William L. McLaughlin, Jr., Esq. Attorney for Plaintiff

Attorney I.D. No. 48307

William L. McLaughlin Law Offices

23 South Valley Road

P.O. Box 494

Paoli, PA 19301

610 644 4545

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

___________________________________

KRISTEN M. LEONARD : CIVIL ACTION

22 Fox Chase Circle :

Newtown Square, PA 19073-2405 :

Plaintiff, :

: No.

v. :

:

MONTGOMERY INSURANCE SERVICES, INC.: COMPLAINT 

330 West State Street :

Media, PA 19063-2616 : DEMAND FOR A JURY TRIAL

Defendant. :

___________________________________:

JURISDICTION

Plaintiff, by and through her attorney, William L. 

McLaughlin, Jr., respectfully represents:

1. This is an action for damages incurred pursuant to Title 

VII of the Civil Rights Act of 1964, 42 U.S.C. Sec 2000e et seq. 

("Title VII"), for discrimination on the basis of gender.

2. Jurisdiction of this Court is invoked pursuant to 42 

U.S.C. Sec. 2000e et seq..

3. The offenses and discriminatory acts as presented below 

were and are being committed within the Eastern District of the 

Federal District Court in the Commonwealth of Pennsylvania.

4. The plaintiff has received a "Notice of Right to Sue" 

letter from the United States Equal Employment Opportunity 

Commission, demonstrating proper prior pursuit of this matter 

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through administrative channels. (Exhibit "A")

COMPLAINT

AND DEMAND FOR A JURY TRIAL

PARTIES

5. Plaintiff, Kristen M. Leonard, is an adult individual 

and citizen of the Commonwealth of Pennsylvania currently 

residing at 22 Fox Chase Circle, Newtown Square, Pennsylvania, 

19073-2405.

6. Defendant, Montgomery Insurance Services, Inc., is a 

Pennsylvania State Corporation and as such, a citizen of the 

Commonwealth of Pennsylvania and may be served at 330 West State 

Street, Media, Pennsylvania 19063-2616.

STATEMENT OF FACTS

7. On or about August 17, 1998, plaintiff began work for 

the defendant.

8. Plaintiff was the only female producer in the company.

9. During plaintiff's tenure with the defendant, she was 

treated differently from the other personal line producer with 

regard to commissions, car allowance and work environment.

10. Plaintiff was discouraged from doing any commercial 

accounts, however, when she did do them, she received lower 

percentage commissions (25%) while the other line producer, Jay 

Ashworth, received higher commissions (40%).

11. Plaintiff did not receive a car allowance during most 

of her first year while other line producers, Jay Ashworth and 

Mike Detta, a life line producer, received automobile allowance 

of up to three hundred and fifty dollars ($350.00) each at the 

Case 2:02-cv-04156-MMB Document 1 Filed 06/27/2002 Page 2 of 7
start of their employment on top of their pay. When plaintiff 

was finally offered automobile allowance, it was originally for 

one hundred and fifty dollars ($150.00), less then what the other 

line producers received, finally three hundred and fifty 

($350.00) was granted however, a two hundred and sixty two 

dollars ($262.00) amount was subtracted from her pay.

12. When plaintiff began working with defendant, her office 

was not equipped with chairs to seat visiting clients.

13. On or about November 1998, Jay Ashworth was hired on as 

a second personal line producer. Mr. Ashworth had limited sales 

experience and was not licensed to sell life insurance.

14. Jay Ashworth was immediately provided with a fully 

furnished office and a three hundred and fifty dollar ($350.00) 

automobile allowance.

15. When it became apparent that Mr. Ashworth was being 

treated differently, plaintiff went to Don Hosier, the supervisor 

of the commercial lines, who was in charge when Steve Montgomery, 

the plaintiff's immediate supervisor was not available. 

Plaintiff told Mr. Hosier about the differences in treatment 

between her and Mr. Ashworth, and that she felt she was being 

discriminated against on the basis of sex.

16. After plaintiff complained about this problem many 

times and only after plaintiff stated that she felt as if she was 

discriminated against on the basis of sex were chairs furnished 

to her office.

17. On or about July 1999, plaintiff was given a lead by 

Don Hosier after Mr. Ashworth had failed to take action on it for 

Case 2:02-cv-04156-MMB Document 1 Filed 06/27/2002 Page 3 of 7
over two weeks.

A. The customer was an official at First Keystone 

Bank, a firm associated with Montgomery Insurance Company. The 

customer complained about the long wait which was the reason 

plaintiff was given the case. 

B. The plaintiff immediately contacted the customer 

and promised a quote within two days. 

C. The customer called back before the two days had 

elapsed and spoke to Steve Montgomery, who, in turn, berated 

plaintiff and informed her that the company now had an expected 

two day turn around time on all quotes.

D. Mr. Montgomery refused to listen when the 

plaintiff explained that she was getting back to the customer 

within her self imposed limit of two days.

E. Mr. Montgomery further refused to place any blame 

on Jay Ashworth who had precipitated the prospective customers 

annoyance, and was also not given the two day turn around 

restriction on customer quotes.

F. The plaintiff informed Mr. Montgomery that she 

felt she was being treated differently from Mr. Ashworth.

18. In August of 1999, plaintiff was scheduled to take a 

vacation. Mr. Hosier demanded that both plaintiff and Mr. 

Ashworth compile a list of prospects and their status in terms of 

contact and stage of sale. The lists demonstrated that:

A. Plaintiff had 42 accounts listed, all with call 

backs noted and/or quotes.

B. Mr. Ashworth had 38 accounts listed with 18 listed 

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as "to be quoted."

19. While on vacation, plaintiff was ordered by Steve 

Montgomery to call in. She complied with that request.

20. On or about September 13, 1999, plaintiff was fired 

from her position with no reasonable explanation given.

21. Jay Ashworth, a producer with less experience and 

tenure and poorer work performance still works at Montgomery 

Insurance Company, Inc.

COUNT I

DISCRIMINATION ON THE BASIS OF SEX

22. Plaintiff, Kristen M. Leonard, incorporates by 

reference all of the allegations contained in paragraphs 1 

through 21 as fully as though the same were herein set forth at 

length.

23. Defendant has discriminated against plaintiff in 

violation of 42 U.S.C. Sec. 2000 et seq. ("Title VII"), on the 

basis of her sex.

24. Defendant has terminated the plaintiff in violation of 

42 U.S.C. Sec. 2000 et seq. ("Title VII"), on the basis of her 

sex. 

WHEREFORE, Plaintiff requests declaratory, equitable and 

injunctive relief be ordered by this Honorable Court for:

(a) declaration of the illegal conduct of the Defendant;

(b) front pay in the full value of lost wages and

 benefits, with interest;

(c) any other lost compensation.

 (d) compensatory and punitive damages in an amount greater

Case 2:02-cv-04156-MMB Document 1 Filed 06/27/2002 Page 5 of 7
 than $100,000.00;

(e) reasonable attorney's fees and costs; and

 (g) such other relief as the Court finds appropriate.

COUNT II

RETALIATION

25. Plaintiff, Kristen M. Leonard, incorporates by 

reference all of the allegations contained in paragraphs 1 

through 24 as fully as though the same were here in set forth at 

length.

26. Defendant unlawfully terminated the plaintiff in 

violation of 42 U.S.C. Sec 2000 et seq. ("Title VII") as 

retaliatory action for her opposition towards her treatment on 

the basis of sex.

WHEREFORE, Plaintiff requests declaratory, equitable and 

injunctive relief be ordered by this Honorable Court for:

(a) declaration of the illegal conduct of the Defendant;

(b) front pay in the full value of lost wages and

 benefits, with interest;

(c) any other lost compensation.

 (d) compensatory and punitive damages in an amount greater

 than $100,000.00;

(e) reasonable attorney's fees and costs; and

 (g) such other relief as the Court finds appropriate.

DEMAND FOR JURY TRIAL

27. Plaintiff demands a trial by jury.

By:_______________________________

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William L. McLaughlin, Jr.

Date: _______________

VERIFICATION

I verify that the facts set forth in the foregoing Complaint 

are true and correct. I understand that false statements herein 

are made subject to the penalties of 18 Pa. C.S.A. Sec. 4904 

relating to unsworn falsifications to authorities, and under 

penalty of perjury.

Date: _______________ ______________________________

Kristen M. Leonard

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