IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION KIMBERLY FULLER, ) ) Plaintiff, ) Case No. 13-CV-00376 ) vs. ) ) TROXEL INDUSTRIES, INC., ) ) Defendant. ) COMPLAINT AND JURY TRIAL DEMAND Plaintiff Kimberly Fuller, by and through her undersigned counsel, for her Complaint against Defendant Troxel Industries, Inc. alleges: JURISDICTION AND VENUE 1. This action is brought to remedy discrimination on the basis of gender in the terms, conditions, and privileges of employment, and for retaliation in violation of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000 et seq . (“Title VII”). 2. Plaintiff Kimberly Fuller filed a charge of sex discrimination and retaliation against Defendant Troxel Industries, Inc. with the Equal Employment Opportunity Commission (“EEOC”) on September 24, 2012. 3. The EEOC issued its Letter of Determination on March 4, 2013, which stated: Charging Party alleged that she was discriminated against in violation of Title VII when her manager made implied promises of success within the company coupled with ongoing unwanted sexual advances and offensive remarks. On several occasions, Charging Party reported the sexual harassment, hostile behavior, and unfair treatment but the harassment continued. In retaliation for having reported the sexual harassment, she was placed in a situation where performing her duties at work became impossible. Due to the hostile work environment and retaliatory treatment, Charging Party was forced to resign her position with her employer. I have considered all the evidence obtained during the investigation and find that there is reasonable cause to believe that Charging Party was sexually harassed.
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- Discrimination, Pleading, Equal Employment Opportunity Commission