EMPLOYMENT DISCRIMINATION DEMAND LETTER

State of Connecticut

Connecticut Fair Employment Practices Act and Federal Anti-Discrimination Claims

[ATTORNEY/FIRM LETTERHEAD]

[Firm Name]
[Address Line 1]
[City, Connecticut ZIP]
Tel: [Phone Number]
Fax: [Fax Number]
[Attorney Email]
[Connecticut Bar Number]

VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED
AND VIA EMAIL TO: [recipient_email]

[Date]

[Employer Contact Name]
[Title]
[Company Legal Name]
[Company Address]
[City, State ZIP]

Copy to:
[Company General Counsel, if known]
[Registered Agent, if different]

Re: Employment Discrimination Claim of [Client Full Name]
CHRO Complaint No.: [Number, if filed]
EEOC Charge No.: [Number, if filed]
Position: [Job Title]
CONFIDENTIAL SETTLEMENT COMMUNICATION PURSUANT TO FRE 408 / CONN. CODE EVID. § 4-8

Dear [Mr./Ms./Mx. Last Name]:

This firm represents [Client Full Name] ("our client") regarding [his/her/their] claims of unlawful employment discrimination against [Company Legal Name] ("[Company Short Name]" or "the Company"). Our client has been subjected to discrimination based on [his/her/their] [protected class] in violation of the Connecticut Fair Employment Practices Act (CFEPA), Connecticut General Statutes Section 46a-51 et seq., and federal anti-discrimination statutes.

Please direct all further communications regarding this matter to our office.

I. CONNECTICUT LEGAL FRAMEWORK

A. Connecticut Fair Employment Practices Act (CFEPA)

Connecticut provides comprehensive employment discrimination protections through CFEPA. Connecticut is a deferral state with a strong state civil rights agency.

Coverage:
- Private employers with 3 or more employees (broader than federal)
- State and local government employers
- Employment agencies and labor organizations

Protected Classes Under Connecticut Law:

B. Key Connecticut-Specific Protections

1. Broader Coverage:
- CFEPA covers employers with only 3 employees (vs. 15 for Title VII)
- No upper age limit for age discrimination claims

2. Unique Protections:
- Learning disability as distinct category
- Intellectual disability as distinct category
- Past history of mental disability
- Victim of domestic violence status

3. No Damage Caps:
- CFEPA imposes no caps on compensatory or punitive damages

C. Federal Anti-Discrimination Laws

1. Title VII of the Civil Rights Act of 1964
- Coverage: Employers with 15 or more employees
- EEOC Filing Deadline: 300 days in Connecticut (deferral state)

2. Age Discrimination in Employment Act
- Coverage: Employers with 20 or more employees
- EEOC Filing Deadline: 300 days in Connecticut

3. Americans with Disabilities Act
- Coverage: Employers with 15 or more employees
- EEOC Filing Deadline: 300 days in Connecticut

D. Administrative Exhaustion Requirements

Connecticut Commission on Human Rights and Opportunities (CHRO):

CHRO Contact Information:
- Connecticut Commission on Human Rights and Opportunities
- 450 Columbus Boulevard, Suite 2
- Hartford, CT 06103
- Phone: (860) 541-3400
- Website: portal.ct.gov/CHRO

EEOC Filing (Cross-Filed with CHRO):

II. PROTECTED CLASS STATUS

A. Client's Protected Class

Our client is a member of the following protected class(es):

[ ] Race: [Specify]
[ ] Color: [Specify]
[ ] Religious Creed: [Specify]
[ ] Sex: [Specify, including pregnancy]
[ ] Gender Identity or Expression: [Specify]
[ ] Sexual Orientation: [Specify]
[ ] Marital Status: [Specify]
[ ] National Origin: [Specify]
[ ] Ancestry: [Specify]
[ ] Age: [Specify]
[ ] Physical Disability: [Specify - present or past history]
[ ] Mental Disability: [Specify - present or past history]
[ ] Learning Disability: [Specify]
[ ] Intellectual Disability: [Specify]
[ ] Genetic Information: [Specify]
[ ] Veteran Status: [Specify]
[ ] Victim of Domestic Violence: [Specify]

B. Evidence of Protected Class Status

[Describe documentation or evidence establishing membership in the protected class]

III. FACTUAL BACKGROUND

A. Employment Relationship

B. Summary of Discriminatory Conduct

Our client was subjected to the following adverse employment action(s):

[ ] Failure to Hire: [Describe circumstances]
[ ] Termination: [Describe circumstances]
[ ] Demotion: [Describe circumstances]
[ ] Failure to Promote: [Describe circumstances]
[ ] Hostile Work Environment: [Describe conduct]
[ ] Unequal Pay: [Describe disparity]
[ ] Denial of Accommodation: [Describe request and denial]
[ ] Retaliation: [Describe protected activity and adverse action]
[ ] Harassment: [Describe conduct]
[ ] Other: [Describe]

C. Timeline of Events

D. Discriminatory Intent / Disparate Treatment

1. Direct Evidence of Discrimination:
- [Describe any discriminatory statements, comments, or written communications]

2. Circumstantial Evidence / Disparate Treatment:
- [Describe how similarly situated employees outside the protected class were treated more favorably]

3. Pretext:
The stated reason—[state employer's justification]—is pretextual, as evidenced by:
- [Describe inconsistencies in employer's explanation]

E. Comparator Evidence

IV. LEGAL CLAIMS

A. Violation of Connecticut CFEPA (Conn. Gen. Stat. § 46a-60)

[Company Short Name] violated CFEPA by discriminating against our client based on [his/her/their] [protected class]. Under Conn. Gen. Stat. § 46a-60(b)(1), it is a discriminatory employment practice:

"For an employer... to refuse to hire or employ or to bar or to discharge from employment any individual or to discriminate against such individual in compensation or in terms, conditions or privileges of employment because of the individual's race, color, religious creed, age, sex, gender identity or expression, marital status, national origin, ancestry, present or past history of mental disability, intellectual disability, learning disability, physical disability..."

B. Hostile Work Environment

[If applicable:] The discriminatory conduct was severe or pervasive enough to create a hostile work environment.

C. Retaliation (Conn. Gen. Stat. § 46a-60(b)(4))

[If applicable:] [Company Short Name] retaliated against our client:

Protected Activity: [Describe complaint, CHRO filing, participation]
Adverse Action: [Describe retaliatory action]
Causal Connection: [Describe evidence]

D. Failure to Accommodate (If Applicable)

[Company Short Name] failed to provide reasonable accommodation:

Disability: [Describe qualifying disability]
Requested Accommodation: [Describe]
Interactive Process: [Describe]
Denial: [Describe]

V. DAMAGES

A. Economic Damages

1. Back Pay

2. Lost Benefits

3. Front Pay

B. Compensatory Damages

Our client has suffered significant emotional distress.

Compensatory Damages: $[Amount]

Note: Connecticut CFEPA imposes NO CAPS on compensatory damages.

C. Punitive Damages

[Company Short Name]'s conduct was willful and in reckless disregard of our client's rights, warranting punitive damages.

Connecticut Standard: Punitive damages available for reckless indifference to rights. No statutory cap under CFEPA.

Punitive Damages Requested: $[Amount]

D. Attorney's Fees and Costs

Under Conn. Gen. Stat. § 46a-104 and 42 U.S.C. § 2000e-5(k), our client is entitled to reasonable attorney's fees and costs.

Estimated Fees and Costs: $[Amount]

E. Summary of Damages

VI. SETTLEMENT DEMAND

Based on the foregoing, we demand that [Company Short Name] pay $[Settlement Demand Amount] to settle all claims.

This demand will remain open for twenty-one (21) calendar days, expiring on [Response Deadline Date].

VII. ADMINISTRATIVE STATUS AND LITIGATION POSTURE

A. Agency Filing Status

[ ] CHRO Complaint filed on [Date] — Complaint No. [Number]
[ ] EEOC Charge filed on [Date] — Charge No. [Number]
[ ] Release of Jurisdiction obtained on [Date]

B. Litigation Venue

If suit is filed, we anticipate filing in:

[ ] Connecticut Superior Court, [Judicial District]
[ ] United States District Court for the District of Connecticut

VIII. DOCUMENT PRESERVATION

LITIGATION HOLD NOTICE

[Company Short Name] must immediately preserve all relevant documents and ESI.

IX. CONFIDENTIALITY

This letter is a confidential settlement communication protected under Federal Rule of Evidence 408 and Connecticut Code of Evidence Section 4-8.

Sincerely,

[Attorney Name]
[Title]
[Firm Name]
[Connecticut Bar No.]

Enclosures:
[ ] Authorization to Represent
[ ] CHRO Complaint (if filed)

cc: [Client Name] (via email)

CONNECTICUT-SPECIFIC PRACTICE NOTES (Do Not Include in Final Letter)

Key Connecticut Considerations

[ ] Deferral State: 300-day filing deadline for both CHRO and EEOC

[ ] Mandatory CHRO Filing: Must file with CHRO before state court suit

[ ] Broad Coverage: CFEPA covers employers with 3+ employees

[ ] No Damage Caps: Unlike Title VII, CFEPA has no caps

[ ] Learning/Intellectual Disability: Distinct protected categories

[ ] Past Mental Disability: Protected even if no longer has condition

[ ] Domestic Violence Victims: Unique Connecticut protection

Agency Contact Information

Connecticut Commission on Human Rights and Opportunities:
- 450 Columbus Boulevard, Suite 2
- Hartford, CT 06103
- Phone: (860) 541-3400
- Website: portal.ct.gov/CHRO

EEOC Boston Area Office (Serves Connecticut):
- Phone: (800) 669-4000

Statute of Limitations Summary