You are on page 1of 12
2019-03-28 14:37 Fite PERRY CO CIR CLK 6064356143 >> P 1/12 19-Cl001f 03/21/2019 Charles tra Patt’ in, Perry Circuit Clerk COMMONWEALTH OF KENTUCKY PERRY CIRCUIT COURT CIVIL ACTION No. _(&-CI-\o% JASON FIELDS PLAINTIFF vs. HAMPTON INN & SUITES; EMPLOYEE RESOURCE GROUP, LLC; And SHARON LINDON DEFENDANTS Serve: Employee Resource Group, LLC Registered Agent, Aroma Bates 601 Main Street Suite 102 Hazard, Kentucky 41701 Serve: Sharon Lindon Hampton Inn & Suites 70 Morton Blyd Hazard, Kentucky 41701 Serve: Hampton Inn é& Suites ¢/o Sharon Lindon 70 Morton Blvd Hazard, Kentucky 41701 COMPLAINT REAL LM LA LIMEUUIN HME LLVLLLL LLL LALA The Plaintiff, JASON FIELDS (hereinafter “Plainti or “Jason”), via counsel, submits the following as his Complaint against the Defendants, HAMPTON INN & SUITES, EMPLOYEE RESOURCE GROUP, LLC, and SHARON LINDON. Filed 19-c1-00109 03/21/2019 Charles Ira Patterson, Perry Circuit Clerk resting Judge: HOW. ALISON ©. WELLS (523348) com; panc01 of caet2 2019-03-28 14:37 Filed 2. 3. 4 5. 6. Filed PERRY CO CIR CLK 6064356143 >> 19-c1-0010" * oai2iiz019 Charles tra Patt’ n, Porry Circult Clerk URISDICTION AND VENU! The Plaintiff, Jason Fields, at all relevant times horein, was a resident of Leslie County. His mailing address was and is 982 Granny Fork Road, Smilax, Kentucky 41764, ‘The Defendant, Hampton Inn & Suites, is located at 70 Morton Bivd., Hazard, Kentucky 41701. It may be served through its Manager, Sharon Lindon, locatcd at 70 Morton Blva., Hazard, Kentucky 41701, The Defendant, Employee Resource Group, LLC, is a Kentucky corporation, with a principal office located at 601 Main Street, Suite 102, Hazard, Kentucky 41701, It may be served through its registered agent, Aroma Bates, located at 601 Main Strect, Suite 102, Hazard, Kentucky 41701. The Defendant, Employee Resource Group, LLC, was the entity listed on the pay checks of the employees of Hampton Inn é& Suites. The Defendant, Sharon Lindon, is the manager of Hampton Inn & Suites located at 70 Morton Rivd., Hazard, Kentucky 41701. She may be served at 70 Morton Bivd., Hazard, Kentucky 41701. The amount in controversy exceeds the jurisdictional requirements of this Court. 19-C1-00109 o3i21/2019 Charles ira Patterson, Perry Circuit Clerk Paste Presiding Judge: HON. ALISON G. WELLS (638948) com: n00r02 of cust 2019-03-28 14:37 Filed Filed 10, i, 12. 13. 14, 415. PERRY CO CIR CLK 6064356143 >> P 3/12 ” os/ew2019 Charles ira Pate”, Parry Cireult Clork FACTS COMMON TO ALL COUNTS ‘The Plaintiff began to work for the Hampton Inn in or around June 2016. ‘The Plaintiff was hired in the position of front desk employce on second shift. Second shift hours were approximately 3:00 p.m. through 11:00 pam. When the Plaintiff was hired, the manager, Defendant Sharon Lindon (‘Lindon’), discovered that the Plaintiff was going through a divorce, Lindon informed the Plaintiff that she was a member of the Common Bond Christian Fellowship Ministries. The church met at the Worship & Warfare Center at 229 Lovern Street, Hazard, Kentucky 41702. Lindon told the Plaintiff that the reason for his marital probleme was that he had demons. Lindon told the Plaintiff that if he were going to works for her he had to be cleansed. Lindon told the Plaintiff she had been cleansed three or four times and it was similar to an exorcism. The Plaintiff was also given a packet of papers by Lindon to be completed and turned in. The packet contained 1 page of 19-C1.00103 03/21/2019 Charles ra Patterson, Perry Circuit Clerk Presicing Jucige: HON. ALISON c, WELLS (933848) cone: 690003 of an00%2