New Jersey Verified Complaint and Jury Demand

Verified Complaint and Jury Demand

JOHN LAWYER, ESQ.

12 MAIN STREET

ANYWHERE, USA

Attorneys for Plaintiff

____________________________

Plaintiff, Jane Doe, maintaining her principal residence at , by way of Complaint against the Defendant, says:

THE PARTIES

1. The plaintiff Jane Doe is a United States Citizens and a resident of County.

2. The defendant ABC, Inc., upon information and belief, is a Corporation lawfully doing business in the State of and maintaining its principal place of business at , and is licensed to do business in this State. Upon further information and belief defendant ABC, Inc. is in the medical equipment manufacturing business specializing in X-Ray machines.

3. The defendant ABC Medical, Inc., upon information and belief, is a Corporation lawfully doing business in the State of and maintaining its principal place of business at and is licensed to do business in this State. Upon further information and belief defendant ABC Medical, Inc. is in the medical treatment business specializing in X-Ray machines.

4. The defendant ABC X-Ray, Inc., upon information and belief, is a Corporation lawfully doing business in the State of and maintaining its principal place of business at , and is licensed to do business in this State. Upon further information and belief defendant ABC Medical, Inc. is in the medical

FIRST COUNT

5. Plaintiff was hired by defendant on or about . At all relevant times, plaintiff was the defendant=s Bookkeeper.

6. Throughout plaintiff=s employment with defendant she received consistent praise for her good work along with annual performance bonuses and raises.

7. On or about , plaintiff=s employment was terminated.

8. Plaintiff was told that her employment was being terminated because her employer felt that she should Aspend more time with her children.@

9. Upon information and belief, plaintiff was replaced by another worker making approximately one-half her then salary.

10. At the time of her termination, plaintiff was approximately month=s pregnant.

11. Previously, prior to her termination, plaintiff had told defendant about her pregnancy.

12. The reasons stated for plaintiff=s termination are without merit and cannot be substantiated by defendant. The reasons given by defendant for plaintiff=s termination were a pretext for the real reason, which is plaintiff=s pregnancy.

13. By terminating plaintiff, defendant denied equal employment opportunities to plaintiff because of her pregnancy.

14. As a direct and proximate result of defendant=s termination of plaintiff, plaintiff was deprived of her employment and equal employment opportunities because of her pregnancy.

15. As a further direct and proximate result of defendant=s termination of plaintiff, plaintiff has been deprived of income and wages, and has been deprived of valuable pension benefits as well as payment for a substantial amount of overtime which has not been compensated to plaintiff. Plaintiff has also lost payment of unused personal days and bonus earnings including stock options which were promised to her.

16. As a further result of defendant=s termination of plaintiff, plaintiff has suffered severe humiliation, embarrassment and emotional distress.

17. Plaintiff has suffered and will continue to suffer injuries as a result of defendant=s wrongful and discriminatory acts.

18. The foregoing actions of the defendants violate New Jersey=s Law Against Discrimination, codified at N.J.S.A. 10:5-1 et seq., which prohibits discrimination against women because of pregnancy.

WHEREFORE, plaintiff demands judgment against the defendant for compensatory damages, including damages for front pay, back pay, bonuses and personal days, lost pension benefits, unpaid overtime, emotional distress, consequential damages, punitive damages, pre- and post-judgment interest, reasonable attorneys= fees multiplied under the Law Against Discrimination, and costs of suit.

SECOND COUNT

19. Plaintiff repeats the foregoing allegations as if same were repeated at length herein.

20. The foregoing actions of the defendants violate Title VII of the Civil Rights Act of 1964, as amended, which prohibit, discrimination on the basis of sex.

WHEREFORE, plaintiff demands judgment against the defendants for compensatory damages, including damages for front pay, back pay, bonuses and personal days, lost pension benefits, unpaid overtime, emotional distress, consequential damages, punitive damages, pre- and post-judgment interest, reasonable attorney=s fees, and costs of suit.

DESIGNATION OF TRIAL COUNSEL

John Lawyer, Esq., is hereby designated as trial counsel in this matter.

JURY DEMAND

The plaintiff hereby demands a jury as to all issues.

DEMAND FOR PRODUCTION OF INSURANCE AGREEMENTS

Pursuant to R. 4:10-2(b), demand is hereby made that you disclose to the undersigned whether there are any insurance agreements or policies under which any person or firm carrying on an insurance business may be liable to satisfy all or part of a judgment which may be entered in the action or to indemnify or reimburse for payment made to satisfy the judgment. If so, please attach a copy of each, or in the alternative state, under oath and certification: (a) policy number; (b) name and address of insurer; c) inception and expiration date: (d) names and addresses of all persons insured thereunder; (e) personal injury limits; (f) property damage limits; and (g) medical payment limits.

CERTIFICATION PURSUANT TO R. 4:5-1

I hereby certify the matters in controversy in this action are not the subject of any other action pending in any other court or of a pending arbitration proceeding, and that no other action or arbitration proceeding is contemplated.

VERIFICATION

STATE OF NEW JERSEY : ss.:

COUNTY OF :

Jane Doe, of full age, being duly sworn, according to law, upon his oath deposes and says:

1. I am the plaintiff in the foregoing Complaint.

2. I hereby certify that the allegations contained in the foregoing Complaint are true to the best of my knowledge and belief. I am aware that if any statements made by me are willfully false, I am subject to punishment.

John Lawyer, An

Attorney At Law In The State Of New Jersey