Original Complaint Page 2 of 6
2. Plaintiff, Lynda Darden currently resides in Dallas, Texas, and began working for Halliburton Energy Services in 2007 in Grand Junction, Colorado. In 2008, she was transferredto Texas and worked as an administrative associate in the dispatch office at the Alvarado Camp.Although a good, dedicated and productive employee, she was terminated on June 3, 2009, whenshe apparently violated the company’s policy against procreation.3. Defendant, Halliburton Energy Services, Inc. (hereinafter, “Halliburton”) was a Delawarecorporation headquartered in Houston, Harris County, Texas at the time Lynda signed her employment contract. Halliburton regularly conducts business throughout the State of Texas andis, thus, amenable to jurisdiction in this State. This Defendant may be served with process byservice upon its registered agent, CT Corporation System, 350 N. St. Paul Street, Suite 2900,Dallas, Texas 75201-4234.
JURISDICTION, VENUE AND LIMITATIONS
4. Jurisdiction is based on federal question. 28 U.S.C. §1332. The amount in controversy issubstantially in excess of Seventy-Five Thousand Dollars ($75,000), exclusive of interest andcosts. Defendant regularly conducts business within the Northern District and the eventsinvolved took place in Johnson County. Therefore, venue is permissible in this District pursuantto 28 U.S.C. §1391.5. Further, this Court has subject matter jurisdiction in that Plaintiff’s injuries arose due toviolations of Title VII of the Civil Rights Act of 1964, as well as pendant jurisdiction over Plaintiff’s claims under Chapter 21 of the Texas Labor Code.
Case 3:10-cv-02609-P Document 1 Filed 12/21/10 Page 2 of 6 PageID 2