Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Look up keyword
Like this
6Activity
0 of .
Results for:
No results containing your search query
P. 1
Darden v. Halliburton

Darden v. Halliburton

Ratings: (0)|Views: 3,450 |Likes:
Published by DallasObserver

More info:

Published by: DallasObserver on Dec 28, 2010
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

12/28/2010

pdf

text

original

 
T
HE
ELLY
L
AW
F
IRM
,
 
P.C.
Original Complaint  Page 1 of 6 
IN THE UNITED STATES DISTRICT COURTFOR THE NORTHERN DISTRICT OF TEXAS(DALLAS DIVISION)LYNDA DARDEN §Plaintiff, §§VS. § CIVIL ACTION NO.
_______ 
 §§HALLIBURTON ENERGY SERVICES, INC. §§Defendant, § JURY TRIAL DEMANDEDPLAINTIFF’S ORIGINAL COMPLAINT AND JURY DEMAND
  NOW COMES, Lynda Darden, and files this suit against Halliburton Energy Services,Inc. complaining about sexual discrimination and wrongful termination, and would show thefollowing:
NATURE OF THE CASE
 1. This is a sex discrimination case arising out of Lynda Darden’s termination fromHalliburton Energy Services, Inc. in Alvarado, Texas as a result of becoming pregnant whileemployed by the company. At all times relevant to these allegations, Lynda Darden was anemployee of Halliburton Energy Services, Inc. when she was sexually discriminated against andterminated as a result of her pregnancy. The individuals who promulgated the acts which madecertain that Halliburton would not continue to employ Plaintiff and which form the basis of thislawsuit were at all times under the employ of Halliburton Energy Services.
Case 3:10-cv-02609-P Document 1 Filed 12/21/10 Page 1 of 6 PageID 1
 
T
HE
ELLY
L
AW
F
IRM
,
 
P.C.
Original Complaint  Page 2 of 6 
PARTIES
 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
 
T
HE
ELLY
L
AW
F
IRM
,
 
P.C.
Original Complaint  Page 3 of 6 
PROCEDURAL BACKGROUND
6. Plaintiff has exhausted all administrative remedies required as a prerequisite to filing thiscivil action. Specifically, Lynda timely filed a Charge of Discrimination with the United StatesEqual Employment Opportunity Commission (“EEOC”) and the Texas Workforce Commissionunder the “dual filing” rule. The EEOC issued Lynda written notice of her right to sue. Lyndafiled this civil action within 90 days of receiving notice of her right to sue from the EEOC.
1
FACTS
 It has become necessary to file this suit as a result of the following facts.7. Lynda Darden was hired by Halliburton Energy Services in 2007 in Grand Junction,Colorado. In 2008, she was transferred to Texas and worked as an administrative associate in thedispatch office at the Alvarado Camp. She was a good employee and well respected.8. In March of 2009, Lynda informed her supervisor, Mike Queener, that she was pregnant.9. On June 3, 2009, when Lynda was 27 weeks pregnant, she was called into KevinAnderson’s office. Kevin Anderson was the subordinate immediately below Mr. Queener. Also present in Mr. Anderson’s office was a woman named Bridgette from Human Resources.10. When Lynda was seated, Mr. Anderson informed Lynda that she was being laid off fromher employment. She was instructed to take only her personal belongings and to leave all other items and vacate the premises.11. Mr. Anderson walked Lynda out to her car to retrieve her badge.12. To her knowledge, Lynda was the only employee “laid off” in her area even though there
1 See Attachment 1, Lynda Darden’s “Right to Sue” Letter 
Case 3:10-cv-02609-P Document 1 Filed 12/21/10 Page 3 of 6 PageID 3

Activity (6)

You've already reviewed this. Edit your review.
1 thousand reads
1 hundred reads

You're Reading a Free Preview

Download
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->