Plaintiff's Original Petition-FMLA, ADEA

IN THE UNITED STATES DISTRICT

FOR THE __________ DISTRICT OF TEXAS

__________ DIVISION

________, §

§

Plaintiff, § §

§ Civil Action No. ____________

v. §

§

________ §

§

Defendant. §

PLAINTIFF’S ORIGINAL PETITION

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW, Plaintiff, complaining of Defendant, and for cause of action would show:

Prefatory Statement

DISCOVERY CONTROL PLAN: LEVEL 2

Plaintiff intends to conduct discovery in this matter under Level 2, Rule 190.2, Tex.R.Civ.P.

I.

PARTIES

1. Plaintiff is an individual residing in _______, Texas.

2. Defendant is ____________ located at ____________, ______, Texas. Defendant may be served with process in this matter by serving a copy of this petition upon its registered agent, __________.

   II.

   VENUE AND JURISDICTION

3. Venue is proper, and is ______ County pursuant to §§15.002(a)(1), (3) of the Texas Civil Practice and Remedies Code, since the cause of action arose, in whole or in part, in ______ County, Texas, and at the time the cause of action arose, Defendant operated its principal office in ______ County, Texas.

4. The Court has subject matter jurisdiction of Plaintiff’s claims under Title VII, the Age Discrimination Employment Act 29 U.S.C. § 621, the Family Medical Leave Act (“FMLA”), 29 U.S.C. §§ 2601-2654, and the Texas Commission on Human Rights Act (“TCHRA”), Chapter 21, Texas Labor Code, pursuant to a right to sue letter issued by the Equal Employment Opportunity Commission (“EEOC”) to Plaintiff on [date]. This action is brought within ninety (90) days of...