UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

JANICE M. GOLDSTEIN, CASE NO. 

 Plaintiff, JUDGE 

v 

PHOENIX LIFE INSURANCE COMPANY, 

a foreign corporation 

Defendant. 

 

LAW OFFICE OF GLEN N. LENHOFF 

BY: GLEN N. LENHOFF (P32610) 

ROBERT KENT-BRYANT (P40806) 

328 South Saginaw Street 

8th Floor, North Building 

Flint, Michigan 48502 

(810) 235-5660 

 

COMPLAINT AND JURY DEMAND

There is no other civil action between these parties arising out of the same transaction or 

occurrence as alleged in this Complaint. 

 NOW COMES Plaintiff, Janice M. Goldstein, by and through her attorney, the 

Law Office of Glen N. Lenhoff, and hereby complains of Defendant, Phoenix Life 

Insurance Company as follows: 

PARTIES AND JURISDICTION

1. Plaintiff, Janice M. Goldstein (hereinafter Plaintiff), is a resident of the City 

of Royal Oak, County of Oakland, State of Michigan. 

2. Defendant Phoenix Life Insurance Company (hereinafter Defendant) is a 

foreign corporation doing business in the State of Michigan. 

 

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3. The Court has subject matter jurisdiction over this case pursuant to 28 

USC §1332 because the parties have diversity of citizenship. 

4. Venue is proper in the United States District Court for the Eastern District 

of Michigan Southern Division pursuant to 29 USC §1391(a) as a substantial part of the 

events or omissions giving rise to the claim occurred in the Eastern District of Michigan 

Southern Division and therefore, Defendant is subject to personal jurisdiction there at 

the time this action commenced. 

5. The claims that Plaintiff asserts in this lawsuit include sex discrimination 

claims in violation of Michigan’s Elliott-Larsen Civil Rights Act. 

GENERAL ALLEGATIONS

6. Plaintiff began her employment with Defendant on April 9, 2001. 

7. Plaintiff was discharged from her employment on June 20, 2009. 

8. At all times pertinent hereto, Plaintiff was an excellent and valuable 

employee for Defendant. 

9. Defendant is an estate and retirement planning company. 

10. At the time of her discharge, Plaintiff was employed as a retirement 

security consultant. 

11. On April 21, 2009, Defendant announced layoffs. 

12. Plaintiff was told she was among those selected for layoff. 

13. Plaintiff was told that her performance and geography were the reasons 

for her layoff. 

14. In truth, Plaintiff was a much better performer and had much more 

seniority than similarly-situated men who were retained. 

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15. Plaintiff has suffered economic and emotional distress damages as a 

result of Defendant’s decision to terminate her employment. 

COUNT I_- SEX DISCRIMINATION CLAIM AGAINST DEFENDANT PURSUANT TO 

MICHIGAN’S ELLIOTT-LARSEN CIVIL RIGHTS ACT, MCLA §37.2202

16. Plaintiff hereby re-alleges and incorporates by reference the preceding 

paragraphs. 

17. Plaintiff was discharged on June 20, 2009. 

18. One motivating factor in the decision to discharge Plaintiff was her sex. 

19. Said sex discrimination is unlawful under Michigan’s Elliott-Larsen Civil 

Rights Act. 

20. Accordingly, Plaintiff hereby asserts a MCLA §37.2202 Sex Discrimination 

claim against Defendant. 

WHEREFORE, Plaintiff requests to be awarded fair and reasonable damages in 

such sum as a jury deems just, together with costs, attorneys fees and interest. 

DEMAND FOR JURY TRIAL

Plaintiff hereby demands a Jury Trial in the above-captioned case as guaranteed 

by Rule 38 of the Federal Rules of Civil Procedure. 

s/Glen N. Lenhoff s/Robert Kent-Bryant 

LAW OFFICE OF GLEN N. LENHOFF LAW OFFICE OF GLEN N. LENHOFF 

328 South Saginaw Street, 8-North 328 South Saginaw Street, 8-North 

Flint, Michigan 48502 Flint, Michigan 48502 

(810) 235-5660 (810) 235-5660 

lenhofflaw@usol.com lenhofflaw@usol.com

(P32610) (P40806) 

Date: 7/31/2009 Date: 7/31/2009 

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