throbber
Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 1 of 18
`
`
`
`
`
`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF LOUISIANA
`
`
`
`GURMEET KAUR,
`
` Plaintiff,
`
`
`
`
`
`
`
`
`v.
`
`
`
`
`WHOLE FOODS MARKET, INC,
`
`
`
`
` Defendant. JURY TRIAL DEMANDED
`
`CIVIL ACTION NO.
`
`
`
`
`
`
`
`
`
`
`COMPLAINT
`
`NOW INTO COURT, Plaintiff, Gurmeet Kaur (“Plaintiff” or “Ms. Kaur”), by and
`
`through undersigned counsel, hereby submits her Complaint against Whole Foods Market, Inc.
`
`(“Defendant” or “WFM”).
`
`INTRODUCTION
`
`1.
`
`Plaintiff Gurmeet Kaur, by and through her attorney, brings this action against WFM
`
`for violations of the Equal Pay Act of 1963, 29 U.S.C. §§ 206(d), et seq. (“EPA”), Title VII of
`
`the Civil Rights Act of 1964, as amended by the Civil Rights Act of 1991, violations of 42
`
`U.S.C. § 2000e et seq. and violations of 42 U.S.C. §1981 et seq. (“Title VII”) and the Lilly
`
`Ledbetter Fair Pay Act of 2009.
`
`
`
`
`
`
`
`1
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 2 of 18
`
`
`
`
`
`JURISDICTION AND VENUE
`
`2.
`
`This Court has jurisdiction over this action pursuant to 28 U.S.C. §1331, which confers
`
`original jurisdiction upon this Court for actions arising under the laws of the United States, and
`
`pursuant to 28 U.S.C. §§ 1343(3) and 1343(4), which confer original jurisdiction upon this Court
`
`in a civil action to recover damages or to secure equitable relief under (a) under any Act of
`
`Congress providing for the protection of civil rights; (ii) the EPA, (iii) the FLSA, (iv) the ADA,
`
`(v) EPSLA and (vi) Title VII. This Court also has jurisdiction over this action pursuant to 28
`
`U.S.C. §1367, which confers supplemental jurisdiction upon this Court for all other claims that are
`
`so related to claims in the action within original jurisdiction that they form part of the same case
`
`or controversy under Article III of the United States Constitution.
`
`3.
`
`Defendant is an “employer” engaged in an industry affecting commerce as defined by 42
`
`U.S.C. § 2000e(b).
`
`4.
`
`This court has personal jurisdiction over WFM. Defendant WFM is a for-profit corporation
`
`doing business in Louisiana. At all times relevant, WFM operated its business within the State of
`
`Louisiana.
`
`5.
`
`Defendant operates its business within the Eastern District of Louisiana. All actions and
`
`inactions by Defendants alleged herein occurred within the Eastern District of Louisiana. Venue
`
`in this district is proper for the Defendant pursuant to 28 U.S.C. §1391(b) & (c).
`
`
`
`
`
`
`
`2
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 3 of 18
`
`
`
`
`
`PARTIES
`
`6.
`
`
`
`Plaintiff Gurmeet Kaur is an Indian minority female residing in Metairie, Louisiana. At
`
`all relevant times, Plaintiff is and has been a resident of the State of Louisiana and met the
`
`definition of an “employee” under all applicable statutes.
`
`7.
`
`Upon information and belief, WFM is a corporation engaged in the operation of
`
`supermarket food chain that sells food products.
`
`FACTS
`
`8.
`
`
`
`WFM is a privately owned multinational supermarket corporation that employees about
`
`90,000 individuals across the United States, including Louisiana.
`
`9.
`
`
`
`The Defendant operates a branch of its corporation at 3420 Veterans Memorial Blvd,
`
`Metairie, LA 70002.
`
`10.
`
`On or about June 1, 2018, Plaintiff began her employment with WFM as a Prepared
`
`Foods Production Team Member.
`
`11.
`
`
`
`Even though Plaintiff was recognized by the company for her achievements, she has been
`
`the victim of continuous harassment, retaliation, racial discrimination, national origin
`
`discrimination, and religious discrimination from about 2019 to until she was wrongfully
`
`terminated.
`
`
`
`3
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 4 of 18
`
`
`
`
`
`
`
`Since Plaintiff began her employment with WFM, she maintained aspirations in growing
`
`12.
`
`withing the company.
`
`13.
`
`
`
`Plaintiff adheres to the regulations and policies upheld by WFM. Furthermore, the
`
`Plaintiff has filed multiple reports concerning the observed violations during her employment
`
`with WFM.
`
`14.
`
`
`
`Plaintiff initially followed the appropriate chain of command when making her reports of
`
`violations witnessed. Plaintiff reported witnessed violations to Store Team Leader, Ernest Roy.
`
`15.
`
`
`
`Plaintiff reported harassment, discrimination, and employee violations including theft,
`
`falsifying records, inappropriate conduct, and dress code violations.
`
`16.
`
`
`
`On or about May 29, 2020, Plaintiff requested Mr. Roy to return the statements she made
`
`of company violations. Plaintiff has been reporting many company violations witnessed from
`
`WFM employees and her complaints were not being addressed.
`
`17.
`
`
`
`Mr. Roy informed Plaintiff that the reports were escalated to WFM President Christina
`
`Minardi. Plaintiff requested the return of her statements. Mr. Roy confessed to discarding
`
`Plaintiff's statements in the trash. While Plaintiff was expressing concerns about professionalism,
`
`Mr. Roy stated, “it’s going to fall back on you” as he insisted that she vacate his office.
`
`
`
`
`
`4
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 5 of 18
`
`
`
`
`
`18.
`
`
`
`Plaintiff was never provided any resolution for her complaints and all evidence of a
`
`years’ worth of complaints was either lost or never provided to Plaintiff.
`
`19.
`
`
`
`Plaintiff has reported numerous violations of Team Trainer Ms. Mauri for harassment
`
`throughout Plaintiff’s employment. WFM management has discussed and admitted to
`
`witnessing Ms. Mauri harassing the Plaintiff.
`
`20.
`
`On or about 2019, Mr. Justin Myers was reassigned for the Assistant Store Team Leader
`
`position at the WFM location where Plaintiff was employed. Plaintiff witnessed Mr. Myers and
`
`Ms. Mauri acting intimately towards one another and reported their conduct to the Ethics
`
`Website.
`
`21.
`
`
`
`Assistant Store Team Leader Justin Myers began harassing Plaintiff in retaliation. The
`
`harassment occurred two to three times a week throughout Plaintiff’s employment. The
`
`harassment included: mocking Plaintiff’s behavior and reading Plaintiff’s confidential
`
`complaints out loud for other employees to hear while mocking them.
`
`22.
`
`
`
`Plaintiff was discriminated by her race (Asian) and national origin (Indian) by constantly
`
`referring to her as curry or chai lattes.
`
`23.
`
`
`
`Plaintiff suffered religious discrimination as she was referred to being Muslim based on
`
`her appearance. As Plaintiff tried to explain that her religion is Sikh, she suffered disparaging
`
`
`
`5
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 6 of 18
`
`
`
`
`
`comments associating her and people of her religion as greedy for coming to America to want a
`
`better future.
`
`24.
`
`
`
`Plaintiff reported the harassment and hostile work environment she is suffering from to
`
`Human Resource representative, Kryz Nicholls; Team Member Services representatives Aaron
`
`Villalobos, Meryl Felsen, and Leslie; and Store Team Leader Mr. Roy.
`
`
`
`The Plaintiff's concerns were not adequately resolved, leading to an escalation in the
`
`25.
`
`harassment and hostile work environment she was experiencing.
`
`26.
`
`
`
`On or about February 19, 2021, Plaintiff was forced to end her shift early and go home
`
`for a uniform violation by Mr. Myers. Plaintiff properly follows the uniform code, and it was
`
`confirmed by the uniform company that sells the uniforms for WFM.
`
`27.
`
`
`
`Prior to the incident on February 19, 2021, Plaintiff has made a plethora of complaints
`
`against Tanya Thomas, Ms. Yolanda, Ms. Mauri, and Mr. Myers for uniform code violations.
`
`28.
`
`
`
`Plaintiff was subjected to disparate treatment and retaliation as she was the only
`
`employee forced to leave despite other employees being in violation of the uniform policy.
`
`
`
`29.
`
`
`
`On or about May 2, 2022, Plaintiff reported to the Ethic Website employees eating
`
`WFM’s food without paying for them. The reported employees included: Team Member Ms.
`
`Maurinella, Ms. Jeanne Ory, Ms. Vera, Ms. Batina, and Cashier Team Member Aziza.
`
`
`
`6
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 7 of 18
`
`On or about June 4, 2022, Plaintiff reported to the Ethics Website she has been suffering
`
`30.
`
`
`
`
`
`
`
`
`
`from retaliation and discrimination from Ms. Batina. Ms. Batina made disparaging comments
`
`such as, “she needs to find another job.” Ms. Batina called Plaintiff racist for reporting Ms.
`
`Maurinella for stealing food. Plaintiff’s concerns were not addressed.
`
`31.
`
`
`
`Plaintiff reported to the Ethics Website that she fears her complaints are leading to further
`
`harassment as they are not being kept confidential.
`
`32.
`
`
`
`On or about July 13, 2022, Plaintiff made a complaint against Mr. Roy through the Ethics
`
`Website. Mr. Roy instructed Plaintiff to stop making reports on the Ethics Website.
`
`33.
`
`
`
`Plaintiff’s Ethics reports are subject to investigation and have added additional workload
`
`for Mr. Roy.
`
`34.
`
`
`
`Plaintiff reported continuous harassment from WFM employee Ms. Vera since 2020. Ms.
`
`Vera wanted Plaintiff to perform job duties that were not in alignment with her position and
`
`when Plaintiff refused, Ms. Vera began harassing Plaintiff in retaliation.
`
`35.
`
`
`
`After management failed to act regarding Plaintiff’s harassment from Ms. Vera, Plaintiff
`
`was forced to abide by Ms. Vera’s bullying and harassment in fear for her safety.
`
`
`
`
`
`7
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 8 of 18
`
`
`
`
`
`Plaintiff suffered an adverse employment action when she was intentionally not given her
`
`36.
`
`proper raise by Team Leader Tanya Thomas.
`
`37.
`
`Plaintiff has been reporting Ms. Thomas for misuse of company time, harassment,
`
`intentionally not allowing Plaintiff to leave after her shift ends, hostile work environment,
`
`discrimination, and retaliation.
`
`38.
`
`
`
`On or about June 13, 2022, Plaintiff was alleged to have bumped into WFM employee
`
`Batina without offering an "excuse me," as claimed by Ms. Thomas and Mr. Roy. Plaintiff
`
`refuted these allegations and clarified that it was, in fact, Ms. Batina who had elbowed her while
`
`she was walking. Despite this, Plaintiff still courteously said "excuse me."
`
`39.
`
`
`
`Plaintiff was told to sign a write up acknowledging the incident after WFM management
`
`refused to consider Plaintiff’s account of the event.
`
`40.
`
`On or about June 30, 2022, WFM management began forcing Plaintiff to perform the job
`
`duties of other departments. Plaintiff was tasked with washing the dishes for the Prepared Foods
`
`Team. The Bakery Team constantly leaves their dirty dishes Prepared Foods Team to clean.
`
`Plaintiff washed the dishes for her team only and refused to wash the dishes for the Bakery Team
`
`as they constantly leave their unclean dishes.
`
`41.
`
`Plaintiff was hired to the Prepared Foods Team. Plaintiff’s responsibilities are to prepare
`
`8
`
`
`
`
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 9 of 18
`
`
`
`
`
`food, counter service, stocking of products, and provide courteous, friendly, and efficient
`
`customer service.
`
`42.
`
`
`
`All departments are assigned to clean their own dishes. The Bakery Team has been
`
`avoiding cleaning their own dishes with WFM. This is a constant complaint for several years and
`
`WFM management has refused to act or resolve this issue.
`
`43.
`
`
`
`Plaintiff was instructed to perform tasks for separate teams despite there being an
`
`employee in that particular team who was readily available. Plaintiff refused to wash the dishes
`
`for the Bakery Team.
`
`44.
`
`Plaintiff was issued a write up by Mr. Roy for being insubordinate. Plaintiff refused to
`
`sign the write up.
`
`45.
`
`The Bakery Team employees for WFM started retaliating and harassing Plaintiff for
`
`refusing to perform their job duties.
`
`46.
`
`Plaintiff reported the disparate treatment and discrimination to the Ethics Website.
`
`47.
`
`
`
` On or about July 11, 2022, Plaintiff was sent home on administrative leave for refusing
`
`to wash dishes for the Bakery Team.
`
`Plaintiff’s employment was terminated on July 18, 2022.
`
`48.
`
`9
`
`
`
`
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 10 of 18
`
`
`
`
`
`CAUSES OF ACTION
`
`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)
`
`49.
`
`Plaintiff repeats and re-alleges the allegations contained in the paragraphs above, as if
`
`fully set forth herein.
`
`50.
`
`Defendant has engaged in intentional racial and national origin discrimination in the
`
`terms and conditions of the Plaintiff’s employment, including, but not limited to, the Plaintiff’s
`
`constructive termination in violation of the Civil Rights Act of 1964.
`
`
`
`Defendants’ conduct violates Title VII.
`
`51.
`
`52.
`
`By the conduct described above, Defendant intentionally deprived the Plaintiff of the
`
`same rights as enjoyed by other citizens to the creation, performance, enjoyment, and all benefits
`
`and privileges, of their employment relationship with Defendant, in violation of 42 U.S.C. §
`
`1981.
`
`53.
`
`
`
`As a result of defendant’s discrimination in violation of Section 1981, the Plaintiff has
`
`been denied employment advancement opportunities providing additional compensation, thereby
`
`entitling her to injunctive and equitable monetary relief; and have suffered anguish, humiliation,
`
`distress, inconvenience and loss of enjoyment of life because of defendant’s actions, thereby
`
`entitling her to compensatory damages.
`
`
`
`10
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 11 of 18
`
`
`
`
`
`54.
`
`In its discriminatory actions as alleged above, WFM has acted with malice or
`
`reckless indifference to the rights of the above-named African American Plaintiff and, thereby
`
`entitling her to an award of punitive damages.
`
`Plaintiff’s requests for relief are set forth below.
`
`55.
`
`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)
`
`56.
`
`Plaintiff repeats and re-alleges the allegations contained in the paragraphs above, as if
`
`fully set forth herein.
`
`57.
`
`Plaintiff is a member of a protected class and repeats and re-alleges the allegations
`
`contained in the paragraphs above, as if fully set forth herein.
`
`58.
`
`The conduct alleged herein violates Title VII of the Civil Rights Act of 1964, as
`
`amended, 42 U.S.C. § 2000e et seq., as Defendant WFM engaged in the practice of
`
`discrimination against Plaintiff.
`
`
`
`59.
`
`Defendant WFM intentionally discriminated against Plaintiff by subjecting her to
`
`discriminatory compensation, in violation of Title VII of the Civil Rights Act of 1964 and the
`
`Lilly Ledbetter Fair Pay Act.
`
`
`
`11
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 12 of 18
`
`Plaintiff’s requests for relief are set forth below.
`
`60.
`
`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)
`
`
`
`61.
`
`Plaintiff repeats and re-alleges the allegations contained in the paragraphs above as if
`
`
`
`
`
`
`
`
`
`fully set forth herein.
`
`62.
`
`
`
`Plaintiff lodged complaints with Defendant WFM and the EEOC regarding the
`
`discrimination to which she was subjected under the EPA, and as such engaged in protected
`
`activity.
`
`63.
`
`
`
`WFM retaliated against Plaintiff by, in addition to other retaliatory behavior, further
`
`isolating her, constantly monitoring and criticizing her work, adding additional workload and
`
`new, draconian work conditions, subjecting her to threatening and abusive behavior, subjecting
`
`her to harassment, and in each case, as a result of her complaints of unlawful employment
`
`practices and termination.
`
`64.
`
`
`
`
`
`The conduct alleged herein violates The Equal Pay Act of 1963, 29 U.S.C. §§ 206, et seq.
`
`WFM's actions were taken with malice or reckless indifference, entitling Plaintiff to
`
`65.
`
`recover punitive damages.
`
`
`
`
`
`12
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 13 of 18
`
`
`
`
`
`66.
`
`Plaintiff’s requests for relief are set forth below.
`
`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)
`
`67.
`
`
`
`Plaintiff repeats and re-alleges the allegations contained in the paragraphs above as if
`
`fully set forth herein.
`
`68.
`
`
`
`Plaintiff is a member of a protected class and repeats and re-alleges the allegations
`
`contained in the paragraphs above as if fully set forth herein.
`
`69.
`
`
`
`Plaintiff lodged complaints with Defendant WFM and the EEOC regarding the
`
`discrimination to which she was subjected, and as such engaged in protected activity under
`
`Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e et seq.
`
`70.
`
`WFM retaliated against Plaintiff by, in addition to other retaliatory behavior, further
`
`isolating her, constantly monitoring and criticizing her work, adding additional workload and
`
`new, draconian work conditions, subjecting her to threatening and abusive behavior, subjecting
`
`her to harassment, and in each case, as a result of her complaints of unlawful employment
`
`practices.
`
`71.
`
`
`
`The conduct alleged herein violates Title VII of the Civil Rights Act of 1964, as
`
`amended, 42 U.S.C. § 2000e et seq.
`
`
`
`13
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 14 of 18
`
`
`
`
`
`WFM's actions were taken with malice or reckless indifference, entitling Plaintiff to
`
`72.
`
`recover punitive damages.
`
`Plaintiff’s requests for relief are set forth below.
`
`73.
`
`
`
`
`
`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)
`
`Plaintiff is a member of a protected class and repeats and re-alleges the allegations
`
`74.
`
`contained in the paragraphs above, as if fully set forth herein.
`
`75.
`
`The conduct alleged herein violates Title VII of the Civil Rights Act of 1964, as
`
`amended, 42 U.S.C. §2000e et seq., as Defendant WFM created and fostered a hostile work
`
`environment based on Plaintiff's race.
`
`76.
`
`Defendant WFM intentionally discriminated against Plaintiff by creating and fostering
`
`policies and a work environment that singled out and disadvantaged Plaintiff compared to
`
`similarly situated Caucasian employees, in violation of Title VII of the Civil Rights Act of 1964.
`
`Plaintiff requests for relief are set forth below.
`
`77.
`
`
`
`
`
`
`
`
`
`14
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 15 of 18
`
`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)
`
`Plaintiff repeats and re-alleges the allegations contained in the paragraphs above as if
`
`78.
`
`
`
`
`
`
`
`
`
`fully set forth herein.
`
`79.
`
`
`
`Plaintiff is a member of a protected class and repeats and re-alleges the allegations
`
`contained in the paragraphs above as if fully set forth herein.
`
`
`
`Plaintiff practices the religion of Sikh.
`
`80.
`
`81.
`
`WFM intentionally referenced Plaintiff as a Muslim despite being put on notice she
`
`practices the religion of Sikh. Plaintiff was mocked for being a practicing Sikh.
`
`
`
`The conduct alleged herein violates Title VII of the Civil Rights Act of 1964, as
`
`82.
`
`amended, 42 U.S.C. § 2000e et seq.
`
`83.
`
`WFM's actions were taken with malice or reckless indifference, entitling Plaintiff to
`
`recover punitive damages.
`
`84.
`
`Plaintiff’s requests for relief are set forth below.
`
`
`
`
`
`
`15
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 16 of 18
`
`
`
`
`
`ADMINISTRATIVE PROCEDURES
`
`1.
`
`On or about October 21, 2022, the Plaintiff filed a timely Charge of Discrimination
`
`alleging racial discrimination with the Equal Employment Opportunity Commission (“EEOC”).
`
`(A true and accurate copy of EEOC Charge of Discrimination # 461-2022-01109, is attached
`
`hereto as “Exhibit A”)
`
`2.
`
`
`
`The Plaintiff has satisfied all statutory prerequisites for filing this action.
`
`3.
`
`On or about August 17, 2023, the EEOC issued a “Determination and Notice Of Rights”
`
`letter for her Charge of Discrimination. On or about August 18, 2023, Plaintiff received this
`
`letter. (A true and accurate copy of the EEOC “Dismissal and Notice of Rights” letter for EEOC
`
`Charge of Discrimination # 461-2022-01109, is attached hereto as “Exhibit B”)
`
`To remedy the violations of the rights of the Plaintiff, Plaintiff requests that the Court
`
`4.
`
`award her the relief prayed for below.
`
`
`PRAYER FOR RELIEF
`
`
`
`WHEREFORE, Gurmeet Kaur prays for the following relief:
`
`1.
`
`That the practices of Defendant WFM complained of herein be determined and adjudged
`
`to be in violation of the rights of Plaintiff under Title VII, 42 U.S.C. § 1981, the EPA and any
`
`other cause(s) of action that can be inferred from the facts set forth herein;
`
`
`
`16
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 17 of 18
`
`
`
`
`
`2.
`
`All damages which Ms. Kaur has sustained as a result of Defendant WFM's conduct,
`
`including back pay, front pay, liquidated damages, punitive damages, general and special damages
`
`for lost compensation and job benefits she would have received but for Defendant WFM’s
`
`unlawful and retaliatory conduct;
`
`3.
`
`
`
`An award to Plaintiff of pre-judgment interest at the highest available rate, from and after
`
`the date of service of the initial complaint in this action on all owed wages from the date such
`
`wages were earned and due;
`
`4.
`
`
`
`An award representing Defendant WFM's share of FICA, FUTA, state unemployment
`
`insurance and any other required employment taxes;
`
`5.
`
`
`
`Awarding Ms. Kaur her costs and disbursements incurred in connection with this action,
`
`including reasonable attorneys' fees, expert witness fees, and other costs;
`
`6.
`
`
`
`An award to Plaintiff of compensatory and punitive damages against all Defendants,
`
`including but not limited to damages for physical injury, emotional distress, humiliation,
`
`embarrassment, and anguish;
`
`
`
`Post-judgment interest, as provided by law; and
`
`7.
`
`8.
`
`17
`
`
`
`
`
`

`

`Case 2:23-cv-06830-JCZ-DPC Document 1 Filed 11/13/23 Page 18 of 18
`
`
`
`
`
`
`
`Such other and further legal and equitable relief as may be found appropriate and may be
`
`deemed just or equitable.
`
`JURY DEMAND
`
`Ms. Kaur demands a trial by jury of all issues do triable in this action.
`
`Respectfully submitted this 13th day of November 2023.
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully Submitted,
`
`THE MINIAS LAW FIRM
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/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
`
`
`SERVICE INFORMATION
`
`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:
`
`Corporation Service Company
`450 Laurel Street, 8th Floor
`Baton Rouge, LA 70801
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Christopher Minias
`CHRISTOPHER MINIAS
`
`
`
`
`
`
`
`18
`
`
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket