Note: Below is a legal complaint filed by Simone Greggs against Autism Speaks.
COMES NOW, Plaintiff Simone Greggs, as and for her complaint in this action against Defendant Autism Speaks hereby alleges as follows:
NATURE OF THE CLAIMS
JURISDICTION AND VENUE
FIRST CAUSE OF ACTION
SECOND CAUSE OF ACTION
THIRD CAUSE OF ACTION
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays that the Court enter judgment in her favor and against Defendant, containing the following relief:
A. A declaratory judgment that the actions, conduct and practices of Defendant complained of herein violate the laws of the United States and the District of Columbia;
B. An injunction and order permanently restraining Defendant from engaging in such unlawful conduct;
C. An order directing Defendant to take such affirmative action as is necessary to ensure that the effects of these unlawful employment practices are eliminated and do not continue to be practiced when determining employment;
D. An award of damages in an amount to be determined at trial, plus prejudgment interest, to compensate Plaintiff for all monetary and/or economic harm;
E. An award of damages in an amount to be determined at trial, plus prejudgment interest, to compensate Plaintiff for harm to her professional and personal reputations and loss of career fulfillment;
F. An award of damages in an amount to be determined at trial, plus prejudgment interest, to compensate Plaintiff for all non-monetary and/or compensatory harm, including but not limited to, compensation for her mental anguish, humiliation, embarrassment, stress and anxiety, emotional pain and suffering, emotional distress and physical injuries;
G. An award of damages for any and all other monetary and/or non-monetary losses suffered by Plaintiff in an amount to be determined at trial, plus prejudgment interest;
H. An award of punitive damages;
I. An award of costs that Plaintiff has incurred in this action, as well as Plaintiff's reasonable attorneys' fees to the fullest extent permitted by law; and
J. Such other and further relief as the Court may deem just and proper.
Plaintiff hereby demands a trial by jury on all issues of fact and damages stated herein.
Simone L. Greggs
219 Red Jade Drive
Upper Marlboro, MD 20774
I, Simone Greggs, am a plaintiff in the above-entitled action. I have read the foregoing and know the contents thereof. The same is true of my own knowledge, except as to those matters which are therein alleged on information and belief, and as to those matters, I believe it to be true. I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed in the District of Columbia.
STATE OF MARYLAND
I, ______________________________________________, a Notary Public in and for said County and State, do hereby certify that Simone Greggs personally appeared before me this day, and acknowledged the due execution of the foregoing Complaint; that the said Simone Greggs stated that she signed the same freely and voluntarily, without fear or compulsion of any person; and that he voluntarily assents thereto.
Witness my hand and seal this ______ day of ___________, 2012.
My Commission Expires:_____________________