EMPLOYMENT DISCRIMINATION DEMAND LETTER

State of Kansas

Kansas Act Against Discrimination and Federal Anti-Discrimination Claims

[ATTORNEY/FIRM LETTERHEAD]

[Firm Name]
[Address Line 1]
[City, Kansas ZIP]
Tel: [Phone Number]
Fax: [Fax Number]
[Attorney Email]
[Kansas 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]
KHRC Complaint No.: [Number, if filed]
EEOC Charge No.: [Number, if filed]
Position: [Job Title]
CONFIDENTIAL SETTLEMENT COMMUNICATION PURSUANT TO FRE 408 / K.S.A. 60-452

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 Kansas Act Against Discrimination (K.S.A. 44-1001 et seq.) and federal anti-discrimination statutes.

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

I. KANSAS LEGAL FRAMEWORK

A. Kansas Act Against Discrimination (KAAD)

Kansas provides employment discrimination protections through the Kansas Act Against Discrimination. Kansas is a deferral state with a work-sharing agreement with the EEOC.

Coverage:
- Private employers with 4 or more employees (broader than federal)
- State and local government employers
- Employment agencies and labor organizations

Protected Classes Under Kansas Law:

Note: Kansas does NOT protect sexual orientation or gender identity under state law.

B. Key Kansas-Specific Features

1. Short Filing Deadline:
- KHRC complaint deadline is only 6 months (180 days) from discriminatory act

2. Age Limits:
- State law protects ages 40-70 (vs. ADEA's 40+ with no upper limit)

3. Coverage:
- Covers employers with 4 or more employees

C. Administrative Exhaustion Requirements

Kansas Human Rights Commission (KHRC):

KHRC Contact Information:
- Kansas Human Rights Commission
- 900 SW Jackson, Suite 568-S
- Topeka, KS 66612
- Phone: (785) 296-3206
- Website: khrc.net

EEOC Filing (Cross-Filed with KHRC):

II. PROTECTED CLASS STATUS

A. Client's Protected Class

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

[ ] Race: [Specify]
[ ] Religion: [Specify]
[ ] Color: [Specify]
[ ] Sex: [Specify, including pregnancy]
[ ] National Origin: [Specify]
[ ] Ancestry: [Specify]
[ ] Age: [Specify - 40-70 for state; 40+ for federal]
[ ] Disability: [Specify condition]
[ ] Military Status: [Specify]
[ ] Genetic Information: [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]

C. Timeline of Events

D. Discriminatory Intent / Disparate Treatment

[Describe direct and circumstantial evidence of discrimination]

IV. LEGAL CLAIMS

A. Violation of Kansas Act Against Discrimination (K.S.A. 44-1009)

[Company Short Name] violated KAAD by discriminating against our client based on [his/her/their] [protected class].

B. Federal Claims (Title VII / ADEA / ADA)

Our client also asserts federal discrimination claims.

C. Retaliation (K.S.A. 44-1009(a)(6))

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

V. DAMAGES

A. Economic Damages

B. Compensatory Damages

Compensatory Damages: $[Amount]

C. Punitive Damages

Title VII Damage Caps:

Punitive Damages: $[Amount]

D. 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

[ ] KHRC Complaint filed on [Date]
[ ] EEOC Charge filed on [Date]
[ ] Right to Sue obtained on [Date]

B. Litigation Venue

[ ] Kansas District Court, [County] County
[ ] United States District Court for the District of Kansas

VIII. DOCUMENT PRESERVATION

LITIGATION HOLD NOTICE — Preserve all relevant documents and ESI.

Sincerely,

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

cc: [Client Name]

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

Key Kansas Considerations

[ ] Deferral State: 300-day EEOC deadline; 180-day KHRC deadline

[ ] Short State Deadline: Only 6 months (180 days) for KHRC

[ ] No Sexual Orientation/Gender Identity: Not protected under state law

[ ] Age Limits: State protects only ages 40-70; ADEA has no upper limit

[ ] Broader Coverage: KAAD covers employers with 4+ employees

Agency Contact Information

Kansas Human Rights Commission:
- 900 SW Jackson, Suite 568-S
- Topeka, KS 66612
- Phone: (785) 296-3206
- Website: khrc.net

EEOC Kansas City Area Office:
- Phone: (800) 669-4000

Statute of Limitations