Fill and Sign the Harassment Work Form

UNITED STATES DISTRICT COURT FOR THE _____________ (Name of District) OF ______________ (Name of State) ___________________ (Name of Division) ___________________ (Name of Plaintiff) PLAINTIFF V. CAUSE NO. _____, _______ ___________________ (Names of Defendants) DEFENDANTS COMPLAINT COMES NOW ___________________ (Name of Plaintiff) , Plaintiff in the above- styled and numbered cause, by and through her attorneys, and files this Complaint against Defendants, ___________________ (Names of Defendant) , and in support thereof would show unto the Court the following matters and facts: 1. Plaintiff is an adult resident citizen of ___________________ (city, county, state) . 2. ___________________ (Name of Defendant) , hereinafter called Corporate Defendant , is a ___________________ (name of state) corporation doing business in and duly licensed to do business in ___________________ (name of state) and may be served with process through its registered agent, ___________________ (name of agent) , at ____________________________________________________________ (street address, city, state, zip code) . 3. ___________________ (Name of Defendant) , hereinafter called Individual Defendant , is an adult resident citizen of ___________________ (city, county, state) . 4. This honorable Court has jurisdiction to hear this matter, a cause of action brought pursuant to Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C.A. §§ 2000e et seq. (“Title VII”). 5. This honorable Court has personal jurisdiction over the Defendants as they reside within this state and this Court’s District, and because they committed sufficient and specific acts in this state, namely, sexual harassment and discrimination. 6. Plaintiff began working for Corporate Defendant in the position of ____________ (title of position) on ___________________ (date) . Individual Defendant, ___________________ (Name of Defendant) , was Plaintiff's Supervisor. 7. ___________________ (Name of Individual Defendant) continuously and consistently made improper and lewd sexual comments and remarks both to and about Plaintiff, and otherwise created a hostile working environment for Plaintiff because of Plaintiff's gender. The environment because so severe that Plaintiff was forced to _____________________________________________________________________ (description of defensive actions) for her own protection from __________________ (Name of Individual Defendant) , and eventually was forced to resign her position and, thus, was constructively discharged. Plaintiff made Individual Defendant aware that she did not approve of his conduct, but individual Defendant continued to act in the same manner. Some examples of the conduct which created the hostile work environment are: ________________________________________________________________ (list and describe harassing conduct) . Plaintiff filed a charge of discrimination with the Equal Employment Opportunity Commission (EEOC) and received a ____________ (favorable or unfavorable) determination. A true and correct copy of the Right to Sue Letter issued to Plaintiff is attached hereto as Exhibit A. All other prerequisites to filing this suit have been met. 8. The facts previously set out give rise to a cause of action for discrimination as set forth in Title VII. According to Title VII, it is unlawful for an employer to discriminate against an employee on the basis of gender, or to otherwise create a hostile work environment for women. Corporate Defendant had no written policy dealing with sexual harassment. 9. Defendants, _______________________ (Name of Corporation) and ______________________ (Name of individual Defendant) discriminated against Plaintiff by creating and allowing a hostile work environment because of Plaintiff's gender. Corporate Defendant knew or reasonably should have known of the Supervisor's conduct. Plaintiff has been injured because of this discrimination for which Plaintiff seeks relief. 10. Plaintiff has suffered damages because of the actions and inaction of the Defendants. Defendants' conduct proximately caused Plaintiff to suffer severe emotional distress, mental anguish, indignation, wounded pride, shame, and despair. Plaintiff has had the following physical and emotional injuries: ____________________________ _____________________________________________________________________ (list and description of injuries) . In addition to these injuries, Defendants' conduct has proximately caused Plaintiff to suffer pecuniary losses and lost employment opportunities. 11. The conduct of Individual Defendant described in this Complaint was willful and malicious so as to entitle the Plaintiff to recover exemplary damages to punish Defendants and to deter such conduct in the future. Plaintiff will show that, as a result of Defendants' conduct, Plaintiff has suffered loss of time and expenses, including reasonable attorneys fees incurred in this investigation and prosecution of this action. Accordingly, Plaintiff asks that exemplary damages be awarded against Defendants. WHEREFORE, Plaintiff requests that Defendants be cited to appear in this action, and that after trial by jury, a judgment be entered granting Plaintiff the following: 1. Actual damages according to proof; 2. Punitive damages according to proof; 3. Mental anguish damages according to proof; 4. Pre-judgment and post-judgment interest at the legal rate; 5. Reasonable attorney's fees and costs of court; and 6. Such other and further relief, both general and special, at law and in equity, to which Plaintiff is justly entitled. Respectfully submitted, _______________________________ (Name of Plaintiff) By: _______________________________ (Name of Plaintiff’s Attorney) State Bar No. _____________ Her Attorney OF COUNSEL: (Name of Plaintiff’s Attorney ) _______________________ Post Office Box ________________ (City, State, Zip Code ) _______________________ (Telephone) _________________