- 4 -
b. Defendant, acted in a discriminatory
manner towards her because Defendant retaliated against
her by terminating her employment because she com-
plained to management about the alleged sexual harass-
ment, to wit:
i. the supervisor about whom she com-
plained had threatened to “get even” with her if she
ever reported him to management again
ii. Plaintiff s [sic] supervisor was
instrumental in the decision to terminate her
iii. and was retaliating against her
because she had reported his acts of sexual harassment
to management.
12. As a further result of the Defendant’s above-
stated actions, the Plaintiff has been and is being
deprived of income in the form of wages and of prospec-
tive retirement benefits, social security and other
benefits due to her as a worker solely because of her
sex in the sum to be proven at the trial.
* * * * * * *
14. Plaintiff invokes this court’s jurisdiction
* * * [to] adjudicate claims arising out of the trans-
actions set forth above that violate rights and duties
established by the law of Utah, to wit:
a. That the Plaintiff s [sic] termination
was wrongful in that it violates of [sic] the public
policy set forth in 42 U.S.C. � 2000e.
b. That the Plaintiff s [sic] termination
was in violation of Title 35-9-11, Utah Code Annotated.
15. The treatment of Plaintiff by Defendant and
by Supervisor were [sic] intentional and with the
purpose and intent of causing Plaintiff severe and
grievous mental and emotional harm which in turn re-
sulted in severe physical consequences in violation of
the common law of Utah.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully prays this Court
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011