Fill and Sign the Comes Now the Plaintiff and Sues the Defendant Form

- 1 - IN THE COURT OFCOUNTY, )))))))))Petitioner/Plaintiff, V. CAUSE NO. Defendant/Respondent, JURY TRIAL DEMANDED COMPLAINT COMES NOW the Plaintiff, _________________, and sues the Defendant, _________________, for compensatory and punitive damages and for this cause of action would most respectfully show unto this Court the following facts, to wit: PARTIES 1.The Plaintiff, _________________, is an adult resident citizen of __________, _____________.2.The Defendant, _________________, is a Delaware corporation doing business in the State of __________ at _________________, _____________, ________. The agent for service of process is _________________, _________________, _________, __________.3.The Plaintiff is an employee within the meaning of the Civil Rights Act of 1964, as amended by the Civil Rights Act of 1991. The Defendant is an employer within the meaning of the Civil Rights Act of 1964, as amended by the Civil Rights Act of 1991. JURISDICTION AND VENUE - 2 - 4.This Court has jurisdiction pursuant to 28 USC § 1331 and 28 USC § 1343 and this action is brought pursuant to Title VII of the Civil Rights Act of 1964 as amended by the Civil Rights Act of 1991, cited as 42 USC §2000e(k). FACTUAL SITUATIONS 5.(Insert Facts) CAUSES OF ACTION 6.The Defendant has violated numerous federal and state laws in the unlawful termination of the Plaintiff. The Defendant has deprived the Plaintiff of her job and has severely affected the substantial interest she had in her reputation and her ability to earn a living. The Plaintiff has further been denied access to certain benefits to which she was entitled under Defendant's employee benefit plan. The Defendant's termination of the Plaintiff was arbitrary, unreasonably discriminatory, and retaliatory, all in violation of Title VII of the Civil Rights Act of 1964 as amended by the Civil Rights Act of 1991, cited as 42 USC §2000e(k). The Defendant exhibited ill will, malice, improper motive, and indifference to the Plaintiffs civil rights by forcing her to take a leave of absence without pay or benefits. DAMAGES 7.The Plaintiff, as a result of the actions of the Defendant, has suffered lost wages, mental anxiety and stress, and other damages for which she will show at a trial of this cause of action.8. The Plaintiff has suffered compensatory damages and punitive damages as a result of the actions of the Defendant; is entitled to back pay and front pay as a result of the actions of the Defendant; and is further entitled to reinstatement to her former position with the Defendant. PRAYER FOR RELIEF WHEREFORE, the Plaintiff; _________________, respectfully prays for the following relief against the Defendant, _________________:A. Compensatory damages in an amount to be determined by this Court.B. Punitive damages in an amount to be determined by this Court.C.Back pay in an amount to be determined by this Court.D.Front pay in an amount to be determined by this Court. - 3 - E.Reasonable attorney's fees and all costs of this court.F.Such other general and special relief as appears reasonable and just in this cause. RESPECTFULLY SUBMITTED,________________________________