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Senor Frog's - First Amended Complaint

Senor Frog's - First Amended Complaint

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Published by: Honolulu Star-Advertiser on Nov 02, 2012
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07/10/2013

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ANNA Y. PARK, CA SBN 164242U.S. EQUAL EMPLOYMENTOPPORTUNITY COMMISSION255 E. Temple Street, 4th FloorLos Angeles, California 90012Telephone: (213) 894-1080Facsimile: (213) 894-1301E-mail: lado.legal@eeoc.gov  AMRITA MALLIK, CA SBN 249152U.S. EQUAL EMPLOYMENTOPPORTUNITY COMMISSION300 Ala Moana Boulevard, 7
th
FloorHonolulu, Hawaii 96850Telephone: (808) 541-3133Facsimile: (808) 541-3390E-mail: amrita.mallik@eeoc.gov  Attorneys for Plaintiff U.S. EQUAL EMPLOYMENTOPPORTUNITY COMMISSIONUNITED STATES DISTRICT COURTDISTRICT OF HAWAIIEQUAL EMPLOYMENTOPPORTUNITY COMMISSION,Plaintiff,v.LA RANA HAWAII, LLC D/B/ASENOR FROG’S and ALTRES, INC.;and DOES 1-15, INCLUSIVE;Defendants.))))))))))))Civil No. CV 11-00799 LEK BMK
FIRST AMENDEDCOMPLAINT
 
CIVIL RIGHTS
 
EMPLOYMENTDISCRIMINATION(42 U.S.C. §§ 2000e, et seq.)JURY TRIAL DEMAND
 
Case 1:11-cv-00799-LEK-BMK Document 61 Filed 11/01/12 Page 1 of 19 PageID #:750
 
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This is an action under Title VII of the Civil Rights Act of 1964 and Title Iof the Civil Rights Act of 1991 to correct unlawful employment practices on thebasis of sex (female), and retaliation, and to provide appropriate relief to a class of female employees similarly situated to Charging Party Heather Colletto(collectively, the “Claimants”), young women employed at the Senor Frog’srestaurant in Waikiki, who were adversely affected by such practices.NATURE OF THE ACTIONAs alleged with greater particularity in paragraphs 24 through 28 herein,Plaintiff, the United States Equal Employment Opportunity Commission (“EEOC”or the “Commission”) alleges that Defendants La Rana Hawaii, LLC d/b/a SenorFrog’s; Altres, Inc. and Does 1 through 15 (“Defendant Employers”) engaged inunlawful discrimination when they subjected the Claimants to unwelcome physicaland verbal sexual conduct which was sufficiently severe or pervasive to adverselyaffect the terms and conditions of their employment and create a hostile work environment. Defendant Employers also subjected Claimants to disparatetreatment, and constructive discharge on the basis of sex (female). The EEOCfurther alleges that Defendant Employers subjected Claimants to unlawfulretaliation when they reduced their work hours, subjected them to unfavorableterms and conditions of employment and/or terminated their employment foropposing the hostile work environment, a statutorily protected activity.1.
 
Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§ 451,1331, 1337, 1343 and 1345. This action is authorized and instituted pursuant toSections 706(f)(1) and (3) of Title VII of the Civil Rights Act of 1964, asamended, 42 U.S.C. §§ 2000e-5(f)(1) and (3) (“Title VII”) and Section 102 of theCivil Rights Act of 1991, 42 U.S.C. § 1981a.JURISDICTION AND VENUE
Case 1:11-cv-00799-LEK-BMK Document 61 Filed 11/01/12 Page 2 of 19 PageID #:751
 
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2.
 
The employment practices alleged to be unlawful were committedwithin the jurisdiction of the United States District Court for the District of Hawaii.3.
 
Plaintiff, the Equal Employment Opportunity Commission (the“Commission”), is the agency of the United States of America charged with theadministration, interpretation, and enforcement of Title VII, and is expresslyauthorized to bring this action by Sections 706(f)(1) and (3) of Title VII, 42U.S.C. §§ 2000e-5(f)(1) and (3).PARTIES4.
 
At all relevant times, Defendant La Rana Hawaii, LLC d/b/a SenorFrog’s (“La Rana”) has continuously been a Hawaii corporation doing business inthe State of Hawaii and has continuously had at least 15 employees.5.
 
At all relevant times, Defendant La Rana has continuously been anemployer engaged in an industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of Title VII, 42 U.S.C. §§ 2000e(b), (g) and (h).6.
 
At all relevant times, Altres, Incorporated (“Altres”) has continuouslybeen a Hawaii corporation doing business in the State of Hawaii and hascontinuously had at least 15 employees7.
 
At all relevant times, Defendant Altres has continuously been anemployer engaged in an industry affecting commerce within the meaning of Sections 701(b), (g) and (h) of Title VII, 42 U.S.C. §§ 2000e(b), (g) and (h).8.
 
Between at least July 2007 and December 2008, Defendant Altreshad continuously been under contract with Defendant La Rana for servicesrendered in Hawaii.a) The contract, titled Human Resources Services Agreement(“Agreement”), “covers the workforce administratively employed byALTRES and working at [La Rana’s] workplace (“WorkforceEmployees”).”
Case 1:11-cv-00799-LEK-BMK Document 61 Filed 11/01/12 Page 3 of 19 PageID #:752

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