Malay Parekh

[Enter Address]

[Enter Date]


[Enter Address]

Re: Complaint for Discrimination and Unlawful Dismissal


I am writing in reference to the unlawful termination of my services, and discriminatory conduct that I was subjected to at your Company. I have been working as a Software Architect in your company. I am a woman approaching my 50s in the next few years.

First, I highly appreciate the fact that I worked in your respectable Company. Working with your Company gave me an opportunity to exercise my skills and advance my career. However, I would like to state that I find staff at your company including my supervisors at fault for their discriminatory conduct against me; and for terminating my employment without due cause.

The incidences that form the subject matter of this Complaint letter are as follows:

  1. On or about November 2020, my physician recommended a two-week rest. However, my supervisor, Ian Temple (hereinafter “Ian”), insisted that I report to work. I then informed him that I would give him my physician’s number so he gets the information from him. He immediately stopped and the conversation ended.
  • On or about March 2021, Ian got upset with me for allegedly not documenting culture prep in the logbook. I informed him that the information is documented in the “Smartlab Session” but he refused to listen insulted me, and made me document culture prep in “Laboratory Notebook”. He then proceeded to make a copy of my “standard work steps” for that particular (Phage) procedure then cut it to size and made me paste it in Laboratory Notebook. During all this he treated me with attitude that I had a made gross error. It is notable that this was no error. I had many examples where other techs reported using this step during or at the end of the session. Between 2020- March 2021, there were about 50 sessions of “Phag” testing where all other analysts including me have documented their culture prep activity in SmartLab (LIMS system), and not in the Logbook.
  • On the same day, Kaylee, a microbiologist, instituted an investigation against me on the allegations that I failed to report a micrometer run. I informed both Kaylee and Ian that another staff member who was known to be an expert, was aware of the run and had permitted me to conduct it. Kaylee kept insisting rudely that I had to inform the microbiologist.
  • In 2020, my previous supervisor, Trisha Poer, allowed my fellow female co-worker to work from home, but I was denied that chance when I asked for it.
  • I was told by Ian to come to work on time, but they would allow two of my fellow employees to report to work late. Besides, Ian would check with me by asking when I had come to work, but per my knowledge he would not ask other employees.
  • Ian denied me the full two-weeks off of COVID-related leave when I was in close contact with someone who was COVID positive. He called me 11 days into the leave, without me having a negative result. On the other hand, he allowed another employee to quarantine for two full weeks.
  • Kaylee would on many occasions catch my errors in the second-person verification process, but would let go other employees for the same errors.
  • I was denied a change of shift during the COVID period, but other employees were granted shift changes in the same period.
  1. I was removed from performing crystal testing when I complained about defective media being used in crystal sample processing. On the other hand, they retained other analysts to test crystals, who did not complain about defective media. Notably, from 2020 to April 2021, I was rarely scheduled to run crystals. I complained about it to Ian in 2021 but I was assured that I would be rescheduled and that I should not worry.
  • My supervisor made me work in a very small and enclosed lab where sewer was backed up. The place was reeking of sewer gas. When I complained about it, I was told to leave the door open. I also reported of headaches as a result of the situation too. However, I was told by Ian that no other analyst has raised the same complaint. In fact another analyst called “Matt” had complained about headache when I discussed this with him. In casual talk he mentioned, “Sewer Gas gave me headache.”
  • In meeting with Ian when I expressed my concerns that I felt that I was being discriminated in the lab. My supervisor did not take it seriously but shook it off and told me “we all are different”.
  • I described how I was treated by Kaylee with whom I had to deal with the most. However, he just listened. I raised the following concerns:
  1. Kaylee threw away sign which was on shaker when I was working on Dan’s project. I found it to be a very mean behaviour which was seen by M.Verburg.
  1. One day in 2020 after sanitizing BSC, I accidentally and unknowingly turned off the light of that particular BSC. When she walked in to lab, she asked me whether BSC was cleaned or not. I replied I had sanitized it that morning. She then turned on the light of that BSC and loudly said, “if you turn on the light of BSC after sanitizing, other analysts would know that the BSC is clean.” Further she added that the florescent light will kill bacteria too. This was ridiculous. I have worked 18 years and never heard this. After a little while, M. Verburg (Senior Microbiologist) walked in. I asked him, whether florescent light kills bacteria.  He replied, “not really.” I then told him what had happened, upon which he changed his answer little and said,”maybe it does.”
  1. During 2019 I was schedule to run A method and Endotoxin testing on water samples. First I started with Endotoxin samples and I was planning to run A method samples in afternoon. Around 1230 when I was adding reagents to samples(the last step before running samples) Kaylee walked in to Endotoxin lab and asked me to confirm that weather I was on A method or not. I replied that I was on A method. She said she noticed A method samples in the refrigerator so she was worried. Usually when we are running Endotoxin samples people do not make the analyst talk, but this was Kaylee she just walked in and started talking in bossy manner. After this(adding reagents) I went to then supervisor Trisha Poer and told her what had happened. Further I requested her to say something to Kaylee. Trisha poer told me that she will talk to Krystal about it. I realized that management has not done anything to curb bullying behaviour of Kaylee because I kept getting same kind of attitude from her.
  • In the month of March 2021, I had trouble with UVVIS calibration. Since I was running pH samples I had to work on UVVIS first. I started at 10:30 am on UVVIS but did not get help till 2:30 pm. Kaylee came to help me after six hours. My Shaker/Incubator time was almost over. She told me to place the “Ready” culture flask in the bio safety cabinet. Therefore I believe that I used the culture after two hours, which was against procedure. All this time, she tried to communicate through “MS TEAMS”. I went to her desk to tell her to come to the lab but she was on her phone all these time. In other cases she (Kaylee) would come to the lab right away. She always avoided me.
  • I was mistreated by my Kaylee who was responsible for verifying whether data documentation was accurate or not. Kaylee would let other analysts’ mistake go but catch my mistake and escalate it to supervision.
  • I told Ian during the 1:1 meeting that there are few things in the lab which should not be happening, then I added I would be able show him to prove it. He did not show any interest at that meeting and he never asked about it later.
  • I commented on Eli Lilly’s efforts about making the employees aware of bias by showing video to the employees. I commented that “I do not understand the purpose of this “Conscious Bias” Agenda. He did not reply. Further I said bias and discrimination seems same to me.
  • On Ian and Trisha Poer’s supervision, I had to be in the lab during sample receipt time whereas fellow female employees were allowed to spend time at her desk (even though they were on sample receipt). When mentioned about this to my supervisor (Trisha-2020), Trisha took her side and told me “Oh.. She is young, naive millennial, she has lot to learn.”  She was not told anything about this because her behavior never changed.
  • On March 2021, Ian scheduled everyone for a new system (ROBOT) for Endotoxin testing but left me out. Per my title as Senior Specialist, I believe I should have been scheduled first but I did not see my name on the schedule.
  • My supervisor Ian would schedule me for A and B method most of the times. He would rarely schedule me for Endotoxin tests, and Crystals testings. These A and B methods are not liked by all the analysts. I did not like it too but I was put on the methods most of the time. I had complained to Trisha Poer in 2019 about pain in my shoulder when I run heavy loads of B method samples. She loudly told me to get a doctors’ note about it. Later I was able to get a doctor’s note.
  • Ian would not schedule EM technicians whose name-initials are RG, CH, and LB on A and B methods. I told Ian the EM technicians would work 2 hours out of 8 hours, and sometimes just 30 to 40 min. He took CH and RG’s side and said they have to transport MAS units and CLIMETS to other buildings. During 1:1, I told Ian, what was in Robert’s mind for the management. In his (RG’s) words, he stated that the company could not afford to lose him because a new technician would take six month for the training. He further stated that he was too valuable to them and that he was at the top of his career where he does not care for the pay raise. In short RG did not care for the company. Both EM technicians would work sometimes 2 hour out of 8 hours and sometimes just 30 to 40 min.
  • In 2020, during one of the training over the “Microsoft Teams” with RG, CH, and myself, my female supervisor Trisha Poer kept asking Robert and Chris whether they understood and whether they had any questions. However, during the training that lasted for almost 45 to 60 min, she never mentioned my name or asked me whether I understood. I found this very hurtful. She treated me as if I was not there.
  • I have some examples (with dates) to show that data documentation was not done in a timely manner by others, for which my employment was terminated. In some cases, data documentation was done after five hours and after two days in some cases. The SPVer had let go other people’s mistakes but treated me worse for the same. They also created a wrong impression in my supervisors’ mind, that I was the one who makes lots of mistakes.
  • One day, I called Kaylee on her cell phone and reported that the sample I just read has abnormal results. Without looking at the data she said that she must have labeled them wrong. She would not do same for me.
  • I have an email from Kaylee directing me to put sample position numbers that I had missed a few days after samples were processed. Clearly, she was directing me to create a false record.
  • During the same sample receipt (for which I was terminated), the second person verifiers had asked me and others about when the sample was received. We would say that we received them with other samples and we would update the time later on.
  • When I had the very first meeting with the HR representative on April 26, 2021, I was asked about what happened during this sample receipt. I stated that I was under lot of stress during this time. And that I made the error because of the stress. However, they could not listen to me. My employment was terminated on the next day.
  1. I was vaccinated on 16th April 2021 and I made an error on 19th April 2021 since I was under stress. I was stressed out by the reaction I had after taking the COVID vaccine. The reaction was on my left hand which my supervisor Ian knew about. I had shown it to him and I had described it as crawling pain. I had filed this complain with CDC, my family physician, and at Riley Hospital where I was vaccinated. As of today I have residue spots on my left hand.
  • On March 29, 2021, I was stressed out by chest pain. I had to go to the EHS (employee health services). I reported this to my supervisor Ian after I went back to work at 3:30PM on the same day. At EHS, they had told me to see my cardiologist. My supervisor Ian knew all these. After this I had to see cardiologist on April 30, 2021.
  1. About 8-10 years ago one employee named “Brandon” was let go for falsifying data in the same department where I was working. But he was first put on probation and retraining but he was let go after he made another violation while on probation. They did not give me another chance.

It is a well-laid principle of natural justice that one should be accorded fairness and equal treatment in all associations of life. Besides, it is immoral and unethical for an employee to be treated unfairly and/or unjustly by reason of the employee’s race or origin, or on any other ground.

It follows, this letter serves as my complaint and notifies you of the circumstances that led to my unfair dismissal. Accordingly, I request that you help me take necessary action that is fair and just to remedy my unfair dismissal.

Thank you for your prompt attention to this matter.



Malay Parekh

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