[COURT NAME]
[COUNTY], [STATE]

[PLAINTIFF NAME], )
Plaintiff, )
) Case No. [CASE NUMBER]
v. )
)
[DEFENDANT NAME], )
Defendant. )

COMPLAINT FOR EMPLOYMENT DISCRIMINATION

1. Parties

1.1 Plaintiff [PLAINTIFF NAME] is a resident of [STATE].
1.2 Defendant [DEFENDANT NAME] is an employer doing business in [STATE] with [NUMBER] employees.

2. Jurisdiction and Venue

2.1 This Court has jurisdiction under [STATUTE].
2.2 Venue is proper in [COUNTY] because Plaintiff worked here and the discriminatory acts occurred here.

3. Administrative Exhaustion

3.1 Plaintiff filed a charge with [EEOC/STATE AGENCY] on [DATE].
3.2 A right-to-sue notice was issued on [DATE], and this action is timely.

4. Factual Allegations

4.1 Plaintiff is a member of a protected class: [PROTECTED CLASS].
4.2 Plaintiff performed job duties satisfactorily.
4.3 Defendant subjected Plaintiff to adverse actions, including [ACTIONS].
4.4 Defendant's actions were motivated by discriminatory and/or retaliatory intent.

5. Cause of Action - Discrimination

5.1 Plaintiff realleges the foregoing paragraphs.
5.2 Defendant discriminated against Plaintiff in violation of [TITLE VII/ADA/ADEA/STATE LAW].

6. Cause of Action - Retaliation (Optional)

6.1 Plaintiff engaged in protected activity by [COMPLAINT/REPORT].
6.2 Defendant took adverse action because of Plaintiff's protected activity.

7. Damages

7.1 Plaintiff seeks back pay, front pay, compensatory damages, punitive damages where permitted, and attorney fees.

8. Prayer for Relief

Plaintiff requests judgment against Defendant as follows:
a. Back pay, front pay, and lost benefits.
b. Compensatory and punitive damages where allowed.
c. Attorney fees and costs.
d. Injunctive relief as appropriate.
e. Any other relief the Court deems just.

9. Jury Demand

Plaintiff demands a trial by jury on all issues so triable.

10. Signature Block

text
Dated: [DATE]

______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for Plaintiff