The Plaintiff, Elle Woods, hereby moves This Honorable Court to Compel [Building Management] to provide suitable working conditions based on terms and conditions of the Operating Agreement signed by [Building Management] and Ms. Woods' employer, [Bill, More and Hours]. Elle Woods states as follows:
- [Building Management] is the sole owner and operator of the facility at [address].
- [Bill, More and Hours] are tenants in [Building] at [address] who pay rent in exchange for office space as well as the expectation that reasonable repairs and maintenance shall be performed by [Building Management]. (See Exhibit A)
- Ms. Woods has been using her current office on [Floor] for over 7 months at the time of the filing of this motion.
- Ms. Woods office contains 2 overhead light fixtures of the non-flattering fluorescent variety.
- During her entire tenure in the office in question one of the overhead lighting fixtures has remained off.
- When Ms. Woods inquired as to why one lighting fixture was not operational she was told by an agent of [Building Management] that the previous employee was "sensitive to light" and that it would be turned on again.
- 3 months have passed since the promise to turn on the overhead light.
- At the time Ms. Woods made an inquiry about the overhead light which was never on she also made a complaint about the flickering of her other light.
- At this time she was told this light could not be replaced until all 3 fluorescent tubes were burned out.
- Ms. Woods has waited patiently in a dim office with flickering lights for over 3 months.
- This morning (7.10.06) when Ms. Woods turned on her office light none of the lighting was functioning.
- Ms. Woods made a call to maintenance and explained the situation politely and that her window does not get a lot of sun.
- Ms. Woods wears glasses and does not wish to do any further damage to her eyes by reading in a dimly lit environment.
- At no point during the day was Ms. Woods visited by maintenance to repair her lighting.
- These conditions cause strain on Ms. Woods eyes and are unacceptable working conditions.
Wherefore, Plaintiff respectfully requests this court Compel [Building Management] to repair Ms. Woods lighting, as she is sick of feeling like a Vampire in her office and clearly [Building Management] is in breach of their duty to service their tenants as provided in the terms and conditions of the lease agreement (See Exhibit A) as well as any fees, costs, and damages for emotional distress this Court sees fit.
Elle Woods-Junior Attorney at Law