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`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF LOUISIANA
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`GURMEET KAUR,
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` Plaintiff,
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`v.
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`WHOLE FOODS MARKET, INC,
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` Defendant. JURY TRIAL DEMANDED
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`CIVIL ACTION NO.
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`COMPLAINT
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`NOW INTO COURT, Plaintiff, Gurmeet Kaur (“Plaintiff” or “Ms. Kaur”), by and
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`through undersigned counsel, hereby submits her Complaint against Whole Foods Market, Inc.
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`(“Defendant” or “WFM”).
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`INTRODUCTION
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`1.
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`Plaintiff Gurmeet Kaur, by and through her attorney, brings this action against WFM
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`for violations of the Equal Pay Act of 1963, 29 U.S.C. §§ 206(d), et seq. (“EPA”), Title VII of
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`the Civil Rights Act of 1964, as amended by the Civil Rights Act of 1991, violations of 42
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`U.S.C. § 2000e et seq. and violations of 42 U.S.C. §1981 et seq. (“Title VII”) and the Lilly
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`Ledbetter Fair Pay Act of 2009.
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`1
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 2 of 18
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`JURISDICTION AND VENUE
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`2.
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`This Court has jurisdiction over this action pursuant to 28 U.S.C. §1331, which confers
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`original jurisdiction upon this Court for actions arising under the laws of the United States, and
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`pursuant to 28 U.S.C. §§ 1343(3) and 1343(4), which confer original jurisdiction upon this Court
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`in a civil action to recover damages or to secure equitable relief under (a) under any Act of
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`Congress providing for the protection of civil rights; (ii) the EPA, (iii) the FLSA, (iv) the ADA,
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`(v) EPSLA and (vi) Title VII. This Court also has jurisdiction over this action pursuant to 28
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`U.S.C. §1367, which confers supplemental jurisdiction upon this Court for all other claims that are
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`so related to claims in the action within original jurisdiction that they form part of the same case
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`or controversy under Article III of the United States Constitution.
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`3.
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`Defendant is an “employer” engaged in an industry affecting commerce as defined by 42
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`U.S.C. § 2000e(b).
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`4.
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`This court has personal jurisdiction over WFM. Defendant WFM is a for-profit corporation
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`doing business in Louisiana. At all times relevant, WFM operated its business within the State of
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`Louisiana.
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`5.
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`Defendant operates its business within the Eastern District of Louisiana. All actions and
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`inactions by Defendants alleged herein occurred within the Eastern District of Louisiana. Venue
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`in this district is proper for the Defendant pursuant to 28 U.S.C. §1391(b) & (c).
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`2
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 3 of 18
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`PARTIES
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`6.
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`Plaintiff Gurmeet Kaur is an Indian minority female residing in Metairie, Louisiana. At
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`all relevant times, Plaintiff is and has been a resident of the State of Louisiana and met the
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`definition of an “employee” under all applicable statutes.
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`7.
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`Upon information and belief, WFM is a corporation engaged in the operation of
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`supermarket food chain that sells food products.
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`FACTS
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`8.
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`WFM is a privately owned multinational supermarket corporation that employees about
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`90,000 individuals across the United States, including Louisiana.
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`9.
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`The Defendant operates a branch of its corporation at 3420 Veterans Memorial Blvd,
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`Metairie, LA 70002.
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`10.
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`On or about June 1, 2018, Plaintiff began her employment with WFM as a Prepared
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`Foods Production Team Member.
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`11.
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`Even though Plaintiff was recognized by the company for her achievements, she has been
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`the victim of continuous harassment, retaliation, racial discrimination, national origin
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`discrimination, and religious discrimination from about 2019 to until she was wrongfully
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`terminated.
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`3
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 4 of 18
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`Since Plaintiff began her employment with WFM, she maintained aspirations in growing
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`12.
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`withing the company.
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`13.
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`Plaintiff adheres to the regulations and policies upheld by WFM. Furthermore, the
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`Plaintiff has filed multiple reports concerning the observed violations during her employment
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`with WFM.
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`14.
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`Plaintiff initially followed the appropriate chain of command when making her reports of
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`violations witnessed. Plaintiff reported witnessed violations to Store Team Leader, Ernest Roy.
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`15.
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`Plaintiff reported harassment, discrimination, and employee violations including theft,
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`falsifying records, inappropriate conduct, and dress code violations.
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`16.
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`On or about May 29, 2020, Plaintiff requested Mr. Roy to return the statements she made
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`of company violations. Plaintiff has been reporting many company violations witnessed from
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`WFM employees and her complaints were not being addressed.
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`17.
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`Mr. Roy informed Plaintiff that the reports were escalated to WFM President Christina
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`Minardi. Plaintiff requested the return of her statements. Mr. Roy confessed to discarding
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`Plaintiff's statements in the trash. While Plaintiff was expressing concerns about professionalism,
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`Mr. Roy stated, “it’s going to fall back on you” as he insisted that she vacate his office.
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`4
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 5 of 18
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`18.
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`Plaintiff was never provided any resolution for her complaints and all evidence of a
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`years’ worth of complaints was either lost or never provided to Plaintiff.
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`19.
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`Plaintiff has reported numerous violations of Team Trainer Ms. Mauri for harassment
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`throughout Plaintiff’s employment. WFM management has discussed and admitted to
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`witnessing Ms. Mauri harassing the Plaintiff.
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`20.
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`On or about 2019, Mr. Justin Myers was reassigned for the Assistant Store Team Leader
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`position at the WFM location where Plaintiff was employed. Plaintiff witnessed Mr. Myers and
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`Ms. Mauri acting intimately towards one another and reported their conduct to the Ethics
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`Website.
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`21.
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`Assistant Store Team Leader Justin Myers began harassing Plaintiff in retaliation. The
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`harassment occurred two to three times a week throughout Plaintiff’s employment. The
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`harassment included: mocking Plaintiff’s behavior and reading Plaintiff’s confidential
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`complaints out loud for other employees to hear while mocking them.
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`22.
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`Plaintiff was discriminated by her race (Asian) and national origin (Indian) by constantly
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`referring to her as curry or chai lattes.
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`23.
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`Plaintiff suffered religious discrimination as she was referred to being Muslim based on
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`her appearance. As Plaintiff tried to explain that her religion is Sikh, she suffered disparaging
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`5
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 6 of 18
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`comments associating her and people of her religion as greedy for coming to America to want a
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`better future.
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`24.
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`Plaintiff reported the harassment and hostile work environment she is suffering from to
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`Human Resource representative, Kryz Nicholls; Team Member Services representatives Aaron
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`Villalobos, Meryl Felsen, and Leslie; and Store Team Leader Mr. Roy.
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`The Plaintiff's concerns were not adequately resolved, leading to an escalation in the
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`25.
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`harassment and hostile work environment she was experiencing.
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`26.
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`On or about February 19, 2021, Plaintiff was forced to end her shift early and go home
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`for a uniform violation by Mr. Myers. Plaintiff properly follows the uniform code, and it was
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`confirmed by the uniform company that sells the uniforms for WFM.
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`27.
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`Prior to the incident on February 19, 2021, Plaintiff has made a plethora of complaints
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`against Tanya Thomas, Ms. Yolanda, Ms. Mauri, and Mr. Myers for uniform code violations.
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`28.
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`Plaintiff was subjected to disparate treatment and retaliation as she was the only
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`employee forced to leave despite other employees being in violation of the uniform policy.
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`29.
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`On or about May 2, 2022, Plaintiff reported to the Ethic Website employees eating
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`WFM’s food without paying for them. The reported employees included: Team Member Ms.
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`Maurinella, Ms. Jeanne Ory, Ms. Vera, Ms. Batina, and Cashier Team Member Aziza.
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`6
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 7 of 18
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`On or about June 4, 2022, Plaintiff reported to the Ethics Website she has been suffering
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`30.
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`from retaliation and discrimination from Ms. Batina. Ms. Batina made disparaging comments
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`such as, “she needs to find another job.” Ms. Batina called Plaintiff racist for reporting Ms.
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`Maurinella for stealing food. Plaintiff’s concerns were not addressed.
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`31.
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`Plaintiff reported to the Ethics Website that she fears her complaints are leading to further
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`harassment as they are not being kept confidential.
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`32.
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`On or about July 13, 2022, Plaintiff made a complaint against Mr. Roy through the Ethics
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`Website. Mr. Roy instructed Plaintiff to stop making reports on the Ethics Website.
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`33.
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`Plaintiff’s Ethics reports are subject to investigation and have added additional workload
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`for Mr. Roy.
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`34.
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`Plaintiff reported continuous harassment from WFM employee Ms. Vera since 2020. Ms.
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`Vera wanted Plaintiff to perform job duties that were not in alignment with her position and
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`when Plaintiff refused, Ms. Vera began harassing Plaintiff in retaliation.
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`35.
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`After management failed to act regarding Plaintiff’s harassment from Ms. Vera, Plaintiff
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`was forced to abide by Ms. Vera’s bullying and harassment in fear for her safety.
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`7
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 8 of 18
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`Plaintiff suffered an adverse employment action when she was intentionally not given her
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`36.
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`proper raise by Team Leader Tanya Thomas.
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`37.
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`Plaintiff has been reporting Ms. Thomas for misuse of company time, harassment,
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`intentionally not allowing Plaintiff to leave after her shift ends, hostile work environment,
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`discrimination, and retaliation.
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`38.
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`On or about June 13, 2022, Plaintiff was alleged to have bumped into WFM employee
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`Batina without offering an "excuse me," as claimed by Ms. Thomas and Mr. Roy. Plaintiff
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`refuted these allegations and clarified that it was, in fact, Ms. Batina who had elbowed her while
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`she was walking. Despite this, Plaintiff still courteously said "excuse me."
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`39.
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`Plaintiff was told to sign a write up acknowledging the incident after WFM management
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`refused to consider Plaintiff’s account of the event.
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`40.
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`On or about June 30, 2022, WFM management began forcing Plaintiff to perform the job
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`duties of other departments. Plaintiff was tasked with washing the dishes for the Prepared Foods
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`Team. The Bakery Team constantly leaves their dirty dishes Prepared Foods Team to clean.
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`Plaintiff washed the dishes for her team only and refused to wash the dishes for the Bakery Team
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`as they constantly leave their unclean dishes.
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`41.
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`Plaintiff was hired to the Prepared Foods Team. Plaintiff’s responsibilities are to prepare
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`8
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 9 of 18
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`food, counter service, stocking of products, and provide courteous, friendly, and efficient
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`customer service.
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`42.
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`All departments are assigned to clean their own dishes. The Bakery Team has been
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`avoiding cleaning their own dishes with WFM. This is a constant complaint for several years and
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`WFM management has refused to act or resolve this issue.
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`43.
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`Plaintiff was instructed to perform tasks for separate teams despite there being an
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`employee in that particular team who was readily available. Plaintiff refused to wash the dishes
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`for the Bakery Team.
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`44.
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`Plaintiff was issued a write up by Mr. Roy for being insubordinate. Plaintiff refused to
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`sign the write up.
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`45.
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`The Bakery Team employees for WFM started retaliating and harassing Plaintiff for
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`refusing to perform their job duties.
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`46.
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`Plaintiff reported the disparate treatment and discrimination to the Ethics Website.
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`47.
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` On or about July 11, 2022, Plaintiff was sent home on administrative leave for refusing
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`to wash dishes for the Bakery Team.
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`Plaintiff’s employment was terminated on July 18, 2022.
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`48.
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`9
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 10 of 18
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`CAUSES OF ACTION
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`AS FOR THE FIRST CAUSE OF ACTION AGAINST DEFENDANT WFM
`FOR A VIOLATION OF
`Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e et seq.
`and 42 U.S.C. § 1981
`(Racial and National Origin Discrimination)
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`49.
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`Plaintiff repeats and re-alleges the allegations contained in the paragraphs above, as if
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`fully set forth herein.
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`50.
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`Defendant has engaged in intentional racial and national origin discrimination in the
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`terms and conditions of the Plaintiff’s employment, including, but not limited to, the Plaintiff’s
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`constructive termination in violation of the Civil Rights Act of 1964.
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`Defendants’ conduct violates Title VII.
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`51.
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`52.
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`By the conduct described above, Defendant intentionally deprived the Plaintiff of the
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`same rights as enjoyed by other citizens to the creation, performance, enjoyment, and all benefits
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`and privileges, of their employment relationship with Defendant, in violation of 42 U.S.C. §
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`1981.
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`53.
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`As a result of defendant’s discrimination in violation of Section 1981, the Plaintiff has
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`been denied employment advancement opportunities providing additional compensation, thereby
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`entitling her to injunctive and equitable monetary relief; and have suffered anguish, humiliation,
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`distress, inconvenience and loss of enjoyment of life because of defendant’s actions, thereby
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`entitling her to compensatory damages.
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`10
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 11 of 18
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`54.
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`In its discriminatory actions as alleged above, WFM has acted with malice or
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`reckless indifference to the rights of the above-named African American Plaintiff and, thereby
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`entitling her to an award of punitive damages.
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`Plaintiff’s requests for relief are set forth below.
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`55.
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`AS FOR THE SECOND CAUSE OF ACTION AGAINST DEFENDANT
`WFM FOR A VIOLATION OF
`Title VII of the Civil rights Act of 1964, as amended and Lilly Ledbetter
` Fair Pay Act
`(Discrimination in Pay)
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`56.
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`Plaintiff repeats and re-alleges the allegations contained in the paragraphs above, as if
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`fully set forth herein.
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`57.
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`Plaintiff is a member of a protected class and repeats and re-alleges the allegations
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`contained in the paragraphs above, as if fully set forth herein.
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`58.
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`The conduct alleged herein violates Title VII of the Civil Rights Act of 1964, as
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`amended, 42 U.S.C. § 2000e et seq., as Defendant WFM engaged in the practice of
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`discrimination against Plaintiff.
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`59.
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`Defendant WFM intentionally discriminated against Plaintiff by subjecting her to
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`discriminatory compensation, in violation of Title VII of the Civil Rights Act of 1964 and the
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`Lilly Ledbetter Fair Pay Act.
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`11
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 12 of 18
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`Plaintiff’s requests for relief are set forth below.
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`60.
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`AS AND FOR A THIRD CAUSE OF ACTION AGAINST DEFENDANT
`WFM FOR A VIOLATION OF
`The Equal Pay Act of 1963, 29 U.S.C. §§ 206, et seq.
`(Retaliation)
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`61.
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`Plaintiff repeats and re-alleges the allegations contained in the paragraphs above as if
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`fully set forth herein.
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`62.
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`Plaintiff lodged complaints with Defendant WFM and the EEOC regarding the
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`discrimination to which she was subjected under the EPA, and as such engaged in protected
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`activity.
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`63.
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`WFM retaliated against Plaintiff by, in addition to other retaliatory behavior, further
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`isolating her, constantly monitoring and criticizing her work, adding additional workload and
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`new, draconian work conditions, subjecting her to threatening and abusive behavior, subjecting
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`her to harassment, and in each case, as a result of her complaints of unlawful employment
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`practices and termination.
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`64.
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`The conduct alleged herein violates The Equal Pay Act of 1963, 29 U.S.C. §§ 206, et seq.
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`WFM's actions were taken with malice or reckless indifference, entitling Plaintiff to
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`65.
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`recover punitive damages.
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`12
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 13 of 18
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`66.
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`Plaintiff’s requests for relief are set forth below.
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`AS AND FOR A FOURTH CAUSE OF ACTION AGAINST DEFENDANT
`WFM FOR A VIOLATION OF
`Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e et seq.
`(Retaliation)
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`67.
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`Plaintiff repeats and re-alleges the allegations contained in the paragraphs above as if
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`fully set forth herein.
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`68.
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`Plaintiff is a member of a protected class and repeats and re-alleges the allegations
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`contained in the paragraphs above as if fully set forth herein.
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`69.
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`Plaintiff lodged complaints with Defendant WFM and the EEOC regarding the
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`discrimination to which she was subjected, and as such engaged in protected activity under
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`Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e et seq.
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`70.
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`WFM retaliated against Plaintiff by, in addition to other retaliatory behavior, further
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`isolating her, constantly monitoring and criticizing her work, adding additional workload and
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`new, draconian work conditions, subjecting her to threatening and abusive behavior, subjecting
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`her to harassment, and in each case, as a result of her complaints of unlawful employment
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`practices.
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`71.
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`The conduct alleged herein violates Title VII of the Civil Rights Act of 1964, as
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`amended, 42 U.S.C. § 2000e et seq.
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`13
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 14 of 18
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`WFM's actions were taken with malice or reckless indifference, entitling Plaintiff to
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`72.
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`recover punitive damages.
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`Plaintiff’s requests for relief are set forth below.
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`73.
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`AS AND FOR A FIFTH CAUSE OF ACTION AGAINST
`DEFENDANT WFM FOR A VIOLATION OF
`Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §§ 2000e et seq.,
`(Hostile Work Environment Based on Race)
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`Plaintiff is a member of a protected class and repeats and re-alleges the allegations
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`74.
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`contained in the paragraphs above, as if fully set forth herein.
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`75.
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`The conduct alleged herein violates Title VII of the Civil Rights Act of 1964, as
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`amended, 42 U.S.C. §2000e et seq., as Defendant WFM created and fostered a hostile work
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`environment based on Plaintiff's race.
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`76.
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`Defendant WFM intentionally discriminated against Plaintiff by creating and fostering
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`policies and a work environment that singled out and disadvantaged Plaintiff compared to
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`similarly situated Caucasian employees, in violation of Title VII of the Civil Rights Act of 1964.
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`Plaintiff requests for relief are set forth below.
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`77.
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`14
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 15 of 18
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`AS AND FOR AN SIXTH CAUSE OF ACTION AGAINST
`DEFENDANT WFM FOR A VIOLATION OF
`Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §§ 2000e et seq.,
`(Religious Discrimination)
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`Plaintiff repeats and re-alleges the allegations contained in the paragraphs above as if
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`78.
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`fully set forth herein.
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`79.
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`Plaintiff is a member of a protected class and repeats and re-alleges the allegations
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`contained in the paragraphs above as if fully set forth herein.
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`
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`Plaintiff practices the religion of Sikh.
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`80.
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`81.
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`WFM intentionally referenced Plaintiff as a Muslim despite being put on notice she
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`practices the religion of Sikh. Plaintiff was mocked for being a practicing Sikh.
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`The conduct alleged herein violates Title VII of the Civil Rights Act of 1964, as
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`82.
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`amended, 42 U.S.C. § 2000e et seq.
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`83.
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`WFM's actions were taken with malice or reckless indifference, entitling Plaintiff to
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`recover punitive damages.
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`84.
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`Plaintiff’s requests for relief are set forth below.
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`15
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 16 of 18
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`ADMINISTRATIVE PROCEDURES
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`1.
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`On or about October 21, 2022, the Plaintiff filed a timely Charge of Discrimination
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`alleging racial discrimination with the Equal Employment Opportunity Commission (“EEOC”).
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`(A true and accurate copy of EEOC Charge of Discrimination # 461-2022-01109, is attached
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`hereto as “Exhibit A”)
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`2.
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`The Plaintiff has satisfied all statutory prerequisites for filing this action.
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`3.
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`On or about August 17, 2023, the EEOC issued a “Determination and Notice Of Rights”
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`letter for her Charge of Discrimination. On or about August 18, 2023, Plaintiff received this
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`letter. (A true and accurate copy of the EEOC “Dismissal and Notice of Rights” letter for EEOC
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`Charge of Discrimination # 461-2022-01109, is attached hereto as “Exhibit B”)
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`To remedy the violations of the rights of the Plaintiff, Plaintiff requests that the Court
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`4.
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`award her the relief prayed for below.
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`PRAYER FOR RELIEF
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`WHEREFORE, Gurmeet Kaur prays for the following relief:
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`1.
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`That the practices of Defendant WFM complained of herein be determined and adjudged
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`to be in violation of the rights of Plaintiff under Title VII, 42 U.S.C. § 1981, the EPA and any
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`other cause(s) of action that can be inferred from the facts set forth herein;
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`16
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 17 of 18
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`2.
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`All damages which Ms. Kaur has sustained as a result of Defendant WFM's conduct,
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`including back pay, front pay, liquidated damages, punitive damages, general and special damages
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`for lost compensation and job benefits she would have received but for Defendant WFM’s
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`unlawful and retaliatory conduct;
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`3.
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`An award to Plaintiff of pre-judgment interest at the highest available rate, from and after
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`the date of service of the initial complaint in this action on all owed wages from the date such
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`wages were earned and due;
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`4.
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`An award representing Defendant WFM's share of FICA, FUTA, state unemployment
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`insurance and any other required employment taxes;
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`5.
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`Awarding Ms. Kaur her costs and disbursements incurred in connection with this action,
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`including reasonable attorneys' fees, expert witness fees, and other costs;
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`6.
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`An award to Plaintiff of compensatory and punitive damages against all Defendants,
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`including but not limited to damages for physical injury, emotional distress, humiliation,
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`embarrassment, and anguish;
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`Post-judgment interest, as provided by law; and
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`7.
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`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 18 of 18
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`Such other and further legal and equitable relief as may be found appropriate and may be
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`deemed just or equitable.
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`JURY DEMAND
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`Ms. Kaur demands a trial by jury of all issues do triable in this action.
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`Respectfully submitted this 13th day of November 2023.
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`Respectfully Submitted,
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`THE MINIAS LAW FIRM
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`/s/ Christopher Minias
`Christopher A. Minias (#36230)
`1615 Poydras Street
`Suite 900
`New Orleans, LA 70112
`Phone: (504) 777-7529
`Fax: (504) 556-2866
`Email: chris@miniaslaw.com
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`SERVICE INFORMATION
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`Plaintiff mailed this day, November 13, 2023 by USPS certified mail Notice of Lawsuit and
`Request to Waive Service of a Summons, two copies of the Waiver of the Service of the
`Summons Citation and Acceptance of Service and a stamped self-addressed envelope to
`Defendant’s agent:
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`Corporation Service Company
`450 Laurel Street, 8th Floor
`Baton Rouge, LA 70801
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`/s/ Christopher Minias
`CHRISTOPHER MINIAS
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