonable fee for their services.

Pursuant to 42 USC §1988, Plaintiff is entitled to request that the Court allow him to recover [his/her] reasonable attorney’s fees incurred in successfully prosecuting this cause, should he retain an attorney.

REQUEST FOR JURY TRIAL

Pursuant to Amendment 7 of the United States Constitution (and Rule 38(b) Fed. R. Civ. P., Rule 81(c) Fed. R. Civ. P.), Plaintiff respectfully requests that this honorable Court grant him a trial by jury on all issues so triable.

REQUEST FOR RELIEF

WHEREFORE Plaintiff respectfully requests that this Court enter judgment in favor of Plaintiff and against Defendant on all claims herein, and enter an Order providing the following relief:

Declaring that Defendant violated {[§1981], [§1983], [the ADA], [the ADEA], [the EPA], [the GINA], and [Title VII]};

Enjoining Defendant from committing further violations of the law;

Enjoining Defendant from committing further violations of the US Constitution;

Awarding Plaintiff back pay and front pay, including interest, in the form of lost wages (including lost fringe benefits), which resulted from the illegal discrimination, harassment and wrongful [adverseEmploymentAct].

Awarding Plaintiff the cost of this action, together with reasonable attorney’s fees (if any).

Awarding Plaintiff pre-judgment interest.

Awarding Plaintiff punitive damages; and

Awarding such other and further relief as is just, equitable, and proper.

Dated this [D]th day of [MMM] [YYYY].

Respectfully submitted,

/s/ [plfName]

[plfName], Plaintiff

[plfAddy]

P: [plfPhn]

E: [plfEml]

W: TextBookDiscrimination.com

Get Booked Up on Justice!

Endnotes:

1/ [endNote01]	2/ [endNote02]
3/ [endNote03]	4/ [endNote04]

How-To Guide: (interactive)

TextBookDiscrimination.com/Guides/FileComplaint-Federal.html

EXHIBIT A

Charge of Discrimination

From: Plaintiff

To: State Agency (FCHR)

[EEOC Form 5]

EXHIBIT B

Notice of Right to Sue

From: Federal Agency (EEOC)

To: Plaintiff

[EEOC Form 161]

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