UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF CALIFORNIA JOHN DOE, ) ) Plaintiff, ) vs. ) COMPLAINT REGARDING ) UNFAIR EMPLOYMENT PRACTICES ANY COMPANY, U.S.A., ) ) ) Civ. No. Defendant. ) ) COMPLAINT Comes now the Plaintiff(s), and for cause of action against the Defendant(s), and each of them, complains and alleges as follows: 1.This cause of action arises, and jurisdiction of the Office of the Chief Administrative Hearing Officer is invoked, under 8 U.S.C. 1324b.2.( Complainant, include address ) is[a United States citizen],[a United States national], OR[an alien authorized to be employed in the United States] who has been employed by (Respondent ) at all times relevant hereto, and is of ____________ national origin.2A.( Complainant, include address ) is a[citizen],[national], OR[intending citizen] of the United States of America, as defined by 8 U.S.C. 1324b(a)(3).3.( Respondent, include address ) is a person or entity employing more than three employees on the date of the alleged discriminatory act(s) and is subject to the jurisdiction of the Offrice of the Chief Administrative Hearing Officer.4.On or about ( date ), (the Complainant )[applied for] OR[worked in] the position of (describe job ), at (Respondent's office ) located at (address ).5.( The Complainant ), was qualified for the position of (describe position ),[for which (Respondent ) was seeking applicants.] OR[from which (Complainant ) was dismissed.]6.On or about ( date ), (the Respondent ) knowingly and intentionally[fired] OR[refused to hire] (Complainant ) because of his/her[citizenship status] OR[ ____________ national origin] in violation of 8 U.S.C. 1324b.7.[After] OR[Although] ( Complainant ) was[refused employment] OR[fired],[the position remained open and (Respondent ) continued to seek applications from individuals with ( Complainant's ) qualifications.] OR[similarly situated individuals of a different citizenship status (or national origin) were not fired.]8.On ( date ), the (Complainant ) filed a written charge with the Office of Special Counsel. The Office of Special Counsel has[not filed a complaint with respect to this charge as of this date, which is more than 120 days since the charge was received by the Office of Special Counsel.] OR[notified the (Complainant ) by written communication, a copy of which is attached, that the Office of Special Counsel will not file a complaint based on the aforesaid charge.] WHEREFORE, Complainant respectfully requests:A. That the Office of the Chief Administrative Hearing Officer serve a copy of the Complaint on the Respondent and assign an Administrative Law Judge to preside at a hearing as soon as practicable;B. That the Administrative Law Judge grant the following relief: 1.That ( Respondent ) cease and desist from the discriminatory practices;2.That ( Respondent ) be required to[hire] OR[reemploy] (Complainant ) for ____________ position[with] OR[without] back pay from ( date ).3.The ( Complainant ) respectfully requests reasonable attorney's fees and any other appropriate relief. DATED this ____ day of June, 2008. Jane Smith, Esq. D.C. Bar No. 420557 950 Pennsylvania Avenue, N.W. Washington, D.C. 20530-0001 Attorneys for Plaintiffs,
UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF CALIFORNIA
JOHN DOE, )
)
Plaintiff, )
vs. ) COMPLAINT REGARDING
) UNFAIR EMPLOYMENT PRACTICES
ANY COMPANY, U.S.A., ) )
) Civ. No.
Defendant. )
COMPLAINT
Comes now the Plaintiff(s), and for cause of action against the Defendant(s), and each of them, complains and alleges as follows:
1.This cause of action arises, and jurisdiction of the Office of the Chief Administrative Hearing Officer is invoked, under 8 U.S.C. 1324b.2.( Complainant, include address ) is[a United States citizen],[a United States national], OR[an alien authorized to be employed in the United States] who has been employed by (Respondent ) at all times relevant hereto, and is of ____________ national origin.2A.( Complainant, include address ) is a[citizen],[national], OR[intending citizen] of the United States of America, as defined by 8 U.S.C. 1324b(a)(3).3.( Respondent, include address ) is a person or entity employing more than three employees on the date of the alleged discriminatory act(s) and is subject to the jurisdiction of the Offrice of the Chief Administrative Hearing Officer.4.On or about ( date ), (the Complainant )[applied for] OR[worked in] the position of (describe job ), at (Respondent's office ) located at (address ).5.( The Complainant ), was qualified for the position of (describe position ),[for which (Respondent ) was seeking applicants.] OR[from which (Complainant ) was dismissed.]6.On or about ( date ), (the Respondent ) knowingly and intentionally[fired] OR[refused to hire] (Complainant ) because of his/her[citizenship status] OR[ ____________ national origin] in violation of 8 U.S.C. 1324b.7.[After] OR[Although] ( Complainant ) was[refused employment] OR[fired],[the position remained open and (Respondent ) continued to seek applications from individuals with ( Complainant's ) qualifications.] OR[similarly situated individuals of a different citizenship status (or national origin) were not fired.]8.On ( date ), the (Complainant ) filed a written charge with the Office of Special Counsel. The Office of Special Counsel has[not filed a complaint with respect to this charge as of this date, which is more than 120 days since the charge was received by the Office of Special Counsel.] OR[notified the (Complainant ) by written communication, a copy of which is attached, that the Office of Special Counsel will not file a complaint based on the aforesaid charge.]
WHEREFORE, Complainant respectfully requests:A. That the Office of the Chief Administrative Hearing Officer serve a copy of the Complaint on the Respondent and assign an Administrative Law Judge to preside at a hearing as soon as practicable;B. That the Administrative Law Judge grant the following relief:
1.That ( Respondent ) cease and desist from the discriminatory practices;2.That ( Respondent ) be required to[hire] OR[reemploy] (Complainant ) for ____________ position[with] OR[without] back pay from ( date ).3.The ( Complainant ) respectfully requests reasonable attorney's fees and any other appropriate relief.
DATED this ____ day of June, 2008.
Jane Smith, Esq.
D.C. Bar No. 420557
950 Pennsylvania Avenue, N.W.
Washington, D.C. 20530-0001
Attorneys for Plaintiffs,
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