Fill and Sign the Unpaid Wages Form

IN THE ___________COURT OF ___________ (County), ___________ (State) ________________ (Name of Plaintiff) PLAINTIFFV. CAUSE NO. _____,______________________ (Name of Defendant) DEFENDANT COMPLAINT COMES NOW ________________ (Name of Plaintiff) , Plaintiff in the above- styled and numbered cause, by and through his attorney, and files this Complaint against Defendant, ________________ (Name 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. Defendant, __________________ (Name of Defendant) , is, and at all times mentioned in this Complaint was, a corporation organized and existing under the laws of ________________ (name of state), with its principal place of business located at ________________ (street address of business), ________________ (name of city), ________________ (name of county), ________________ (name of state).3. Plaintiff was employed by Defendant under a contract of employment that was partly oral and partly implied. The terms of the contract provided that Plaintiff was to be paid $________ per ________________ (e.g., monthly) for serving as ________________ (name or title of job) for Defendant. 4. On ________________ (date of termination) , Defendant terminated Plaintiff's employment. At the time of Plaintiff's termination, Plaintiff had accrued unpaid wages in the amount of $_____________.5. In violation of Plaintiff’s contract, Defendant failed to pay Plaintiff any of the amounts of wages due and owing Plaintiff. Although Plaintiff has demanded payment, Defendant has refused and continues to refuse to pay Plaintiff the amount due and owing Plaintiff.6. Defendant’s failure to pay Plaintiff the wages due and owing Plaintiff as specified above was and has been willful in that Plaintiff has made both verbal and written demands for this payment but Defendant has refused to pay any part of the amount due and owing Plaintiff. Wherefore, Plaintiff requests judgment against Defendant for: 1. Compensatory damages in the amount of $_____________, representing wages and other compensation earned by and owed to Plaintiff on ________________ (due date of payment);2. Interest on the amount of $__________ from ________________ (date);3. Reasonable attorney's fees;4. Costs of suit; 5. Punitive damages in the amount of $__________.6. Such other and further relief as the Court considers just and proper.Respectfully submitted, _______________________________ (Name of Plaintiff)By: _______________________________ (Name of Plaintiff’s Attorney) State Bar No. _____________ His Attorney OF COUNSEL: _______________________________ (Name of Plaintiff’s Attorney)Post Office Box ___________________________________________ (City, State, Zip Code)Telephone: _________________