Hi all,
I am going to type up here just the pertinent points for now of these court records.
Scanned in complete copies will be available soon.
CIVIL COVER SHEET
1a.
Plaintiffs
Michael R. McClaughry
Defendants
David Morse and Associates, Inc.
VI Cause of Action 42 USC 2000e-discimination
VII Requested in complaint
(jury demand yes box checked)
filed 7/25/000 case number CS-00-0250-RHW
Next document is the summons to David Morse and Associates, who has 30 days to respond or judgement by default will be taken.
-- next is Complaint FOR MONEY DAMAGES AND INJUNCTIVE RELIEF/JURY DEMAND
Comes Now the plaintiff, Michael R. McClaughry, etc. etc.
I. JURISDICTION
1. This action is brought by plaintiff seeking damages pursuant to 28 USC 1331 and 1343 (4).
2. Jurisdiction is conferred upon this court by 28 USC 1331 and/or 28 USC 1343 (4).
3. Plaintiff is entitled to protection against religious discrimination pursuant to 42USC 2000e et seq.
4. Plaintiff has exhausted all administrative requirements precedent to the bringing of this action. See attachment "A", Notice of Right to Sue, which is incorporated herein by this reference as though fully set forth.
II.
PARTIES
5. Plaintiff, Michael R. McClaughry, is a citizen of the United States and a resident of Post Falls, State of Idaho.
6. Defendant, David Morse & Associates, Inc., is a California corporation engaged in the insurance adjusting business in Spokane Count, State of Washington. Defendant employs more than 15 employees.
III.
FEDERAL DISCRIMINATION CLAIM
7. Plaintiff, Michael R. McClaughry, began his employment with defendant, David Morse & Associates, Inc., on or about January 1996.
Plaintiff, Michael R. McClaughry, was terminated from his employment with the defendant, David Morse & Associates, Inc., in July, 1999.
8. Plaintiff, Michael R. McClaughry, was terminated because of his religious beliefs. Specifically, plaintiff was advised by Bernard P. Daugherty, his supervisor, that he would have to leave the employ of David Morse & Associates, Inc., because the plaintiff was in the process of being expelled from the Church of Scientology. Bernard P. daugherty is a member of the Church of Scientology, along with a number of high ranking officials and employees of defendant, david Morse & Associates, Inc. It is a requirement of the Church of Scientology that a member not associate with an expelled former member of the Church of Scientology. mr. Daugherty was aware that the plaintiff was in the process of being expelled from the Church of Scientology.
9. these acts and failures to act by defendant constitute religious discrimination in violation of plaintiff's civil rights pursuant to Title VII of the Civil Rights Act of 1964, as amended, 42 USC 2000e. et seq.
IV
PENDENT JURISDICTION/STATE CLAIMS
10. Plaintiff realleges the foregoing paragraphs as though fully set forth.
11. These acts and failures to act by defendant constitute creed/religious discrimination in violation of RCW 49.60 for which plaintiff has suffered economic and non-economic damages in an amount to be proven at trial and exceeding the jurisdictional limits of this court.
12. These acts and failures to act by defendant constitute the torts of : intentional infliction of emotional distress, outrage, and negligent infliction of emotional distress.
Wherefore, Plaintiff, Michael R. McClaughry, prays for the following relief:
1. Judgement against defendant for damages in an amount to be proven at trial;
2. Judgement against defendant for back pay, interest on back pay, front pay, and other relief authorized by 42 USC 2000e-5;
3. For an award of costs, including a reasonable attorney fee pursuant to 42 USC 2000e et seq., 29USC 1001, et seq., RCW 46.60.030, and RCW 49.48.030;
4. For an award of double damages pursuant to RCW 49.52.070;
5. For punitive damages and other relief pursuant to 42 USC 1981, et seq.;
6. For injunctive relief enjoing defendant from all further discrimination against plaintiff pursuant to 42 USC 2000e et seq. and RCW 49.60.030; and
7. For such other and further relief as the court deems just and equitable.
DATED this 25th day of July, 2000.