UNITED STATES DISTRICT COURT! WESTERN DISTRICT OF MICHIGAN! SOUTHERN DIVISION!

Similar documents
Case 1:18-cv JTN-ESC ECF No. 7 filed 06/11/18 PageID.30 Page 1 of 12

2016 WL (U.S.) (Appellate Petition, Motion and Filing) Supreme Court of the United States.

Case 2:16-cv JTM-TJJ Document 1 Filed 05/25/16 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

Case 4:16-cv JEG-CFB Document 1 Filed 12/23/16 Page 1 of 13

Case3:05-cv WHA Document1 Filed02/14/05 Page1 of 5

STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE

Case: 1:15-cv Document #: 1 Filed: 02/03/15 Page 1 of 10 PageID #:1

2:13-cv GCS-DRG Doc # 1 Filed 10/15/13 Pg 1 of 15 Pg ID 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

Case: 5:15-cv SL Doc #: 1 Filed: 07/20/15 2 of 9. PageID #: 2

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

9:12-cv PMD-BHH Date Filed 09/17/12 Entry Number 1 Page 1 of 8

2:18-cv PDB-EAS Doc # 1 Filed 03/06/18 Pg 1 of 16 Pg ID 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION CASE NO.

Courthouse News Service

Case 1:16-cv Document 1 Filed 11/21/16 Page 1 of 10 PageID #: 1 UNITED STATES DISTRICT COURT STATE OF RHODE ISLAND COMPLAINT INTRODUCTION

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH DAKOTA SOUTHERN DIVISION

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION

Case 4:10-cv CW Document 1 Filed 10/13/10 Page 1 of 8

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA CIVIL DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN

IN THE UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

Case: 1:06-cv JRA Doc #: 28 Filed: 05/08/09 1 of 9. PageID #: 220

Courthouse News Service

Case 1:16-cv Document 1 Filed 11/21/16 Page 1 of 9 PageID #: 1 UNITED STATES DISTRICT COURT STATE OF RHODE ISLAND COMPLAINT INTRODUCTION

Case 3:19-cv Document 1 Filed 01/30/19 Page 1 of 17

Case 2:16-cv GMN-VCF Document 1 Filed 04/26/16 Page 1 of 10

CASE NO. 5:00-CV COMPLAINT IN INTERVENTION ON BEHALF OF JACKQULINE STOKES

PRELIMINARY STATEMENT. Brooklyn in which he was serving out the last months of his prison sentence to a

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

Case 1:18-cv RP Document 1 Filed 06/13/18 Page 1 of 13 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

Courthouse News Service

Case 5:12-cv LS Document 1 Filed 03/19/12 Page 1 of 14 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case: 1:13-cv Document #: 1 Filed: 07/25/13 Page 1 of 7 PageID #:1

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) FIRST AMENDED COMPLAINT AND JURY DEMAND

Case5:11-cv EJD Document28 Filed09/09/11 Page1 of 10

INDEX NO /2017 NYSCEF DOC. NO. 65 RECEIVED NYSCEF: 07/06/2018

2016 WL (U.S.) (Appellate Petition, Motion and Filing) Supreme Court of the United States.

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS ) THIRD JUDICIAL CIRCUIT COUNTY OF WILLIAMSBURG ) C/A NO CP-45-

FILED: RICHMOND COUNTY CLERK 01/16/ :56 AM INDEX NO /2017 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/16/2017

Case 3:08-cv CRW-CFB Document 1 Filed 11/07/2008 Page 1 of 12

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF HAWAII

Case 1:06-cv VM-HBP Document 1 Filed 07/10/06 Page 1 of 9

CASE 0:12-cv PJS-TNL Document 15 Filed 08/14/12 Page 1 of 7 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

the Sheriff, Contra Costa County and DOES 1-20 seized his medical marijuana and destroyed it

STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE. vs.

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA

Case 5:15-cv SAC-KGS Document 1 Filed 08/06/15 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

Case 1:07-cv NLH-AMD Document 1 Filed 08/10/2007 Page 1 of 12

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Case 3:15-cv EDL Document 1 Filed 12/09/15 Page 1 of 16

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF OAKLAND

Case: 1:12-cv Document #: 1 Filed: 05/25/12 Page 1 of 24 PageID #:1

Courthouse News Service

Case 1:19-cv LY Document 1 Filed 04/12/19 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

FILED: NEW YORK COUNTY CLERK 01/17/ :57 AM INDEX NO /2015

Case 1:14-cv KAM-JO Document 8 Filed 07/02/14 Page 1 of 11 PageID #: 36

IN THE UNITED STATE DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI SOUTHERN DIVISION

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

Case 1:17-cv JCB Document 5 Filed 02/15/17 Page 1 of 16 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS CIVIL ACTION NO.

Case: 2:10-cv GLF-NMK Doc #: 1 Filed: 12/06/10 Page: 1 of 8 PAGEID #: 1

Case 2:17-cv JEM Document 1 Entered on FLSD Docket 11/01/2017 Page 1 of 17

2:18-cv CSB-EIL # 1 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS URBANA DIVISION COMPLAINT

COMPLAINT AND JURY DEMAND

Case 2:17-cv GJQ-TPG ECF No. 1 filed 01/25/17 PageID.1 Page 1 of 14 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN NORTHERN DIVISION

From Article at GetOutOfDebt.org

~D la'ls DISTRIC;iO~e 2

SUPERIOR COURT OF THE STATE OF WASHINGTON FOR KING COUNTY NO. Plaintiff CESAR SANCHEZ-GUZMAN, by and through his attorneys, hereby states

SUPERIOR COURT OF CALIFORNIA FOR SANTA CRUZ COUNTY

FIRST AMENDED COMPLAINT

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF BUTTE UNLIMITED JURISDICTION

.JAh : Plaintiff Salah Williams, residir,g at 129 Chancellor Avenue in the City of Newark,

Case 2:06-cv FSH-PS Document 20 Filed 01/10/08 Page 1 of 7

Case 1:14-cv CKK Document 1 Filed 08/22/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

2:15-cv PDB-DRG Doc # 1 Filed 02/11/15 Pg 1 of 8 Pg ID 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

Case 1:17-cv JCB Document 1 Filed 02/13/17 Page 1 of 14 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS GALVESTON DIVISION. Plaintiffs, CIVIL ACTION NO. v.

Case 3:18-cv JSC Document 1 Filed 05/02/18 Page 1 of 11

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

Case 2:16-cv RSL Document 1 Filed 08/05/16 Page 1 of 13

Case 2:17-cv Document 1 Filed in TXSD on 12/12/17 Page 1 of 10

Case 5:14-cv CMC Document 1 Filed 12/05/14 Page 1 of 11 PageID #: 1

Case 4:17-cv Document 1 Filed in TXSD on 07/20/17 Page 1 of 8

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION. Defendants. COMPLAINT AND JURY DEMAND JURISDICTION

Case 1:14-cv RM-MJW Document 1 Filed 05/27/14 USDC Colorado Page 1 of 21 IN THE UNITED STATES DISTRICT COURT IN AND FOR THE STATE OF COLORADO

FILED: NEW YORK COUNTY CLERK 12/19/ :09 PM INDEX NO /2016 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 12/19/2017

Case 2:18-cv JWL-TJJ Document 1 Filed 12/05/18 Page 1 of 15 IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

Case 2:14-cv Document 1 Filed 04/29/14 Page 1 of 21 PageID #: 1

IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO

Case 1:08-cv REB Document 1 Filed 12/16/2008 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

INTRODUCTION. 1. This is an action, filed pursuant to U.S. Const. Amend. XIV, Title 42

Case 3:14-cv BR Document 1 Filed 10/09/14 Page 1 of 7

Case 1:11-cv JTN Doc #1 Filed 10/04/11 Page 1 of 10 Page ID#1 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MICHIGAN

)(

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

Transcription:

Case 1:13-cv-01294-PLM Doc #1 Filed 11/27/13 Page 1 of 10 Page ID#1 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION JILL CRANE, PLAINTIFF, v. MARY FREE BED REHABILITATION HOSPITAL, DEFENDANT. GAFKAY & DAFOE, PLC BY: JULIE A. GAFKAY (P53680) Attorney for Plaintiff 175 S. Main Street Frankenmuth, Michigan 48734 (989) 652-9240 jgafkay@gafkaylaw.com DEMAND FOR JURY TRIAL There is no other civil action between the parties arising out of the same transaction or occurrence as alleged in this Complaint pending in this Court, nor has any such action been previously filed and dismissed or transferred after having been assigned to a judge, nor do I know of any other civil action, not between the parties, arising out of the same transaction or occurrence as alleged in this Complaint that is either pending or was previously filed and dismissed, transferred, or otherwise disposed of after having been assigned to a Judge in this Court. PLAINTIFF S COMPLAINT AND JURY DEMAND

Case 1:13-cv-01294-PLM Doc #1 Filed 11/27/13 Page 2 of 10 Page ID#2 NOW COMES Plaintiff, Jill Crane, by and through her attorney, GAFKAY & DAFOE, PLC, by Julie A. Gafkay and files this Complaint against Defendant, Mary Free Bed Rehabilitation Hospital, as follows: 1. Plaintiff, Jill Crane (hereinafter Plaintiff ) is a citizen of the United States and resides in the County of Kent, State of Michigan. 2. Defendant, Mary Free Bed Rehabilitation Hospital (hereinafter Defendant ) is a non-profit corporation located in the County of Kent, State of Michigan. 3. This is a civil action brought pursuant to Federal claims under 42 U.S.C. 1981 and Title VI of the Civil Rights Act of 1964, as amended, 42 U.S.C. 2000, et seq. for racial discrimination. 4. Plaintiff also asserts State claims against Defendant under the Michigan Elliott-Larsen Civil Rights Act and a common law tort claim for intentional infliction of emotional distress. 5. Plaintiff has also filed a Charge of Discrimination with the Michigan Department of Civil Rights and Equal Employment Opportunity Commission for race discrimination and retaliation. Plaintiff reserves the right to amend her Complaint to assert claims under Title VII once the administrative procedure has been exhausted. 6. This Court has federal question jurisdiction under 28 U.S.C. 1331 and supplemental jurisdiction over Plaintiff s State claims. RELEVANT FACTS 7. Plaintiff is African-American. 8. Plaintiff began her employment as a temporary nurse on the floor with Defendant in or about 2000.

Case 1:13-cv-01294-PLM Doc #1 Filed 11/27/13 Page 3 of 10 Page ID#3 9. In or about 2008, Plaintiff accepted a position as Nursing Supervisor with Defendant. 10. Plaintiff is well-qualified for her position as Nursing Supervisor and has sought promotions within Defendant. 11. In or about October of 2011, Plaintiff participated in a leadership meeting with management employees of Defendant including the Director of Nursing at the time, Connie Brown-Olds. 12. The Director of Nursing told the nursing supervisors present, including Plaintiff, that a Caucasian patient had been admitted into the facility and the family did not want any Black caregivers caring for him. 13. Plaintiff immediately objected to the racially discriminatory directive at the time, however, the Director of Nursing disregarded Plaintiff s objection and told the leadership team that Defendant was going to honor the patient s wishes. 14. Plaintiff, who has a Masters in Nursing, was precluded from caring for the said patient even if the patient s call light was on or a beeper in the patient s room went off for the sole reason that she is African-American. 15. Plaintiff, who is a Nursing Supervisor, was required to give the directive to her nursing subordinates that any African-American caregivers were not to go into the said patient s room solely because the color of their skin. 16. Plaintiff felt harassed, humiliated and discriminated against as a result of the assignment of the said patient based on race. 17. In or about October of 2012, Plaintiff applied for the position of Director of Education.

Case 1:13-cv-01294-PLM Doc #1 Filed 11/27/13 Page 4 of 10 Page ID#4 18. Plaintiff was well-qualified for the position; Plaintiff has Masters in Nursing, she has worked as an adjunct and instructor at several colleges, and has worked in nursing since 1985. 19. Despite Plaintiff s superior qualifications, Plaintiff was denied the promotion which was given to a Caucasian applicant with no nursing experience. 20. In or about 2012, an African-American nurse, Timika Foster, was denied a promotion to a nursing supervisor position. 21. A Caucasian nurse was instead promoted to the position Timika Foster applied for even though she only had an associate s degree in nursing and no prior rehabilitation experience. 22. Plaintiff believed the decision not to promote Timika Foster was based, at least in part, on her race and, therefore, Plaintiff assisted Ms. Foster with a complaint regarding the failure to be promoted. 23. In or about June of 2013, Plaintiff applied for another promotion to the position of Nurse Manager, however, Defendant allegedly did not want to fill the position because a new Director of Nursing was being hired. However, other positions were filled between June to the present such as clinical coordinators, even though a new Director of Nursing was being hired. 24. A motiving factor for Plaintiff not being promoted is because of her race and complaints of racial discrimination. 25. Plaintiff has suffered damages as result of the above.

Case 1:13-cv-01294-PLM Doc #1 Filed 11/27/13 Page 5 of 10 Page ID#5 COUNT I - 42 USC 1981 RACE DISCRIMINATION CLAIM AGAINST DEFENDANT WITH REGARD TO DENIAL OF ENJOYMENT OF ALL BENEFITS, PRIVILEGES, TERMS AND CONDITIONS OF EMPLOYMENT 26. Plaintiff hereby re-alleges and incorporates by reference the above paragraphs. 27. Plaintiff is African-American. 28. Defendant intentionally discriminated against African-American employees, including Plaintiff, when it required that no African-American employees care for a certain Caucasian patient in or about October of 2011. 29. The said racial discrimination related to Plaintiff s employment with Defendant and she was denied the enjoyment of all benefits, privileges, terms and conditions of that employment relationship because of her race. 30. Accordingly, Plaintiff hereby asserts a 42 U.S.C. 1981 claim against Defendant. 31. That as a direct and proximate result of Defendant s aforesaid violations of Plaintiff s rights, Plaintiff has suffered and sustained reassignment, emotional distress and mental anguish, past and future injuries to feelings including extreme embarrassment and humiliation, past and future outrage, damages to reputation, and whatever punitive damages are recoverable herein. COUNT II - 42 USC 1981 RACE DISCRIMINATION AND RETALIATION CLAIM AGAINST DEFENDANT WITH REGARD TO FAILURE TO PROMOTE 32. Plaintiff hereby re-alleges and incorporates by reference the above paragraphs.

Case 1:13-cv-01294-PLM Doc #1 Filed 11/27/13 Page 6 of 10 Page ID#6 33. Plaintiff complained of race discrimination by Defendant. 34. Defendant was aware of Plaintiff s complaint of race discrimination. 35. Plaintiff applied for a promotion to the Director of Eduction in October of 2012, and was denied. She applied for a promotion to Nurse Manager in June of 2012 which wasn t filled. 36. A motivating factor for Plaintiff s denial of promotion opportunities was her complaint of race discrimination. 37. A motivating factor for Plaintiff s denial of promotion opportunities is her race. 38. Accordingly, Plaintiff hereby asserts a 42 U.S.C. 1981 claim against Defendant with regard to failure to be promoted. 39. As a direct and proximate result of Defendant s aforesaid violations of Plaintiff s rights, Plaintiff has suffered and sustained past and future wage loss, emotional distress and mental anguish, past and future injuries to feelings including extreme embarrassment and humiliation, past and future outrage, damages to reputation, and whatever punitive damages are recoverable herein. COUNT III - MICHIGAN ELLIOTT-LARSEN CIVIL RIGHTS ACT RACE DISCRIMINATION CLAIM AGAINST DEFENDANT AS TO DENIAL OF BENEFITS, PRIVILEGES, TERMS AND CONDITIONS OF EMPLOYMENT 40. Plaintiff hereby re-alleges and incorporates by reference the above paragraphs.

Case 1:13-cv-01294-PLM Doc #1 Filed 11/27/13 Page 7 of 10 Page ID#7 41. At all material times, Plaintiff was an employee, and Defendant was her employer, covered by and within the meaning of the Michigan Elliott- Larsen Civil Rights Act, MCL 37.2101, et seq. 42. Plaintiff is African-American. 43. Defendant intentionally discriminated against African-American employees, including Plaintiff, when it required that no African-American employees care for a certain Caucasian patient in or about October of 2011. 44. The said racial discrimination related to Plaintiff s employment with Defendant and she was denied the enjoyment of all benefits, privileges, terms and conditions of that employment relationship because of her race. 45. Accordingly, Plaintiff hereby asserts a claim for race discrimination against Defendant pursuant to the Michigan Elliott-Larsen Civil Rights Act. 46. That as a direct and proximate result of Defendant s aforesaid violations of Plaintiff s rights, Plaintiff has suffered and sustained reassignment, emotional distress and mental anguish, past and future injuries to feelings including extreme embarrassment and humiliation, past and future outrage, and damages to reputation. COUNT IV - MICHIGAN ELLIOTT-LARSEN CIVIL RIGHTS ACT RACE DISCRIMINATION AND RETALIATION CLAIM AGAINST DEFENDANT WITH REGARD TO FAILURE TO PROMOTE 47. Plaintiff hereby re-alleges and incorporates by reference the above paragraphs. 48. Plaintiff complained of race discrimination by Defendant. 49. Defendant was aware of Plaintiff s complaint of race discrimination.

Case 1:13-cv-01294-PLM Doc #1 Filed 11/27/13 Page 8 of 10 Page ID#8 50. Plaintiff applied for a promotion to the Director of Education in October of 2012 and was denied. She applied for a promotion to Nurse Manager in June of 2012 which wasn t filled. 51. A motivating factor for Plaintiff s denial of promotion opportunities was her complaint of race discrimination. 52. A motivating factor for Plaintiff s denial of promotion opportunities is her race. 53. Accordingly, Plaintiff hereby asserts a race discrimination and retaliation claim against Defendant under the Michigan Elliott-Larsen Civil Rights Act with regard to the failure to be promoted. 54. That as a direct and proximate result of Defendant s aforesaid violations of Plaintiff s rights, Plaintiff has suffered and sustained past and future wage loss, emotional distress and mental anguish, past and future injuries to feelings including extreme embarrassment and humiliation, past and future outrage, and damages to reputation. COUNT V - INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS OF PLAINTIFF BY DEFENDANT 55. Plaintiff hereby re-alleges and incorporates by reference the above paragraphs. 56. Defendant s conduct as outlined above was intentional. 57. Defendant s conduct as outlined above was extreme, outrageous, and of such character as not to be tolerated by a civilized society. 58. Defendant s conduct as outlined above was for an ulterior motive or purpose.

Case 1:13-cv-01294-PLM Doc #1 Filed 11/27/13 Page 9 of 10 Page ID#9 59. Defendant s conduct resulted in severe and serious emotional distress. 60. As a direct and proximate result of Defendant s conduct, Plaintiff has been damaged in the manner outlined above. COUNT VI - TITLE VI OF THE CIVIL RIGHTS ACT OF 1964, 42 U.S.C. 2000d to 2000d-7 61. Plaintiff hereby re-alleges and incorporates by reference the above paragraphs. 62. Defendant is the recipient of federal financial assistance from the United States Department of Health and Human Services. 63. Defendant discriminated against Plaintiff on the basis of race. 64. The discrimination was intentional. 65. That as a direct and proximate result of Defendant s aforesaid violations of Plaintiff s rights, Plaintiff has suffered and sustained reassignment, emotional distress and mental anguish, past and future injuries to feelings including extreme embarrassment and humiliation, past and future outrage, damages to reputation, and whatever punitive damages are recoverable herein. 66. Plaintiff requests that this Court enter judgment against Defendant for the following relief: 1. An award to Plaintiff of compensatory damages sufficient to compensate her for mental anguish and emotional distress, embarrassment and humiliation, and damage to her professional reputation as a result of Defendant s actions.

Case 1:13-cv-01294-PLM Doc #1 Filed 11/27/13 Page 10 of 10 Page ID#10 2. An award of past and future wages as a result of Defendant s failure to promote Plaintiff. 3. An award to Plaintiff of punitive damages against Defendant as a result of the reckless indifference with which it violated Plaintiff s rights under the law. 4. An award to Plaintiff of the costs and disbursements of this action, including reasonable attorney fees pursuant to statute. 5. An award to Plaintiff of other and additional legal and/or equitable relief to which she may be entitled. DEMAND FOR JURY TRIAL Plaintiff, hereby demands a Trial by Jury in the above-entitled matter. Respectfully submitted, Dated: 11/27/2013 GAFKAY & DAFOE, PLC s/julie A. Gafkay JULIE A. GAFKAY (P53680) Attorney for Plaintiff 175 S. Main Street Frankenmuth, Michigan 48734 (989) 652-9240 jgafkay@gafkaylaw.com