Employment and Labor
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Amended Trial Management Order
A sample proposed trial management order which states plaintiff’s claim for relief, defendant’s claim and defenses, as well as stimulated facts and a list of witness’.
Model Telecommuting Letter Agreement
This is model telecommuting agreement between an employer and employee provides key terms of the arrangement.
Confidentiality Agreement for Employees/Consultants of Art Advisory Services
This Confidentiality Agreement is for employees or consultants who provide art advisory and consultation services. It contains provisions that are specific to the fine art world and has tailored provisions for “family” like employers who may have unique confidentiality requirements relative to a large organization.
Guide To Colorado Unemployment Benefits
A Employee and Employer Guide to Colorado Unemployment benefits, What to expect, how to apply for unemployment benefits, Do you qualify? If you are denied, How to appeal.
Workers Comp Motion withdraw Expedited hearing Application
Motion to Withdraw the application that was filed for an expedited hearing in workers compensation
Administrative Pre-hearing statment
A Colorado State Personnel appeal, where my client was wrongfully terminated. A pre-hearing statement is filed prior to the hearing
Answer to Title VII Complaint
Defendants answer to complaint for title VII
Complaint for Age Discrimination
Age discrimination involves treating an applicant or employee less favorably because of his or her age.
Complaint in Federal court for age discrimination:
To establish an age discrimination claim, plaintiff must show that:
–she was older than 40;
–she was discharged;
–she was qualified for the job and met the defendant’s legitimate expectations; and.
–her position remained open or was filled by a similarly qualified individual who was substantially younger.
An average out of court settlement is about $40,000. In addition, 10 percent of wrongful termination and discrimination cases result in a $1 million dollar settlement. The majority of cases, about 67 percent, are ruled in the plaintiff’s favor when taken to litigation.
What are grounds for age discrimination?
The employee, at the time of the act alleged to be discriminatory, is 40 or older; The employee is qualified for their job position; The employee experiences an adverse employment action; Adverse actions include actions such as demotions, firings, or changes to the terms, conditions or privileges of employment); and.
Complaint for Fair Labor Standard Act – Ohio
1. the Fair Labor Standards Act (“FLSA”), 29 U.S.C. §201, et seq., the Ohio Minimum Fair Wage Standards Act, O.R.C. Chapter 4111 (“the Ohio Wage Act”), the Ohio Prompt Pay Act, O.R.C. § 4113.15 (“OPPA”), and 28 U.S.C. §1331.
Complaint for Injunctive Relief & Damages Discrimination
RETALIATORY DISCHARGE IN VIOLATION OF THE FAMILY AND MEDICAL LEAVE ACT, WRONGFUL TERMINATION BASED ON DISABILITY DISCRIMINATION, FAILURE TO PROVIDE REASONABLE ACCOMMODATION
Civil Complaint for Damages, Declaratory Relief, Extraordinary Writs, and Preliminary Injunction
Federal Civil Rights Complaint (42 USC 1983), including requests for damages, injunction, extraordinary writs, and declaratory relief out of the US District Court for the Eastern District of Michigan.
Declaratory relief refers to a judgment of a court which determines the rights of parties without ordering anything be done or awarding damages. By seeking a declaratory judgment, the party making the request is seeking for an official declaration of the status of a matter in controversy.
The declaratory judgment is generally considered a statutory remedy and not an equitable remedy in the United States, and is thus not subject to equitable requirements, though there are analogies that can be found in the remedies granted by courts of equity.
Declaratory relief refers to a judgment of a court which determines the rights of parties without ordering anything be done or awarding damages. By seeking a declaratory judgment, the party making the request is seeking for an official declaration of the status of a matter in controversy.
Federal Civil Complaint under ERISA
Federal ciil complaint brought under ERISA against Veteran’s Affairs. US District Court for the Eastern District of Michigan.
Plaintiff’s Motion to Compel Production of Documents and for Expedited Hearing
PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND FOR EXPEDITED HEARING in an employment Title vII case
Plaintiff’s Motion for Evidentiary Hearing on Back Pay
PLAINTIFF’S MOTION FOR EVIDENTIARY HEARING ON BACK PAY after receiving a judgment on title VII case