[COURT NAME]
[COUNTY], [STATE]

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

COMPLAINT FOR WRONGFUL TERMINATION

1. Parties

1.1 Plaintiff [PLAINTIFF NAME] was employed by Defendant from [DATE] to [DATE].
1.2 Defendant [DEFENDANT NAME] is an employer doing business in [STATE].

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 termination occurred here.

3. Factual Allegations

3.1 Plaintiff performed job duties satisfactorily.
3.2 Plaintiff engaged in protected activity and/or refused to engage in unlawful conduct.
3.3 Defendant terminated Plaintiff on [DATE] for reasons that violate public policy and applicable law.

4. Cause of Action - Wrongful Termination in Violation of Public Policy

4.1 Plaintiff realleges the foregoing paragraphs.
4.2 Defendant terminated Plaintiff for reasons that contravene [PUBLIC POLICY/STATUTE].

5. Cause of Action - Breach of Implied Contract (Optional)

5.1 Defendant created an implied contract of continued employment through policies and practices.
5.2 Defendant breached the implied contract without good cause.

6. Cause of Action - Retaliation (Optional)

6.1 Defendant retaliated against Plaintiff for engaging in protected activity.

7. Damages

7.1 Plaintiff seeks back pay, front pay, benefits, emotional distress damages, and attorney fees where allowed.

8. Prayer for Relief

Plaintiff requests judgment against Defendant as follows:
a. Back pay and front pay.
b. Compensatory damages and statutory penalties where allowed.
c. Attorney fees and costs.
d. Injunctive or declaratory relief.
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