IN THE UNITED STATES DISTRICT COURT FOR THESOUTHERN DISTRICT OF TEXAS,HOUSTON DIVISIONKaren L. Tounkara, §Plaintiff, §§v. § Civil Action No. __________§ JuryK.B.R., Inc., §Defendant. §PLAINTIFF'S ORIGINAL COMPLAINTA. Parties1. Plaintiff, Karen L. Tounkara, is an individual that is a citizen of the State of Texas.2. Defendant, K.B.R., Inc., is a corporation that is incorporated under the laws of the State of Texas. Defendant has its principal place of business in the State of Texas.Defendant may be served with process by serving its registered agent, CT Corporation, at350 N. St. Paul Street, Dallas, Texas 75201.B. Jurisdiction3. The court has jurisdiction over the lawsuit because the action arises under 42U.S.C. §2000e

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2. Plaintiff was discriminated against on the basis of religion, Islam.C. Venue4. Venue is proper in this district under 42 U.S.C. §2000e-5(f)(3) because thealleged unlawful employment practice was committed in this district. Plaintiff was

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discrimi

nated against on the basis of religion at the employer’s location, 4100 Clinton

Drive, Houston, Texas 77020.D. Exhaustion of Administrative Procedures5. Plaintiff timely filed a charge of discrimination against defendant with the EqualEmployment Opportunity Commission (EEOC). Plaintiff files this complaint within 90days after receiving a notice of the right to sue from the EEOC. A copy of the notice of the right to sue is attached as Exhibit A.E. Count 1 - Discrimination Under Title VII6. Plaintiff is an employee within the meaning of Title VII and belongs to a classprotected under the statute, namely employees protected from religious discrimination.7. Defendant is an employer within the meaning of Title VII.8. Defendant intentionally discriminated against plaintiff because of her religion

inviolation of Title VII by failing to make a reasonable, religious accommodation to allowthe plaintiff to wear her hijab (headscarf) in observance of her Muslim faith during herhours of employment.F. Damages9. As a direct and proximate result of defendant's conduct, plaintiff suffered thefollowing injuries and damages.

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a. Plaintiff was discharged from employment with defendant. Althoughplaintiff has diligently sought other employment, she has been unable tofind a job. In addition, plaintiff has incurred expenses in seeking otheremployment

b. Plaintiff suffered mental anguish and emotional distress in the form of depression, anxiety, personal humiliation and shame.c. Plaintiff suffered physical illness in the form of depression, stress, insomnia,lack of appetite, chronic irritability.G. Attorney Fees10. Plaintiff is entitled to an award of attorney fees and costs under Title VII, 42U.S.C. §2000e-5(k).H. Prayer11. For these reasons, plaintiff asks for judgment against defendant for thefollowing:a. Compensatory damages.b. Punitive Damages.c. Pre-judgment interest.d. Post-judgment interest.