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12345678910111213141516171819202122232425262728Page 1 of 15Jay Edelson
*
Rafey S. Balabanian
*
Steven Lezell
*
K 
AMBER 
E
DELSON
,
 
LLC350 N. LaSalle AveSuite 1300Chicago, Illinois 60654Tel: (312) 589-6370Fax: (312) 589-6378
* Pro hac vice admittance to be sought
Marc Cook Bailus Cook & Kelesis400 S. 4th St.Suite 300Las Vegas, NV 89101Tel: (702) 385-3788Fax: (702) 737-7712
UNITED STATES DISTRICT COURTDISTRICT OF NEVADA
TOMO STEPHENS, on her own behalf and on behalf of all otherssimilarly situated,Plaintiff,v.HARRAH’S ENTERTAINMENT,INC. a Delaware corporation d/b/aCAESAR’S PALACE HOTEL ANDCASINO,Defendant.Case No.JudgeMagistrate Judge
DEMAND FOR JURY TRIALCLASS ACTIONCLASS ACTION COMPLAINT
Plaintiff, TOMO STEPHENS, brings this Class Action Complaint against DefendantHARRAH’S ENTERTAINMENT, INC. d/b/a CAESAR’S PALACE HOTEL AND CASINO.Plaintiff alleges as follows upon personal knowledge as to herself and her own acts andexperiences, and, as to all other matters, upon information and belief, including investigationconducted by her attorneys.
Case 2:09-cv-01332-RCJ-RJJ Document 1 Filed 07/22/2009 Page 1 of 15
 
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See
Office of the Surgeon General,
available at URL
1
http://www.surgeongeneral.gov/library/secondhandsmoke/factsheets/factsheet1.html. (lastvisited July 14, 2009).
Id.
2
Page 2 of 15
NATURE OF ACTION
1.Second-hand smoke refers to smoke from cigarettes and cigars that isexhaled or otherwise released into the atmosphere. Non-smokers who are exposed to second-hand smoke inhale the same chemicals that smokers inhale. Second-hand smoke has been
1
designated as a known human carcinogen (cancer-causing agent) by the U.S. EnvironmentalProtection Agency, the National Toxicology Program, and the International Agency for Research on Cancer, as well as an occupational carcinogen by the National Institute for Occupational Safety and Health.
2
2.A multi-year investigation by the National Institute of Occupational Safety andHealth (“NIOSH”) of second-hand smoke levels in three Casinos in Las Vegas, includingDefendant CAESAR’S PALACE, was released in May 2009. The study found that chemicalsfound in second-hand smoke exist both on casino floors and in the bloodstreams of casino
Case 2:09-cv-01332-RCJ-RJJ Document 1 Filed 07/22/2009 Page 2 of 15
 
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Chandran Achutan
et al 
., Department of Health and Human Services, Environmental and
3
Biological Assessment of Environmental Tobacco Smoke Exposure Among Casino Dealers, iv(2009). 
 Id 
.
4
Page 3 of 15employees who work on the gaming floor. NIOSH recommended that casinos ensure
3
ventilation systems are working properly, create health and safety committees for employees,and ban smoking on casino floors.
4
3.Recognizing the dangers of second-hand smoke, some casinos in Nevada havevoluntarily taken measures to minimize the amount of second-hand smoke on their gamingfloors. The Bellagio Hotel and Casino, for example, has installed a high-tech air filtrationsystem designed to minimize the amount of second-hand smoke on their casino floors. ThePalazzo Hotel and Casino built “smoke-free corridors” through their casino and designatedfifty-percent of their casino floor as non-smoking. Even CAESAR’S PALACE hasacknowledged the dangers of second-hand smoke, as it has made at least some of its poker rooms smoke-free.4.Despite overwhelming scientific evidence, CAESAR’S PALACE has failed to protect the health and welfare of many of its employees who must perform their jobs while breathing in second-hand smoke. Employers have a duty to provide their employees with a safeworkplace. CAESAR’S PALACE is failing their employees, and breaching its duty to them, bynot taking reasonable steps to minimize exposure to second-hand smoke. Plaintiff brings thisaction to ensure the health and welfare of all casino employees at CAESAR’S PALACE.
Case 2:09-cv-01332-RCJ-RJJ Document 1 Filed 07/22/2009 Page 3 of 15
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tomostephens

I DON'T KNOW IF THIS IS GOING TO THE PROPER RECEIVING PERSONS. BUT, I WOULD LIKE TO MAKE A STATEMENT TO MAKE MY STAND PERFECTLY CLEAR. WHEN I STARTED DEALING IN 1980, I KNEW THAT SMOKING WOULD BE PRESENT IN MY WORK CONDITION. BUT AFTER ALMOST 30 YEARS OF DEALING, THERE HAS BEEN NO EFFORT MADE ON OUR BEHALF TO IMPROVE THE WORK CONDITIONS. IT IS MOST EVIDENT AT CAESARS PALACE. BEFORE HARRAHS TOOK OVER, WE HAD NO SMOKING TABLES AND WE COULD ASK PEOPLE TO NOT BLOW SMOKE IN OUR FACE. WITH HARRAHS, THEY TOOK AWAY THE NON-SMOKING TABLES AND WE WERE TOLD THAT IN NO WAY WERE WE TO MAKE ANY COMMENTS TO RUDE PLAYER THAT BLEW SMOKE IN OUR FACES. ALSO, IF YOU READ SOME OF THE ARTICLES, IT STATES THAT I MYSELF AM NOT SEEKING MONETARY COMPENSATION. JUST A BETTER WORK ENVIRONEMENT FOR THOSE OF YOU WHO ARE STILL WORKING UNDER THESE CONDITIONS. BY THE WAY, IF YOU THINK THAT THE SMOKE ISN'T KILLING YOU. I AM GETTING BETTER HEALTHWISE EVERY DAY THAT I AM AWAY FROM CAEASARS. I NOW LIVE IN CALIFORNIA AND I HAVE NOT HAD TO BREATH IN A PUFF OF SMOKE SINCE I HAVE BEEN HERE. THE GAMBLERS WHO SMOKE, DO SO WITHOUT ANY REGARDS TO OTHER PEOPLE. THEY BLOW SMOKE IN YOUR FACE AND MAKE NO PRETENSE TO HOW THEY CAN AFFECT THE HEALTH OF DEALER AND THE NON-SMOKING PLAYERS. MOST DON'T CARE IF YOU HAVE ASTHMA, BRONCHITIS, OR EVEN PREGNANT. SO, IT IS UP TO YOUR EMPLOYER TO PROTECT YOU AS MUCH AS THEY CAN. IF YOU HAVE ANYTHING YOU WANT TO SAY TO ME OR ASK ANY QUESTIONS PLEASE FEEL FREE TO DO SO AT MY E-MAIL ADDRESS tomostephens@aol.com

reply09 / 04 / 2009
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