A sample complaint that may be used to commence an employment discrimination and retaliation action in New York State Supreme Court. The sample complaint alleges claims under the New York State Human Rights Law (NYSHRL) and the New York City Human Rights Law (NYCHRL). This Standard Document contains integrated drafting notes with important explanations and tips for drafting the complaint's caption, introduction, jurisdiction and parties sections, statement of facts, causes of action, demand for relief, and signature block. It also contains a sample verification page.