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1 BOYS NIGHT IN WITH ANDREW DICE CLAY

2 NO GIRLS ALLOWED
3
2. Yet, as seen in the below excerpt from Exhibit 1 to this Complaint, an advertisement for
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Defendants’ “GIRLS NIGHT IN WITH ILIZA – NO BOYS ALLOWED” comedy show, Defendants,
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had no problem – zero, zilch, nada – organizing, hosting, employing, booking, putting on, performing
6
in, or at least aiding a comedy show on November 13, 2017 at Los Angeles’ The Coronet Theater,
7
which is also known as Largo At The Coronet (collectively heretofore referred to as the “Theater”),
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both of or either of which is owned by Defendant Mark Brian Flanagan, and which boldly promised
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and/or threatened that it would not allow male theatergoers into its GIRLS NIGHT IN WITH ILIZA
10
– NO BOYS ALLOWED show as follows:
11
12
GIRLS NIGHT IN WITH ILIZA
13
NO BOYS ALLOWED
14
15 3. On November 13, 2017, and at all times relevant to this Complaint, Plaintiff George St. George
16 was and is a male. Before attempting to attend Defendants’ GIRLS NIGHT IN WITH ILIZA – NO
17 BOYS ALLOWED show, Mr. St. George obtained a $30 ticket for the show through the www.largo-
18 la.com website.
19 4. Then, on November 13, 2017, well before the show was scheduled to start at 8:00 p.m., Mr. St.
20 George, along with a male friend who also obtained a $25 ticket for Defendants’ GIRLS NIGHT IN
21 WITH ILIZA – NO BOYS ALLOWED show, appeared very early at the Theater’s will-call window
22 to get their tickets by showing their proofs of purchase of their tickets through the above website to a
23 female Theater employee. Upon showing the will-call window’s female employee their proofs of
24 purchase, this Theater employee paused for some time, and then told Mr. St. George and his male
25 friend that the Theater would admit them to Defendants’ GIRLS NIGHT IN WITH ILIZA – NO BOYS
26 ALLOWED show despite the fact that they were males, but that both of the men would have to sit in
27 the back row of the Theater for the show because of their sex.
28

Complaint for Injunctive Relief and Damages


1 5. The two men walked away with their tickets after this Theater employee told them they would
2 have to sit in the back of the Theater solely because of their sex. At this time, the Theater was not yet
3 allowing ticketholders inside the Theater, for which the seating was first come first served, from the
4 front of the theatre to the back, so the two men went to a nearby restaurant to get a quick bite to eat.
5 Mr. St. George and his male friend soon returned to the Theater where they were two of the first
6 would-be patrons in line to enter the Theater, which they were not allowed to do because of what
7 happened next, which perhaps can best be described as being akin to the Montgomery City Lines bus
8 company in Montgomery, Alabama circa 1955 morphing into the Woolworth’s department store lunch
9 counter in Greensboro, North Carolina in 1960.
10 6. As Mr. St. George and his male friend were in the beginning of the line with their tickets to
11 enter and sit in the back of the Theater as ordered, the same female theater employee who was working
12 at the will-call window earlier approached Mr. St. George and his male friend. This female employee
13 told Mr. St. George and his male friend that since she last spoke to them and told them that they would
14 have to sit in the back of the Theater, that “Iliza” and the Theater had decided to not allow Mr. St.
15 George and his male friend to even enter the Theater because only females were being allowed to be
16 admitted to the show – just as promised and/or threatened. This same Theater employee told the two
17 men that the Theater would refund them the money for their tickets.
18 7. What happened to Mr. St. George and his male friend is consistent with what happened to at
19 least one other male consumer who was a victim of Defendants’ War On Men by being denied entry
20 to Defendants’ GIRLS NIGHT IN WITH ILIZA – NO BOYS ALLOWED show because of his sex
21 This can be seen in Exhibit 2 to the Complaint, in a comment by a male visitor to Defendant Iliza
22 Shlesinger’s Facebook page on which Ms. Shlesinger announced her GIRLS NIGHT IN WITH ILIZA
23 – NO BOYS ALLOWED show. Page 2 of Exhibit 2 displays that this comment was made at 7:52 p.m.
24 on the evening of the November 13, 2017, show by Morgan King, who wrote “Hey ILIZA! Can I just
25 grab a pic with you? Huge fan but got turned away for being a dude! I get it! But was hoping to meet
26 you real quick and snap a pic as a constellation prize!”
27 8. Despite the many State of California anti-discrimination statutes, California Supreme Court
28 opinions, California Attorney General and Department of Fair Employment and Housing actions, and

Complaint for Injunctive Relief and Damages


1 California Department of Alcoholic Beverage Control regulations that prohibit California businesses
2 from treating patrons unequally based on their sex, and specifically condemn and forbid events or
3 promotions that treat female and male patrons unequally, Defendants boldly organized, hosted,
4 employed, booked, put on, performed in or at least aided a sex-based comedy show that treated male
5 and female theatergoers unequally based solely on their sex.
6 9. As a result of Defendants’ unequal treatment of patrons based solely on their sex, Defendants
7 denied consumers the equal accommodations, advantages, facilities, privileges, or services they are
8 entitled to under Civil Code sections 51 (the codification of the Unruh Civil Rights Act) and 51.5, as
9 well as under Business & Professions Code section 125.6. Defendants GIRLS NIGHT IN WITH
10 ILIZA – NO BOYS ALLOWED show violated California’s strong public policy to eradicate sex
11 discrimination, reflected in the many California statutes that prohibit businesses from discriminating
12 against patrons based on their sex. Defendants’ GIRLS NIGHT IN WITH ILIZA – NO BOYS
13 ALLOWED show violated California Civil Code sections 51, 51.5, and 52, which prohibit California
14 businesses and individuals from treating patrons unequally based on their sex, and also prohibit
15 California businesses and individuals from aiding in the discrimination or unequal treatment of
16 consumers based on their sex.
17 10. For any business or any individual in the year 2017, in the progressive state of California, to
18 provide or aid in providing accommodations, advantages, privileges, or services to only females as
19 Defendants did here, is as repugnant and unlawful as a business or an individual being involved in a
20 “Caucasian Night” or a “Heterosexual Night” and providing admission, entertainment, and other
21 accommodations, advantages, privileges, or services to only white or heterosexual patrons,
22 respectively. Simply put, it is against many California laws for a business to discriminate against
23 patrons based on their sex or other personal characteristics, such as race or sexual orientation, which
24 should surprise no one.
25 11. The seminal California Supreme Court case on businesses that treat male and female
26 consumers unequally based on their sex, Koire v. Metro Car Wash (1985) 40 Cal.3d 24, held that
27 Ladies’ Day and Ladies’ Night promotions that treated patrons unequally based on sex by charging
28 male patrons more than female patrons for the same thing—as little fifteen cents more—violated the

Complaint for Injunctive Relief and Damages


1 Unruh Civil Rights Act. Koire found “Public policy in California strongly supports eradication of
2 discrimination based on sex. The Unruh Act expressly prohibits sex discrimination by business
3 enterprises.” Id. at 37.
4 12. Defendants’ GIRLS NIGHT IN WITH ILIZA – NO BOYS ALLOWED show repudiated
5 hundreds of years of women’s struggles to be viewed as being equal to men and is typical of old-
6 fashioned sexism that might also advise a young woman that her best chance for a happy life is to ace
7 her home economics class and learn how to make a queso dip from Velveeta to catch a good man. Not
8 only has the California Supreme Court twice unanimously expressed its disapproval of how Ladies’
9 Day and Ladies’ Night promotions harm women, the United States Supreme Court has similarly
10 weighed in as well about "romantic paternalism" directed at women. In Frontiero v. Richardson, 411
11 U.S. 677, 684 (1973), the U.S. Supreme Court ruled the military must provide its female members
12 with the same housing and medical benefits as it provides its male members. Justice William J.
13 Brennan Jr. wrote that the military’s unequal treatment of men and women is yet another example of
14 one of those types of traditional sex discrimination that ostensibly appears to benefit women, but is
15 “rationalized by an attitude of ‘romantic paternalism’ which, in practical effect, put women, not on a
16 pedestal, but in a cage.”
17 13. The Judicial Counsel of California's jury instructions for violations of Civil Code sections 51,
18 and 51.5, i.e., CACI 3060 ad 3061, respectively, reflect the Judicial Counsel's recognition of the
19 California Supreme Court’s ruling in Koire that sex-based promotions are “per se injurious.” The
20 Directions For Use for CACI 3060 and 3061, recognize that a plaintiff asking for only the statutory
21 damages provided by Civil Code section 52 for violations of section 51 or 51.5, respectively, such as
22 Plaintiff in this Complaint, does not have to prove that he or she was harmed or that defendant’s
23 conduct was a substantial factor in causing the plaintiff’s harm, because harm is presumed.
24 Nevertheless, Plaintiff was harmed by first being ordered to sit in the back of the Theater because of
25 his sex, and then told he could not even enter the Theater and watch the show because of his sex.

26 14. Koire was upheld by the California Supreme Court in its most recent opinion on single sex

27 events, Angelucci v. Century Supper Club (2007) 41 Cal.4th 160, wherein the Court unanimously ruled

28 that men who were charged more than women to enter a supper club on Ladies’ Night did not have to

Complaint for Injunctive Relief and Damages


1 first demand their right to equal treatment to the offending business and be refused in order to have
2 standing for a Civil Code section 51 or 51.5 claim.
3 15. Defendants’ GIRLS NIGHT IN WITH ILIZA – NO BOYS ALLOWED show caused
4 discontent, animosity, harm, resentment, or envy among the sexes, constituted arbitrary, unreasonable,
5 and/or invidious discrimination, constituted a willful and malicious injury to Plaintiff, and contravened
6 California’s historical effort to eradicate sex discrimination. Defendants willfully and maliciously
7 injured Plaintiff during their show by knowingly and intentionally denying Plaintiff admission and
8 other services based solely on Plaintiff’s sex.
9 16. The California Department of Fair Employment and Housing (“DFEH”), the State agency
10 charged with preventing unlawful discrimination in places of public accommodation, has published a
11 brochure specifically addressing the unlawfulness of sex-based or no-men-allowed events. This
12 DFEH brochure is attached hereto as Exhibit 3, and can also be found at
13 http://www.dfeh.ca.gov/DFEH/Publications/PublicationDocs/UnruhActBrochure.pdf.
14 17. The California Department of Justice and the California Bureau of Gambling Control has
15 similarly expressed its condemnation of sex-based events, specifically their disapproval of the
16 proliferation of no-men-allowed poker tournaments hosted by California’s licensed card rooms. The
17 California Attorney General and the Bureau of Gambling Control issued a Gambling Establishment
18 Advisory, attached hereto as Exhibit 4, warned card rooms that women-only poker tournaments
19 violated the Unruh Act. The Attorney General warned that it may be unlawful under the Unruh Act
20 to simply advertise tournaments as “ladies only” even if men were in fact admitted. This Advisory
21 can also be found at http://ag.ca.gov/gambling/pdfs/NUM8LOT.pdf.
22 18. By this action, Plaintiff George St. George seeks redress for Defendants’ War On Men via their

23 GIRLS NIGHT IN WITH ILIZA – NO BOYS ALLOWED show, which prohibited Plaintiff and other

24 men from entering the Theater and taking in the show based solely on their sex.

25 PARTIES

26 19. Plaintiff George St. George is a man, over the age of 21, and a California resident.

27 20. On information and belief, at all times relevant hereto, Defendant Iliza Shlesinger is a business

28 acting or working as a self-employed, sole proprietorship comedian. Iliza Shlesinger has been

Complaint for Injunctive Relief and Damages


1 described or quoted in an Esquire article as “taking a stronger feminist stance (don't be scared,
2 gentlemen),” “I found myself coming up with a lot of the material about being on the side of women.
3 I wanted to talk about feminism in the way that I like to talk about it, which is digestible. It's not
4 excluding men.” While a Los Angeles Times article on Ms. Shlesinger reads, “She is a nuanced
5 feminist and a comic with the instincts and sensibility to address women's rights while inviting men
6 — who in her humor can be monosyllabic and imposing but are mostly well-meaning if misguided —
7 inside the tent.” The same L.A. Times article quoted Ms. Shlesinger saying, “because women want to
8 be treated as equals, and we want feminism to be a thing, but it's really difficult when every woman
9 makes the same point about her vagina, over and over.” However, contrary to these articles, during
10 Ms. Shlesinger’s GIRLS NIGHT IN WITH ILIZA – NO BOYS ALLOWED show she excluded men,
11 she did not invite men into the tent, and she did not want women and men to be treated as equals. Ms.
12 Shlesinger discriminated against and treated Mr. St. George unequally based solely on Mr. St.
13 George’s sex by prohibiting Mr. St. George from entering the Theater and from taking in the
14 entertainment and refreshments provided during Defendants’ GIRLS NIGHT IN WITH ILIZA – NO
15 BOYS ALLOWED show, and by organizing, hosting, employing, booking, putting on, performing in
16 or at least aiding this no-men-allowed commercial event.
17 21. On information and belief, at all times relevant hereto, Defendant Largo At The Coronet is a
18 business of unknown form, not registered with the California Secretary of State, doing business as a
19 bar and theater at 366 N. La Cienega Boulevard, Los Angeles, California 90048. Largo At The Coronet
20 discriminated against and treated Mr. St. George unequally based solely on Mr. St. George’s sex by
21 prohibiting Mr. St. George from entering the Theater and from taking in the entertainment and
22 refreshments provided during Defendants’ GIRLS NIGHT IN WITH ILIZA – NO BOYS ALLOWED
23 show, and by organizing, hosting, employing, booking, putting on, or at least aiding this no-men-
24 allowed commercial event.
25 22. On information and belief, at all times relevant hereto, Defendant The Coronet Theater is a

26 business of unknown form, not registered with the California Secretary of State, doing business as a

27 bar and theater at 366 N. La Cienega Boulevard, Los Angeles, California 90048. The Coronet Theater

28 discriminated against and treated Mr. St. George unequally based solely on Mr. St. George’s sex by

Complaint for Injunctive Relief and Damages


1 prohibiting Mr. St. George from entering the Theater and from taking in the entertainment and
2 refreshments provided during Defendants’ GIRLS NIGHT IN WITH ILIZA – NO BOYS ALLOWED
3 show, and by organizing, hosting, employing, booking, putting on, or at least aiding this no-men-
4 allowed commercial event.
5 23. On information and belief, at all times relevant hereto, Defendant Mark Brian Flanagan is a
6 business and the lessee of the Largo At The Coronet Theater, which is also known as and is registered
7 with the State of California Department of Alcoholic Beverage Control (“ABC”) as “The Coronet
8 Theater.” Mark Brian Flanagan, doing business as The Coronet Theater, is the holder of ABC License
9 Number 475296, which is a License Type 42 for on-sale beer and wine on public premises. Mr.
10 Flanagan discriminated against and treated Mr. St. George unequally based solely on Mr. St. George’s
11 sex by prohibiting Mr. St. George from entering the Theater and from taking in the entertainment and
12 the alcoholic and non-alcoholic refreshments provided during Defendants’ GIRLS NIGHT IN WITH
13 ILIZA – NO BOYS ALLOWED show, and by organizing, hosting, employing, booking, putting on,
14 or at least aiding this no-men-allowed commercial event.
15 24. On information and belief, at all times relevant hereto, Defendant United Talent Agency, LLC
16 is a Delaware limited liability company registered as a limited liability company with the California
17 Secretary of State with the registration number 201421310352, and doing business as United Talent
18 Agency at 9336 Civic Center Drive in Beverly Hills, California 90210. On information and belief,
19 United Talent Agency, LLC is an agent for Defendant Iliza Shlesinger, responsible for booking or
20 arranging for professional appearances by Ms. Shlesinger, and United Talent Agency discriminated
21 against and treated Mr. St. George unequally based solely on Mr. St. George’s sex by booking or
22 arranging Ms. Shlesinger’s appearance at Defendants’ GIRLS NIGHT IN WITH ILIZA – NO BOYS
23 ALLOWED show, and at least aiding this no-men-allowed commercial event.
24 25. The true names and capacities of Does 1 through 50 are unknown to Plaintiff. When their true
25 names and capacities are learned, Plaintiff will amend this complaint accordingly. Plaintiff is informed

26 and believes, and on that basis alleges, each fictitiously named defendant is responsible in some way

27 for the occurrences herein alleged, and those defendants proximately caused plaintiff and the other

28 male consumers’ damages. Each reference in this complaint to “defendant,” “defendants,” or a

Complaint for Injunctive Relief and Damages


1 specifically named defendant refers to all defendants sued under fictitious names.
2 26. Unless otherwise alleged, whenever reference is made in this complaint to any act of
3 “defendant,” “defendants,” or to a specifically named defendant, such allegation shall mean that each
4 defendant acted individually and jointly with the other defendant named in the complaint.
5 27. Unless otherwise alleged, whenever reference is made in this complaint to any act or omission
6 of any corporate or business defendant, such allegation shall mean that such corporation or other
7 business defendant committed or omitted to act as in this complaint through its officers, members,
8 directors, stockholders, employees, agents, and/or representatives while they were acting within the
9 actual or apparent scope of their authority.
10 28. At all relevant times alleged herein, each defendant has been each the agent, alter-ego,
11 representative, partner, joint venturer, employee, or assistant of the other defendants and has acted
12 within the course and scope of said agency, alter-ego, representation, partnership, or joint venture with
13 the knowledge, notification, authorization, and consent of each of the other defendants.
14
15 JURISDICTION AND VENUE
16 29. This court has subject matter jurisdiction over this matter pursuant to Article VI, section
17 10 of the California Constitution because this action is a cause not given by statute to other trial courts,
18 and seeks, among other relief, a permanent injunction. Subject matter jurisdiction is also premised on,
19 inter alia, California Civil Code sections 51 and 51.5, and Business & Professions Code section 125.,6.
20 30. This court has personal jurisdiction over defendants in this action because all
21 defendants do sufficient business in California and have sufficient minimum contacts in California to
22
render the exercise of personal jurisdiction over them by California courts consistent with traditional
23
notions of fair play and substantial justice.
24
31. Venue is proper in this court because the sex discrimination and unequal treatment
25
alleged herein occurred in Los Angeles, California.
26
27
28

Complaint for Injunctive Relief and Damages


1 FIRST CAUSE OF ACTION
2 Against All Defendants
Violation of The Unruh Civil Rights Act, Civil Code Section 51
3 Refusing to Allow Plaintiff Admission Defendants’ Girls Night In With Iliza – No Boys
4 Allowed Show

5 32. Plaintiff incorporates in this cause of action the allegations contained in each and every
6 preceding paragraph of this Complaint as if they were set out at length herein.
7 33. By denying Plaintiff admission into Defendants’ GIRLS NIGHT IN WITH ILIZA –
8
NO BOYS ALLOWED show, and/or by organizing, hosting, employing, booking, putting on,
9
performing in, or at least aiding the sex discrimination associated with the show that only female
10
consumers were allowed to attend, Defendants intentionally denied equal accommodations,
11
advantages, facilities, privileges, or services to Plaintiff based on his sex, which is prohibited by the
12
Unruh Civil Rights Act, codified as Civil Code section 51.
13
34. A substantial motivating reason for Defendants’ conduct was the Plaintiff’s sex.
14
35. Defendants’ conduct harmed Plaintiff.
15
36. Defendants’ conduct was a substantial factor in causing harm to Plaintiff.
16
37. Defendants’ unequal treatment of customers subjects Defendants to injunctive relief.
17
18
19 SECOND CAUSE OF ACTION

20 Against All Defendants


Violation of The Unruh Civil Rights Act, Civil Code Section 51
21 Denying Plaintiff Beverages Provided To Attendees To Defendants’ Girls Night In With Iliza –
No Boys Allowed Show
22
23 38. Plaintiff incorporates in this cause of action the allegations contained in each and every
24 preceding paragraph of this Complaint as if they were set out at length herein.
25 39. By denying Plaintiff the beverages provided to attendees of Defendants’ GIRLS
26 NIGHT IN WITH ILIZA – NO BOYS ALLOWED show, and/or by organizing, hosting, employing,
27 booking, putting on, performing in, or at least aiding the sex discrimination associated with the show
28
that only female consumers were allowed to attend, Defendants intentionally denied equal

10

Complaint for Injunctive Relief and Damages


1 accommodations, advantages, facilities, privileges, or services to Plaintiff based on his sex, which is
2 prohibited by the Unruh Civil Rights Act, codified as Civil Code section 51.
3 40. A substantial motivating reason for Defendants’ conduct was the Plaintiff’s sex.
4 41. Defendants’ conduct harmed Plaintiff.
5 42. Defendants’ conduct was a substantial factor in causing harm to Plaintiff.
6
43. Defendants’ unequal treatment of customers subjects Defendants to injunctive relief.
7
8
THIRD CAUSE OF ACTION
9
Against All Defendants
10 Violation of Civil Code Section 51.5
11 Violation of The Unruh Civil Rights Act, Civil Code Section 51
Refusing to Allow Plaintiff Admission Defendants’ Girls Night In With Iliza – No Boys
12 Allowed Show
13
44. Plaintiff incorporates in this cause of action the allegations contained in each and every
14
preceding paragraph of this Complaint as if they were set out at length herein.
15
45. By denying Plaintiff admission into Defendants’ GIRLS NIGHT IN WITH ILIZA –
16
17 NO BOYS ALLOWED show, and/or by organizing, hosting, employing, booking, putting on,

18 performing in, or at least aiding the sex discrimination associated with the show that only female

19 consumers were allowed to attend, Defendants discriminated against Plaintiff based on his sex, which

20 is prohibited by Civil Code section 51.5.


21 46. A substantial motivating reason for Defendants’ conduct was the Plaintiff’s sex.
22 47. Defendants’ conduct harmed Plaintiff.
23 48. Defendants’ conduct was a substantial factor in causing harm to Plaintiff.
24 49. Defendants’ unequal treatment of customers subjects Defendants to injunctive relief.
25
26
27
28

11

Complaint for Injunctive Relief and Damages


1 FOURTH CAUSE OF ACTION
2 Against All Defendants
3 Violation of Civil Code Section 51.5
Denying Plaintiff The Beverages Provided To Attendees To Defendants’ Girls Night In With
4 Iliza – No Boys Allowed Show
5
50. Plaintiff incorporates in this cause of action the allegations contained in each and every
6
preceding paragraph of this Complaint as if they were set out at length herein.
7
51. By denying Plaintiff the food provided to attendees of Defendants’ GIRLS NIGHT IN
8
WITH ILIZA – NO BOYS ALLOWED show, and/or by organizing, hosting, employing, booking,
9
10 putting on, performing in, or at least aiding the sex discrimination associated with the show that only

11 female consumers were allowed to attend, Defendants discriminated against Plaintiff based on his sex,

12 which is prohibited by Civil Code section 51.5.

13 52. A substantial motivating reason for Defendants’ conduct was the Plaintiff’s sex.

14 53. Defendants’ conduct harmed Plaintiff.


15 54. Defendants’ conduct was a substantial factor in causing harm to Plaintiff.
16 55. Defendants’ unequal treatment of customers subjects Defendants to injunctive relief.
17
18 FIFTH CAUSE OF ACTION
19 Against Defendants Largo At The Coronet, The Coronet Theater, and Mark Brian Flanagan
20 Violation of Business & Professions Code Section 125.6

21 56. Plaintiff incorporates in this cause of action the allegations contained in each and every
22 preceding paragraph of this Complaint as if they were set out at length herein.
23 57. Defendant Mark Brian Flanagan is the holder of California Department of Alcoholic
24 Beverage Control License Number 475296, the business establishment doing business as The Coronet
25
Theater, which is also known as Largo At The Coronet.
26
58. Upon information and belief, by denying Plaintiff admission to Defendants’ GIRLS
27
NIGHT IN WITH ILIZA – NO BOYS ALLOWED show, and by denying Plaintiff alcoholic
28
beverages during the show, Defendants Largo At The Coronet, The Coronet Theater, and Mark Brian

12

Complaint for Injunctive Relief and Damages


1 Flanagan made a discrimination or restriction in the performance of its ABC-licensed activity of
2 providing alcoholic beverages to the public on the basis of the patrons’ sex, as proscribed by California
3 Business & Professions Code section 125.6.
4 59. Defendants Largo At The Coronet, The Coronet Theater, and Mark Brian Flanagan’s
5 conduct harmed Plaintiff.
6
60. Defendants Largo At The Coronet, The Coronet Theater, and Mark Brian Flanagan’s
7
conduct subjects Defendants Largo At The Coronet, The Coronet Theater, and Mark Brian Flanagan
8
to injunctive relief.
9
10
SIXTH CAUSE OF ACTION
11
Against All Defendants
12 Negligence
13 61. Plaintiff incorporates in this cause of action the allegations contained in each and every
14 preceding paragraph of this Complaint as if the same were set out at length herein.
15
62. Defendants had a duty of care to avoid injury to Plaintiff. Specifically, Defendants had
16
a duty of care to avoid treating Plaintiff unequally based on his sex.
17
63. Defendants selected, hired, retained, and contracted with persons and/or entities that
18
harmed Plaintiff, as described above.
19
64. Defendants had the authority and duty to supervise, prohibit, control, and/or regulate
20
these persons and/or entities that harmed Plaintiff.
21
65. Defendants knew or reasonably should have known that persons or entities would
22
indeed harm Plaintiff.
23
24 66. Defendants breached its duty of care by (1) denying Plaintiff his right to equal

25 treatment, and (2) failing to use reasonable care in selecting, hiring, supervising, retaining, or

26 contracting with persons or entities that harmed Plaintiff.

27 67. In the alternative, Defendants negligently conceived, organized, hosted, employed

28 and/or aided Defendants’ GIRLS NIGHT IN WITH ILIZA – NO BOYS ALLOWED show.

13

Complaint for Injunctive Relief and Damages


1 68. As a direct and proximate result of Defendants’ negligence and negligent hiring,
2 supervision, and retention, Plaintiff suffered damages in amounts to be proven at trial.
3
4 PRAYER FOR RELIEF
5 WHEREFORE, Plaintiff prays for the following relief:
6 1. For an order providing equitable and injunctive relief permanently enjoining
7 Defendants from engaging in unequal treatment of consumers based on the consumers’ sex in violation
8 of Civil Code sections 51 and 51.5, and Business and Professions Code section 125.6.
9 2. For an order providing equitable and injunctive relief ordering Defendants to undergo
10 sensitivity training regarding sex discrimination.
11
3. For statutory damages pursuant to Civil Code section 52;
12
4. For costs incurred herein, including attorneys’ fees to the extent allowable by statute,
13
including but not limited to Civil Code sections 52 and Code of Civil Procedure section 1021.5; and
14
5. For such other and further legal and equitable relief as this court may deem proper.
15
16
Dated: December 20, 2017 Respectfully submitted,
17
18
By: _____________________
19 Alfred G. Rava
Rava Law Firm
20
21
22
23
24
25
26
27
28

14

Complaint for Injunctive Relief and Damages


EXHIBIT 1
Largo at the Coronet » GIRLS’ NIGHT IN with ILIZA and special guests – Tickets – Largo at the Coronet – Los Angeles, CA – November 13th, 2017

366 N La Cienega Blvd, Los Angeles, CA


(310) 855- 0350
Enter an Artist or Event Search

CALENDAR TICKET INFO LOCATION/CONTACT

VIDEOS PHOTOS PRESS MAILING LIST


GIRLS' NIGHT
IN with ILIZA Sign Up For Our Email List Submit

and special
guests RSVP

Mon, November 13, 2017


Doors: 7:00 pm / Show: 8:00 pm
$30.00 MORE UPCOMING
Tickets SHOWS
Seat assignments begin at 6:00PM, Doors Fri 12/15 - Middleditch and Schwartz
open for drinks at 7:00PM, Showtime at (Thomas Middleditch and Ben
8:00PM | When you arrive at Will Call on Schwartz)
the night of the show, seats will be
assigned first come first served, from the Sat 12/16 - Harry Shearer and Judith
front of the theatre to the back. If you want Owen's Christmas Without Tears
to sit closer, be sure to come earlier. | NO (Does This Tree Make Me Look Fat?)
LATE ENTRY * NO REFUNDS * NO
Sun 12/17 - The BGS Christmas
EXCHANGES * SPECIAL GUESTS ARE
Situation with Ed Helms, The
SUBJECT TO CANCEL WITHOUT
Dustbowl Revival & Friends
NOTICE
Tue 12/19 - Rob Bell Christmas
Show with special guests the band
Share This Event Joseph
Wed 12/20 - Jane Lynch's A Swingin' 
Little Christmas!
Thu 12/21 - The Watkins Family Hour
Like You and 8 others like this.8 people like this. Be the first of your friends.
Holiday Show
Fri 12/22 - Jon Brion
1 Comment Sort by Oldest
Thu 12/28 - Jeff Tweedy
Fri 12/29 - Jeff Tweedy

Add a comment... Fri 1/05 - Tig Has Friends


Sat 1/06 - The Black Version with
special guest Wayne Brady!
Rachel Powell

https://www.largo-la.com/event/1579879-girls-night-in-iliza-special-los-angeles/[12/15/2017 11:56:11 AM]


Largo at the Coronet » GIRLS’ NIGHT IN with ILIZA and special guests – Tickets – Largo at the Coronet – Los Angeles, CA – November 13th, 2017

yes. and thank you. Mon 1/08 - Wild Horses with special
guest Matthew Gray Gubler
Like · Reply · 6w
Tue 1/09 - WOMP It Up! Live with
Facebook Comments Plugin Jessica St. Clair and Lennon Parham
GIRLS' NIGHT IN with ILIZA and special guests with special guests Jason
Iliza is bringing her girls invited only show back to Los Mantzoukas, Brian Huskey and many
Angeles. Girls' Night In is a hybrid stand up show and more from the Wompler Universe!
interactive discussion between Iliza and the women in the
Wed 1/10 - Trae Crowder & Friends
audience aimed at giving women a place to vent in a
supportive, fun and inclusive environment. She invites women Thu 1/11 - Peter Rowan & Ramblin'
of all walks of life to come, laugh with her and at her and be Jack Elliott
ready to share and feel safe for an awesome night of comedy
and love.

A portion of ticket proceeds will be donated to Planned Parenthood.


INSTAGRAM
Iliza will also be meeting fans after the show and signing copies of her new
book, Girl Logic, which hits shelves November 7th. Books will be available for PHOTOS
purchase on site.

Venue Information:
Largo at the Coronet
366 N La Cienega Blvd
Los Angeles, CA, 90048
http://www.largo- la.com

View More →

TWITTER FEED
RT @laurenlapkus: GUYYYS! Our
guest for our next @WildHorsesShow
at @LargoLosAngeles is
@GUBLERNATION!!! January 8 at
8:30! We will have an… about 17
hours ago

RT @BenBlacker: @TheExorcistFOX
@jerslater @Seanecrouch
@bendanielsss @JohnTheCho
@FOXTV @Brianne_Howey
@hkasulka @lijunli @briannahilde
PL… 11:12:22 AM December 14, 2017

RT @deadpilotspod: It's here! The new


episode of @deadpilotspod!
#Jetpackula written by @RobSchrab
starring @pattonoswalt
@ConstanceWu and… 11:11:35 AM
December 14, 2017

RT @WildHorsesShow: If you missed


the live Wild Horses show with
@nickkroll (or just want to relive the
magic), you can hear it now for fre…
11:11:27 AM December 14, 2017

https://www.largo-la.com/event/1579879-girls-night-in-iliza-special-los-angeles/[12/15/2017 11:56:11 AM]


EXHIBIT 2
(7) Iliza Shlesinger - Home

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Brandon Hill You say limited opportunities but the company I work for just
promoted a woman to president and it’s a male dominated industry and
company. The only thing that limits anyone is their self.
LikeShow more reactions · Reply · 10 · November 13 at 3:09pm · Edited

5 Replies

Mike Winklepleck Limited opportunities? This is the problem, telling


girls/woman that they have no chance from the get go. Those who work hard
find opportunities. Or am I allowed to say anything because I'm a guy?
LikeShow more reactions · Reply · 8 · November 13 at 3:32pm

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Iliza Shlesinger
November 12 at 6:10pm ·

Tomorrow is my ONLY GIRLS ALLOWED show #GirlsNightIn - we are


gonna have @jesswellington2 and @jessdweck share some awesome
stories and then we are gonna have a fun talk about our world, girls.
Very special. Tickets at ILIZA.COM and the show is at 8 at Largo! Don't
delay. Come with an open mind, and open heart and wear something fun!

https://www.facebook.com/IlizaShlesinger/[11/16/2017 8:27:28 AM]


(7) Iliza Shlesinger - Home

 
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Morgan King Hey ILIZA! Can I just grab a pic with you? Huge fan but got
turned away for being a dude! I get it! But was hoping to meet you real quick
and snap a pic as a constellation prize!
LikeShow more reactions · Reply · November 13 at 7:52pm · Edited

Bea Cohen I’m so bummed I wasn’t able to get tickets!


LikeShow more reactions · Reply · November 13 at 1:53pm

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Iliza Shlesinger
November 11 at 12:30pm ·

TONIGHT I AM PLAYING NEW YORK! Iliza.com/tour for


#Repost @comedy_nyc (@get_repost)
・・・
What's good funny followers in NYC!? It's Saturday which is a great night to
go see comedy especially since it's #newyorkcomedyfestival ! DAY 5
features include:...
See More

https://www.facebook.com/IlizaShlesinger/[11/16/2017 8:27:28 AM]


EXHIBIT 3
Protections Under the Law Against Sex Businesses that are Governed by the Filing a Complaint
Discrimination Unruh Civil Rights Act
The Department of Fair Employment and
Housing ( DFEH or Department) is charged with
The list below includes examples of businesses that
The Unruh Civil Rights Act (Civ. Code, § 51), the task of upholding the Unruh Act, and
are covered by the Unruh Act. This list is
originally enacted in 1959, was designed to protect ensuring that its laws and principles are not
non-exhaustive, and may include any place of public
the rights of Californians from arbitrary violated. If you believe you are a victim of
accommodation regardless of whether the entity is a
discrimination and to guarantee their rights to full unlawful discrimination, do not hesitate to call
traditional business or non-profit entity.
and equal access to all public accommodations the DFEH and file a complaint following these
regardless of sex. steps:

Discrimination by business establishments on the Contact the DFEH by calling the toll
basis of sex is against the law. It is unlawful for any Bars and Nightclubs. free number at (800) 884-1684 to
business that is open to the general public to Restaurants. schedule an appointment.
discriminate against a patron based on any of the Hotels and Motels. "Be prepared to present specific
following classifications: sex, race, color, religion, Retail Shops. facts about the alleged harassment
ancestry, national origin, disability, medical Golf Courses. of discrimination.
condition, marital status, or sexual orientation. The Fitness Clubs or Gyms. "Provide any copies you may have
Unruh Act protection is not limited to these Theaters. of documents that support the
classifications. It is an Unruh Act violation for a Hospitals. charges in the complaint.
business to offer special treatment, whether Barber Shops and Beauty Salons. Keep records and documents about
preferential or detrimental, to one class of patrons Non-Profit Organizations (open to the complaint, such as receipts,
regardless of the business' motives for doing so. the public). stubs, bills, applications, flyers,
Public Agencies. witness contact information, and
Housing Accommodations. other materials.

Examples of Sex-Based Discrimination establishment while providing admittance to


Maintaining "women only" or "men only" exercise members of the other sex without the same
Under the Unruh Violations areas of a fitness club or gym and excluding or level or degree of search.
deterring the opposite sex from those areas.
The following are examples of potential violations of Promoting a business with "ladies night"
Establishing a "women only" or "men only" business
the Unruh Act. The list is not meant to be discounts on admission and services.
establishment which would otherwise be completely
exhaustive, and there is other conduct that may Denying access to a business, such as a
open to the public.
violate the Act. nightclub to a particular sex, or giving
Excluding one sex from a business premises during
Providing free admission, discounts, or preference to one sex over the other.
certain times.
promotional gifts to only one sex.
Posting signs or adopting policies for "women
Charging men and women different prices for
recommended" or "men preferred."
comparable services, such as clothing
Requiring members of one sex to submit to searches
alterations, haircuts, dry cleaning, or drinks at a
to gain admittance to a business.
restaurant or bar.
Complaints must be filed within one year For more information, contact the DFEH
from the last act of discrimination. The DFEH Toll Free (800) 884-1684
will conduct an impartial investigation. Sacramento area and out-of-state (916) 227-0551
Videophone for the Deaf (916) 226-5285
The Department is not an advocate for either E-mail contact.center @dfeh.ca.gov
the person complaining or the person Web site www.dfeh.ca.gov
complained against. The Department Facebook State of California
represents the state. The DFEH will, if http://www.facebook.com /#!/pages/Department-of-F DEPARTMENT OF
possible, try to assist both parties to resolve air-Employment-and-Housing/183801915445
FAIR EMPLOYMENT & HOUSING
the complaint. If a voluntary settlement YouTube http://www.youtube.com /califdfeh
cannot be reached, and there is sufficient Twitter http://twitter.com /DFEH
evidence to establish a violation of the law,
the Department may issue an accusation
In accordance with the California Government Code and
and litigate the case before the Fair
Americans with Disabilities Act requirements, this publication
Employment and Housing Commission or in can be made available in Braille, large print, computer disk, or
civil court. This law provides for a variety of tape cassette as a disability-related reasonable
remedies that may include the following: accommodation for an individual with a disability. To discuss
how to receive a copy of this publication in an alternative
Out-of-pocket expenses. format, please contact the DFEH at the telephone numbers
Cease and desist orders. and links above.
Damages for emotional distress.
Statutory damages of three times the
amount of actual damages, or a minimum
of $4,000 for each offense.

References 4. Ibister v. Boys' Club of Santa Cruz (1985) 40 Cal.3d

1. California Civil Code section 51.


72. A non-profit activities center for boys was a place of Unruh Civil Rights Act
public accommodation, and excluding an entire class of
2. Rotary Club of Duarte v. Board of Directors (1987) patrons, such as women, was illegal.
178 Cal.App.3d 1035. A non-profit club was a 5. Angelucci v. Century Supper Club (2007) 41 Cal.4th All persons within the jurisdiction of this
business establishment under the Unruh Act because 160. It was a violation of the Unruh Act for a night club to state are free and equal, and no matter
it offered its members substantial "commercial charge its male patrons a higher price for admission. what their sex, race, color, religion,
advantages and business benefits." Membership in The patrons need not affirmatively request ancestry, national origin, disability,
these kinds of organizations is a privilege or nondiscriminatory treatment, but rather, are entitled to it. medical condition, marital status, or
advantage under the Unruh Act. Thus, termination of The Unruh Act imposes a compulsory duty upon sexual orientation are entitled to the full
membership based on sex is prohibited. business establishments to serve all persons without and equal accommodations, advantages,
3. Warfield v. Peninsula Golf & Country Club (1995) arbitrary discrimination. facilities, privileges, or services in all
10 Cal.4th 594. By offering the public access to its 6. Koire v. Metro Car Wash ( 1985) 40 Cal.3d 24. The business establishments of every kind
facilities, the County Club became a business Unruh Act broadly condemns any business whatsoever.
establishment under the Unruh Act and could not establishment's policy of gender-based price discounts.
exclude women.
EXHIBIT 4
BUREAU OF EDMUND G. BROWN JR.
Attorney General
GAMBLING Mathew J. Campoy

CONTROL Acting Bureau Chief

NUMBER 8 GAMBLING ESTABLISHMENT ADVISORY January 18, 2008

“LADIES ONLY TOURNAMENTS”

It has come to the attention of the Bureau of Gambling Control that some gambling establishments
conduct “ladies only” poker tournaments that exclude men from participating, or admit them on
different terms from those accorded to women. It is the Bureau’s view that such tournaments may
violate California’s anti-discrimination laws.

Under the Unruh Civil Rights Act (Civil Code sections 51 and 51.5), businesses may not
discriminate in admittance, prices, or services offered to customers based on the customers’ sex,
race, color, religion, ancestry, national origin, disability, medical condition, marital status, or sexual
orientation. “Ladies only” tournaments or any other promotional events that fail to admit men and
women to advertised activities on an equal basis regardless of sex are unlawful. It may also be
unlawful under the Unruh Act to advertise tournaments as “ladies only” even if men are in fact
admitted.

The Bureau will approve only those events that include the following features: the event will be
open to all customers, the promotional gifts will be given equally to all event participants, the fees
and prices will be the same for all event participants, any discounts will not be based on gender or
another personal characteristic protected by the Unruh Act, and the event’s promotional materials do
not advertise gender-based discounts or imply a gender-based entrance policy or any other unlawful
discriminatory practice.

Gambling establishments should take notice that pursuant to Business and Professions Code
section 125.6, violations of the Unruh Act are cause for discipline under the Gambling
Control Act.

For more information regarding this advisory, contact the California Department of Justice, Bureau of
Gambling Control at (916) 263-3408.