Fill and Sign the Complaint for Violation of Civil Rights and for Wrongful Discharge for Reporting Illegal Acts 1st 14th Amendments Us Form

- 1 - IN THE UNITED STATES DISTRICT COURT FOR THE ______________DISTRICT OF _____________ _________________ DIVISION _____________________VS._____________AND _______________ JURY TRIAL DEMANDED COMPLAINT 1. This is an action to recover damages for violation of the First Amendment of the United States Constitution. This Court's supplemental jurisdiction is invoked to recover damages for state law claims. Plaintiff shows the Court the following: I. 2. Plaintiff, _________________, is an adult resident citizen of _________________, _________, _____________________.3. Defendant, _________________, is a political subdivision of the state of _____________ and may be served with process by service upon its Director, _________________, at _________________, ____________, ____________________.4. Defendant, _________________, is the director of _________________ and may be served with process by service upon her at her place of employment at _________________, ________________________, _______________. II. 5. At all relevant times, Defendants acted under color of state law. III. 6. This Court has federal question jurisdiction under 28 U.S.C. § 1331 and civil rights jurisdiction under 28 U.S.C. § 1343 for a cause of action arising out of the First Amendment of the United States Constitution, and under this Court's supplemental jurisdiction when a right-to-sue letter is received. IV. - 2 - 7. Plaintiff was employed by Defendant, _________________, for a period of twenty months as an accounts manager. V. 8. During the time of Plaintiff's employment, Defendant _________________ had an intense dislike for her because of an administrative assistant, Mr. _________________. However, this dislike was not sufficient for the termination of Plaintiff's employment. VI. 9. Plaintiff would have remained employed by Defendant _________________, except that in the spring of __________, Plaintiff caused information to be reported to a representative of the Inspector General's office of the United States that certain illegal acts committed by Defendant _________________. These illegal acts included using a Housing Authority motor scooter for private benefit, using a Housing Authority automobile for private benefit, refusing to reimburse tenants for utility payments, misuse of drug grant money by buying office furniture with the grant money, and giving false credit for leave time to which she was not entitled. VII. 10. The above reports by Plaintiff were an exercise of her First Amendment rights. VIII. 11. In addition to reports about the above illegal acts, the report to the Inspector General concerning misconduct also included a report that Defendant _________________ was having an affair with one of the employees, _________________, a police officer. This affair results in differential treatment being given to her lover, as well as the police officers who work at the Housing Authority. IX. 12. The reports by Plaintiff also contain a report that Defendant _________________ had arranged for the purchase of an automobile for the use of her boyfriend, _________________, an employee of the City of ___________. X. 13. Thereafter, Defendant _________________ learned of the report to the Inspector General and wanted to terminate Plaintiff immediately. However, Defendant _________________ became fearful of an immediate termination because she realized that this would be the basis for a suit against her. Thereafter, Defendant terminated Plaintiff claiming that Plaintiff was "unhappy" in her job. Xl. - 3 - 14. During the time of my employment, Plaintiff was also treated differently because of her sex. Defendant _________________ treated her in a hostile fashion and administered the policies of the Housing Authority differently according to whether one was male or female. This sex discrimination made working conditions so difficult as to constitute a hostile working environment. Plaintiff has filed the EEOC charge, attached hereto as Exhibit "A," and requests this complaint to be considered amended to charge the violation of 42 U.S.C. § 2000 for sex discrimination at such time as a right- to-sue letter is received. The sex discrimination violates 42 U.S.C. § 2000, as well as the Equal Employment Clause of the United States Constitution. XII. 15. Plaintiff has suffered lost income, mental anxiety and stress as a result of her discharge. PRAYER Plaintiff prays for actual and punitive damages and for reasonable attorney's fees. Respectfully submitted,_________________________