EMPLOYMENT DISCRIMINATION DEMAND LETTER

District of Columbia

DC Human Rights Act and Federal Anti-Discrimination Claims

[ATTORNEY/FIRM LETTERHEAD]

[Firm Name]
[Address Line 1]
[Washington, DC ZIP]
Tel: [Phone Number]
Fax: [Fax Number]
[Attorney Email]
[DC 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]
DC OHR Complaint No.: [Number, if filed]
EEOC Charge No.: [Number, if filed]
Position: [Job Title]
CONFIDENTIAL SETTLEMENT COMMUNICATION PURSUANT TO FRE 408

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 District of Columbia Human Rights Act (DCHRA), D.C. Code § 2-1401.01 et seq., and federal anti-discrimination statutes.

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

I. DISTRICT OF COLUMBIA LEGAL FRAMEWORK

A. DC Human Rights Act (DCHRA)

The District of Columbia provides the most expansive employment discrimination protections in the nation through the DCHRA. DC is a deferral jurisdiction with the EEOC.

Coverage:
- ALL employers regardless of size (even 1 employee)
- District government employers
- Employment agencies and labor organizations

Protected Classes Under DC Law (Most Extensive in U.S.):

B. Key DC-Specific Protections

1. Universal Coverage:
- DCHRA covers ALL employers (even with just 1 employee)
- No minimum employee threshold

2. Unique Protections (Not Found in Most Jurisdictions):
- Personal appearance (grooming, dress, physical appearance)
- Matriculation (student/enrollment status)
- Political affiliation
- Credit information (cannot discriminate based on credit)
- Homeless status
- Age protection starts at 18 (not 40)

3. No Administrative Exhaustion Required:
- May file directly in DC Superior Court
- No requirement to file with OHR first
- 1-year statute of limitations for direct filing

4. No Damage Caps:
- DCHRA imposes no caps on compensatory or punitive damages
- Unlimited recovery potential

C. Administrative Exhaustion (Optional)

DC Office of Human Rights (OHR):

OHR Contact Information:
- DC Office of Human Rights
- 441 4th Street NW, Suite 570N
- Washington, DC 20001
- Phone: (202) 727-4559
- Website: ohr.dc.gov

EEOC Filing (Federal Claims):

II. PROTECTED CLASS STATUS

A. Client's Protected Class

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

[ ] Race: [Specify]
[ ] Color: [Specify]
[ ] Religion: [Specify]
[ ] National Origin: [Specify]
[ ] Sex: [Specify, including pregnancy, childbirth, breastfeeding]
[ ] Age: [Specify - protected at 18+]
[ ] Marital Status: [Specify]
[ ] Personal Appearance: [Specify]
[ ] Sexual Orientation: [Specify]
[ ] Gender Identity or Expression: [Specify]
[ ] Family Responsibilities: [Specify]
[ ] Genetic Information: [Specify]
[ ] Disability: [Specify condition]
[ ] Matriculation: [Specify student status]
[ ] Political Affiliation: [Specify]
[ ] Credit Information: [Specify]
[ ] Victim Status: [DV/sexual offense/stalking]
[ ] Homeless Status: [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]
[ ] Termination: [Describe]
[ ] Demotion: [Describe]
[ ] Failure to Promote: [Describe]
[ ] Hostile Work Environment: [Describe]
[ ] Unequal Pay: [Describe]
[ ] Denial of Accommodation: [Describe]
[ ] Retaliation: [Describe]
[ ] Harassment: [Describe]
[ ] Credit Check Discrimination: [Describe]
[ ] Personal Appearance Discrimination: [Describe]
[ ] Other: [Describe]

C. Timeline of Events

D. Discriminatory Intent / Disparate Treatment

1. Direct Evidence:
- [Describe any discriminatory statements or communications]

2. Circumstantial Evidence:
- [Describe disparate treatment of similarly situated employees]

3. Pretext:
- [Describe evidence that employer's stated reason is pretextual]

IV. LEGAL CLAIMS

A. Violation of DC Human Rights Act (D.C. Code § 2-1402.11)

[Company Short Name] violated the DCHRA by discriminating against our client based on [his/her/their] [protected class]. Under D.C. Code § 2-1402.11, it is an unlawful discriminatory practice:

"to fail or refuse to hire, or to discharge, any individual; or otherwise to discriminate against any individual, with respect to his compensation, terms, conditions, or privileges of employment, including promotion; or to limit, segregate, or classify employees in any way which would deprive or tend to deprive any individual of employment opportunities, or otherwise adversely affect his status as an employee" based on a protected characteristic.

B. Hostile Work Environment (If Applicable)

The discriminatory conduct was severe or pervasive enough to create a hostile work environment.

C. Retaliation (D.C. Code § 2-1402.61)

[If applicable:] [Company Short Name] retaliated against our client for engaging in protected activity.

D. Failure to Accommodate (If Applicable)

[Company Short Name] failed to provide reasonable accommodation for our client's disability.

V. DAMAGES

A. Economic Damages

B. Compensatory Damages

Compensatory Damages: $[Amount]

Note: DCHRA imposes NO CAPS on compensatory damages.

C. Punitive Damages

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

Punitive Damages: $[Amount]

Note: DCHRA imposes NO CAPS on punitive damages.

D. Attorney's Fees and Costs

Under D.C. Code § 2-1403.16(a) 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

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

[ ] DC OHR Complaint filed on [Date]
[ ] EEOC Charge filed on [Date]
[ ] Right to Sue obtained on [Date]
[ ] No administrative filing — proceeding directly to court

B. Litigation Venue

[ ] DC Superior Court (state-equivalent claims)
[ ] United States District Court for the District of Columbia (federal claims)

VIII. DOCUMENT PRESERVATION

LITIGATION HOLD NOTICE — Preserve all relevant documents and ESI.

IX. CONFIDENTIALITY

This letter is protected under FRE 408.

Sincerely,

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

cc: [Client Name]

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

Key DC Considerations

[ ] Most Protective Jurisdiction: Broadest protected classes in U.S.

[ ] Universal Coverage: ALL employers (even 1 employee)

[ ] No Exhaustion Required: Can file directly in DC Superior Court

[ ] 1-Year Filing Deadline: For both OHR and direct court filing

[ ] No Damage Caps: Unlimited compensatory and punitive damages

[ ] Unique Protections: Personal appearance, matriculation, political affiliation, credit, homeless status

[ ] Age Protection Starts at 18: Much broader than federal (40+)

Agency Contact Information

DC Office of Human Rights:
- 441 4th Street NW, Suite 570N
- Washington, DC 20001
- Phone: (202) 727-4559
- Website: ohr.dc.gov

EEOC Washington Field Office:
- 131 M Street NE
- Washington, DC 20507
- Phone: (800) 669-4000

Statute of Limitations