Agency charge
A two-page charge of discrimination: numbered particulars, each event dated, prepared for dual filing with the EEOC and the state agency.
Fictitious sample charge (PDF, 2 pages, 138 KB)
I draft for law firms. I am not an attorney admitted in any United States jurisdiction, and I do not give legal advice to individuals. If you are an employee looking for a lawyer, please contact a lawyer or your state bar's lawyer referral service.
I prepare drafts for plaintiff-side employment firms: intake memos, agency charges, complaints, and mediation papers. Each draft is for a partner at the firm to review, adopt, and sign.
I have more than seven years of drafting for plaintiff-side employment practices in New York.
Ask about a piece of work for your firm
Please do not send client files or other confidential material by email before an engagement is in place.
I. Selected work
One fictitious matter, followed through the pieces a firm would order.
Federal complaint
The same facts as a federal complaint: caption, numbered factual allegations, five claims for relief, and a signature block left blank for the firm.
Intake screening memo
The packet organized: the facts by date, the documents received and the gaps, and the questions left open for the reviewer's decision.
Fictitious sample intake screening memo (PDF, 3 pages, 190 KB)
Record chronology and source map
Each factual paragraph of the complaint tied to its source and labeled document, client account, belief or open, with a dated chronology and the open items.
Fictitious sample record chronology and source map (PDF, 2 pages, 230 KB)
II. What I take on
- Intake assessment
- A review of the facts and documents the firm sends, with a written screening memo that organizes the facts, lists the documents and the gaps, and sets out the questions for the attorney's decision.
- Agency charge
- Drafts of EEOC and state and local fair-employment agency charges, amendments, and rebuttals, for the firm to review and file.
- Complaint
- Draft complaints, federal or state, for the partner to adopt and sign, including a draft that converts a charge after a right-to-sue notice.
What the firm receives:
- A draft in the firm's caption and house format.
- A source-to-paragraph map tying each factual paragraph to the record.
- Open questions as margin comments.
- Amended complaint
- Draft amended pleadings, worked from the firm's change list, for the partner to adopt and sign.
- Mediation or position statement
- Draft mediation statements or position statements, with exhibit sets and damages chronologies, for the partner to adopt.
Turnaround: three to five business days once the facts and documents are in hand. An agency charge takes three business days and a complaint five; other pieces are scheduled when the work is agreed.
III. How the work flows
- The firm and I agree the piece and the scope, run the conflicts check, and set a secure way to send the file.
- I return a draft in the firm's house format, with every record reference pinned to its source and open questions flagged in margin comments.
- The firm's supervising attorney reviews, adopts, and signs the draft, and decides what is filed.
IV. Background
I hold an LL.M. from the University of Leeds. I was called to the Bar of England and Wales at Lincoln's Inn, and I was admitted as an attorney-at-law in Trinidad and Tobago and in Grenada. I am not in active practice in those places, and I am not admitted in any United States jurisdiction.
V. Contact
Please do not send client files or other confidential material by email before an engagement is in place.