Betty Biggs Case

Plaintiff Betty Biggs,,("Plaintiff" or "Ms. Biggs"), presents her Complaint in this action against Defendant Admiral Health. ("Defendant" or "employer"), hereby alleges as follows:
NATURE OF THE CLAIMS
1. This is an action for declaratory, injunctive and equitable relief, as well as monetary damages, to redress Defendant's unlawful employment practices and retaliation against Plaintiff, including Defendant's unlawful discrimination, harassment and retaliation against Plaintiff because of his race/color, national origin and/or disabilities, and because of his repeated complaints about such unlawful discrimination, harassment and retaliation, in violation of Section 1981 of the Civil Rights Act of 1866, 42 U.S.C. § 1981 ("Section
The Court has jurisdiction over this action pursuant to 28 U.S.C. §§ 1331 and 1343, as this action involves federal questions regarding the deprivation of Plaintiff's civil rights under Title VII, Section 1981. The Court has supplemental jurisdiction over Plaintiff's related claims arising under state and local law pursuant to 28 U.S.C. § 1367(a). Venue is proper in this district pursuant to 28 U.S.C. § 1391(b) because a substantial part of the events or o practices alleged herein, occurred in this district missions giving rise to this action, including the unlawful employment
PARTIES
3. Plaintiff Betty Biggs is an Ecuadorian immigrant to the United States. From in or around June 2000 to the present, Ms. Biggs has been an employee at Defendant's Admiral Health in New York City. At all relevant times, Ms. Biggs met the definition of an "employee" under all applicable statutes. 4.Admiral Health, Defendant, is a corporation authorized to conduct business in the State of New York with its principle executive office located at 1111 Blue Ridge Road , Suite 800 Dublin, New York, 10701. At all relevant times, Defendant owned, operated and maintained the Admiral Health. At all relevant times, Defendant met the definition of an "employer" under all applicable statutes.
PROCEDURAL
On August 15, 2012, Ms. Biggs filed a Verified Complaint (the "August 15, 2012 Complaint") with the EEOC charging Defendant with unlawful discriminatory employment practices based on its unlawful retaliation against him for having filed the May 21, 2012 Complaint. On October 26, 2012, the EEOC rendered a determination finding probable cause to support the allegations of the August 15, 2012 Complaint. 8. On October 27, 2012, the Equal Employment Opportunity Commission ("EEOC") issued Ms. Biggs a notice of right to bring suit in federal district court based on the allegations of unlawful discrimination on the basis of race/color, national origin set forth in the May 21, 2012 Complaint. 9. On October 27, 2012, the EEOC issued Ms. Biggs a notice of right to bring suit in federal district court based on the allegations of unlawful retaliation set forth in the August 15, 2012 Complaint. 10. This action has been filed within 90 days of Plaintiff's receipt of his right-to-sue letters from the EEOC. 11. Any and all other prerequisites to the filing of this suit have been