COMPLAINT FOR DAMAGES
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INTRODUCTION
1. This is an action for damages as to: (1) Sexual Harassment under the Fair Employment and Housing Act (“FEHA”); (2) Failure to Prevent Harassment under the FEHA; and (3) Negligent Retention of Unfit Employees; (4) Intentional Infliction of Emotional Distress; and Unfair Business Practices (Business and Professions Code § 17200
et seq.
). 2. This action arises out of events involving Plaintiffs KATHERINE PAGE (hereinafter “PAGE”) and ASJA SEVER (hereinafter “SEVER”) (collectively, “PLAINTIFFS”), two former female servers at COQUETA, a San Francisco restaurant owned and operated by celebrity chef Defendant MICHAEL CHIARELLO (hereinafter “CHEF CHIARELLO”) through his company Defendant GRUPPO CHIARELLO LLC, a California Limited Liability Corporation (hereinafter collectively “GRUPPO CHIARELLO”) and/or SERRA HOSPITALITY GROUP, LLC (“SERRA”). Both PAGE and SEVER were sexually harassed and forced to endure a hostile, sexually charged work environment at COQUETA at the hands of Defendants CHEF CHIARELLO, Executive Chef DOMINICK MAIETTA, an individual (hereinafter “CHEF MAIETTA”); current General Manager MIRKO GALLIANI, an individual (“GALLIANI”); and current Assistant General Manager MARC PEYER, an individual (“PEYER”) as well as DOES 1-50, inclusive.
THE PARTIES
3.
PAGE was employed by GRUPPO CHIARELLO and/or SERRA from approximately April 1, 2013 until March 13, 2016. PAGE was employed as a server at COQUETA, a restaurant operated and managed by GRUPPO CHIARELLO at all times relevant to the events described in this complaint. PAGE is female. 4.
SEVER was employed by GRUPPO CHIARELLO and/or SERRA from approximately May 26, 2014 through March 12, 2016. SEVER was also employed as a server at COQUETA. SEVER is female. 5.
PAGE and SEVER are informed and believe and thereon allege that Defendant GRUPPO CHIARELLO was at all times relevant herein a limited liability company duly organized and existing under the laws of the State of California. At all relevant times, PAGE
COMPLAINT FOR DAMAGES
212345678910111213141516171819202122232425262728and SEVER worked at GRUPPO CHIARELLO’S COQUETA restaurant located on Pier 5 in San Francisco, California. PAGE and SEVER are informed and believe and thereon allege that GRUPPO CHIARELLO owns and operates the COQUETA restaurant. 6.
PAGE and SEVER are informed and believe and thereon allege that Defendant SERRA was at all times relevant herein a limited liability company duly organized and existing under the laws of the State of California. At all relevant times, PAGE and SEVER worked at the COQUETA restaurant located on Pier 5 in San Francisco, California. PAGE and SEVER are informed and believe and thereon allege that SERRA owns and operates COQUETA, among other restaurants in the San Francisco Bay Area. 7.
Defendant CHEF CHIARELLO was at all relevant times mentioned herein the President of GRUPPO CHIARELLO and a resident of the State of California. CHEF CHIARELLO is an American celebrity chef and author and has been a national television host of his own cooking shows for over a decade on PBS, Food Network and Cooking Channel. He has also appeared on the highest rated food competition shows,
Top Chef
and
Top Chef Masters
. His Emmy Award-winning show
Easy Entertaining with Michael Chiarello
began in 2003 and airs daily on Cooking Channel. CHEF CHIARELLO is a regular contributor to NBC’s
The Today Show
, CBS’s
The Early Show
,
Martha Stewart Living Radio
,
Regis & Kelly
, and the San Francisco Chronicle’s
“Inside Scoop Voices”
Column.
CHEF CHIARELLO also owns and/or operates several local businesses including but not limited COQUETA, the Spanish tapas style restaurant located at Pier 5 in San Francisco, Bottega Ristorante in Yountville, and the Chiarello Family Vineyards which is also located in Yountville. He also founded NapaStyle, a company that offers a wide selection of specialty products for the kitchen, home and garden that express a unique way of living based on the beauty and style of the Napa Valley experience.
8.
Defendant CHEF MAIETTA was at all relevant times mentioned herein the Executive Chef at COQUETA and, on information and belief, is currently an employee of GRUPPO CHIARELLO that supervised both PAGE and SEVER. CHEF MAIETTA was at all relevant times a resident of the State of California. CHEF MAIETTA is male.
