UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

JOHN MARTZ, ) 

 ) 

 Plaintiff, ) No. 

 ) 

 v. ) 

 ) 

FEDERAL HOME LOAN BANK OF ) 

CHICAGO, ) 

 ) JURY TRIAL DEMANDED 

 Defendant. ) 

COMPLAINT

 NOW COMES Plaintiff, JOHN MARTZ (“Martz”), by and through his attorneys, 

Barry A. Gomberg and Barry A. Gomberg & Associates, Ltd., and for his Complaint 

against the Defendant, FEDERAL HOME LOAN BANK OF CHICAGO, alleges as 

follows: 

PARTIES

 1. John Martz is a sixty (60) year-old resident of the State of Illinois residing 

in Cook County in Oak Park, Illinois 60302. 

 2. Defendant is a wholesale bank and one of 12 district banks chartered in 

1932 by the U.S. Congress to ensure a secure source of mortgage funds to thrifts, 

insurance companies, and housing finance institutions. Defendant is located at 200 East 

Randolph Drive, Chicago, Illinois 60601. 

JURISDICTION AND VENUE

3. The claim against Defendant is for age discrimination pursuant to the Age 

Discrimination in Employment Act of 1967 (“ADEA”), 29 U.S.C. § 621 et seq. 

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 4. Jurisdiction is conveyed upon this Court by virtue of 28 U.S.C. § 1343 as 

this claim arises under the laws of the United States of America. 

COUNT I – AGE DISCRIMINATION

 5. Martz re-alleges and incorporates as if fully set forth herein paragraphs 1 

though 4 above. 

 6. Pursuant to Section 14(b) of the ADEA, 29 U.S.C. § 633(b) and Section 

7(d) of the ADEA, 29 U.S.C. §626(c), Martz has filed this cause more than sixty (60) 

days after the filing of a Charge of Discrimination with the State of Illinois Department 

of Human Rights (“IDHR”), pursuant to the requirements of the ADEA and the Equal 

Employment Opportunity Commission (“EEOC”), a copy of which is attached hereto as 

Exhibit A and fully incorporated herein by reference. 

 7. Plaintiff has filed this cause pursuant to a Notice of Right to Sue issued by 

the EEOC within the statutory time requirement, a copy of which is attached hereto as 

Exhibit B. 

 8. In direct violation of the ADEA, Defendant engaged in the age 

discriminatory acts described in the Charge of Discrimination, attached as Exhibit A and 

fully incorporated herein by reference. 

 9. Plaintiff began his employment with Federal Home Loan Bank of Chicago 

on June 6, 2004 as an engineer. 

 10. Plaintiff was discharged on February 22, 2010.

 11. The reason given to Plaintiff for his discharge by his supervisor, Sohail 

Zakaria (who is younger than Plaintiff), was that Plaintiff exhibited a pattern of behavior 

that increased risks to the performance of the Bank system. 

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 12. Plaintiff’s performance was as good as, if not better, than that of 

employees under the age of forty (40) who were not fired under similar circumstances. 

13. At all times, Plaintiff met the legitimate expectations of his employer/ 

 14. Plaintiff was terminated, but his younger co-workers were permitted to 

continue working for Defendant. 

15. As a result of Defendant’s discriminatory conduct, as aforesaid, Martz has 

been damaged in his career and has otherwise suffered monetary and non-monetary 

damage. 

 WHEREFORE, Plaintiff John Martz prays for judgment against Defendant as 

follows: 

A. For damages in an amount equal to Martz’s back pay and lost benefits 

from February 22, 2010 through the present; 

B. For reinstatement to his previous position, or in the alternative, for front 

pay; 

C. For attorney’s fees and costs of this suit; and 

D. For such other and further relief as is just and equitable. 

COUNT II – ADEA WILLFUL VIOLATION

 16. Martz realleges and incorporates as if fully set forth herein paragraphs 1-

15 above. 

 17. Defendant’s discriminatory conduct, as aforesaid, was intentional and/or 

in reckless disregard for Martz’s rights under the law and these acts constitute willful 

indifference to said rights. 

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 WHEREFORE, Plaintiff John Martz prays for judgment against Defendant as 

follows: 

A. For liquidated damages in an amount equal to Martz’s actual damages. 

B. For damages in an amount equal to Martz’s back pay from February 22, 

2010 through the present; 

C. For reinstatement to his previous position, or in the alternative, for front 

pay; 

D. For attorney’s fees and costs of this suit; and 

E. For such other and further relief as is just and equitable. 

 Respectfully submitted, 

 JOHN MARTZ 

 By: s/ Barry A. Gomberg 

 One of Plaintiff’s Attorneys 

Barry A. Gomberg 

Barry A. Gomberg & Associates, Ltd. 

53 W. Jackson Blvd., Suite 1350 

Chicago, Illinois 60604 

(312) 922-0550 

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