Chapter 1. Pre-Litigation/Agency Proceedings
1-001 Introduction—Pre-Litigation/Agency Proceedings
1-002 Demand Letter—Pregnancy Discrimination
1-003 Demand Letter—New York State Whistleblower Law
1-004 EEOC Charge of Discrimination
1-005 Details of EEOC Charge—Gender Discrimination, Age Discrimination and Retaliation
1-006 Details of EEOC Charge—Race Discrimination, Racial Harassment and Retaliation
1-007 Employer’s Position Statement—Retaliation
1-008 New York State Division of Human Rights Complaint
1-009 Answer to Complaint Filed in New York State Division of Human Rights—Disability Discrimination
Chapter 2. Pleadings
2-001 Introduction—Pleadings
2-002 Summons—Civil Action
2-003 Complaint—Fair Labor Standards Act
2-004 Complaint—Race and Gender Discrimination, Sexual Harassment, Retaliation
2-005 Complaint—Sex and Age Discrimination, Retaliation
2-006 Complaint—Disability Discrimination and Retaliation
2-007 Complaint—Age and Disability Discrimination
2-008 Complaint—Race, National Origin, and Religion Discrimination, Intentional Infliction of Emotional Distress, Negligent Infliction of Emotional Distress
2-009 Complaint—Age Discrimination and Retaliation
2-010 Answer—Age and Disability Discrimination (Answer to Complaint 2-007)
2-011 Answer—Age Discrimination and Retaliation (Answer to Complaint 2-009)
2-012 Corporate Disclosure Statement—No Disclosure
2-013 Corporate Disclosure Statement—Disclosure of Subsidiary Relationship
Chapter 3. Discovery Demands
3-001 Introduction—Discovery Demands
3-002 Plaintiff’s Initial Disclosures—Disability Discrimination
3-003 Defendant’s Initial Disclosures—Sexual Harassment
3-004 Plaintiff’s Request for the Production of Documents—Race Discrimination and Retaliation
3-005 Defendant’s Request for the Production of Documents—Age Discrimination
3-006 Plaintiff’s Interrogatories—Disability Discrimination and Retaliation
3-007 Defendant’s Interrogatories—Race Discrimination
3-008 Plaintiff’s Notice to Admit—Disability Discrimination
3-009 Subpoena to Appear to Testify at a Hearing or Trial in a Civil Action
3-010 Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action
3-011 Notice of Deposition 107
3-012 Plaintiff’s Rule 30(b)(6) Notice of Deposition of Representative of Corporate Defendant
3-013 Plaintiff’s Notice of Deposition for a Specific Witness of Defendant
3-014 Errata Sheet
3-015 Disclosure of Plaintiff’s Psychologist
3-016 Disclosure of Plaintiff’s Economics Expert
3-017 Memorandum of Law in Support of Defendant’s Motion for Order Requiring Plaintiff to Submit to a Rule 35 Mental Examination—Disability Discrimination
Chapter 4. Discovery Motions
4-001 Introduction—Discovery Motions
4-002 Letter Requesting Pre-Motion Conference
4-003 Defendant’s Memorandum of Law in Support of its Motion to Compel Answers to Interrogatories and Initial Disclosure—Race Discrimination
4-004 Defendant’s Memorandum of Law in Opposition to Plaintiff’s Motion to Compel Discovery of Investigative Materials—Religion and National Origin Discrimination
4-005 Defendant’s Memorandum of Law in Opposition to Motion to Compel Production of Employment Records—Religion Discrimination
4-006 Defendant’s Memorandum of Law in Support of Motion to Compel Documents Withheld on Basis of Attorney-Client Privilege and Work Product Doctrine—Sexual Harassment
4-007 Defendant’s Memorandum of Law in Support of Motion for Protective Order Limiting the Scope of Witness Deposition—Race Discrimination
4-008 Defendant’s Memorandum of Law in Support of Motion to Quash Deposition Notices
4-009 Plaintiffs’ Memorandum of Law in Support of Motion for Sanctions for Spoliation of Electronic Evidence—Age Discrimination
Chapter 5. Dispositive Motions
5-001 Introduction—Dispositive Motions
5-002 Defendant’s Memorandum in Support of its Motion for Judgment on the Pleadings and Dismissal of Claims—Disability Discrimination Library of New York Employment Law Forms
5-003 Memorandum of Law in Support of Defendant’s Motion to Dismiss—Intentional Infliction of Emotional Distress/Negligent Infliction of Emotional Distress
5-004 Defendant’s Memorandum of Law in Support of Motion for Summary Judgment—Sexual Harassment, Vicarious Liability
5-005 Defendant’s Memorandum of Law in Support of Motion for Summary Judgment—Race Discrimination
5-006 Plaintiff’s Memorandum of Law in Opposition to Defendant’s Motion for Summary Judgment—Race and Gender Discrimination
5-007 Defendant’s Reply Memorandum in Further Support of its Motion for Summary Judgment—Age Discrimination
Chapter 6. Trial
6-001 Introduction—Trial
6-002 Joint Pretrial Order Forms—Eastern District of New York
6-003 Plaintiff’s Proposed Voir Dire Questions—Disability Discrimination
6-004 Plaintiff’s Proposed Voir Dire Questions—Gender Discrimination
6-005 Defendant’s Proposed Voir Dire Questions—Age Discrimination
6-006 Plaintiff’s Proposed Jury Instructions—Disability Discrimination and Retaliation
6-007 Plaintiff’s Proposed Jury Instructions—Disability Discrimination
6-008 Defendant’s Proposed Jury Instructions—Age Discrimination
6-009 Defendant’s Proposed Jury Instructions—Gender Discrimination
6-010 Defendant’s Memorandum of Law in Support of Motion in Limine to Preclude Expert Testimony—Disability Discrimination
6-011 Subpoena to Appear and Testify at Hearing or Trial in a Civil Action
Chapter 7. Appeals
7-001 Introduction—Appeals
7-002 Notice of Appeal
7-003 Second Circuit Civil Appeal Pre-Argument Statement (Form C)
7-004 Second Circuit Civil Appeal Transcript Information (Form D)
7-005 Brief for Plaintiff-Appellant—ERISA
7-006 Brief for Plaintiffs-Appellees—FLSA
7-007 Brief for Defendant-Appellee—Race and Age Discrimination
7-008 Brief for Defendant-Appellee—National Origin and Gender Discrimination
7-009 Reply Brief for Plaintiff-Appellant—Gender Discrimination
Chapter 8. Pleadings
8-001 Introduction—Pleadings
8-002 Summons
8-003 Complaint—Unfair Competition, Misappropriation and Breach of Non-Solicitation Agreement
8-004 Complaint—Age Discrimination, Intentional Infliction of Emotional Distress and Defamation
8-005 Complaint—Race, National Origin, and Religion Discrimination, Breach of Implied Contract, and Violation of Labor Law
8-006 Complaint—Disability Discrimination and Retaliation
8-007 Complaint—Breach of Employment Agreement, Violation of Labor Law and Pregnancy Discrimination
8-008 Complaint—Tortious Interference with Employment Agreements and Unjust Enrichment
8-009 Complaint—Breach of Employment Agreement and Restrictive Covenants, Breach of Fiduciary Duty, Tortious Interference with Contract, Unfair Competition and Injunctive Relief
8-010 Answer—Unfair Competition, Misappropriation of Trade Secrets, and Breach of Non-Solicitation Agreement (Answer to Complaint 8-003)
8-011 Answer—Race, National Origin and Religion Discrimination, Breach of Implied Contract, and violation of Labor Law (Answer to Complaint 8-005)
8-012 Verification for Individual Party
8-013 Verification for Corporate Party
8-014 Attorney Verification
Chapter 9. Demands for Disclosure
9-001 Introduction—Demands for Disclosure
9-002 Authorization for Release of Health Information Pursuant to HIPPA
9-003 Plaintiff’s Request for the Production of Documents—Breach of Employment Agreement, Race and Age Discrimination
9-004 Plaintiff’s Request for the Production of Documents—Gender Discrimination, Sexual Harassment
9-005 Defendant’s Request for the Production of Documents—Race Discrimination
9-006 Plaintiff’s Interrogatories—Breach of Employment Agreement
9-007 Plaintiff’s Interrogatories—Breach of Non-Competition Agreement and Non-Solicitation
9-008 Defendant’s Interrogatories—Disability Discrimination
9-009 Defendant’s Interrogatories—Discrimination and Retaliation
9-010 Defendant’s Interrogatories—Wrongful Solicitation, Breach of Employment Agreement and Unfair Competition
9-011 Subpoena Duces Tecum
9-012 Notice of Deposition
9-013 Notice of Deposition—Videotape, Audiotape
9-014 Demand for Expert Witness Information
Chapter 10. Disclosure Motions
10-001 Introduction—Disclosure Motions
10-002 Notice of Motion
10-003 Plaintiff’s Memorandum of Law in Support of Motion to Establish the Order of Disclosure
10-004 Plaintiff’s Memorandum of Law in Support of Motion to Compel Depositions
10-005 Defendant’s Memorandum of Law in Opposition to Plaintiff’s Motion to Compel Production of EEOC Charges Filed Against Defendant
10-006 Defendant’s Memorandum of Law in Support of Motion to Compel the Production of Documents Regarding Employee Loan
10-007 Defendant’s Memorandum of Law in Opposition to Plaintiff’s Motion for a Protective Order Staying the Deposition of a Non-Party Witness
10-008 Defendant’s Memorandum of Law in Support of Motion for the Imposition of Discovery Sanctions Against Plaintiff
10-009 Good Faith Affirmation
Chapter 11. Dispositive Motions
11-001 Introduction—Dispositive Motions
11-002 Notice of Motion
11-003 Defendant’s Memorandum in Support of Motion to Dismiss Complaint—Breach of Employment Agreement, Violation of New York Labor Law
11-004 Defendant’s Memorandum of Law in Support of Motion for Summary Judgment—Race Discrimination and Harassment
11-005 Plaintiff’s Memorandum of Law in Opposition to Defendant’s Motion to Dismiss—Sexual Orientation and Gender Discrimination
11-006 Defendant’s Reply Memorandum of Law in Further Support of its Motion for Summary Judgment—Limitations Period
Chapter 12. Trial
12-001 Introduction—Trial
12-002 Plaintiff’s Jury Instructions—Disability Discrimination and Hostile Work Environment
12-003 Defendant’s Proposed Jury Instructions—Gender Discrimination and Sexual Harassment
12-004 Defendant’s Proposed Jury Instructions—Age Discrimination
12-005 Defendant’s Memorandum of Law in Support of its Motion In Limine to Preclude Plaintiff’s Testimony on Damages
12-006 Plaintiff’s Memorandum of Law in Opposition to Defendant’s Motion In Limine to Preclude Plaintiff’s Psychiatric Expert
12-007 Plaintiff’s Memorandum of Law in Opposition to Defendant’s Motion In Limine to Preclude Evidence of Other Types of Discrimination
12-008 Trial Subpoena
Chapter 13. Appeals
13-001 Introduction—Appeals
13-002 Notice of Appeal
13-003 Brief for Plaintiff-Appellant—Gender Discrimination
13-004 Brief for Defendant-Appellant—Pregnancy Discrimination
13-005 Brief for Defendant-Respondent—Breach of Restrictive Covenant
13-006 Reply Brief for Plaintiff-Appellant—Age Discrimination
Chapter 14. Settlement Agreements
14-001 Introduction—Settlement Agreements
14-002 Settlement Agreement with Release of ADEA Claims
14-003 Settlement Agreement without Release of ADEA Claims