2006 WL 741847 (N.D.Ill.) (Trial Pleading) United States District Court, N.D. Illinois,
Eastern Division.
Stacey GRIFFIN, Carrie Babb, Jada Johnson, and Monica Moniuszko, Plaintiffs, v.
SUTTON FORD, INC., Richard Mohammed, and Louis Mentor, Defendants.
No. 06CV0931. February 21, 2006.
Jury Demanded
Complaint
Judge Bucklo. Mag. Ashman.
Plaintiffs, by their undersigned attorney, and for their Complaint of discrimination against Defendants, state as follows;
NATURE OF THE CASE
1. The causes of action for the Plaintiffs arise under Title VII of the Civil Rights Act 42 U.S.C. Section 2000e as amended, 28 U.S.C. Paragraph 1331, and 28 U.S.C. 1367.
JURISDICTION AND VENUE
2. That this Court has jurisdiction over this matter based upon 42 U.S.C. 2000e, 28 U.S.C. Paragraph 1331, and 28 U.S.C. 1367.
3. That, Plaintiff CARRIE BABB (“BABB”), also brings her racial harassment claim pursuant to 42 U.S.C. Section 1981.
4. Venue in the Northern District of Illinois is proper. The claim for relief arose in this state as required by 42 U.S.C. 2000e.
5. That on or about November 29, 2004, STACEY GRIFFIN (“GRIFFIN”) filed a charge of discrimination #2102005-01240 with the United States Equal Employment Opportunity Commission (“EEOC”), alleging sexual harassment and retaliation. Said charge and allegations therein are attached and incorporated herein. (Attached as Exhibit 1).
6. That on or about November 29, 2004, BABB filed a charge of discrimination #210-2005-01238 with the EEOC, alleging sexual harassment, racial harassment, retaliation, and constructive discharge. Said charge and allegations therein are attached and incorporated herein. (Attached as Exhibit 2).
7. That on or about November 29, 2004, JADA JOHNSON (“JOHNSON”) filed a charge of discrimination #2102005-01243 with the EEOC, alleging sexual harassment and retaliation. Said charge and allegations therein are attached and incorporated herein. (Attached as Exhibit 3).

8. That on or about January 12,2005, MONICA MONIUSZKO (“MONIUSZKO”) filed a charge of discrimination #210-2005-01242 with the EEOC, alleging sexual harassment and retaliation. Said charge and allegations therein are attached and incorporated herein. (Attached as Exhibit 4).
9. That Plaintiff MONIUSZKO brings her complaint in reliance upon her own charge and those of her co-Plaintiffs pursuant to the single filing rule and continuing violations doctrine.
10. That Plaintiffs requested right-to-sue letters from the EEOC in connection with their charges but the EEOC declined to issue said right-to-sue letters.
11. That Plaintiffs have since made several requests for the issuance of right-to-sue letters. To the present, the EEOC has refused to issue same. Plaintiffs have also repeatedly requested the status of this investigation and when to expect a conclusion. However, the EEOC has failed to provide same. (Letters attached as Exhibit 5).
12. That the charges have been pending for more than 180 days and the EEOC has not dismissed the charges, filed a civil action, or entered into a conciliation agreement with the parties. As such Plaintiffs may file suit pursuant to 42 U.S.C. 2000e-5(f)(1).
13. That Plaintiffs have cooperated with the EEOC’s investigation to the present.
PARTIES
14. That Plaintiff, BABB, is female and a resident of the state of Illinois.
15. That Plaintiff, GRIFFIN, is female and a resident of the state of Illinois.
16. That Plaintiff, JOHNSON, is female and was a resident of the state of Illinois.
17. That Plaintiff, MONIUSZKO, is female and a resident of the state of Illinois.
18. That Defendant, SUTTON FORD, INC. (“SUTTON FORD”), is duly registered to conduct business in the state of Illinois.
19. That at all times relevant herein, SUTTON FORD was engaged in an industry affecting commerce and has had fifteen (15) or more employees for each working day in each of twenty (20) or more calendar weeks in the current or preceding calendar year.
20. That at all times relevant herein, RICHARD MOHAMMED (“MOHAMMED”) was employed by Defendant as a manager.
21. That at all times relevant herein, LOUIS MENTOR (“MENTOR”) was employed by Defendant as a salesperson.
22. That at all times relevant herein, RAMONE (LNU) (“RAMONE”) was employed by Defendant as a porter.
23. That at all times relevant herein, EDDIE (LNU) (“EDDIE”) was employed by Defendant as a manager.
24. That at all times relevant herein, JOHN LEFEBER was employed by Defendant as a manager.
25. That at all times relevant herein, RAY LEFEBER was employed by Defendant as a manager.
26. That at all times relevant herein, JIM IRVING (“IRVING”) was employed by Defendant as a manager.
27. That at all times relevant herein, CHARLES THATCHER (“THATCHER”) was employed by Defendant as a salesperson.

28. That at all times relevant herein, MICHAEL STEIHLER (“STEIHLER”) was employed by Defendant as a salesperson.
29. That at all times relevant herein, SUTTON FORD and its managers created an environment which encouraged and fostered a hostile work environment for Plaintiffs and other females. Such conduct was ongoing, open, and notorious. However, SUTTON FORD failed to take effective remedial action.
30. That at all times relevant herein, SUTTON FORD and its managers created an environment which encouraged and fostered a racially hostile work environment for BABB. Such conduct was ongoing, open, and notorious. SUTTON FORD failed to take effective remedial action.
COUNT I COMPLAINT F STACEY GRIFFIN FOR HOSTILE ENVIRONMENT SEXUAL HARASSMENT DIRECTED AT SUTTON FORD, INC.
31. That Plaintiff was hired by Defendant, SUTTON FORD, in November 2002 as a salesperson.
32. That during her employment, GRIFFIN performed her assigned tasks in a satisfactory and conscientious manner according to Defendant’s standards.
33. That at relevant times during her employment with Defendant, GRIFFIN was supervised by EDDIE, JOHN LEFEBER, RAY LEFEBER, and MOHAMMED.
34. That starting in January of 2004 and continuing until October 2004, GRIFFIN was subjected to persistent sexual harassment by MOHAMMED. Such harassing conduct included sexually offensive comments on a daily basis as well as inappropriate touching.
35. That MOHAMMED’s sexually harassing comments and inappropriate touching were severe and pervasive, with sexually offensive incidents occurring at least twenty (20) times a week.
36. That on one occasion during July of 2004, MOHAMMED grabbed GRIFFIN’s vaginal area and stated, “Yeah, I knew you had a fat pussy!”
37. That from January 2004 through October 2004, MOHAMMED slapped GRIFFIN’s buttocks multiple times a week.
38. That on another occasion, MOHAMMED grabbed GRIFFIN’s shirt, pulled it away from her body, and stated, “I just wanted to see what color bra you have on.”
39. That on another occasion, MOHAMMED touched GRIFFIN’s leg and asked, “Do you shave?”
40. That MOHAMMED made sexually offensive comments daily. For example, MOHAMMED said the following to GRIFFIN on different occasions: a. “How bad do you want this deal done? Are you going to suck my dick?”;
b. “Show me your titties!”;
c. “Do you have hair on your pussy?”;
d. “Do you shave?”;
e. “When are you going to let me hit that?”;
f. “This is my bitch!” (Referring to GRIFFIN);
g. MOHAMMED would unbuckle his pants and say, “I am not scared to pull it out. I will do it.”;

h. “How big are your nipples?”;
i. “When are you going to let me get some?”;
j. “What type of panties do you have on? Thong or granny panties?”; and
k. MOHAMMED would ask customers, “Would you do the deal if ??et you take her [GRIFFIN] home with you?”
41. That GRIFFIN witnessed MOHAMMED tell JOHNSON, “It tastes good. How would this feel?”, while rolling and wiggling his tongue.
42. That on another occasion, MOHAMMED stated to customer MARQUITA DUNBAR (“DUNBAR”), “You don’t have your W-2s, but if you suck my dick and give me some pussy, 1 will make them for you.”
43. That on that same occasion, MOHAMMED locked his office door with DUNBAR inside. MOHAMMED pulled his pants down and asked DUNBAR to “suck” his dick. DUNBAR’s mother complained to SUTTON FORD’s owner, SUTTON. GRIFFIN is not aware if MOHAMMED was ever disciplined for this conduct.
44. That other members of management heard MOHAMMED’s sexually offensive comments towards GRIFFIN and witnessed him inappropriately touch her. For example the following managers witnessed MOHAMMED’s sexually inappropriate behavior: ERIC VATES (“VATES”); JEFFREY RANDOLPH (“RANDOLPH”); ANITA SUTTON; TIFF ARSELA (“ARESELA”); and RAY VILLONE (“VILLONE”).
45. That as a result of GRIFFIN’s rejection of sexual advances and conduct, ARSELA and VATES subjected her to inferior treatment by trying to get GRIFFIN terminated by changing her work to make it appear as though she was making mistakes. GRIFFIN communicated this information to ANITA SUTTON and IRVING. However, ARSELA and VATES were not disciplined.
46. That on another occasion as a result of GRIFFIN’s rejection of sexual advances and conduct, ARSELA lied to the managers and told them that GRIFFIN could not come to work because she was at the circus. However, GRIFFIN had communicated to ARSELA that she was at the hospital for an emergency.
47. That even though other members of management witnessed MOHAMMED’s conduct, no one rebuked MOHAMMED, requested that he stop, or disciplined him.
48. That from February 2004 through August 2004, GRIFFIN complained to management employees. Specifically, GRIFFIN complained to PANSY WHITE (“WHITE”), EMMA WILLIAMS (“WILLIAMS”), and NATE SUTTON about MOHAMMED’s sexually offensive comments and inappropriate touching. However, the harassment never ceased.
49. That in December of 2002, GRIFFIN was subjected to persistent sexual harassment by EDDIE.
50. That starting in December of 2002, EDDIE would grab GRIFFIN’s hands when she brought him work related documents.
51. EDDIE made comments about GRIFFIN’s lips such as: “You got some really nice lips, I know what 1 could use those for” and “Your husband must be really happy to have lips like that.”
52. That in December of 2002, GRIFFIN complained to the owner, SUTTON, that EDDIE was sexually harassing her. SUTTON responded, “Hold off for a little while, we will be making some management decisions soon.” SUTTON never followed up with GRIFFIN following this discussion. GRIFFIN is not aware if EDDIE was ever disciplined.
53. That starting in December of 2002 and continuing until October 2004, GRIFFIN was subjected to persistent sexual harassment by RAMONE (LNU). Such harassing conduct included directing sexually offensive comments to GRIFFIN on a daily basis.
54. Some examples of comments that RAMONE made to GRIFFIN are:

a. “When are you going to let me lick that?” Referring to GRIFFIN’s vagina;
b. “I am always doing something for you. When are you going to do something with me?”;
c. “Oh Stacey, you just don’t know what I would to do you! You just give me one chance. I promise you!” RAMONE grabbed his penis when making this comment to GRIFFIN;
d. “You have the most perfect butt. Really, really you do have a great butt.”
55. That MARVIN (LNU; “MARVIN”), the manager of the porter team, witnessed numerous instances where RAMONE made sexually offensive comments. However, GRIFFIN is not aware if RAMONE was ever disciplined for such offensive comments.
56. That in February 2003, GRIFFIN complained to management employee, WILLIAMS, about RAMONE’s comments and that RAMONE was sexually harassing her. However, the harassment continued.
57. That other members of management heard RAMONE’s sexually offensive comments. For example, RANDOLPH (“RANDOLPH”), MARLON JACKSON (“JACKSON”), TINO (LNU; “TINO”), DOC HENDRIX (“HENDRIX”), and MARVIN were often present when RAMONE made sexually offensive comments.
58. That starting in January of 2003, GRIFFIN was subjected to persistent sexual harassment by one of the managers, JOHN LEFEBER. Such harassing conduct included daily sexually offensive comments.
59. Some examples of comments that JOHN LEFEBER made to GRIFFIN are as follows: a. “Have you ever been with a white man?”;
b. “Would you like to be with a white man?”; and
c. “Do you like cream in your coffee?”
60. That throughout his employment with SUTTON FORD, JOHN LEFEBER would stare at GRIFFIN for prolonged periods of time, thus making her uncomfortable.
61. That throughout 2003, GRIFFIN witnessed JOHN LEFEBER consume alcohol while at work. When JOHN LEFEBER was intoxicated, his sexually offensive comments worsened.
62. That starting in January of 2003, and continuing until October 2004, GRIFFIN was subjected to persistent sexual harassment by MENTOR. Such harassing conduct included making sexually offensive comments on a daily basis, as well as inappropriate touching.
63. Some examples of comments that MENTOR made to GRIFFIN are: a. “Oh yeah, you’ve got pink panties on” and “I am going down again, only next time I am not coming back up!” MENTOR made these comments after he crawled under the desk that GRIFFIN was sitting in;
b. “Yeah, you gaining weight in all the right places.”;
c. “Once you get a hold of this [his penis], you will leave Big Rod [GRIFFIN’s Husband]!”, while grabbing his penis;
d. “Big Rod [GRIFFIN’s Husband] must be working that right, because that ass is getting bigger and bigger!”;
e. “You have legs like a race horse”; and
f. “I like those pants, you going to let me take them off?”
64. That MENTOR also often made cat calls such as, “Ohh”, “Ah ah ah”, and “Woo Woo”.

65. That members of management heard MENTOR’s sexually offensive comments towards GRIFFIN. For example, VATES and RANDOLPH witnessed and heard most of MENTOR’s sexually inappropriate behavior.
66. That starting in January of 2003, GRIFFIN was subjected to persistent sexual harassment by, RAY LEFEBER, manager who routinely arranged sexually offensive activities.
67. That in the spring of 2003 for example, RAY LEFEBER arranged for exotic dancers to come to SUTTON FORD after the store had closed. GRIFFIN was working late in the finance office on this day and witnessed the exotic dancer arrive at SUTTON FORD. On that occasion, all of the male employees spoke freely and openly about the stripper.
68. That starting in 2003 and continuing until October 2004, GRIFFIN was subjected to persistent sexual harassment by IRVING, who directed sexually offensive comments to her on a daily basis.
69. Some examples of comments that IRVING made to GRIFFIN are: a. “Oh I just like to keep you around for eye candy.”;
b. “Why don’t you come with me to Las Vegas and hang out with me for a week. I got a jacuzzi and a pool.”; and
c. “Do you like cream in your coffee?”
70. That Defendant failed to take effective and appropriate remedial action in 2002, 2003, or 2004, after GRIFFIN complained about sexual harassment to management employees.
71. That as a result, MOHAMMED, EDDIE, JOHN LEFEBER, RAY LEFEBER, MENTOR, RAMONE, and IRVING continued their conduct, and extended their harassment and assault to other females under their supervision or that worked with them.
72. That Defendant’s officers and agents must also have been aware of this ongoing sexual harassment by MOHAMMED, EDDIE, JOHN LEFEBER, and RAY LEFEBER of their female subordinates, because it occurred on a daily basis in an open and notorious manner, such that it was observed by employees, managers, and supervisors alike.
73. That Defendant condoned sexual harassment, and failed to maintain a harassment-free work environment by failing to provide adequate training, counseling, and instructions to its employees and officers.
74. That Defendant failed to maintain a harassment-free work environment by failing to take effective corrective action against MOHAMMED, EDDIE, JOHN LEFEBER, RAY LEFEBER, MENTOR, RAMONE, and IRVING, after it became aware that they were making unwelcome sexual advances and comments towards women who worked for them, and assaulting them on an ongoing basis.
75. That as a result of these failures by Defendant, MOHAMMED, EDDIE, JOHN LEFEBER, and RAY LEFEBER continued to use their authority as supervisors to force their unwelcome sexual advances, offensive conduct and assaults on GRIFFIN and several other subordinate females on an ongoing basis.
76. That Defendant’s treatment of GRIFFIN was motivated by evil motive and intent, and was in reckless and callous indifference to GRIFFIN’s federally protected rights.
77. That the sex discrimination and sexual harassment that GRIFFIN was subjected to in the hands of Defendant, its agents, representatives and employees was persistent in nature, unwelcome, extremely offensive, humiliating, and had the effect of creating a hostile and intimidating work environment for GRIFFIN.
78. That said continuous and persistent sex discrimination and sexual harassment adversely affected the terms and conditions of her employment with Defendant.

79. That as a direct and proximate result of said unlawful employment practices, GRIFFIN has suffered the indignity of discrimination, the invasion of her right to be free from discrimination, and great humiliation which has manifested in physical illnesses, and emotional stress on the relationships between GRIFFIN and her friends and family.
80. That as a further direct and proximate result of said unlawful employment practices, GRIFFIN has suffered extreme mental anguish, outrage, severe anxiety about her future and her ability to support herself, harm to her employability and earning capacity, painful embarrassment among her friends and co-workers, damage to her reputation, disruption of her personal life, and loss of enjoyment of the ordinary pleasures of life.
PRAYER FOR RELIEF
WHEREFORE, GRIFFIN respectfully requests that this Court provide the following equitable and legal relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date, and cause this case to be expedited in every possible way.
b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment.
c. Award Plaintiff, GRIFFIN, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest.
d. Award Plaintiff, GRIFFIN, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses.
e. Award Plaintiff, GRIFFIN, a judgment against Defendant for compensatory damages.
f. Grant judgment against Defendant for punitive damages for willful and wanton conduct.
g. Grant such other and further relief as this court deems just and proper.
COUNT II COMPLAINT OF STACEY GRIFFIN FOR QUID PRO QUO SEX DISCRIMINATION DIRECTED AT SUTTON FORD, INC.
81. That GRIFFIN incorporates the preceding paragraphs by reference here.
82. That MOHAMMED implicitly and explicitly conditioned GRIFFIN’s enjoyment of the various terms, conditions, and benefits of employment on her submission to his sexual advances. Such terms and conditions of employment include the assignment of deals, sales leads and such others.
83. That Defendant’s conduct in subjecting Plaintiff to inferior terms and conditions of employment and in terminating her amounts to quid pro quo sexual harassment in violation of the law.
PRAYER FOR RELIEF
WHEREFORE, GRIFFIN respectfully requests that this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest praticable date, and cause this case to be expedited in every possible way.
b. Order a permanent injunction prohibiting Defendant from further acts of sexual discrimination and sexual harassment.
c. Award Plaintiff, GRIFFIN, back pay, reinstatement, appropriate future earnings and reimbursement for income, and fringe benefits lost to the present with applicable statutory interest.

d. Award Plaintiff, GRIFFIN, a judgment against Defendant for compensatory damages. e. Award Plaintiff, GRIFFIN, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
COUNT III COMPLAINT OF STACEY GRIFFIN FOR RETALIATION DIRECTED AT SUTTON FORD, INC.
84. That GRIFFIN incorporates the preceding paragraphs by reference here. 85. That GRIFFIN was terminated on or around October 5, 2004. 86. That Defendant’s termination of GRIFFIN amounts to illegal retaliation for resisting conduct which GRIFFIN in good faith believed to be sexual harassment. 87. That Defendant and its agents further subjected GRIFFIN to inferior terms and conditions of employment for resisting conduct GRIFFIN in good faith believed to be sexual harassment. 88. That the adverse actions followed GRIFFIN’s protected activity within such a period of time as to raise an inference of retaliatory motivation.
PRAYER FOR RELIEF WHEREFORE, Plaintiff, GRIFFIN respectfully requests this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, GRIFFIN, back pay, reinstatement, appropriate future earnings and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, GRIFFIN, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses. e. Award Plaintiff, GRIFFIN, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.

COUNT IV COMPLAINT OF STACEY GRIFFIN FOR ASSAULT AND BATTERY DIRECTED TO RICHARD MOHAMMED AND SUTTON FORD, INC.
89. That GRIFFIN incorporates the preceding paragraphs by reference here. 90. That MOHAMMED intended to engage in offensive and harmful physical contact with GRIFFIN’s body.
91. That MOHAMMED’s conduct in touching and attempting to touch GRIFFIN was intentional. 92. That MOHAMMED’s conduct in touching and attempting to touch GRIFFIN placed her in apprehension of imminent offensive physical contact by MOHAMMED. 93. That MOHAMMED’s conduct amounts to willful and wanton conduct.
94. That GRIFFIN is free from willful and wanton conduct. 95. That as a result of MOHAMMED’s conduct, GRIFFIN suffered and continues to suffer fright, physical illnesses, mental anguish, humiliation and embarrassment. 96. That Defendant, Sutton Ford, is directly responsible for the assault and battery endured by GRIFFIN because it knew or in the exercise of reasonable care should have known about such conduct, but railed to take reasonable steps to prevent or correct it.
PRAYER FOR RELIEF WHEREFORE, GRIFFIN respectfully requests that the Court provide the following equitable and legal relief: a. Award GRIFFIN a judgment against MOHAMMED for compensatory and punitive damages. b. Award GRIFFIN a judgment against SUTTON FORD for compensatory and punitive damages.
c. Enter an order granting GRIFFIN reasonable compensation for the fright, humiliation, embarrassment, physical illnesses and mental anguish suffered by GRIFFIN as a result of MOHAMMED’s conduct. d. Grant GRIFFIN such other and further relief as this court deems just and proper.
COUNT V COMPLAINT OF CARRIE BABB FOR HOSTILE ENVIRONMENT SEXUAL HARASSMENT DIRECTED TO SUTTON FORD, INC.
97. BABB incorporates the preceding paragraphs by reference here. 98. That BABB was hired by Defendant in April of 2004, as a Car Salesperson. 99. That during her employment, BABB performed her assigned tasks in a satisfactory and conscientious manner according to Defendant’s standards. 100. That at relevant times during her employment with Defendant, BABB was supervised by MOHAMMED. 101. That starting in April of 2004, and continuing until September 2004, BABB was subjected to persistent sexual harassment by MOHAMMED. Such harassing conduct included sexually offensive comments on a daily basis and offensive as well as inappropriate touching.
102. That MOHAMMED’s sexually harassing comments and inappropriate touching were severe and pervasive, and occurred on a daily basis.

103. That from April 2004 through September 2004, MOHAMMED slapped BABB’s buttocks on numerous occasions.
104. That MOHAMMED made daily sexually offensive comments to BABB such as: a. “Is the hair on your pussy blonde too?”;
b. How bad do you want this deal done? Are you going to suck my dick?”;
c. How bad do you want this deal done? Show me your titties!”;
d. “Have you ever licked an asshole before?”;
e. “How big are your nipples?”;
f. “Do you have big nipples?”;
g. “Have you ever been with a black man before?”;
h. “Once you go black, you never go back.”;
i. “Oh is that a thong?”;
j. “Is it red today?” and “Is it pink today?”. Referring to the color of BABB’s underwear;
k. “Do you want some of this dick?” While grabbing his penis;
l. “Do you like your hair pulled?”;
m. “Show me them titties!”;
n. “Let me see them titties!”;
o. “Am I going to see those titties?”;
p. “What’s wrong? Did somebody wear that ass out?”; and
q. “White men have little dicks and you need a black one.”
105. That BABB witnessed MOHAMMED tell JOHNSON, “It tastes good. How would this feel?”, while he rolled and wiggled his tongue.
106. That on a daily basis, rather than say “good morning” to BABB, MOHAMMED would say, “Suck me!”.
107. That BABB asked MOHAMMED to stop making offensive comments, slapping her buttocks. However, every time she complained, MOHAMMED just laughed. BABB also complained to other female employees about MOHAMMED’s conduct.
108. That in or around July and August of 2004, BABB complained to VATES about MOHAMMED’s sexually offensive comments and inappropriate touching. However, the harassment never ceased.
109. That members of management heard MOHAMMED’s sexually offensive comments towards BABB, and witnessed MOHAMMED’s inappropriate touching of her. For example, both VATES and ARSELLA witnessed MOHAMMED’s sexually inappropriate behavior.
110. That starting in April of 2004, and continuing until September 2004, BABB was subjected to persistent sexual harassment by MENTOR. Such harassing conduct included making daily sexually offensive comments to BABB.

111. That one example of a comment that MENTOR made to BABB is, “Put a little extra lip gloss on it. It will make it easier.”
112. That starting in April 2004, and continuing until September 2004, BABB was subjected to persistent sexual harassment by RAMONE who directed offensive comments toward her on a daily basis.
113. That some examples of such comments are as follows: a. “Can I go home with you?”;
b. “When are you going to let me get with that?”;
c. “When are you going to do something for me?”; and
d. “I know why you do not want to get with me. Its because I am not from this country.”
114. That MARVIN, the manager of the porter team, witnessed several of RAMONE’s sexually offensive comments. However, BABB is not aware if RAMONE was ever disciplined for such offensive comments.
115. That as a result of BABB’s rejection of sexual advances and conduct, ARSELA and VATES subjected BABB to inferior treatment by trying to get her terminated by changing her work to make it appear as though she was making mistakes. BABB communicated this information to ANITA SUTTON and IRVING. However, ARSELA and VATES were not disciplined.
116. That as a result of BABB’s rejection of sexual advances and conduct, MOHAMMED subjected BABB to inferior terms and conditions of employment by denying BABB’s financial deals. He also took BABB’s customers away and gave them to other employees.
117. That Defendant failed to take effective and appropriate remedial action in 2004 after BABB complained about sexual harassment to management employees.
118. That as a result, MOHAMMED, MENTOR, and RAMONE continued their conduct and extended their harassment and assault to other females under their supervision or those that worked with them.
119. That Defendant’s officers and agents must also have been aware of this ongoing sexual harassment by MOHAMMED of his female subordinates because it occurred on a daily basis in an open and notorious manner, such that it was observed by employees and supervisors alike.
120. That Defendant condoned sexual harassment and failed to maintain a harassment-free work environment by failing to provide adequate training, counseling, and instructions to their employees and officers.
121. That Defendant failed to maintain a harassment-free work environment by failing to take effective corrective action against MOHAMMED, MENTOR, and RAMONE after it became aware that they were assaulting and making unwelcome sexual advances and comments towards women who worked for them on an ongoing basis.
122. That as a result of these failures by Defendant, MOHAMMED continued to use his authority as a supervisor to force his unwelcome sexual advances, offensive conduct and assaults on BABB and several other subordinate females on an ongoing basis.
123. That Defendant’s treatment of BABB was motivated by evil motive and intent and was in reckless and callous indifference to BABB’s federally protected rights.
124. That the sex discrimination and sexual harassment that BABB was subjected to in the hands of Defendant, its agents, representatives and employees was persistent in nature, unwelcome, extremely offensive, humiliating, and had the effect of creating a hostile and intimidating work environment for BABB.
125. That said continuous and persistent sex discrimination and sexual harassment adversely affected the terms and conditions of her employment with Defendant.

126. That as a direct and proximate result of said unlawful employment practices, BABB has suffered the indignity of discrimination, the invasion of her right to be free from discrimination, and great humiliation which has manifested in physical illnesses and emotional stress on the relationships between BABB and her friends and family.
127. That as a further direct and proximate result of said unlawful employment practices, BABB has suffered extreme mental anguish, outrage, severe anxiety about her future and her ability to support herself, harm to her employability and earning capacity, painful embarrassment among her friends and co-workers, damage to her reputation, disruption of her personal life, and loss of enjoyment of the ordinary pleasures of life.
PRAYER FOR RELIEF
WHEREFORE, BABB respectfully requests that the Court provide the following equitable and legal relief. a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way.
b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment.
c. Award Plaintiff, BABB, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest.
d. Award Plaintiff, BABB, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses.
e. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages.
f. Grant judgment against Defendant for punitive damages for willful and wanton conduct.
g. Grant such other and further relief as this court deems just and proper.
COUNT VI COMPLAINT OF CARRIE BABB FOR QUID PRO QUO SEX DISCRIMINATION DIRECTED AT SUTTON FORD, INC
128. That BABB incorporates the preceding paragraphs by reference here.
129. That MOHAMMED implicitly and explicitly conditioned BABB’s enjoyment of the various terms, conditions, and benefits of employment on her submission to his sexual advances. Such terms and conditions of employment include the assignment of deals, sales leads, and such others.
130. That Defendant’s conduct in subjecting Plaintiff to inferior terms and conditions of employment amounts to quid pro quo sexual harassment in violation of the law.
PRAYER FOR RELIEF WHEREFORE, BABB respectfully requests that this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date, and cause this case to be expedited in every possible way.
b. Order a permanent injunction prohibiting Defendant from further acts of sexual discrimination and sexual harassment.

c. Award Plaintiff, BABB, back pay, reinstatement, appropriate future earnings and reimbursement for income, and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages. e. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
COUNT VII COMPLAINT OF CARRIE BABB FOR RETALIATION DIRECTED AT SUTTON FORD, INC. 131. That Plaintiff, BABB, incorporates the preceding paragraphs by reference here. 132. That Defendant and its agents subjected BABB to inferior terms and conditions of employment for resisting conduct BABB in good faith believed to be sexual harassment. 133. That BABB was constructively discharged in or around September 2004. 134. That the adverse actions followed BABB’s protected activity within such a period of time as to raise an inference of retaliatory motivation.
PRAYER FOR RELIEF WHEREFORE, Plaintiff, BABB respectfully requests this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, BABB, back pay, reinstatement, appropriate future earnings and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, BABB, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses. e. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
COUNT VIII COMPLAINT OF CARRIE BABB FOR ASSAULT AND BATTERY DIRECTED TO RICHARD MOHAMMED AND SUTTON FORD. INC.

135. That BABB incorporates the preceding paragraphs by reference here. 136. That MOHAMMED intended to engage in offensive and harmful physical contact with BABB’s body. 137. That MOHAMMED’s conduct in touching and attempting to touch BABB was intentional. 138. That MOHAMMED’s conduct in touching and attempting to touch BABB placed her in apprehension of imminent offensive physical contact by MOHAMMED. 139. That MOHAMMED’s conduct amounts to willful and wanton conduct. 140. That BABB is free from willful and wanton conduct. 141. That as a result of MOHAMMED’s conduct, BABB suffered and continues to suffer fright, physical illnesses, mental anguish, humiliation and embarrassment. 142. That Defendant, Sutton Ford, is directly responsible for the assault and battery endured by BABB because it knew or in the exercise of reasonable care should have known about such conduct, but failed to take reasonable steps to prevent or correct it.
PRAYER FOR RELIEF WHEREFORE, BABB respectfully requests that the Court provide the following equitable and legal relief: a. Award BABB a judgment against MOHAMMED for compensatory and punitive damages. b. Award BABB a judgment against SUTTON FORD for compensatory and punitive damages. c. Enter an order granting BABB reasonable compensation for the fright, humiliation, embarrassment, physical illnesses and mental anguish suffered by BABB as a result of MOHAMMED’s conduct. d. Grant BABB such other and further relief as this court deems just and proper.
COUNT IX COMPLAINT OF CARRIE BABB OF RACE DISCRIMINATION AND RACIAL HARASSMENT DIRECTED AT SUTTON FORD, INC.
143. That BABB incorporates the preceding paragraphs by reference here. 144. That BABB is Caucasian. 145. That MOHAMMED is African-American. 146. That throughout BABB’s employment with SUTTON FORD, she was subjected to persistent and continuous racial discrimination and harassment. 147. That during the period from April 2004 through September 2004, MOHAMMED regularly made racially offensive comments around BABB such as: a. “I don’t like white people!”; b. “White people ain’t got no business selling cars!”; c. “White men have little dicks, you need a black one!”; d. “Once you go black, you never go back! Its true!”; and

e. “You white people can’t sell cars, I’m taking this customer.”
148. That BABB was subjected to unequal treatment in the various terms and conditions of employment duc to her race by MOHAMMED.
149. That MOHAMMED would often take customers away from BABB and give them to the African-American sales people.
150. That Defendant condoned racial harassment and failed to maintain a harassment-free work environment by failing to provide adequate training, counseling, and instructions to its employees and officers.
151. That Defendant failed to implement and enforce an effective race discrimination policy. Had Defendant done so, it could have prevented said race discrimination.
152. That all of these and similar incidents have created a hostile and offensive work environment for BABB.
153. That Defendant’s treatment of BABB was motivated by evil motive and intent and was recklessly and callously indifferent to BABB’s federally protected rights
154. That Defendant’s treatment of Plaintiff, BABB, was motivated by racial animus and Defendant and its agents acted with racial animus directed toward Caucasians in violation of the law.
155. That the racial discrimination and racial harassment BABB was subjected to at the hands of Defendant, its agents, representatives and employees was persistent in nature, unwelcome, extremely offensive, humiliating, and resulted in creating a hostile and intimidating work environment for Plaintiff.
156. That said continuous and persistent racial discrimination and racial harassment adversely affected the terms and conditions of BABB’s employment with Defendant.
157. That as a direct and proximate result of said unlawful employment practices and disregard for BABB’s rights and sensibilities, BABB has lost and will continue to lose substantial income, including, but not limited to, wages, fringes, seniority benefits, and other employment benefits
158. That as a further direct and proximate result of said unlawful employment practices, BABB has suffered the indignity of discrimination, the invasion of her right to be free from discrimination, and great humiliation which is manifest in physical illnesses and emotional stress on the relationships between BABB and her friends, family, and colleagues.
159. That as a further direct and proximate result of said unlawful employment practices, BABB has suffered extreme mental anguish, outrage, severe anxiety about her future and her ability to support herself, harm to her employability and earning capacity, shameful embarrassment among her friends, colleagues, and co-workers, damage to her reputation, disruption of her personal life, and loss of enjoyment of the ordinary pleasures of life.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff, BABB, respectfully prays that the Court provide the following equitable and legal relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way.
b. Award Plaintiff, BABB, appropriate back-pay, reinstatement, future earnings and reimbursement for income and fringe benefits lost to the present with applicable statutory interest.
c. Award Plaintiff, BABB, costs of litigation, including reasonable attorney’s fees and expert fees and expenses.
d. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages.

e. Grant judgment against Defendant for punitive damages for willful and wanton conduct. f. Enter an order requiring Defendant to implement effective steps to eliminate discrimination from Defendant’s organization. g. Grant such other and further relief as this court deems just and proper.
COUNT X COMPLAINT OF CARRIE BABB OF CONSTRUCTIVE DISCHARGE DIRECTED AT SUTTON FORD. INC.
160. That BABB incorporates the preceding paragraphs by reference here. 161. That Defendant had notice, condoned Plaintiff’s intolerable conditions, and did nothing. 162. That Plaintiff had no other choice but to resign because of Defendant’s intolerable conditions which included inferior treatment of Plaintiff, coupled with inferior benefits, terms, and conditions of employment.
PRAYER FOR RELIEF WHEREFORE, Plaintiff, BABB, respectfully prays that the Court provide the following equitable and legal relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, BABB, back pay, reinstatement, appropriate future earnings and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, BABB, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses e. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for will ful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
COUNT XI COMPLAINT OF JADA JOHNSON FOR HOSTILE ENVIRONMENT SEXUAL HARASSMENT DIRECTED TO SUTTON FORD, INC.
163. That JOHNSON incorporates the preceding paragraphs by reference here. 164. That JOHNSON was hired by Defendant in April of 2004, as a Car Salesperson. 165. That during her employment, JOHNSON performed her assigned tasks in a satisfactory and conscientious manner according to Defendant’s standards. 166. That at relevant times during her employment with Defendant, JOHNSON was supervised by MOHAMMED.

167. That starting in April of 2004 and continuing until July 2004, JOHNSON was subjected to persistent sexual harassment by MOHAMMED. Such harassing conduct included offensive and inappropriate touching and sexually offensive comments directed towards JOHNSON on a daily basis.
168. That for example, MOHAMMED said the following to JOHNSON: a. “How bad do you want this deal done? Let me see those titties!” When MOHAMMED was making this statement he would slam his hands down on his desk;
b. “Bend over and I will get your deal approved.”;
c. “Jada, can I just smell it?” While pointing to JOHNSON’s vaginal area;
d. “What color? Black? What color panties are you wearing?”;
e. “Can you take two guys at the same time?”;
f. “Show me your titties!”;
g. “I’m rich bitch! Let me see those titties!”;
h. “I know that it tastes good. How would this feel?” While rolling/wiggling his tongue in reference to him performing oral sex on JOHNSON);
i. “Looks like he [JOHNSON’s boyfriend at the time] has made that ass spread.”; and
j. “He is smiling because he [JOHNSON’s boyfriend at the time] got that ass!”
169. That on another occasion, MOHAMMED stated to JOHNSON, “I know I am a nymphomaniac and I know I need help. I just love pussy. I ain’t lying. I make you sick, don’t I?”
170. On another occasion during the summer of 2004, MOHAMMED put his hand under JOHNSON’s buttocks as she was sitting down on a chair. His hand touched her buttocks on that occasion.
171. On numerous occasions, when JOHNSON bent over, MOHAMMED stood behind her and simulated that he was having sex with her. MOHAMMED rubbed his penis against JOHNSON’s buttocks in a back and forth motion, humping her.
172. That MOHAMMED often drank gin from a coffee cup in the workplace. When he became intoxicated, the sexual harassment intensified.
173. That JOHNSON often asked MOHAMMED to stop making offensive comments, and to stop touching her. However, every time she complained, MOHAMMED just laughed and the harassment continued.
174. That on another occasion when JOHNSON complained to MOHAMMED, she told him, “You make me feel like a piece of meat.” MOHAMMED responded, “You are a piece of meat.”
175. That in or around June or July of 2004, JOHNSON complained to management employees, WHITE, WILLIAMS, and SUTTON about MOHAMMED’s sexually offensive comments and inappropriate touching. However, the harassment never ceased.
176. That in or around May or June of 2004, JOHNSON also complained to RANDOLPH and VATES about being sexually harassed. JOHNSON is not aware if MOHAMMED was disciplined as a result of her complaints.
177. That other members of management heard MOHAMMED’s sexually offensive comments toward JOHNSON, and witnessed MOHAMMED’s inappropriate touching of her. For example the following managers witnessed

MOHAMMED’s sexually inappropriate behavior: VATES; RANDOLPH; ANITA SUTTON; ARSELA; and VILLONE.
178. That VATES witnessed almost all of MOHAMMED’s sexually inappropriate behavior, but often just laughed and giggled in response to such behavior.
179. That starting in April of 2004 and continuing until July of 2004, JOHNSON was subjected to persistent sexual harassment by MENTOR. Such harassing conduct included inappropriate touching and sexually offensive comments directed toward her on a daily basis.
180. That on one occasion during June or July of 2004, MENTOR touched the side of JOHNSON’s breast and said, “Put that thing back.” JOHNSON told MENTOR never to touch her again.
181. That some examples of comments that MENTOR made to JOHNSON are: a. “Jada, I see you just sucked and fucked your way into another deal “;
b. “Jada, you should let the customers grab your ass.”;
c. “You look more like my speed then Jeff’s.” While simulating intercourse with his chair.;
d. “Put it under Jada’s ass, it will stay dry.”MENTOR said this outside while it was raining.; and
e. “Jada, I see you were a little nervous with those customers, next time call me over and I will work that out for you.”
182. That after complaining about MOHAMMED’s sexual harassment, he subjected JOHNSON to inferior treatment by making her wait longer periods of time for her financial deals to go through. This caused JOHNSON to lose money because customers did not want to wait extended periods of time.
183. That members of management and customers heard MENTOR’s sexually offensive comments toward JOHNSON. For example, customer CHARLES HANCOCKS, witnessed MENTOR sexually harass JOHNSON. VATES, ARSELLA, JACKSON and RANDOLPH also witnessed MENTOR’s sexually inappropriate behavior.
184. That starting in April of 2004 and continuing until July of 2004, JOHNSON was subjected to persistent sexual harassment by RAMONE (LNU). Such harassing conduct included making sexually offensive comments directed to JOHNSON on a daily basis.
185. That Some examples of comments that RAMONE made to JOHNSON are: a. “Let me show you how we do it where I’m from.” While sticking out his tongue. and
b. “Just let me taste you and you won’t want another man!”
186. That MARVIN, the manager of the porter team, witnessed several of RAMONE’s sexually offensive comments. However, JOHNSON is not aware if RAMONE was ever disciplined for such offensive comments.
187. That Defendant failed to take effective and appropriate remedial action in 2004 after JOHNSON complained about sexual harassment to management employees.
188. That as a result, MOHAMMED, MENTOR, and RAMONE continued their conduct and extended their harassment and assault to other females under their supervision or those that worked with them.
189. That Defendant’s officers and agents must also have been aware of this ongoing sexual harassment by MOHAMMED of his female subordinates because it occurred on a daily basis in an open and notorious manner, such that it was observed by employees and supervisors alike.
190. That Defendant condoned sexual harassment, and failed to maintain a harassment-free work environment by failing to provide adequate training, counseling, and instructions to its employees and officers.

191. That Defendant failed to maintain a harassment-free work environment by failing to take effective corrective action against MOHAMMED, MENTOR, and RAMONE after they became aware that they were making unwelcome sexual advances and comments towards women who worked for them and assaulting them on an ongoing basis.
192. That as a result of these failures by Defendant, MOHAMMED continued to use his authority as a supervisor to force his unwelcome sexual advances, offensive conduct, and assaults on JOHNSON and several other subordinate females on an ongoing basis.
193. That Defendant’s treatment of JOHNSON was motivated by evil motive and intent, and was in reckless and callous indifference to JOHNSON’s federally protected rights.
194. That the sex discrimination and sexual harassment that JOHNSON was subjected to in the hands of Defendant, its agents, representatives and employees was persistent in nature, unwelcome, extremely offensive, humiliating, and had the effect of creating a hostile and intimidating work environment for JOHNSON.
195. That said continuous and persistent sex discrimination and sexual harassment adversely affected the terms and conditions of her employment with Defendant.
196. That as a direct and proximate result of said unlawful employment practices, JOHNSON has suffered the indignity of discrimination, the invasion of her right to be free from discrimination and great humiliation which has manifested in physical illnesses, and emotional stress on the relationships between JOHNSON and her friends and family.
197. That as a further direct and proximate result of said unlawful employment practices, JOHNSON has suffered extreme mental anguish, outrage, severe anxiety about her future and her ability to support herself, harm to her employability and earning capacity, painful embarrassment among her friends and co-workers, damage to her reputation, disruption of her personal life, and loss of enjoyment of the ordinary pleasures of life.
PRAYER FOR RELIEF
WHEREFORE, JOHNSON respectfully requests that the Court provide the following equitable and legal relief. a. Advance this case on the docket, order a speedy hearing at the earliest practicable date, and cause this case to be expedited in every possible way.
b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment.
c. Award Plaintiff, JOHNSON, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest.
d. Award Plaintiff, JOHNSON, costs of litigation, including reasonable attorneys’ fees and expert fees, and expenses.
e. Award Plaintiff, JOHNSON, a judgment against Defendant for compensatory damages.
f. Grant judgment against Defendant for punitive damages for willful and wanton conduct.
g. Grant such other and further relief as this court deems just and proper.
COUNT XII COMPLAINT OF JADA JOHNSON FOR QUID PRO QUO SEX DISCRIMINATION DIRECTED AT SUTTON FORD, INC.
198. That JOHNSON incorporates the preceding paragraphs by reference here.

199. That MOHAMMED implicitly and explicitly conditioned JOHNSON’s enjoyment of the various terms, conditions, and benefits of employment on her submission to his sexual advances. Such terms and conditions of employment include the assignment of deals, sales leads and such others.
200. That Defendant’s conduct in subjecting Plaintiff to inferior terms and conditions of employment and in terminating her amounts to quid pro quo sexual harassment in violation of the law.
PRAYER FOR RELIEF WHEREFORE, JOHNSON respectfully requests that this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date, and cause this case to be expedited in every possible way.
b. Order a permanent injunction prohibiting Defendant from further acts of sexual discrimination and sexual harassment.
c. Award Plaintiff, JOHNSON, back pay, reinstatement, appropriate future earnings and reimbursement for income, and fringe benefits lost to the present with applicable statutory interest.
d. Award Plaintiff, JOHNSON, a judgment against Defendant for compensatory damages.
e. Award Plaintiff, JOHNSON, a judgment against Defendant for compensatory damages.
f. Grant judgment against Defendant for punitive damages for willful and wanton conduct.
g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company.
h. Grant such other and further relief as this Court deems just and proper.
COUNT XIII COMPLAINT OF JADA JOHNSON FOR RETALIATION DIRECTED AT SUTTON FORD, INC.
201. That Plaintiff, JOHNSON, incorporates the preceding paragraphs by reference here.
202. That JOHNSON was terminated on or around July 25, 2004.
203. That Defendant’s termination of JOHNSON amounts to illegal retaliation for resisting conduct which JOHNSON in good faith believed to be sexual harassment.
204. That Defendant and its agents further subjected JOHNSON to inferior terms and conditions of employment for resisting conduct JOHNSON in good faith believed to be sexual harassment.
205. That the adverse action followed JOHNSON’s protected activity within such a period of time as to raise an inference of retaliatory motivation.
PRAYER FOR RELIEF WHEREFORE, Plaintiff, JOHNSON respectfully requests this Court provide the following equitable and legal remedies for relief:

a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, JOHNSON, back pay, reinstatement, appropriate future earnings and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, JOHNSON, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses. e. Award Plaintiff, JOHNSON, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
COUNT XIV COMPLAINT OF JADA JOHNSON FOR ASSAULT AND BATTERY DIRECTED TO LOUIS MENTOR AND SUTTON FORD, INC.
206. That JOHNSON incorporates the preceding paragraphs by reference here. 207. That MENTOR intended to engage in offensive and harmful physical contact with JOHNSON’s body. 208. That MENTOR’s conduct in touching and attempting to touch JOHNSON was intentional. 209. That MENTOR’s conduct in touching and attempting to touch JOHNSON placed her in apprehension of imminent offensive physical contact by MENTOR. 210. That MENTOR’s conduct amounts to willful and wanton conduct. 211. That JOHNSON is free from willful and wanton conduct. 212. That as a result of MENTOR’s conduct, JOHNSON suffered and continues to suffer fright, physical illnesses, mental anguish, humiliation and embarrassment. 213. That Defendant, Sutton Ford, is directly responsible for the assault and battery endured by JOHNSON because it knew or in the exercise of reasonable care should have known bout such conduct, but failed to take reasonable steps to prevent or correct it.
PRAYER FOR RELIEF WHEREFORE, JOHNSON respectfully requests that the Court provide the following equitable and legal relief: a. Award JOHNSON a judgment against MENTOR for compensatory and punitive damages. b. Award JOHNSON a judgment against SUTTON FORD for compensatory and punitive damages. c. Enter an order granting JOHNSON reasonable compensation for the fright, humiliation, embarrassment, physical illnesses and mental anguish suffered by JOHNSON as a result of MENTOR’s conduct. d. Grant JOHNSON such other and further relief as this court deems just and proper.

COUNT XV COMPLAINT OF JADA JOHNSON FOR ASSAULT AND BATTERY DIRECTED TO RICHARD MOHAMMED AND SUTTON FORD, INC.
214. That JOHNSON incorporates the preceding paragraphs by reference here. 215. That MOHAMMED intended to engage in offensive and harmful physical contact with JOHNSON’s body. 216. That MOHAMMED’s conduct in touching and attempting to touch JOHNSON was intentional. 217. That MOHAMMED’s conduct in touching and attempting to touch JOHNSON placed her in apprehension of imminent offensive physical contact by MOHAMMED. 218. That MOHAMMED’s conduct amounts to willful and wanton conduct. 219. That JOHNSON is free from willful and wanton conduct. 220. That as a result of MOHAMMED’s conduct, JOHNSON suffered and continues to suffer fright, physical illnesses, mental anguish, humiliation and embarrassment. 221. That Defendant, Sutton Ford, is directly responsible for the assault and battery endured by JOHNSON because it knew or in the exercise of reasonable care should have known bout such conduct, but failed to take reasonable steps to prevent or correct it.
PRAYER FOR RELIEF WHEREFORE, JOHNSON respectfully requests that the Court provide the following equitable and legal relief: a. Award JOHNSON a judgment against MOHAMMED for compensatory and punitive damages. b. Award JOHNSON a judgment against SUTTON FORD for compensatory and punitive damages. c. Enter an order granting JOHNSON reasonable compensation for the fright, humiliation, embarrassment, physical illnesses and mental anguish suffered by JOHNSON as a result of MOHAMMED’s conduct. d. Grant JOHNSON such other and further relief as this court deems just and proper.
COUNT XVI COMPLAINT OF MONICA MONIUSZKO FOR HOSTILE ENVIRONMENT SEXUAL HARASSMENT DIRECTED TO SUTTON FORD, INC.
222. That MONIUSZKO incorporates the preceding paragraphs by reference here. 223. That MONIUSZKO was hired by Defendant in the fall of 2002 as a Finance Assistant. 224. That on March 11, 2003, MONIUSZKO was subjected to sexual harassment by STEIHLER who directed sexually offensive comments to her. 225. That for example, STEIHLER stated to MONIUSZKO: a. “What is wrong? Do you have boyfriend problems?” b. “What do you do for sex?”; c. “Do you have a boyfriend?”; and

d. “I suggest you try girl on girl. It would be good for you.”
226. MONIUSZKO reported the incidents to SUE SCHAFROTH (“SCHAFROTH”) who then reported them to WILLIAMS. WILLIAMS made both STEIHLER and MONIUSZKO sign a copy of the complaint. MONIUSZKO is not aware if STEIHLER was disciplined.
227. That in 2003, MONIUSZKO was subjected to sexual harassment by RANDOLPH who touched her inappropriately.
228. That on many occasions, RANDOLPH rubbed MONIUSZKO’s shoulders and hair, touched her leg, put his arms around her, and ran his foot up her leg. Every time he touched MONIUSZKO, she pulled away and told him to stop.
229. That RANDOLPH put his arms around MONIUSZKO almost every day that he worked with her.
230. That MONIUSZKO complained to RANDOLPH and asked him to stop each time he touched her. She also complained to other females that worked for Defendant.
231. That almost every day, RANDOLPH stared at MONIUSZKO for extended periods of time. He would not say anything when he stared at her.
232. That in approximately February and March of 2003, MONIUSZKO was subjected to sexual harassment by THATCHER. Such harassing conduct included inappropriate comments such as. a. “I want to take you home”;
b. “I could do some things to you”; and
c. “Do you want to hang out after work?”
233. That in February and March of 2003, MONIUSZKO was subjected to sexual harassment by MENTOR who made inappropriate comments and touched her in an offensive manner.
234. That MENTOR stated to MONIUSZKO: a. “I would go out with you if I wasn’t married” and
b. “Oh you are so hot!”
235. That MENTOR often grabbed MONIUSZKO’s hands for extended periods of time. Each time he did this, MONIUSZKO pulled away from him.
236. That from approximately January 2003 through March of 2003, MONIUSZKO was also subjected to sexual harassment by EDDIE who made sexually offensive and inappropriate comments.
237. That Defendant failed to maintain a harassment-free work environment by failing to take effective corrective action against EDDIE, MENTOR, RANDOLPH, THATCHER, and STEIHLER after they became aware that they were making sexually offensive comments and inappropriately touching women.
238. That as a result of these failures by Defendant, EDDIE, continued to use his authority as supervisor to force his unwelcome sexual advances, offensive conduct and sexually harass MONIUSZKO and other subordinate females on an ongoing basis.
239. That Defendant’s treatment of MONIUSZKO was motivated by evil intent and was in reckless and callous indifference to their federally protected rights.

240. That the sex discrimination and sexual harassment that MONIUSZKO was subjected to in the hands of the Defendant, its agents, representatives and employees was persistent in nature, unwelcome, extremely offensive, humiliating, and had the effect of creating a hostile and intimidating work environment for MONIUSZKO.
241. That said continuous and persistent sex discrimination and sexual harassment adversely affected the terms and conditions of her employment with Defendant.
242. That as a direct and proximate result of said unlawful employment practices, MONIUSZKO has suffered the indignity of discrimination, the invasion of her right to be free from discrimination and great humiliation which is manifest in physical illnesses and emotional stress on the relationships between MONIUSZKO and her friends and family.
243. That as a further direct and proximate result of said unlawful employment practices, MONIUSZKO has suffered extreme mental anguish, outrage, severe anxiety about her future and her ability to support herself, harm to her employability and earning capacity, painful embarrassment among her friends and co-workers, damage to her reputations, disruption of her personal life, and loss of enjoyment of the ordinary pleasures of life.
PRAYER FOR RELIEF
WHEREFORE, MONIUSZKO respectfully requests that the Court provide the following equitable and legal relief. a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way.
b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment.
c. Award Plaintiff, MONIUSZKO, back pay, reinstatement, appropriate future earnings and reimbursement for income and fringe benefits lost to the present with applicable statutory interest.
d. Award Plaintiff, MONIUSZKO, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses,
e. Award Plaintiff, MONIUSZKO, a judgment against Defendant for compensatory damages.
f. Grant judgment against Defendant for punitive damages for willful and wanton conduct.
g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company.
h. Grant such other and further relief as this court deems just and proper.
COUNT XVII COMPLAINT OF MONICA MONIUSZKO FOR RETALIATION DIRECTED AT SUTTON FORD, INC.
244. Thai MONIUSZKO incorporates the preceding paragraphs by reference here,
245. That MONIUSZKO was terminated in or around May of 2003.
246. That Defendant’s termination of MONIUSZKO amounts to illegal retaliation for resisting conduct which MONIUSZKO in good faith believed to be sexual harassment.
247. That Defendant and its agents further subjected JOHNSON to inferior terms and conditions of employment for resisting conduct JOHNSON in good faith believed to be sexual harassment.

248. That the adverse action followed MONIUSZKO’s protected activity within such a period of time as to raise an inference of retaliatory motivation.
PRAYER FOR RELIEF WHEREFORE, Plaintiff, MONIUSZKO respectfully requests this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, MONIUSZKO, back pay, reinstatement, appropriate future earnings and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, MONIUSZKO, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses. e. Award Plaintiff, MONIUSZKO, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
JURY DEMAND NOW COME Plaintiffs by their undersigned attorney, and demand a trial by jury in the above entitled cause of action.
Appendix not available.

 
 Stacey GRIFFIN, Carrie Babb, Jada Johnson, and Monica..., 2006 WL 741847 (2006)
2006 WL 741847 (N.D.Ill.) (Trial Pleading) United States District Court, N.D. Illinois,
Eastern Division. Stacey GRIFFIN, Carrie Babb, Jada Johnson, and Monica Moniuszko, Plaintiffs,
v. SUTTON FORD, INC., Richard Mohammed, and Louis Mentor, Defendants.
No. 06CV0931. February 21, 2006. Jury Demanded
Complaint
Judge Bucklo. Mag. Ashman. Plaintiffs, by their undersigned attorney, and for their Complaint of discrimination against Defendants, state as follows;
NATURE OF THE CASE 1. The causes of action for the Plaintiffs arise under Title VII of the Civil Rights Act 42 U.S.C. Section 2000e as amended, 28 U.S.C. Paragraph 1331, and 28 U.S.C. 1367.
JURISDICTION AND VENUE 2. That this Court has jurisdiction over this matter based upon 42 U.S.C. 2000e, 28 U.S.C. Paragraph 1331, and 28 U.S.C. 1367. 3. That, Plaintiff CARRIE BABB (“BABB”), also brings her racial harassment claim pursuant to 42 U.S.C. Section 1981. 4. Venue in the Northern District of Illinois is proper. The claim for relief arose in this state as required by 42 U.S.C. 2000e. 5. That on or about November 29, 2004, STACEY GRIFFIN (“GRIFFIN”) filed a charge of discrimination #210-2005-01240 with the United States Equal Employment Opportunity Commission (“EEOC”), alleging sexual harassment and retaliation. Said charge and allegations therein are attached and incorporated herein. (Attached as Exhibit 1). 6. That on or about November 29, 2004, BABB filed a charge of discrimination #210-2005-01238 with the EEOC, alleging sexual harassment, racial harassment, retaliation, and constructive discharge. Said charge and allegations therein are attached and incorporated herein. (Attached as Exhibit 2). 7. That on or about November 29, 2004, JADA JOHNSON (“JOHNSON”) filed a charge of discrimination #210-2005-01243 with the EEOC, alleging sexual harassment and retaliation. Said charge and allegations therein are attached and incorporated herein. (Attached as Exhibit 3).
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8. That on or about January 12,2005, MONICA MONIUSZKO (“MONIUSZKO”) filed a charge of discrimination #210-2005-01242 with the EEOC, alleging sexual harassment and retaliation. Said charge and allegations therein are attached and incorporated herein. (Attached as Exhibit 4). 9. That Plaintiff MONIUSZKO brings her complaint in reliance upon her own charge and those of her co-Plaintiffs pursuant to the single filing rule and continuing violations doctrine. 10. That Plaintiffs requested right-to-sue letters from the EEOC in connection with their charges but the EEOC declined to issue said right-to-sue letters. 11. That Plaintiffs have since made several requests for the issuance of right-to-sue letters. To the present, the EEOC has refused to issue same. Plaintiffs have also repeatedly requested the status of this investigation and when to expect a conclusion. However, the EEOC has failed to provide same. (Letters attached as Exhibit 5). 12. That the charges have been pending for more than 180 days and the EEOC has not dismissed the charges, filed a civil action, or entered into a conciliation agreement with the parties. As such Plaintiffs may file suit pursuant to 42 U.S.C. 2000e-5(f)(1). 13. That Plaintiffs have cooperated with the EEOC’s investigation to the present.
PARTIES 14. That Plaintiff, BABB, is female and a resident of the state of Illinois. 15. That Plaintiff, GRIFFIN, is female and a resident of the state of Illinois. 16. That Plaintiff, JOHNSON, is female and was a resident of the state of Illinois.
17. That Plaintiff, MONIUSZKO, is female and a resident of the state of Illinois. 18. That Defendant, SUTTON FORD, INC. (“SUTTON FORD”), is duly registered to conduct business in the state of Illinois. 19. That at all times relevant herein, SUTTON FORD was engaged in an industry affecting commerce and has had fifteen (15) or more employees for each working day in each of twenty (20) or more calendar weeks in the current or preceding calendar year. 20. That at all times relevant herein, RICHARD MOHAMMED (“MOHAMMED”) was employed by Defendant as a manager. 21. That at all times relevant herein, LOUIS MENTOR (“MENTOR”) was employed by Defendant as a salesperson.
22. That at all times relevant herein, RAMONE (LNU) (“RAMONE”) was employed by Defendant as a porter. 23. That at all times relevant herein, EDDIE (LNU) (“EDDIE”) was employed by Defendant as a manager. 24. That at all times relevant herein, JOHN LEFEBER was employed by Defendant as a manager.
25. That at all times relevant herein, RAY LEFEBER was employed by Defendant as a manager.
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26. That at all times relevant herein, JIM IRVING (“IRVING”) was employed by Defendant as a manager.
27. That at all times relevant herein, CHARLES THATCHER (“THATCHER”) was employed by Defendant as a salesperson.
28. That at all times relevant herein, MICHAEL STEIHLER (“STEIHLER”) was employed by Defendant as a salesperson.
29. That at all times relevant herein, SUTTON FORD and its managers created an environment which encouraged and fostered a hostile work environment for Plaintiffs and other females. Such conduct was ongoing, open, and notorious. However, SUTTON FORD failed to take effective remedial action.
30. That at all times relevant herein, SUTTON FORD and its managers created an environment which encouraged and fostered a racially hostile work environment for BABB. Such conduct was ongoing, open, and notorious. SUTTON FORD failed to take effective remedial action.
COUNT I COMPLAINT F STACEY GRIFFIN FOR HOSTILE ENVIRONMENT SEXUAL HARASSMENT DIRECTED AT SUTTON FORD, INC.
31. That Plaintiff was hired by Defendant, SUTTON FORD, in November 2002 as a salesperson.
32. That during her employment, GRIFFIN performed her assigned tasks in a satisfactory and conscientious manner according to Defendant’s standards.
33. That at relevant times during her employment with Defendant, GRIFFIN was supervised by EDDIE, JOHN LEFEBER, RAY LEFEBER, and MOHAMMED.
34. That starting in January of 2004 and continuing until October 2004, GRIFFIN was subjected to persistent sexual harassment by MOHAMMED. Such harassing conduct included sexually offensive comments on a daily basis as well as inappropriate touching.
35. That MOHAMMED’s sexually harassing comments and inappropriate touching were severe and pervasive, with sexually offensive incidents occurring at least twenty (20) times a week.
36. That on one occasion during July of 2004, MOHAMMED grabbed GRIFFIN’s vaginal area and stated, “Yeah, I knew you had a fat pussy!”
37. That from January 2004 through October 2004, MOHAMMED slapped GRIFFIN’s buttocks multiple times a week.
38. That on another occasion, MOHAMMED grabbed GRIFFIN’s shirt, pulled it away from her body, and stated, “I just wanted to see what color bra you have on.”
39. That on another occasion, MOHAMMED touched GRIFFIN’s leg and asked, “Do you shave?”
40. That MOHAMMED made sexually offensive comments daily. For example, MOHAMMED said the following to GRIFFIN on different occasions: a. “How bad do you want this deal done? Are you going to suck my dick?”;
b. “Show me your titties!”;
c. “Do you have hair on your pussy?”;
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d. “Do you shave?”;
e. “When are you going to let me hit that?”;
f. “This is my bitch!” (Referring to GRIFFIN);
g. MOHAMMED would unbuckle his pants and say, “I am not scared to pull it out. I will do it.”;
h. “How big are your nipples?”;
i. “When are you going to let me get some?”;
j. “What type of panties do you have on? Thong or granny panties?”; and
k. MOHAMMED would ask customers, “Would you do the deal if ??et you take her [GRIFFIN] home with you?”
41. That GRIFFIN witnessed MOHAMMED tell JOHNSON, “It tastes good. How would this feel?”, while rolling and wiggling his tongue.
42. That on another occasion, MOHAMMED stated to customer MARQUITA DUNBAR (“DUNBAR”), “You don’t have your W-2s, but if you suck my dick and give me some pussy, 1 will make them for you.”
43. That on that same occasion, MOHAMMED locked his office door with DUNBAR inside. MOHAMMED pulled his pants down and asked DUNBAR to “suck” his dick. DUNBAR’s mother complained to SUTTON FORD’s owner, SUTTON. GRIFFIN is not aware if MOHAMMED was ever disciplined for this conduct.
44. That other members of management heard MOHAMMED’s sexually offensive comments towards GRIFFIN and witnessed him inappropriately touch her. For example the following managers witnessed MOHAMMED’s sexually inappropriate behavior: ERIC VATES (“VATES”); JEFFREY RANDOLPH (“RANDOLPH”); ANITA SUTTON; TIFF ARSELA (“ARESELA”); and RAY VILLONE (“VILLONE”).
45. That as a result of GRIFFIN’s rejection of sexual advances and conduct, ARSELA and VATES subjected her to inferior treatment by trying to get GRIFFIN terminated by changing her work to make it appear as though she was making mistakes. GRIFFIN communicated this information to ANITA SUTTON and IRVING. However, ARSELA and VATES were not disciplined.
46. That on another occasion as a result of GRIFFIN’s rejection of sexual advances and conduct, ARSELA lied to the managers and told them that GRIFFIN could not come to work because she was at the circus. However, GRIFFIN had communicated to ARSELA that she was at the hospital for an emergency.
47. That even though other members of management witnessed MOHAMMED’s conduct, no one rebuked MOHAMMED, requested that he stop, or disciplined him.
48. That from February 2004 through August 2004, GRIFFIN complained to management employees. Specifically, GRIFFIN complained to PANSY WHITE (“WHITE”), EMMA WILLIAMS (“WILLIAMS”), and NATE SUTTON about MOHAMMED’s sexually offensive comments and inappropriate touching. However, the harassment never ceased.
49. That in December of 2002, GRIFFIN was subjected to persistent sexual harassment by EDDIE.
50. That starting in December of 2002, EDDIE would grab GRIFFIN’s hands when she brought him work related documents.
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51. EDDIE made comments about GRIFFIN’s lips such as: “You got some really nice lips, I know what 1 could use those for” and “Your husband must be really happy to have lips like that.”
52. That in December of 2002, GRIFFIN complained to the owner, SUTTON, that EDDIE was sexually harassing her. SUTTON responded, “Hold off for a little while, we will be making some management decisions soon.” SUTTON never followed up with GRIFFIN following this discussion. GRIFFIN is not aware if EDDIE was ever disciplined.
53. That starting in December of 2002 and continuing until October 2004, GRIFFIN was subjected to persistent sexual harassment by RAMONE (LNU). Such harassing conduct included directing sexually offensive comments to GRIFFIN on a daily basis.
54. Some examples of comments that RAMONE made to GRIFFIN are: a. “When are you going to let me lick that?” Referring to GRIFFIN’s vagina;
b. “I am always doing something for you. When are you going to do something with me?”;
c. “Oh Stacey, you just don’t know what I would to do you! You just give me one chance. I promise you!” RAMONE grabbed his penis when making this comment to GRIFFIN;
d. “You have the most perfect butt. Really, really you do have a great butt.”
55. That MARVIN (LNU; “MARVIN”), the manager of the porter team, witnessed numerous instances where RAMONE made sexually offensive comments. However, GRIFFIN is not aware if RAMONE was ever disciplined for such offensive comments.
56. That in February 2003, GRIFFIN complained to management employee, WILLIAMS, about RAMONE’s comments and that RAMONE was sexually harassing her. However, the harassment continued.
57. That other members of management heard RAMONE’s sexually offensive comments. For example, RANDOLPH (“RANDOLPH”), MARLON JACKSON (“JACKSON”), TINO (LNU; “TINO”), DOC HENDRIX (“HENDRIX”), and MARVIN were often present when RAMONE made sexually offensive comments.
58. That starting in January of 2003, GRIFFIN was subjected to persistent sexual harassment by one of the managers, JOHN LEFEBER. Such harassing conduct included daily sexually offensive comments.
59. Some examples of comments that JOHN LEFEBER made to GRIFFIN are as follows: a. “Have you ever been with a white man?”;
b. “Would you like to be with a white man?”; and
c. “Do you like cream in your coffee?”
60. That throughout his employment with SUTTON FORD, JOHN LEFEBER would stare at GRIFFIN for prolonged periods of time, thus making her uncomfortable.
61. That throughout 2003, GRIFFIN witnessed JOHN LEFEBER consume alcohol while at work. When JOHN LEFEBER was intoxicated, his sexually offensive comments worsened.
62. That starting in January of 2003, and continuing until October 2004, GRIFFIN was subjected to persistent sexual harassment by MENTOR. Such harassing conduct included making sexually offensive comments on a daily basis, as well as
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inappropriate touching.
63. Some examples of comments that MENTOR made to GRIFFIN are: a. “Oh yeah, you’ve got pink panties on” and “I am going down again, only next time I am not coming back up!” MENTOR made these comments after he crawled under the desk that GRIFFIN was sitting in;
b. “Yeah, you gaining weight in all the right places.”;
c. “Once you get a hold of this [his penis], you will leave Big Rod [GRIFFIN’s Husband]!”, while grabbing his penis;
d. “Big Rod [GRIFFIN’s Husband] must be working that right, because that ass is getting bigger and bigger!”;
e. “You have legs like a race horse”; and
f. “I like those pants, you going to let me take them off?”
64. That MENTOR also often made cat calls such as, “Ohh”, “Ah ah ah”, and “Woo Woo”.
65. That members of management heard MENTOR’s sexually offensive comments towards GRIFFIN. For example, VATES and RANDOLPH witnessed and heard most of MENTOR’s sexually inappropriate behavior.
66. That starting in January of 2003, GRIFFIN was subjected to persistent sexual harassment by, RAY LEFEBER, manager who routinely arranged sexually offensive activities.
67. That in the spring of 2003 for example, RAY LEFEBER arranged for exotic dancers to come to SUTTON FORD after the store had closed. GRIFFIN was working late in the finance office on this day and witnessed the exotic dancer arrive at SUTTON FORD. On that occasion, all of the male employees spoke freely and openly about the stripper.
68. That starting in 2003 and continuing until October 2004, GRIFFIN was subjected to persistent sexual harassment by IRVING, who directed sexually offensive comments to her on a daily basis.
69. Some examples of comments that IRVING made to GRIFFIN are: a. “Oh I just like to keep you around for eye candy.”;
b. “Why don’t you come with me to Las Vegas and hang out with me for a week. I got a jacuzzi and a pool.”; and
c. “Do you like cream in your coffee?”
70. That Defendant failed to take effective and appropriate remedial action in 2002, 2003, or 2004, after GRIFFIN complained about sexual harassment to management employees.
71. That as a result, MOHAMMED, EDDIE, JOHN LEFEBER, RAY LEFEBER, MENTOR, RAMONE, and IRVING continued their conduct, and extended their harassment and assault to other females under their supervision or that worked with them.
72. That Defendant’s officers and agents must also have been aware of this ongoing sexual harassment by MOHAMMED, EDDIE, JOHN LEFEBER, and RAY LEFEBER of their female subordinates, because it occurred on a daily basis in an open and notorious manner, such that it was observed by employees, managers, and supervisors alike.
73. That Defendant condoned sexual harassment, and failed to maintain a harassment-free work environment by failing to
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provide adequate training, counseling, and instructions to its employees and officers.
74. That Defendant failed to maintain a harassment-free work environment by failing to take effective corrective action against MOHAMMED, EDDIE, JOHN LEFEBER, RAY LEFEBER, MENTOR, RAMONE, and IRVING, after it became aware that they were making unwelcome sexual advances and comments towards women who worked for them, and assaulting them on an ongoing basis.
75. That as a result of these failures by Defendant, MOHAMMED, EDDIE, JOHN LEFEBER, and RAY LEFEBER continued to use their authority as supervisors to force their unwelcome sexual advances, offensive conduct and assaults on GRIFFIN and several other subordinate females on an ongoing basis.
76. That Defendant’s treatment of GRIFFIN was motivated by evil motive and intent, and was in reckless and callous indifference to GRIFFIN’s federally protected rights.
77. That the sex discrimination and sexual harassment that GRIFFIN was subjected to in the hands of Defendant, its agents, representatives and employees was persistent in nature, unwelcome, extremely offensive, humiliating, and had the effect of creating a hostile and intimidating work environment for GRIFFIN.
78. That said continuous and persistent sex discrimination and sexual harassment adversely affected the terms and conditions of her employment with Defendant.
79. That as a direct and proximate result of said unlawful employment practices, GRIFFIN has suffered the indignity of discrimination, the invasion of her right to be free from discrimination, and great humiliation which has manifested in physical illnesses, and emotional stress on the relationships between GRIFFIN and her friends and family.
80. That as a further direct and proximate result of said unlawful employment practices, GRIFFIN has suffered extreme mental anguish, outrage, severe anxiety about her future and her ability to support herself, harm to her employability and earning capacity, painful embarrassment among her friends and co-workers, damage to her reputation, disruption of her personal life, and loss of enjoyment of the ordinary pleasures of life.
PRAYER FOR RELIEF
WHEREFORE, GRIFFIN respectfully requests that this Court provide the following equitable and legal relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date, and cause this case to be expedited in every possible way.
b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment.
c. Award Plaintiff, GRIFFIN, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest.
d. Award Plaintiff, GRIFFIN, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses.
e. Award Plaintiff, GRIFFIN, a judgment against Defendant for compensatory damages.
f. Grant judgment against Defendant for punitive damages for willful and wanton conduct.
g. Grant such other and further relief as this court deems just and proper.
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COUNT II COMPLAINT OF STACEY GRIFFIN FOR QUID PRO QUO SEX DISCRIMINATION DIRECTED AT SUTTON FORD, INC.
81. That GRIFFIN incorporates the preceding paragraphs by reference here. 82. That MOHAMMED implicitly and explicitly conditioned GRIFFIN’s enjoyment of the various terms, conditions, and benefits of employment on her submission to his sexual advances. Such terms and conditions of employment include the assignment of deals, sales leads and such others. 83. That Defendant’s conduct in subjecting Plaintiff to inferior terms and conditions of employment and in terminating her amounts to quid pro quo sexual harassment in violation of the law.
PRAYER FOR RELIEF WHEREFORE, GRIFFIN respectfully requests that this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest praticable date, and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sexual discrimination and sexual harassment. c. Award Plaintiff, GRIFFIN, back pay, reinstatement, appropriate future earnings and reimbursement for income, and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, GRIFFIN, a judgment against Defendant for compensatory damages. e. Award Plaintiff, GRIFFIN, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
COUNT III COMPLAINT OF STACEY GRIFFIN FOR RETALIATION DIRECTED AT SUTTON FORD, INC. 84. That GRIFFIN incorporates the preceding paragraphs by reference here. 85. That GRIFFIN was terminated on or around October 5, 2004. 86. That Defendant’s termination of GRIFFIN amounts to illegal retaliation for resisting conduct which GRIFFIN in good faith believed to be sexual harassment. 87. That Defendant and its agents further subjected GRIFFIN to inferior terms and conditions of employment for resisting conduct GRIFFIN in good faith believed to be sexual harassment. 88. That the adverse actions followed GRIFFIN’s protected activity within such a period of time as to raise an inference of retaliatory motivation.
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PRAYER FOR RELIEF WHEREFORE, Plaintiff, GRIFFIN respectfully requests this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, GRIFFIN, back pay, reinstatement, appropriate future earnings and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, GRIFFIN, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses. e. Award Plaintiff, GRIFFIN, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
COUNT IV COMPLAINT OF STACEY GRIFFIN FOR ASSAULT AND BATTERY DIRECTED TO RICHARD MOHAMMED AND SUTTON FORD, INC.
89. That GRIFFIN incorporates the preceding paragraphs by reference here. 90. That MOHAMMED intended to engage in offensive and harmful physical contact with GRIFFIN’s body. 91. That MOHAMMED’s conduct in touching and attempting to touch GRIFFIN was intentional. 92. That MOHAMMED’s conduct in touching and attempting to touch GRIFFIN placed her in apprehension of imminent offensive physical contact by MOHAMMED. 93. That MOHAMMED’s conduct amounts to willful and wanton conduct. 94. That GRIFFIN is free from willful and wanton conduct. 95. That as a result of MOHAMMED’s conduct, GRIFFIN suffered and continues to suffer fright, physical illnesses, mental anguish, humiliation and embarrassment. 96. That Defendant, Sutton Ford, is directly responsible for the assault and battery endured by GRIFFIN because it knew or in the exercise of reasonable care should have known about such conduct, but railed to take reasonable steps to prevent or correct it.
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PRAYER FOR RELIEF WHEREFORE, GRIFFIN respectfully requests that the Court provide the following equitable and legal relief: a. Award GRIFFIN a judgment against MOHAMMED for compensatory and punitive damages. b. Award GRIFFIN a judgment against SUTTON FORD for compensatory and punitive damages. c. Enter an order granting GRIFFIN reasonable compensation for the fright, humiliation, embarrassment, physical illnesses and mental anguish suffered by GRIFFIN as a result of MOHAMMED’s conduct. d. Grant GRIFFIN such other and further relief as this court deems just and proper.
COUNT V COMPLAINT OF CARRIE BABB FOR HOSTILE ENVIRONMENT SEXUAL HARASSMENT DIRECTED TO SUTTON FORD, INC.
97. BABB incorporates the preceding paragraphs by reference here. 98. That BABB was hired by Defendant in April of 2004, as a Car Salesperson. 99. That during her employment, BABB performed her assigned tasks in a satisfactory and conscientious manner according to Defendant’s standards. 100. That at relevant times during her employment with Defendant, BABB was supervised by MOHAMMED. 101. That starting in April of 2004, and continuing until September 2004, BABB was subjected to persistent sexual harassment by MOHAMMED. Such harassing conduct included sexually offensive comments on a daily basis and offensive as well as inappropriate touching. 102. That MOHAMMED’s sexually harassing comments and inappropriate touching were severe and pervasive, and occurred on a daily basis. 103. That from April 2004 through September 2004, MOHAMMED slapped BABB’s buttocks on numerous occasions. 104. That MOHAMMED made daily sexually offensive comments to BABB such as: a. “Is the hair on your pussy blonde too?”; b. How bad do you want this deal done? Are you going to suck my dick?”; c. How bad do you want this deal done? Show me your titties!”; d. “Have you ever licked an asshole before?”; e. “How big are your nipples?”; f. “Do you have big nipples?”; g. “Have you ever been with a black man before?”; h. “Once you go black, you never go back.”;
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i. “Oh is that a thong?”; j. “Is it red today?” and “Is it pink today?”. Referring to the color of BABB’s underwear; k. “Do you want some of this dick?” While grabbing his penis;
l. “Do you like your hair pulled?”; m. “Show me them titties!”; n. “Let me see them titties!”; o. “Am I going to see those titties?”;
p. “What’s wrong? Did somebody wear that ass out?”; and q. “White men have little dicks and you need a black one.”
105. That BABB witnessed MOHAMMED tell JOHNSON, “It tastes good. How would this feel?”, while he rolled and wiggled his tongue. 106. That on a daily basis, rather than say “good morning” to BABB, MOHAMMED would say, “Suck me!”. 107. That BABB asked MOHAMMED to stop making offensive comments, slapping her buttocks. However, every time she complained, MOHAMMED just laughed. BABB also complained to other female employees about MOHAMMED’s conduct.
108. That in or around July and August of 2004, BABB complained to VATES about MOHAMMED’s sexually offensive comments and inappropriate touching. However, the harassment never ceased. 109. That members of management heard MOHAMMED’s sexually offensive comments towards BABB, and witnessed MOHAMMED’s inappropriate touching of her. For example, both VATES and ARSELLA witnessed MOHAMMED’s sexually inappropriate behavior.
110. That starting in April of 2004, and continuing until September 2004, BABB was subjected to persistent sexual harassment by MENTOR. Such harassing conduct included making daily sexually offensive comments to BABB. 111. That one example of a comment that MENTOR made to BABB is, “Put a little extra lip gloss on it. It will make it easier.”
112. That starting in April 2004, and continuing until September 2004, BABB was subjected to persistent sexual harassment by RAMONE who directed offensive comments toward her on a daily basis. 113. That some examples of such comments are as follows: a. “Can I go home with you?”; b. “When are you going to let me get with that?”;
c. “When are you going to do something for me?”; and d. “I know why you do not want to get with me. Its because I am not from this country.”
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114. That MARVIN, the manager of the porter team, witnessed several of RAMONE’s sexually offensive comments. However, BABB is not aware if RAMONE was ever disciplined for such offensive comments.
115. That as a result of BABB’s rejection of sexual advances and conduct, ARSELA and VATES subjected BABB to inferior treatment by trying to get her terminated by changing her work to make it appear as though she was making mistakes. BABB communicated this information to ANITA SUTTON and IRVING. However, ARSELA and VATES were not disciplined.
116. That as a result of BABB’s rejection of sexual advances and conduct, MOHAMMED subjected BABB to inferior terms and conditions of employment by denying BABB’s financial deals. He also took BABB’s customers away and gave them to other employees.
117. That Defendant failed to take effective and appropriate remedial action in 2004 after BABB complained about sexual harassment to management employees.
118. That as a result, MOHAMMED, MENTOR, and RAMONE continued their conduct and extended their harassment and assault to other females under their supervision or those that worked with them.
119. That Defendant’s officers and agents must also have been aware of this ongoing sexual harassment by MOHAMMED of his female subordinates because it occurred on a daily basis in an open and notorious manner, such that it was observed by employees and supervisors alike.
120. That Defendant condoned sexual harassment and failed to maintain a harassment-free work environment by failing to provide adequate training, counseling, and instructions to their employees and officers.
121. That Defendant failed to maintain a harassment-free work environment by failing to take effective corrective action against MOHAMMED, MENTOR, and RAMONE after it became aware that they were assaulting and making unwelcome sexual advances and comments towards women who worked for them on an ongoing basis.
122. That as a result of these failures by Defendant, MOHAMMED continued to use his authority as a supervisor to force his unwelcome sexual advances, offensive conduct and assaults on BABB and several other subordinate females on an ongoing basis.
123. That Defendant’s treatment of BABB was motivated by evil motive and intent and was in reckless and callous indifference to BABB’s federally protected rights.
124. That the sex discrimination and sexual harassment that BABB was subjected to in the hands of Defendant, its agents, representatives and employees was persistent in nature, unwelcome, extremely offensive, humiliating, and had the effect of creating a hostile and intimidating work environment for BABB.
125. That said continuous and persistent sex discrimination and sexual harassment adversely affected the terms and conditions of her employment with Defendant.
126. That as a direct and proximate result of said unlawful employment practices, BABB has suffered the indignity of discrimination, the invasion of her right to be free from discrimination, and great humiliation which has manifested in physical illnesses and emotional stress on the relationships between BABB and her friends and family.
127. That as a further direct and proximate result of said unlawful employment practices, BABB has suffered extreme mental anguish, outrage, severe anxiety about her future and her ability to support herself, harm to her employability and earning capacity, painful embarrassment among her friends and co-workers, damage to her reputation, disruption of her personal life, and loss of enjoyment of the ordinary pleasures of life.
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PRAYER FOR RELIEF WHEREFORE, BABB respectfully requests that the Court provide the following equitable and legal relief. a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, BABB, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, BABB, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses. e. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Grant such other and further relief as this court deems just and proper.
COUNT VI COMPLAINT OF CARRIE BABB FOR QUID PRO QUO SEX DISCRIMINATION DIRECTED AT SUTTON FORD, INC
128. That BABB incorporates the preceding paragraphs by reference here. 129. That MOHAMMED implicitly and explicitly conditioned BABB’s enjoyment of the various terms, conditions, and benefits of employment on her submission to his sexual advances. Such terms and conditions of employment include the assignment of deals, sales leads, and such others. 130. That Defendant’s conduct in subjecting Plaintiff to inferior terms and conditions of employment amounts to quid pro quo sexual harassment in violation of the law.
PRAYER FOR RELIEF WHEREFORE, BABB respectfully requests that this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date, and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sexual discrimination and sexual harassment. c. Award Plaintiff, BABB, back pay, reinstatement, appropriate future earnings and reimbursement for income, and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages. e. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages.
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f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
COUNT VII COMPLAINT OF CARRIE BABB FOR RETALIATION DIRECTED AT SUTTON FORD, INC. 131. That Plaintiff, BABB, incorporates the preceding paragraphs by reference here. 132. That Defendant and its agents subjected BABB to inferior terms and conditions of employment for resisting conduct BABB in good faith believed to be sexual harassment. 133. That BABB was constructively discharged in or around September 2004. 134. That the adverse actions followed BABB’s protected activity within such a period of time as to raise an inference of retaliatory motivation.
PRAYER FOR RELIEF WHEREFORE, Plaintiff, BABB respectfully requests this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, BABB, back pay, reinstatement, appropriate future earnings and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, BABB, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses. e. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
COUNT VIII COMPLAINT OF CARRIE BABB FOR ASSAULT AND BATTERY DIRECTED TO RICHARD MOHAMMED AND SUTTON FORD. INC.
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135. That BABB incorporates the preceding paragraphs by reference here. 136. That MOHAMMED intended to engage in offensive and harmful physical contact with BABB’s body. 137. That MOHAMMED’s conduct in touching and attempting to touch BABB was intentional. 138. That MOHAMMED’s conduct in touching and attempting to touch BABB placed her in apprehension of imminent offensive physical contact by MOHAMMED. 139. That MOHAMMED’s conduct amounts to willful and wanton conduct. 140. That BABB is free from willful and wanton conduct. 141. That as a result of MOHAMMED’s conduct, BABB suffered and continues to suffer fright, physical illnesses, mental anguish, humiliation and embarrassment. 142. That Defendant, Sutton Ford, is directly responsible for the assault and battery endured by BABB because it knew or in the exercise of reasonable care should have known about such conduct, but failed to take reasonable steps to prevent or correct it.
PRAYER FOR RELIEF WHEREFORE, BABB respectfully requests that the Court provide the following equitable and legal relief: a. Award BABB a judgment against MOHAMMED for compensatory and punitive damages. b. Award BABB a judgment against SUTTON FORD for compensatory and punitive damages. c. Enter an order granting BABB reasonable compensation for the fright, humiliation, embarrassment, physical illnesses and mental anguish suffered by BABB as a result of MOHAMMED’s conduct. d. Grant BABB such other and further relief as this court deems just and proper.
COUNT IX COMPLAINT OF CARRIE BABB OF RACE DISCRIMINATION AND RACIAL HARASSMENT DIRECTED AT SUTTON FORD, INC.
143. That BABB incorporates the preceding paragraphs by reference here. 144. That BABB is Caucasian. 145. That MOHAMMED is African-American. 146. That throughout BABB’s employment with SUTTON FORD, she was subjected to persistent and continuous racial discrimination and harassment. 147. That during the period from April 2004 through September 2004, MOHAMMED regularly made racially offensive comments around BABB such as: a. “I don’t like white people!”;
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b. “White people ain’t got no business selling cars!”;
c. “White men have little dicks, you need a black one!”;
d. “Once you go black, you never go back! Its true!”; and
e. “You white people can’t sell cars, I’m taking this customer.”
148. That BABB was subjected to unequal treatment in the various terms and conditions of employment duc to her race by MOHAMMED.
149. That MOHAMMED would often take customers away from BABB and give them to the African-American sales people.
150. That Defendant condoned racial harassment and failed to maintain a harassment-free work environment by failing to provide adequate training, counseling, and instructions to its employees and officers.
151. That Defendant failed to implement and enforce an effective race discrimination policy. Had Defendant done so, it could have prevented said race discrimination.
152. That all of these and similar incidents have created a hostile and offensive work environment for BABB.
153. That Defendant’s treatment of BABB was motivated by evil motive and intent and was recklessly and callously indifferent to BABB’s federally protected rights
154. That Defendant’s treatment of Plaintiff, BABB, was motivated by racial animus and Defendant and its agents acted with racial animus directed toward Caucasians in violation of the law.
155. That the racial discrimination and racial harassment BABB was subjected to at the hands of Defendant, its agents, representatives and employees was persistent in nature, unwelcome, extremely offensive, humiliating, and resulted in creating a hostile and intimidating work environment for Plaintiff.
156. That said continuous and persistent racial discrimination and racial harassment adversely affected the terms and conditions of BABB’s employment with Defendant.
157. That as a direct and proximate result of said unlawful employment practices and disregard for BABB’s rights and sensibilities, BABB has lost and will continue to lose substantial income, including, but not limited to, wages, fringes, seniority benefits, and other employment benefits
158. That as a further direct and proximate result of said unlawful employment practices, BABB has suffered the indignity of discrimination, the invasion of her right to be free from discrimination, and great humiliation which is manifest in physical illnesses and emotional stress on the relationships between BABB and her friends, family, and colleagues.
159. That as a further direct and proximate result of said unlawful employment practices, BABB has suffered extreme mental anguish, outrage, severe anxiety about her future and her ability to support herself, harm to her employability and earning capacity, shameful embarrassment among her friends, colleagues, and co-workers, damage to her reputation, disruption of her personal life, and loss of enjoyment of the ordinary pleasures of life.
PRAYER FOR RELIEF
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WHEREFORE, Plaintiff, BABB, respectfully prays that the Court provide the following equitable and legal relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Award Plaintiff, BABB, appropriate back-pay, reinstatement, future earnings and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. c. Award Plaintiff, BABB, costs of litigation, including reasonable attorney’s fees and expert fees and expenses. d. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages. e. Grant judgment against Defendant for punitive damages for willful and wanton conduct. f. Enter an order requiring Defendant to implement effective steps to eliminate discrimination from Defendant’s organization. g. Grant such other and further relief as this court deems just and proper.
COUNT X COMPLAINT OF CARRIE BABB OF CONSTRUCTIVE DISCHARGE DIRECTED AT SUTTON FORD. INC.
160. That BABB incorporates the preceding paragraphs by reference here. 161. That Defendant had notice, condoned Plaintiff’s intolerable conditions, and did nothing. 162. That Plaintiff had no other choice but to resign because of Defendant’s intolerable conditions which included inferior treatment of Plaintiff, coupled with inferior benefits, terms, and conditions of employment.
PRAYER FOR RELIEF WHEREFORE, Plaintiff, BABB, respectfully prays that the Court provide the following equitable and legal relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, BABB, back pay, reinstatement, appropriate future earnings and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, BABB, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses e. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for will ful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
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COUNT XI COMPLAINT OF JADA JOHNSON FOR HOSTILE ENVIRONMENT SEXUAL HARASSMENT DIRECTED TO SUTTON FORD, INC.
163. That JOHNSON incorporates the preceding paragraphs by reference here. 164. That JOHNSON was hired by Defendant in April of 2004, as a Car Salesperson. 165. That during her employment, JOHNSON performed her assigned tasks in a satisfactory and conscientious manner according to Defendant’s standards. 166. That at relevant times during her employment with Defendant, JOHNSON was supervised by MOHAMMED. 167. That starting in April of 2004 and continuing until July 2004, JOHNSON was subjected to persistent sexual harassment by MOHAMMED. Such harassing conduct included offensive and inappropriate touching and sexually offensive comments directed towards JOHNSON on a daily basis. 168. That for example, MOHAMMED said the following to JOHNSON: a. “How bad do you want this deal done? Let me see those titties!” When MOHAMMED was making this statement he would slam his hands down on his desk; b. “Bend over and I will get your deal approved.”; c. “Jada, can I just smell it?” While pointing to JOHNSON’s vaginal area; d. “What color? Black? What color panties are you wearing?”; e. “Can you take two guys at the same time?”; f. “Show me your titties!”; g. “I’m rich bitch! Let me see those titties!”; h. “I know that it tastes good. How would this feel?” While rolling/wiggling his tongue in reference to him performing oral sex on JOHNSON); i. “Looks like he [JOHNSON’s boyfriend at the time] has made that ass spread.”; and j. “He is smiling because he [JOHNSON’s boyfriend at the time] got that ass!”
169. That on another occasion, MOHAMMED stated to JOHNSON, “I know I am a nymphomaniac and I know I need help. I just love pussy. I ain’t lying. I make you sick, don’t I?” 170. On another occasion during the summer of 2004, MOHAMMED put his hand under JOHNSON’s buttocks as she was sitting down on a chair. His hand touched her buttocks on that occasion. 171. On numerous occasions, when JOHNSON bent over, MOHAMMED stood behind her and simulated that he was having sex with her. MOHAMMED rubbed his penis against JOHNSON’s buttocks in a back and forth motion, humping her.
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172. That MOHAMMED often drank gin from a coffee cup in the workplace. When he became intoxicated, the sexual harassment intensified.
173. That JOHNSON often asked MOHAMMED to stop making offensive comments, and to stop touching her. However, every time she complained, MOHAMMED just laughed and the harassment continued.
174. That on another occasion when JOHNSON complained to MOHAMMED, she told him, “You make me feel like a piece of meat.” MOHAMMED responded, “You are a piece of meat.”
175. That in or around June or July of 2004, JOHNSON complained to management employees, WHITE, WILLIAMS, and SUTTON about MOHAMMED’s sexually offensive comments and inappropriate touching. However, the harassment never ceased.
176. That in or around May or June of 2004, JOHNSON also complained to RANDOLPH and VATES about being sexually harassed. JOHNSON is not aware if MOHAMMED was disciplined as a result of her complaints.
177. That other members of management heard MOHAMMED’s sexually offensive comments toward JOHNSON, and witnessed MOHAMMED’s inappropriate touching of her. For example the following managers witnessed MOHAMMED’s sexually inappropriate behavior: VATES; RANDOLPH; ANITA SUTTON; ARSELA; and VILLONE.
178. That VATES witnessed almost all of MOHAMMED’s sexually inappropriate behavior, but often just laughed and giggled in response to such behavior.
179. That starting in April of 2004 and continuing until July of 2004, JOHNSON was subjected to persistent sexual harassment by MENTOR. Such harassing conduct included inappropriate touching and sexually offensive comments directed toward her on a daily basis.
180. That on one occasion during June or July of 2004, MENTOR touched the side of JOHNSON’s breast and said, “Put that thing back.” JOHNSON told MENTOR never to touch her again.
181. That some examples of comments that MENTOR made to JOHNSON are: a. “Jada, I see you just sucked and fucked your way into another deal “;
b. “Jada, you should let the customers grab your ass.”;
c. “You look more like my speed then Jeff’s.” While simulating intercourse with his chair.;
d. “Put it under Jada’s ass, it will stay dry.”MENTOR said this outside while it was raining.; and
e. “Jada, I see you were a little nervous with those customers, next time call me over and I will work that out for you.”
182. That after complaining about MOHAMMED’s sexual harassment, he subjected JOHNSON to inferior treatment by making her wait longer periods of time for her financial deals to go through. This caused JOHNSON to lose money because customers did not want to wait extended periods of time.
183. That members of management and customers heard MENTOR’s sexually offensive comments toward JOHNSON. For example, customer CHARLES HANCOCKS, witnessed MENTOR sexually harass JOHNSON. VATES, ARSELLA, JACKSON and RANDOLPH also witnessed MENTOR’s sexually inappropriate behavior.
184. That starting in April of 2004 and continuing until July of 2004, JOHNSON was subjected to persistent sexual harassment by RAMONE (LNU). Such harassing conduct included making sexually offensive comments directed to
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JOHNSON on a daily basis.
185. That Some examples of comments that RAMONE made to JOHNSON are: a. “Let me show you how we do it where I’m from.” While sticking out his tongue. and
b. “Just let me taste you and you won’t want another man!”
186. That MARVIN, the manager of the porter team, witnessed several of RAMONE’s sexually offensive comments. However, JOHNSON is not aware if RAMONE was ever disciplined for such offensive comments.
187. That Defendant failed to take effective and appropriate remedial action in 2004 after JOHNSON complained about sexual harassment to management employees.
188. That as a result, MOHAMMED, MENTOR, and RAMONE continued their conduct and extended their harassment and assault to other females under their supervision or those that worked with them.
189. That Defendant’s officers and agents must also have been aware of this ongoing sexual harassment by MOHAMMED of his female subordinates because it occurred on a daily basis in an open and notorious manner, such that it was observed by employees and supervisors alike.
190. That Defendant condoned sexual harassment, and failed to maintain a harassment-free work environment by failing to provide adequate training, counseling, and instructions to its employees and officers.
191. That Defendant failed to maintain a harassment-free work environment by failing to take effective corrective action against MOHAMMED, MENTOR, and RAMONE after they became aware that they were making unwelcome sexual advances and comments towards women who worked for them and assaulting them on an ongoing basis.
192. That as a result of these failures by Defendant, MOHAMMED continued to use his authority as a supervisor to force his unwelcome sexual advances, offensive conduct, and assaults on JOHNSON and several other subordinate females on an ongoing basis.
193. That Defendant’s treatment of JOHNSON was motivated by evil motive and intent, and was in reckless and callous indifference to JOHNSON’s federally protected rights.
194. That the sex discrimination and sexual harassment that JOHNSON was subjected to in the hands of Defendant, its agents, representatives and employees was persistent in nature, unwelcome, extremely offensive, humiliating, and had the effect of creating a hostile and intimidating work environment for JOHNSON.
195. That said continuous and persistent sex discrimination and sexual harassment adversely affected the terms and conditions of her employment with Defendant.
196. That as a direct and proximate result of said unlawful employment practices, JOHNSON has suffered the indignity of discrimination, the invasion of her right to be free from discrimination and great humiliation which has manifested in physical illnesses, and emotional stress on the relationships between JOHNSON and her friends and family.
197. That as a further direct and proximate result of said unlawful employment practices, JOHNSON has suffered extreme mental anguish, outrage, severe anxiety about her future and her ability to support herself, harm to her employability and earning capacity, painful embarrassment among her friends and co-workers, damage to her reputation, disruption of her personal life, and loss of enjoyment of the ordinary pleasures of life.
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PRAYER FOR RELIEF WHEREFORE, JOHNSON respectfully requests that the Court provide the following equitable and legal relief. a. Advance this case on the docket, order a speedy hearing at the earliest practicable date, and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, JOHNSON, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, JOHNSON, costs of litigation, including reasonable attorneys’ fees and expert fees, and expenses. e. Award Plaintiff, JOHNSON, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Grant such other and further relief as this court deems just and proper.
COUNT XII COMPLAINT OF JADA JOHNSON FOR QUID PRO QUO SEX DISCRIMINATION DIRECTED AT SUTTON FORD, INC.
198. That JOHNSON incorporates the preceding paragraphs by reference here. 199. That MOHAMMED implicitly and explicitly conditioned JOHNSON’s enjoyment of the various terms, conditions, and benefits of employment on her submission to his sexual advances. Such terms and conditions of employment include the assignment of deals, sales leads and such others. 200. That Defendant’s conduct in subjecting Plaintiff to inferior terms and conditions of employment and in terminating her amounts to quid pro quo sexual harassment in violation of the law.
PRAYER FOR RELIEF WHEREFORE, JOHNSON respectfully requests that this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date, and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sexual discrimination and sexual harassment. c. Award Plaintiff, JOHNSON, back pay, reinstatement, appropriate future earnings and reimbursement for income, and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, JOHNSON, a judgment against Defendant for compensatory damages. e. Award Plaintiff, JOHNSON, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct.
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g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
COUNT XIII COMPLAINT OF JADA JOHNSON FOR RETALIATION DIRECTED AT SUTTON FORD, INC. 201. That Plaintiff, JOHNSON, incorporates the preceding paragraphs by reference here. 202. That JOHNSON was terminated on or around July 25, 2004. 203. That Defendant’s termination of JOHNSON amounts to illegal retaliation for resisting conduct which JOHNSON in good faith believed to be sexual harassment. 204. That Defendant and its agents further subjected JOHNSON to inferior terms and conditions of employment for resisting conduct JOHNSON in good faith believed to be sexual harassment. 205. That the adverse action followed JOHNSON’s protected activity within such a period of time as to raise an inference of retaliatory motivation.
PRAYER FOR RELIEF WHEREFORE, Plaintiff, JOHNSON respectfully requests this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, JOHNSON, back pay, reinstatement, appropriate future earnings and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, JOHNSON, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses. e. Award Plaintiff, JOHNSON, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
COUNT XIV COMPLAINT OF JADA JOHNSON FOR ASSAULT AND BATTERY DIRECTED TO LOUIS MENTOR AND SUTTON FORD, INC.
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206. That JOHNSON incorporates the preceding paragraphs by reference here. 207. That MENTOR intended to engage in offensive and harmful physical contact with JOHNSON’s body. 208. That MENTOR’s conduct in touching and attempting to touch JOHNSON was intentional. 209. That MENTOR’s conduct in touching and attempting to touch JOHNSON placed her in apprehension of imminent offensive physical contact by MENTOR. 210. That MENTOR’s conduct amounts to willful and wanton conduct. 211. That JOHNSON is free from willful and wanton conduct. 212. That as a result of MENTOR’s conduct, JOHNSON suffered and continues to suffer fright, physical illnesses, mental anguish, humiliation and embarrassment. 213. That Defendant, Sutton Ford, is directly responsible for the assault and battery endured by JOHNSON because it knew or in the exercise of reasonable care should have known bout such conduct, but failed to take reasonable steps to prevent or correct it.
PRAYER FOR RELIEF WHEREFORE, JOHNSON respectfully requests that the Court provide the following equitable and legal relief: a. Award JOHNSON a judgment against MENTOR for compensatory and punitive damages. b. Award JOHNSON a judgment against SUTTON FORD for compensatory and punitive damages. c. Enter an order granting JOHNSON reasonable compensation for the fright, humiliation, embarrassment, physical illnesses and mental anguish suffered by JOHNSON as a result of MENTOR’s conduct. d. Grant JOHNSON such other and further relief as this court deems just and proper.
COUNT XV COMPLAINT OF JADA JOHNSON FOR ASSAULT AND BATTERY DIRECTED TO RICHARD MOHAMMED AND SUTTON FORD, INC.
214. That JOHNSON incorporates the preceding paragraphs by reference here. 215. That MOHAMMED intended to engage in offensive and harmful physical contact with JOHNSON’s body. 216. That MOHAMMED’s conduct in touching and attempting to touch JOHNSON was intentional. 217. That MOHAMMED’s conduct in touching and attempting to touch JOHNSON placed her in apprehension of imminent offensive physical contact by MOHAMMED. 218. That MOHAMMED’s conduct amounts to willful and wanton conduct. 219. That JOHNSON is free from willful and wanton conduct.
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220. That as a result of MOHAMMED’s conduct, JOHNSON suffered and continues to suffer fright, physical illnesses, mental anguish, humiliation and embarrassment. 221. That Defendant, Sutton Ford, is directly responsible for the assault and battery endured by JOHNSON because it knew or in the exercise of reasonable care should have known bout such conduct, but failed to take reasonable steps to prevent or correct it.
PRAYER FOR RELIEF WHEREFORE, JOHNSON respectfully requests that the Court provide the following equitable and legal relief: a. Award JOHNSON a judgment against MOHAMMED for compensatory and punitive damages. b. Award JOHNSON a judgment against SUTTON FORD for compensatory and punitive damages. c. Enter an order granting JOHNSON reasonable compensation for the fright, humiliation, embarrassment, physical illnesses and mental anguish suffered by JOHNSON as a result of MOHAMMED’s conduct. d. Grant JOHNSON such other and further relief as this court deems just and proper.
COUNT XVI COMPLAINT OF MONICA MONIUSZKO FOR HOSTILE ENVIRONMENT SEXUAL HARASSMENT DIRECTED TO SUTTON FORD, INC.
222. That MONIUSZKO incorporates the preceding paragraphs by reference here. 223. That MONIUSZKO was hired by Defendant in the fall of 2002 as a Finance Assistant. 224. That on March 11, 2003, MONIUSZKO was subjected to sexual harassment by STEIHLER who directed sexually offensive comments to her. 225. That for example, STEIHLER stated to MONIUSZKO: a. “What is wrong? Do you have boyfriend problems?” b. “What do you do for sex?”; c. “Do you have a boyfriend?”; and d. “I suggest you try girl on girl. It would be good for you.”
226. MONIUSZKO reported the incidents to SUE SCHAFROTH (“SCHAFROTH”) who then reported them to WILLIAMS. WILLIAMS made both STEIHLER and MONIUSZKO sign a copy of the complaint. MONIUSZKO is not aware if STEIHLER was disciplined. 227. That in 2003, MONIUSZKO was subjected to sexual harassment by RANDOLPH who touched her inappropriately. 228. That on many occasions, RANDOLPH rubbed MONIUSZKO’s shoulders and hair, touched her leg, put his arms around her, and ran his foot up her leg. Every time he touched MONIUSZKO, she pulled away and told him to stop.
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229. That RANDOLPH put his arms around MONIUSZKO almost every day that he worked with her.
230. That MONIUSZKO complained to RANDOLPH and asked him to stop each time he touched her. She also complained to other females that worked for Defendant.
231. That almost every day, RANDOLPH stared at MONIUSZKO for extended periods of time. He would not say anything when he stared at her.
232. That in approximately February and March of 2003, MONIUSZKO was subjected to sexual harassment by THATCHER. Such harassing conduct included inappropriate comments such as. a. “I want to take you home”;
b. “I could do some things to you”; and
c. “Do you want to hang out after work?”
233. That in February and March of 2003, MONIUSZKO was subjected to sexual harassment by MENTOR who made inappropriate comments and touched her in an offensive manner.
234. That MENTOR stated to MONIUSZKO: a. “I would go out with you if I wasn’t married” and
b. “Oh you are so hot!”
235. That MENTOR often grabbed MONIUSZKO’s hands for extended periods of time. Each time he did this, MONIUSZKO pulled away from him.
236. That from approximately January 2003 through March of 2003, MONIUSZKO was also subjected to sexual harassment by EDDIE who made sexually offensive and inappropriate comments.
237. That Defendant failed to maintain a harassment-free work environment by failing to take effective corrective action against EDDIE, MENTOR, RANDOLPH, THATCHER, and STEIHLER after they became aware that they were making sexually offensive comments and inappropriately touching women.
238. That as a result of these failures by Defendant, EDDIE, continued to use his authority as supervisor to force his unwelcome sexual advances, offensive conduct and sexually harass MONIUSZKO and other subordinate females on an ongoing basis.
239. That Defendant’s treatment of MONIUSZKO was motivated by evil intent and was in reckless and callous indifference to their federally protected rights.
240. That the sex discrimination and sexual harassment that MONIUSZKO was subjected to in the hands of the Defendant, its agents, representatives and employees was persistent in nature, unwelcome, extremely offensive, humiliating, and had the effect of creating a hostile and intimidating work environment for MONIUSZKO.
241. That said continuous and persistent sex discrimination and sexual harassment adversely affected the terms and conditions of her employment with Defendant.
242. That as a direct and proximate result of said unlawful employment practices, MONIUSZKO has suffered the indignity of discrimination, the invasion of her right to be free from discrimination and great humiliation which is manifest in physical
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illnesses and emotional stress on the relationships between MONIUSZKO and her friends and family. 243. That as a further direct and proximate result of said unlawful employment practices, MONIUSZKO has suffered extreme mental anguish, outrage, severe anxiety about her future and her ability to support herself, harm to her employability and earning capacity, painful embarrassment among her friends and co-workers, damage to her reputations, disruption of her personal life, and loss of enjoyment of the ordinary pleasures of life.
PRAYER FOR RELIEF WHEREFORE, MONIUSZKO respectfully requests that the Court provide the following equitable and legal relief. a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, MONIUSZKO, back pay, reinstatement, appropriate future earnings and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, MONIUSZKO, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses, e. Award Plaintiff, MONIUSZKO, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this court deems just and proper.
COUNT XVII COMPLAINT OF MONICA MONIUSZKO FOR RETALIATION DIRECTED AT SUTTON FORD, INC. 244. Thai MONIUSZKO incorporates the preceding paragraphs by reference here, 245. That MONIUSZKO was terminated in or around May of 2003. 246. That Defendant’s termination of MONIUSZKO amounts to illegal retaliation for resisting conduct which MONIUSZKO in good faith believed to be sexual harassment. 247. That Defendant and its agents further subjected JOHNSON to inferior terms and conditions of employment for resisting conduct JOHNSON in good faith believed to be sexual harassment. 248. That the adverse action followed MONIUSZKO’s protected activity within such a period of time as to raise an inference of retaliatory motivation.
PRAYER FOR RELIEF
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Stacey GRIFFIN, Carrie Babb, Jada Johnson, and Monica..., 2006 WL 741847 (2006) WHEREFORE, Plaintiff, MONIUSZKO respectfully requests this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, MONIUSZKO, back pay, reinstatement, appropriate future earnings and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, MONIUSZKO, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses. e. Award Plaintiff, MONIUSZKO, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
JURY DEMAND NOW COME Plaintiffs by their undersigned attorney, and demand a trial by jury in the above entitled cause of action.
Appendix not available.
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 Stacey GRIFFIN, Carrie, Babb, Jada Johnson, Nikita..., 2006 WL 1773592...
2006 WL 1773592 (N.D.Ill.) (Trial Pleading) United States District Court, N.D. Illinois, Eastern Division.
Stacey GRIFFIN, Carrie, Babb, Jada Johnson, Nikita Lockett, and Monica Moniuszko, Plaintiffs, v.
SUTTON FORD, INC., Richard Muhammed, and Louis Minter, Defendants. No. 06 C 0931. May 31, 2006.
Plaintiffs’ Second Amended Complaint
Uche O. Asonye - 06209522, Mark Pando - 6283683, Craig T. Papka - 6287051, Asonye & Associates, 11 South LaSalle Street, Suite 2140, Chicago, Illinois 60603, (312) 795-9110, (312) 795-9114 (Fax) Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, and Monica Moniuszko, Uche O. Asonye, One of their Attorneys Judge: Bucklo. Magistrate: Ashman. Plaintiffs, by their undersigned attorney, and for their Second Amended Complaint against Defendants, state as follows:
NATURE OF THE CASE 1. The causes of action for the Plaintiffs arise under Title VII of the Civil Rights Act 42 U.S.C. Section 2000e as amended, 28 U.S.C. Paragraph 1331, and 28 U.S.C. 1367.
JURISDICTION AND VENUE 2. That this Court has jurisdiction over this matter based upon 42 U.S.C. 2000e, 28 U.S.C. Paragraph 1331, and 28 U.S.C. 1367.
3. That Plaintiff, CARRIE BABB (“BABB”), also brings her racial discrimination claims pursuant to 42 U.S.C. Section 1981.
4. That venue in the Northern District of Illinois is proper. The claim for relief arose in this state as required by 42 U.S.C. 2000e.
5. That all conditions precedent have been fulfilled by Plaintiff, STACEY GRIFFIN (“GRIFFIN”). On or about November 29, 2004, she filed a charge of discrimination #210-2005-01240 with the United States Equal Employment Opportunity Commission (“EEOC”), alleging sexual harassment and retaliation. GRIFFIN received her right-to-sue letter from the EEOC on March 29, 2006. Said right-to-sue letter and charge are attached and incorporated herein. (Attached as Exhibit 1).
6. That all conditions precedent have been fulfilled by Plaintiff, BABB. On or about November 29, 2004, she filed a charge of discrimination # 210-2005-01238 with the EEOC, alleging sexual harassment, racial harassment, retaliation, and constructive discharge. BABB received her right-to-sue letter from the EEOC on March 29, 2006. Said right-to-sue letter and charge are attached and incorporated herein. (Attached as Exhibit 2).
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7. That all conditions precedent have been fulfilled by Plaintiff, JADA JOHNSON (“JOHNSON”). On or about November 29, 2004, she filed a charge of discrimination # 210-2005-01243 with the EEOC, alleging sexual harassment and retaliation. JOHNSON received her right-to-sue letter from the EEOC on March 29, 2006. Said right-to-sue letter and charge are attached and incorporated herein. (Attached as Exhibit 3).
8. That all conditions precedent have been fulfilled by Plaintiff, NIKITA LOCKETT (“LOCKETT”). On or about July 25, 2005, she filed a charge of discrimination # 210-2005-07816 with the EEOC, alleging sexual harassment. LOCKETT received her right-to-sue letter from the EEOC on March 29, 2006. Said right-to-sue letter and charge are attached and incorporated herein. (Attached as Exhibit 4).
9. That all conditions precedent have been fulfilled by Plaintiff, MONICA MONIUSZKO (“MONIUSZKO”). On or about January 12, 2005, she filed a charge of discrimination # 210-2005-01242 with the EEOC, alleging sexual harassment and retaliation. MONIUSZKO received her right-to-sue letter from the EEOC on March 29, 2006. Said right-to-sue letter and charge are attached and incorporated herein. (Attached as Exhibit 5).
10. That Plaintiff MONIUSZKO brings her complaint in reliance on her own charge and those of her co-Plaintiffs pursuant to the single filing rule and continuing violations doctrine. The charges of her co-Plaintiffs are not defective and her claims arose out of similar discriminatory treatment, and in the same time frame as theirs.
11. That Plaintiffs cooperated with the EEOC’s investigations of their charges in this matter.
PARTIES 12. That Plaintiff, BABB, is female and a resident of the state of Illinois.
13. That Plaintiff, GRIFFIN, is female and a resident of the state of Illinois.
14. That Plaintiff, JOHNSON, is female and was a resident of the state of Illinois.
15. That Plaintiff, LOCKETT, is female and a resident of the state of Illinois.
16. That Plaintiff, MONIUSZKO, is female and a resident of the state of Illinois.
17. That Defendant, SUTTON FORD, INC. (“SUTTON FORD”), is duly registered to conduct business in the state of Illinois.
18. That at all times relevant herein, SUTTON FORD was engaged in an industry affecting commerce and has had fifteen (15) or more employees for each working day in each of twenty (20) or more calendar weeks in the current or preceding calendar year.
19. That at all times relevant herein, RICHARD MU HAM MED (“MUHAMMED”) was employed by Defendant as a manager.
20. That at all times relevant herein, LOUIS MINTER (“MINTER”) was employed by Defendant as a salesperson.
21. That at all times relevant herein, RAMONE (LNU) (“RAMONE”) was employed by Defendant as a porter.
22. That at all times relevant herein, EDDIE (LNU) (“EDDIE”) was employed by Defendant as a manager.
23. That at all times relevant herein, JOHN LEFEBER was employed by Defendant as a manager.
24. That at all times relevant herein, RAY LEFEBER was employed by Defendant as a manager.
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25. That at all times relevant herein, JIM IRVING (“IRVING”) was employed by Defendant as a manager.
26. That at all times relevant herein, CHARLES THATCHER (“THATCHER”) was employed by Defendant as a salesperson.
27. That at all times relevant herein, MICHAEL STEIHLER (“STEIHLER”) was employed by Defendant as a salesperson.
28. That at all times relevant herein, MARK RADIGURO (“RADIGURO”) was employed by Defendant as a salesperson.
29. That at all times relevant herein, SUTTON FORD, its managers, and employees created an environment which encouraged and fostered a sexually hostile work environment for Plaintiffs and other females. SUTTON FORD failed to take effective preventive or remedial action.
30. That SUTTON FORD’s officers and agents must also have been aware of this ongoing sexually hostile work environment because it occurred on a daily basis, in an open and notorious manner, and was authored by various management and nonmanagement employees daily to the observation of employees, supervisors, and managers alike.
31. That as a result of the sexually harassing conduct, Plaintiffs and other female employees were adversely impacted by the various tangible employment actions taken against them by SUTTON FORD and its managerial agents.
COUNT I
COMPLAINT OF STACEY GRIFFIN FOR HOSTILE ENVIRONMENT SEXUAL HARASSMENT DIRECTED AT SUTTON FORD, INC.
32. That GRIFFIN incorporates the preceding paragraphs by reference here.
33. That Plaintiff was hired by Defendant, SUTTON FORD, in November 2002 as a salesperson.
34. That during her employment, GRIFFIN performed her assigned tasks in a satisfactory and conscientious manner according to Defendant’s standards.
35. That at relevant times during her employment with Defendant, GRIFFIN was supervised by EDDIE, JOHN LEFEBER, RAY LEFEBER, and MUHAMMED.
36. That starting in January of 2004 and continuing until October 2004, GRIFFIN was subjected to persistent sexual harassment by MUHAMMED. Such harassing conduct included sexually offensive comments on a daily basis as well as inappropriate touching.
37. That MUHAMMED’s sexually harassing comments and inappropriate touching of GRIFFIN occurred at least twenty (20) times per week.
38. That on one occasion during July of 2004, MUHAMMED grabbed GRIFFIN’s vaginal area and stated, “Yeah, I knew you had a fat pussy!”
39. That on another occasion, MUHAMMED grabbed GRIFFIN’s shirt, pulled it away from her body, and stated, “I just wanted to see what color bra you have on.”
40. That from January 2004 through October 2004, MUHAMMED slapped GRIFFIN’s buttocks multiple times a week and once touched GRIFFIN’s leg and asked her, “Do you shave?”
41. That MUHAMMED directed such and other sexually offensive comments to GRIFFIN on a daily basis, asked her for
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sexual favors and acts, requested that she perform sexual favors in order for her deals to close, requested that she show him her body parts, and threatened to expose his private parts to her.
42. That GRIFFIN observed MU HAM MED humiliate other females by directing sexually explicit comments to them and requesting sexual favors in order for them to enjoy the ordinary benefits of employment.
43. That on one occasion, MUHAMMED locked his office door with MARQUITA DUNBAR (“DUNBAR”) inside. MUHAMMED pulled his pants down and asked DUNBAR to “suck” his dick. DUNBAR’s mother complained to SUTTON about this incident.
44. That even though other members of management witnessed MUHAMMED’s conduct, he was neither disciplined nor asked to stop. Instead, SUTTON FORD’s agents, and her co-workers sabotaged GRIFFIN’S work and spread false rumors about her in an attempt to cause her to be disciplined, with impunity.
45. That in December of 2002, GRIFFIN was sexually harassed and subjected to sexually offensive language and unwelcome bodily contact of a sexual nature by EDDIE. EDDIE would grab GRIFFIN’S hands when she brought him work-related documents and made various sexually offensive comments to her during this period.
46. That starting in December of 2002 and continuing until October 2004, GRIFFIN was sexually harassed by RAMONE (LNU) who directed sexually offensive comments and requests for sexual favors to GRIFFIN on a daily basis.
47. That on one occasion, RAMONE grabbed his penis while urging GRIFFIN to give him just “one chance.”
48. That MARVIN (LNU; “MARVIN”), the manager of the porter team, also observed numerous instances during which RAMONE made sexually offensive comments and gestures to GRIFFIN.
49. That in addition to her complaints, members of SUTTON’s management observed RAMONE’s sexually harassing conduct but took no remedial action.
50. That starting in January of 2003, GRIFFIN was sexually harassed by JOHN LEFEBER (“LEFEBER”), manager. LEFEBER directed sexually offensive comments and requests for sexual favors to GRIFFIN on a daily basis.
51. That throughout his employment, LEFEBER would stare at GRIFFIN for prolonged periods of time, thus making her uncomfortable.
52. That starting in January of 2003, and continuing until October 2004, GRIFFIN was subjected to sexually explicit comments, cat calls, unwelcome bodily contact, and requests for sexual favors to her in the hands of MINTER on a daily basis.
53. That on occasion, MINTER would crawl under GRIFFIN’S desk to view her underwear, comment on its color, and loudly express his desire to remain under the desk for such view.
54. That MINTER once grabbed his penis while commenting that GRIFFIN would leave her husband once she gets a hold of his penis.
55. That members of SUTTON’s management such as VATES and RANDOLPH observed MINTER’s sexually inappropriate behavior and took no remedial action.
56. That starting in January of 2003 and continuing, GRIFFIN was subjected to sexual harassment by RAY LEFEBER, manager, who routinely invited exotic dancers and strippers to SUTTON FORD’s premises, causing male employees to follow with sexually explicit conversation and commentary.
57. That starting in 2003 and continuing until October 2004, GRIFFIN was subjected to sexual harassment, sexually offensive comments, and requests for sexual favors by IRVING on a daily basis.
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58. That as a result, MUHAMMED, EDDIE, JOHN LEFEBER, RAY LEFEBER, MINTER, RAMONE, and IRVING continued their conduct, and extended their harassment and assault to other females under their supervision or that worked with them.
59. That Defendant’s treatment of GRIFFIN was motivated by evil motive and intent, and was in reckless and callous indifference to GRIFFIN’S federally protected rights.
60. That as a direct and proximate result of said unlawful employment practices, GRIFFIN has suffered the indignity of discrimination, the invasion of her right to be free from discrimination, and great humiliation which has manifested in physical illnesses, and emotional stress on the relationships between GRIFFIN and her friends and family.
61. That as a further direct and proximate result of said unlawful employment practices, GRIFFIN has suffered extreme mental anguish, outrage, severe anxiety about her future and her ability to support herself, harm to her employability and earning capacity, painful embarrassment among her friends and co-workers, damage to her reputation, disruption of her personal life, and loss of enjoyment of the ordinary pleasures of life.
PRAYER FOR RELIEF WHEREFORE, GRIFFIN respectfully requests that this Court provide the following equitable and legal relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date, and cause this case to be expedited in every possible way.
b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment.
c. Award Plaintiff, GRIFFIN, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest.
d. Award Plaintiff, GRIFFIN, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses.
e. Award Plaintiff, GRIFFIN, a judgment against Defendant for compensatory damages.
f. Grant judgment against Defendant for punitive damages for willful and wanton conduct.
g. Grant such other and further relief as this court deems just and proper.
COUNT II
COMPLAINT OF STACEY GRIFFIN FOR QUID PRO QUO SEX DISCRIMINATION DIRECTED AT SUTTON FORD, INC.
62. That GRIFFIN incorporates the preceding paragraphs by reference here.
63. That MU HAM MED implicitly and explicitly conditioned GRIFFIN’S enjoyment of the various terms, conditions, and benefits of employment on her submission to his sexual advances. Such terms and conditions of employment include the assignment of deals, sales leads, and such others.
64. That Defendant’s conduct in subjecting Plaintiff to inferior terms and conditions of employment and in terminating her amounts to quid pro quo sexual harassment in violation of the law.That as a further result of said harassing conduct, GRIFFIN was adversely affected by the various tangible employment actions that she suffered at the hands of Defendants
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and their agents.
PRAYER FOR RELIEF WHEREFORE, GRIFFIN respectfully requests that this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date, and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sexual discrimination and sexual harassment. c. Award Plaintiff, GRIFFIN, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. e. Award Plaintiff, GRIFFIN, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
COUNT III
COMPLAINT OF STACEY GRIFFIN FOR RETALIATION DIRECTED AT SUTTON FORD, INC. 66. That GRIFFIN incorporates the preceding paragraphs by reference here. 67. That GRIFFIN was terminated on or around October 5, 2004. 68. That Defendant’s termination of GRIFFIN amounts to illegal retaliation for resisting conduct which GRIFFIN in good faith believed to be sexual harassment. 69. That Defendant and its agents further subjected GRIFFIN to inferior terms and conditions of employment for resisting conduct GRIFFIN in good faith believed to be sexual harassment. 70. That the adverse actions followed GRIFFIN’S protected activity within such a period of time as to raise an inference of retaliatory motivation.
PRAYER FOR RELIEF WHEREFORE, Plaintiff, GRIFFIN respectfully requests this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment.
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c. Award Plaintiff, GRIFFIN, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, GRIFFIN, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses. e. Award Plaintiff, GRIFFIN, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
COUNT IV
COMPLAINT OF STACEY GRIFFIN FOR ASSAULT AND BATTERY DIRECTED TO RICHARD MUHAMMED AND SUTTON FORD, INC.
71. That GRIFFIN incorporates the preceding paragraphs by reference here. 72. That MUHAMMED intended to engage in offensive and harmful physical contact with GRIFFIN’S body. 73. That MUHAMMED’s conduct in touching and attempting to touch GRIFFIN was intentional. 74. That MUHAMMED’s conduct in touching and attempting to touch GRIFFIN placed her in apprehension of imminent offensive physical contact by MUHAMMED. 75. That MUHAMMED’s conduct amounts to willful and wanton conduct. 76. That as a result of MUHAMMED’s conduct, GRIFFIN suffered and continues to suffer fright, physical illnesses, mental anguish, humiliation and embarrassment. 77. That Defendant, SUTTON FORD, is directly responsible for the assault and battery endured by GRIFFIN because it knew or in the exercise of reasonable care should have known about such conduct, but failed to take reasonable steps to prevent or correct it. 78. SUTTON FORD improperly condoned and failed to prevent the assault and battery of Plaintiff by its agents, managers, and employees and is thus liable for such.
PRAYER FOR RELIEF WHEREFORE, GRIFFIN respectfully requests that the Court provide the following equitable and legal relief: a. Award GRIFFIN a judgment against MU HAM MED and SUTTON FORD for compensatory and punitive damages. b. Enter an order granting GRIFFIN reasonable compensation for the fright, humiliation, embarrassment, physical illnesses and mental anguish suffered by GRIFFIN as a result of MUHAMMED’s conduct. c. Grant GRIFFIN such other and further relief as this court deems just and proper.
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COUNT V
COMPLAINT OF STACEY GRIFFIN FOR INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS DIRECTED TO RICHARD MUHAMMED AND SUTTON FORD, INC.
79. That GRIFFIN incorporates the preceding paragraphs by reference here. 80. That Defendants’ conduct toward GRIFFIN amounts to intentional infliction of emotional distress because said conduct was extreme and outrageous and Defendants intended to inflict severe emotional distress on GRIFFIN. 81. That as a result, GRIFFIN has suffered and continues to suffer severe emotional distress, fright, physical illnesses, mental anguish, humiliation, and embarrassment.
PRAYER FOR RELIEF WHEREFORE, GRIFFIN respectfully requests that the Court provide the following equitable and legal relief: a. Award GRIFFIN a judgment against MUHAMMED and SUTTON FORD for compensatory and punitive damages. b. Enter an order granting GRIFFIN reasonable compensation for the severe emotional distress, fright, humiliation, embarrassment, and physical illnesses suffered by GRIFFIN. c. Grant GRIFFIN such other and further relief as this court deems just and proper.
COUNT VI
COMPLAINT OF CARRIE BABB FOR HOSTILE ENVIRONMENT SEXUAL HARASSMENT DIRECTED TO SUTTON FORD, INC.
82. BABB incorporates the following preceding paragraphs by reference here: ¶¶1-31. 83. That BABB was hired by Defendant in April of 2004, as a Car Salesperson. 84. That during her employment, BABB performed her assigned tasks in a satisfactory and conscientious manner according to Defendant’s standards. 85. That at relevant times during her employment with Defendant, BABB was supervised by MUHAMMED. 86. That starting in April of 2004, and continuing until September 2004, BABB was subjected to sexual harassment, offensive language, and unwelcome physical contact by MUHAMMED on a daily basis. 87. That during this period, MUHAMMED slapped BABB’s buttocks on numerous occasions. 88. That in addition, MUHAMMED made daily sexually explicit comments and invitations to BABB. Such comments included references to her pubic hair, requests for sexual favors and acts in exchange for assistance in closing deals, questions about various parts of her body, invitations to engage in assorted sexual acts, requests to view parts of her body, comments about the color of her underwear and the size of his penis.
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89. On occasion, MUHAMMED would grab his penis while asking BABB if she wanted some.
90. That on a daily basis, rather than say “good morning” to BABB, MUHAMMED would say, “Suck me!”.
91. That BABB repeatedly asked MUHAMMED to stop making offensive comments and slapping her buttocks but MUHAMMED simply laughed each time.
92. That in about July and August of 2004, BABB complained to VATES about MUHAMMED’s sexually offensive comments and inappropriate touching to no avail.
93. That members of SUTTON FORD’s management such as VATES and ARSELLA, observed MUHAMMED’s offensive comments and unwelcome physical contact.
94. That starting in April of 2004, and continuing until September 2004, MINTER made sexually explicit comments to BABB. Such included comments asking BABB to “Put a little extra lip gloss on it. It will make it easier” referring to oral sex. MINTER subjected BABB to this and similar comments on a daily basis during this period.
95. That furthermore, RAMONE subjected BABB to sexually explicit and offensive remarks and invitations to perform sexual acts and favors on a daily basis.
96. That MARVIN, the manager of the porter team, witnessed several of RAMONE’s sexually offensive comments and took no action to prevent or correct same.
97. That as a result of BABB’s rejection of sexual advances and conduct, ARSELA and VATES sabotaged BABB’s work in an attempt to cause her to be disciplined and possibly terminated. Even though BABB complained about this conduct, no discipline was issued as a result.
98. That as a result of BABB’s rejection of sexual advances and conduct, MUHAMMED interfered with BABB’s enjoyment of the ordinary benefits of employment by denying her lucrative sales deals, leads, and by steering away to other employees customers that would otherwise have been BABB’s.
99. That Defendant’s treatment of BABB was motivated by evil motive and intent and was in reckless and callous indifference to BABB’s federally protected rights.
100. That as a direct and proximate result of said unlawful employment practices, BABB has suffered the indignity of discrimination, the invasion of her right to be free from discrimination, and great humiliation which has manifested in physical illnesses and emotional stress on the relationships between BABB and her friends and family.
101. That as a further direct and proximate result of said unlawful employment practices, BABB has suffered extreme mental anguish, outrage, severe anxiety about her future and her ability to support herself, harm to her employability and earning capacity, painful embarrassment among her friends and co-workers, damage to her reputation, disruption of her personal life, and loss of enjoyment of the ordinary pleasures of life.
PRAYER FOR RELIEF
WHEREFORE, BABB respectfully requests that the Court provide the following equitable and legal relief. a. Advance this case on the docket, order a speedy hearing at the earliest practicable date, and cause this case to be expedited in every possible way.
b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment.
c. Award Plaintiff, BABB, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe 9

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benefits lost to the present with applicable statutory interest. d. Award Plaintiff, BABB, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses. e. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Grant such other and further relief as this court deems just and proper.
COUNT VII
COMPLAINT OF CARRIE BABB FOR QUID PRO QUO SEX DISCRIMINATION DIRECTED AT SUTTON FORD, INC.
102. That BABB incorporates the following preceding paragraphs by reference here: ¶¶ 1-31 and ¶¶ 82-101. 103. That MUHAMMED implicitly and explicitly conditioned BABB’s enjoyment of the various terms, conditions, and benefits of employment on her submission to his sexual advances. Such terms and conditions of employment include the assignment of deals, sales leads, and such others. 104. That Defendant’s conduct in subjecting Plaintiff to inferior terms and conditions of employment amounts to quid pro quo sexual harassment in violation of the law. 105. That as a further result of said harassing conduct, BABB was adversely affected by the various tangible employment actions that she suffered at the hands of Defendants and their agents.
PRAYER FOR RELIEF WHEREFORE, BABB respectfully requests that this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date, and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sexual discrimination and sexual harassment. c.Award Plaintiff, BABB, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages. e. Grant judgment against Defendantfor punitive damages for willful and wanton conduct. f. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
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COUNT VIM
COMPLAINT OF CARRIE BABB FOR RETALIATION DIRECTED AT SUTTON FORD, INC. 106. That BABB incorporates the following preceding paragraphs by reference here: ¶¶ 31and ¶¶ 82-10. 107. That Defendant and its agents subjected BABB to inferior terms and conditions of employment for resisting conduct BABB in good faith believed to be sexual harassment. 108. That the adverse actions followed BABB’s protected activity within such a period of time as to raise an inference of retaliatory motivation.
PRAYER FOR RELIEF WHEREFORE, Plaintiff, BABB respectfully requests this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date, and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, BABB, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, BABB, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses. e. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
COUNT IX
COMPLAINT OF CARRIE BABB FOR ASSAULT AND BATTERY DIRECTED TO RICHARD MUHAMMED AND SUTTON FORD, INC.
109. That BABB incorporates the following preceding paragraphs by reference here: ¶¶ 1-31 and ¶¶ 82-105. 110. That MUHAMMED intended to engage in offensive and harmful physical contact with BABB’s body. 111. That MUHAMMED’s conduct in touching and attempting to touch BABB was intentional. 112. That MUHAMMED’s conduct in touching and attempting to touch BABB placed her in apprehension of imminent offensive physical contact by MUHAMMED.
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113. That MUHAMMED’s conduct amounts to willful and wanton conduct. 114. That as a result of MUHAMMED’s conduct, BABB suffered and continues to suffer fright, physical illnesses, mental anguish, humiliation, and embarrassment. 115. That Defendant, SUTTON FORD, is directly responsible for the assault and battery endured by BABB because it knew or in the exercise of reasonable care should have known about such conduct, but failed to take reasonable steps to prevent or correct it. 116. SUTTON FORD improperly condoned and failed to prevent the assault and battery of Plaintiff by its agents, managers, and employees and is thus liable for such.
PRAYER FOR RELIEF WHEREFORE, BABB respectfully requests that the Court provide the following equitable and legal relief: a. Award BABB a judgment against MUHAMMED and SUTTON FORD for compensatory and punitive damages. b. Enter an order granting BABB reasonable compensation for the fright, humiliation, embarrassment, physical illnesses, and mental anguish suffered by BABB as a result of MUHAMMED’s conduct. c. Grant BABB such other and further relief as this court deems just and proper.
COUNT X
COMPLAINT OF CARRIE BABB OF
RACE DISCRIMINATION AND RACIAL
HARASSMENT DIRECTED AT SUTTON FORD, INC. 117. hat BABB incorporates the following preceding paragraphs by reference here: ¶¶ 1-31 and ¶¶ 82-105. 118. That BABB is Caucasian. 119. That MUHAMMED is African-American. 120. That throughout BABB’s employment with SUTTON FORD, she was subjected to persistent and continuous racial discrimination and harassment. 121. That during the period from April 2004 through September 2004, MUHAMMED regularly made racially offensive comments in BABB’s presence, such as: “I don’t like white people!”; “white people ain’t got no business selling cars!”; “white men have little dicks, you need a black one!”; once you go black, you never go back! Its true!”; and “you white people can’t sell cars, I’m taking this customer.” 122. That BABB was also subjected to unequal treatment in the various terms and conditions of employment due to her race by MUHAMMED in that MUHAMMED would often take customers away from BABB and give them to the AfricanAmerican sales people.
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123. That all of these and similar incidents have created a hostile and offensive work environment for BABB. 124. That Defendant’s treatment of BABB was motivated by evil motive and intent and was recklessly and callously indifferent to BABB’s federally protected rights. 125. That Defendant’s treatment of Plaintiff, BABB, was motivated by racial animus and Defendant and its agents acted with racial animus directed toward Caucasians in violation of the law. 126. That as a direct and proximate result of said unlawful employment practices and disregard for BABB’s rights and sensibilities, BABB has lost and will continue to lose substantial income, including, but not limited to, wages, fringes, seniority benefits, and other employment benefits. 127. That as a further direct and proximate result of said unlawful employment practices, BABB has suffered the indignity of discrimination, the invasion of her right to be free from discrimination, and great humiliation which is manifest in physical illnesses, and emotional stress on the relationships between BABB and her friends, family, and colleagues. 128. That as a further direct and proximate result of said unlawful employment practices, BABB has suffered extreme mental anguish, outrage, severe anxiety about her future and her ability to support herself, harm to her employability and earning capacity, shameful embarrassment among her friends, colleagues, and co-workers, damage to her reputation, disruption of her personal life, and loss of enjoyment of the ordinary pleasures of life.
PRAYER FOR RELIEF WHEREFORE, Plaintiff, BABB, respectfully prays that the Court provide the following equitable and legal relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Award Plaintiff, BABB, appropriate back-pay, reinstatement, future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. c. Award Plaintiff, BABB, costs of litigation, including reasonable attorney’s fees and expert fees and expenses. d. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages. e. Grant judgment against Defendant for punitive damages for willful and wanton conduct. f. Enter an order requiring Defendant to implement effective steps to eliminate discrimination from Defendant’s organization. g. Grant such other and further relief as this court deems just and proper.
COUNT XI
COMPLAINT OF CARRIE BABB OF
CONSTRUCTIVE DISCHARGE DIRECTED AT SUTTON FORD, INC. 129. That BABB incorporates the following preceding paragraphs by reference here: ¶¶ 1-31 and ¶¶ 82-128.
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130. That Defendant had notice, condoned Plaintiff’s intolerable conditions, and did nothing. 131. That Plaintiff had no other choice but to resign because SUTTON FORD and its agent constructed intolerable conditions for her. 132. That BABB was constructively discharged in or around September 2004.
PRAYER FOR RELIEF WHEREFORE, Plaintiff, BABB, respectfully prays that the Court provide the following equitable and legal relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, BABB, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, BABB, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses e. Award Plaintiff, BABB, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
COUNT XII
COMPLAINT OF CARRIE BABB
FOR INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
DIRECTED TO RICHARD MUHAMMED
AND SUTTON FORD, INC. 133. That BABB incorporates the following preceding paragraphs by reference here: ¶¶ 1-31 and ¶¶ 82-128. 134. That Defendants’ conduct toward BABB amounts to intentional infliction of emotional distress because said conduct was extreme and outrageous and Defendants intended to inflict severe emotional distress on BABB. 135. That as a result, BABB has suffered and continues to suffer severe emotional distress, fright, physical illnesses, mental anguish, humiliation, and embarrassment.
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PRAYER FOR RELIEF WHEREFORE, BABB respectfully requests that the Court provide the following equitable and legal relief: a. Award BABB a judgment against MUHAMMED and SUTTON FORD for compensatory and punitive damages. b. Enter an order granting BABB reasonable compensation for the severe emotional distress, fright, humiliation, embarrassment, and physical illnesses suffered by BABB. c. Grant BABB such other and further relief as this court deems just and proper.
COUNT XIII
COMPLAINT OF JADA JOHNSON FOR
HOSTILE ENVIRONMENT SEXUAL HARASSMENT
DIRECTED TO SUTTON FORD, INC. 136. That JOHNSON incorporates the following preceding paragraphs by reference here: ¶¶ 1-31. 137. That JOHNSON was hired by Defendant in April of 2004, as a Car Salesperson. 138. That during her employment, JOHNSON performed her assigned tasks in a satisfactory and conscientious manner according to Defendant’s standards. 139. That at relevant times during her employment with Defendant, JOHNSON was supervised by MUHAMMED. 140. That starting in April of 2004 and continuing until July 2004, JOHNSON was subjected to persistent sexual harassment by MUHAMMED. 141. That such harassing conduct included offensive and inappropriate touching and sexually offensive comments on a daily basis, requests to view and/or smell her body parts, that she bend over in order for her deal to be approved, and comments on the color of her underwear and sexual preferences. 142. That MUHAMMED also stated to JOHNSON, “I know I am a nymphomaniac and I know I need help. I just love pussy. I ain’t lying. I make you sick, don’t I?” During the summer of 2004, MUHAMMED placed his hand under JOHNSON’S buttocks as she was sitting down on a chair. 143. On numerous occasions, when JOHNSON bent over, MUHAMMED stood behind her, simulated intercourse while rubbing his penis against her buttocks in a back and forth motion. 144. That JOHNSON often asked MUHAMMED to stop making offensive comments, and to stop touching her. However, every time she complained, MUHAMMED just laughed and the harassment continued. 145. That in or around May, June or July of 2004, JOHNSON complained to management employees, WHITE, WILLIAMS, RANDOLPH, VATES and SUTTON about MUHAMMED’s sexually offensive comments and inappropriate touching. However, the harassment never ceased. 146. That after complaining about MUHAMMED’s sexual harassment, he subjected JOHNSON to inferior treatment by making her wait longer periods of time for her financial deals to go through, thus causing her to lose valuable income.
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147. That other members of management heard MUHAMMED’s sexually offensive comments toward JOHNSON and observed MUHAMMED’s inappropriate touching of her but took no action to prevent or correct same. Instead, certain of them such as VATES often laughed and/or giggled in response to such behavior. 148. That starting in April of 2004 and continuing until July of 2004, JOHNSON was subjected to persistent sexual harassment by MINTER. 149. That on one occasion during June or July of 2004, MINTER touched the side of JOHNSON’S breast and said, “Put that thing back.” JOHNSON told MINTER never to touch her again. He routinely made comments of a sexual nature, requested that JOHNSON permit customers to touch her, and simulated intercourse against a chair in JOHNSON’S presence. 150. That members of SUTTON FORD’s management and customers heard MINTER’s daily sexual comments. 151. That JOHNSON also suffered similar degradation and intimidation at the hands of RAMONE (LNU) on a daily basis during the period from April of 2004 until July of 2004 in the presence of members of SUTTON FORD’s management. 152. That Defendant’s treatment of JOHNSON was motivated by evil motive and intent, and was in reckless and callous indifference to JOHNSON’S federally protected rights. 153. That as a direct and proximate result of said unlawful employment practices, JOHNSON has suffered the indignity of discrimination, the invasion of her right to be free from discrimination and great humiliation which has manifested in physical illnesses, and emotional stress on the relationships between JOHNSON and her friends and family. 154. That as a further direct and proximate result of said unlawful employment practices, JOHNSON has suffered extreme mental anguish, outrage, severe anxiety about her future and her ability to support herself, harm to her employability and earning capacity, painful embarrassment among her friends and co-workers, damage to her reputation, disruption of her personal life, and loss of enjoyment of the ordinary pleasures of life.
PRAYER FOR RELIEF WHEREFORE, JOHNSON respectfully requests that the Court provide the following equitable and legal relief. a. Advance this case on the docket, order a speedy hearing at the earliest practicable date, and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, JOHNSON, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, JOHNSON, costs of litigation, including reasonable attorneys’ fees and expert fees, and expenses. e. Award Plaintiff, JOHNSON, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Grant such other and further relief as this court deems just and proper.
COUNT XIV
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COMPLAINT OF JADA JOHNSON FOR QUID PRO QUO SEX DISCRIMINATION DIRECTED AT SUTTON FORD, INC.
155. That JOHNSON incorporates the following preceding paragraphs by reference here: ¶¶ 1-31 and ¶¶ 136-154. 156. That MUMED implicitly and explicitly conditioned JOHNSON’S enjoyment of the various terms, conditions, and benefits of employment on her submission to his sexual advances. Such terms and conditions of employment include the assignment of deals, sales leads, and such others. 157. That Defendant’s conduct in subjecting Plaintiff to inferior terms and conditions of employment and in terminating her amounts to quid pro quo sexual harassment in violation of the law. 158. That as a further result of said harassing conduct, JOHNSON was adversely affected by the various tangible employment actions that she suffered in the hands of Defendants and their agents.
PRAYER FOR RELIEF WHEREFORE, JOHNSON respectfully requests that this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date, and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sexual discrimination and sexual harassment. c. Award Plaintiff, JOHNSON, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, JOHNSON, a judgment against Defendant for compensatory damages. e. Grant judgment against Defendantfor punitive damages for willful and wanton conduct. f. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassmentfrom Defendant’s company. g.Grant such other and further relief as this Court deems just and proper.
COUNT XV
COMPLAINT OF JADA JOHNSON FOR RETALIATION DIRECTED AT SUTTON FORD, INC. 159. That JOHNSON incorporates the following preceding paragraphs by reference here: ¶¶ 1-31 and ¶¶ 136-158. 160. That JOHNSON was terminated on or around July 25, 2004. 161. That Defendant’s termination of JOHNSON amounts to illegal retaliation for resisting conduct which JOHNSON in good faith believed to be sexual harassment. 162. That the adverse action followed JOHNSON’S protected activity within such a period of time as to raise an inference of retaliatory motivation.
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PRAYER FOR RELIEF WHEREFORE, Plaintiff, JOHNSON respectfully requests this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, JOHNSON, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, JOHNSON, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses. e. Award Plaintiff, JOHNSON, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendantfor punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassmentfrom Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
COUNT XVI
COMPLAINT OF JADA JOHNSON FOR ASSAULT AND BATTERY DIRECTED TO LOUIS MINTER, RICHARD MUHAMMED, AND SUTTON FORD, INC.
163. That JOHNSON incorporates the following preceding paragraphs by reference here: ¶¶ 1-31 and ¶¶ 136-158. 164. That M INTER and MU HAM MED intended to engage in offensive and harmful physical contact with JOHNSON’S body. 165. That Defendants’ conduct in touching and attempting to touch JOHNSON was intentional. 166. That Defendants’ conduct in touching and attempting to touch JOHNSON placed her in apprehension of imminent offensive physical contact. 167. That as a result, JOHNSON suffered and continues to suffer fright, physical illnesses, mental anguish, humiliation, and embarrassment. 168. That Defendant, SUTTON FORD, is directly responsible for the assault and battery endured by JOHNSON because it knew or in the exercise of reasonable care should have known about such conduct, but failed to take reasonable steps to prevent or correct it. 169. SUTTON FORD improperly condoned and failed to prevent the assault and battery of Plaintiff by its agents, managers, and employees and is thus liable for such.
PRAYER FOR RELIEF
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WHEREFORE, JOHNSON respectfully requests that the Court provide the following equitable and legal relief: a. Award JOHNSON a judgment against MINTER, MOHAMMED and SUTTON FORD for compensatory and punitive damages. b. Enter an order granting JOHNSON reasonable compensation for the fright, humiliation, embarrassment, physical illnesses and mental anguish suffered by JOHNSON as a result of Defendants’ conduct. c. Grant JOHNSON such other and further relief as this court deems just and proper.
COUNT XVII
COMPLAINT OF JADA JOHNSON FOR INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS DIRECTED TO RICHARD MUHAMMED, LOUIS MINTER, AND SUTTON FORD, INC.
170. That JOHNSON incorporates the following preceding paragraphs by reference here: ¶¶ 1-31 and ¶¶136-158. 171. That Defendants’ conduct toward JOHNSON amounts to intentional infliction of emotional distress because said conduct was extreme and outrageous and Defendants intended to inflict severe emotional distress on JOHNSON. 172. That as a result, JOHNSON has suffered and continues to suffer severe emotional distress, fright, physical illnesses, mental anguish, humiliation, and embarrassment.
PRAYER FOR RELIEF WHEREFORE, JOHNSON respectfully requests that the Court provide the following equitable and legal relief: a. Award JOHNSON a judgment against MUHAMMED, MINTER and SUTTON FORD for compensatory and punitive damages. b. Enter an order granting JOHNSON reasonable compensation for the severe emotional distress, fright, humiliation, embarrassment, and physical illnesses suffered by JOHNSON. c. Grant JOHNSON such other and further relief as this court deems just and proper.
COUNT XVIII
COMPLAINT OF NIKITA LOCKETT FOR HOSTILE ENVIRONMENT SEXUAL HARASSMENT DIRECTED TO SUTTON FORD, INC.
173. That LOCKETT incorporates the following preceding paragraphs by reference here: ¶¶ 1-31. 174. That LOCKETT was hired by Defendant in January of 2005, as a Car Salesperson. 175. That during her employment, LOCKETT performed her assigned tasks in a satisfactory and conscientious manner according to Defendant’s standards. 176. That starting in May of 2005 and continuing until July 2005, LOCKETT was subjected to persistent sexual harassment
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by RADIGURO. Such harassing conduct included offensive, and inappropriate touching and sexually offensive comments directed toward LOCKETT on a daily basis such as references to her body parts, underwear, and comments about her sexual preferences and male body parts.
177. That some of the comments were made in the presence of other male employees and managers alike who would laugh thus causing significant embarrassment and humiliation to LOCKETT. When LOCKETT complained about said conduct, no action was taken to correct same.
178. That on numerous occasions, RADIGURO intentionallytouched LOCKETT’s buttocks. For example, in approximately June of 2005, RADIGURO told LOCKETT, “You have some dust on your butt.” RADIGURO then proceeded to slap her in the buttocks, pretending to get the dust off of her buttocks. LOCKETT told RADIGURO, “Don’t touch me! Tell me next time and I will get it off myself.”
179. That on numerous occasions, RADIGURO intentionally brushed his hand against LOCKETT’s buttocks. Each time he did this, LOCKETT told him to get away.
180. That LOCKETT complained to SUTTON FORD’s management employees to no avail. Instead of addressing her complaints, WHITE told LOCKETT she was causing a little too much attention for the male employees from male employees due to her clothing.
181. That starting in January of 2005 and continuing until July 2005, LOCKETT was subjected to persistent sexual harassment, offensive and humiliating conduct by MINTER who made daily comments about her breasts, buttocks, and other body parts, requested sexual favors from her, and touched her in an offensive manner.
182. That in approximately April of 2005, MINTER wrapped his arms around LOCKETT’s chest. MINTER then squeezed her chest with his arms. This conduct was unwelcome. LOCKETT broke free from his hug, and told him to get away from her.
183. That Defendant failed to take effective and appropriate remedial action in 2005 after LOCKETT complained about sexual harassment to management employees.
184. That Defendant’s treatment of LOCKETT was motivated by evil motive and intent, and was in reckless and callous indifference to LOCKETT’s federally protected rights.
185. That as a direct and proximate result of said unlawful employment practices, LOCKETT has suffered the indignity of discrimination, the invasion of her right to be free from discrimination and great humiliation which has manifested in physical illnesses, and emotional stress on the relationships between LOCKETT and her friends and family.
186. That as a further direct and proximate result of said unlawful employment practices, LOCKETT has suffered extreme mental anguish, outrage, severe anxiety about her future and her ability to support herself, harm to her employability and earning capacity, painful embarrassment among her friends and co-workers, damage to her reputation, disruption of her personal life, and loss of enjoyment of the ordinary pleasures of life.
PRAYER FOR RELIEF
WHEREFORE, LOCKETT respectfully requests that the Court provide the following equitable and legal relief. a. Advance this case on the docket, order a speedy hearing at the earliest practicable date, and cause this case to be expedited in every possible way.
b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment.
c. Award Plaintiff, LOCKETT, back pay, reinstatement, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest.
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d. Award Plaintiff, LOCKETT, costs of litigation, including reasonable attorneys’ fees and expert fees, and expenses. e. Award Plaintiff, LOCKETT, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendantfor punitive damages for willful and wanton conduct. g. Grant such other and further relief as this court deems just and proper.
COUNT XIX
COMPLAINT OF NIKITA LOCKETT FOR REPLEVIN AND CONVERSION DIRECTED TO SUTTON FORD, INC.
187. That LOCKETT incorporates the following preceding paragraphs by reference here: ¶¶ 1-31. 188. That prior to July 5, 2005, LOCKETT had the following personal items at or in her desk at SUTTON FORD: a. Her Texas Instrument calculator; b. Her photo album with her son’s pictures; c. Her automobile book that she purchased. This book contained all of her commission slips and customers’ names and addresses; d. Her high school diploma; e. Her training certificates; and f. Her tennis shoes.
189. That on July 5, 2005, LOCKETT owned the personal property items listed above. 190. That on or around July 5, 2005, SUTTON FORD, wrongfully detained LOCKETT’s personal property from her desk. LOCKETT never gave SUTTON FORD permission to detain her personal property. 191. That LOCKETT’s personal property has not been taken for any tax, assessment, or fine or seized under any lawful process or held by virtue of any order for replevin. 192. That LOCKETT made numerous requests to SUTTON FORD asking that it return her personal property. 193. That to the present, SUTTON FORD has still not returned said personal property listed above to LOCKETT.
PRAYER FOR RELIEF WHEREFORE, LOCKETT respectfully requests that the Court provide the following equitable and legal relief. a. An order awarding possession of LOCKETT’s personal property described above, or in the alternative, for judgment for the value of her personal property. b. All damages she has sustained by reason of the wrongful taking and detention. c. All damages available under 735 ILCS 5/19.
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d. Grant such other and further relief as this court deems just and proper.
COUNT XX
COMPLAINT OF NIKITA LOCKETT FOR RETALIATION DIRECTED AT SUTTON FORD, INC. 194. That LOCKETT incorporates the following preceding paragraphs by reference e:¶¶ 1-31 and ¶¶ 173-193. 195. That LOCKETT was terminated on or around July 5, 2005. 196. That on or around the day LOCKETT was terminated, Defendant confiscated and or converted her personal belongings from her desk. LOCKETT made repeated requests that Defendant return her confiscated belongings. Despite such requests, Defendant has never returned her belongings. 197. That Defendant’s confiscation and/or conversion of LOCKETT’s personal belongings amounts to illegal retaliation for resisting conduct which LOCKETT in good faith believed to be sexual harassment. 198. That similarly situated employees who did not complain about sexual harassment were not subjected to such treatment. 199. That Defendant and its agents further subjected LOCKETT to inferior terms and conditions of employment for resisting conduct LOCKETT in good faith believed to be sexual harassment. 200. That the adverse action followed LOCKETT’S protected activity within such a period of time as to raise an inference of retaliatory motivation.
PRAYER FOR RELIEF WHEREFORE, Plaintiff, LOCKETT respectfully requests this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, LOCKETT, back pay, appropriate future earnings, and reimbursement for income and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, LOCKETT, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses. e. Award Plaintiff, LOCKETT, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendantfor punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper.
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COUNT XXI
COMPLAINT OF NIKITA LOCKETT FOR ASSAULT AND BATTERY DIRECTED TO LOUIS MINTER AND AND SUTTON FORD, INC.
201. That LOCKETT incorporates the following preceding paragraphs by reference here: ¶¶ 1-31 and ¶¶ 173-186. 202. That MINTER intended to engage in offensive and harmful physical contact with LOCKETT’s body. 203. That MINTER’s conduct in touching and attempting to touch LOCKETT was intentional. 204. That MINTER’s conduct in touching and attempting to touch LOCKETT placed her in apprehension of imminent offensive physical contact. 205. That as a result, LOCKETT suffered and continues to suffer fright, physical illnesses, mental anguish, humiliation, and embarrassment. 206. That Defendant, SUTTON FORD, is directly responsible for the assault and battery endured by LOCKETT because it knew or in the exercise of reasonable care should have known about such conduct, but failed to take reasonable steps to prevent or correct it. 207. SUTTON FORD improperly condoned and failed to prevent the assault and battery of Plaintiff by its agents, managers and employees and is thus liable for such.
PRAYER FOR RELIEF WHEREFORE, LOCKETT respectfully requests that the Court provide the following equitable and legal relief: a. Award LOCKETT a judgment against MINTER and SUTTON FORD for compensatory and punitive damages. b. Enter an order granting LOCKETT reasonable compensation for the fright, humiliation, embarrassment, physical illnesses and mental anguish suffered by LOCKETT as a result of Defendants’ conduct. c. Grant LOCKETT such other and further relief as this court deems just and proper.
COUNT XXII
COMPLAINT OF NIKITA LOCKETT FOR INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS DIRECTED TO LOUIS MINTER AND SUTTON FORD, INC.
208. That LOCKETT incorporates the following preceding paragraphs by reference here: ¶¶ 1-31 and ¶¶ 173-207. 209. That Defendants’ conduct toward LOCKETT amounts to intentional infliction of emotional distress because said conduct was extreme and outrageous and Defendants intended to inflict severe emotional distress on LOCKETT. 210. That as a result, LOCKETT has suffered and continues to suffer severe emotional distress, fright, physical illnesses, mental anguish, humiliation, and embarrassment.
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PRAYER FOR RELIEF WHEREFORE, LOCKETT respectfully requests that the Court provide the following equitable and legal relief: a. Award LOCKETT a judgment against MUHAMMED and SUTTON FORD for compensatory and punitive damages.
b. Enter an order granting LOCKETT reasonable compensation for the severe emotional distress, fright, humiliation, embarrassment, and physical illnesses suffered by LOCKETT.
c. Grant LOCKETT such other and further relief as this court deems just and proper.
COUNT XXIII
COMPLAINT OF MONICA MONIUSZKO FOR HOSTILE ENVIRONMENT SEXUAL HARASSMENT DIRECTED TO SUTTON FORD, INC.
211. That MONIUSZKO incorporates the following preceding paragraphs by reference here: ¶¶ 1-31.
212. That MONIUSZKO was hired by Defendant in the fall of 2002 as a Finance Assistant.
213. That on March 11, 2003, MONIUSZKO was subjected to sexual harassment by STEIHLER who directed sexually offensive comments to her about her boyfriend and sexual intercourse.
214. That MONIUSZKO reported the incidents to SUE SCHAFROTH (“SCHAFROTH”) who then reported them to WILLIAMS. WILLIAMS made both STEIHLER and MONIUSZKO sign a copy of the complaint. MONIUSZKO is not aware if STEIHLER was disciplined.
215. That in 2003, MONIUSZKO was subjected to daily acts of sexual harassment by RANDOLPH who touched her inappropriately, rubbed her shoulders and hair, touched her leg, put his arms around her, ran his foot up her leg, and stared at her for prolonged periods.
216. That in addition, THATCHER subjected MONIUSZKO to acts of sexual harassment in approximately February and March of 2003 by asking her out, offering to do “some things” to her and such other offensive comments.
217. That in February and March of 2003, MINTER also made inappropriate comments of a sexual nature to MONIUSZKO, and touched her repeatedly without invitation or her consent.
218. That Defendant’s treatment of MONIUSZKO was motivated by evil intent and was in reckless and callous indifference to her federally protected rights.
219. That as a direct and proximate result of said unlawful employment practices, MONIUSZKO has suffered the indignity of discrimination, the invasion of her right to be free from discrimination and great humiliation which is manifest in physical illnesses and emotional stress on the relationships between MONIUSZKO and her friends and family.
220. That as a further direct and proximate result of said unlawful employment practices, MONIUSZKO has suffered extreme mental anguish, outrage, severe anxiety about her future and her ability to support herself, harm to her employability and earning capacity, painful embarrassment among her friends and co-workers, damage to her reputations, disruption of her personal life, and loss of enjoyment of the ordinary pleasures of life.
PRAYER FOR RELIEF
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WHEREFORE, MONIUSZKO respectfully requests that the Court provide the following equitable and legal relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, MONIUSZKO, back pay, reinstatement, appropriate future earnings and reimbursement for income, and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, MONIUSZKO, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses. e. Award Plaintiff, MONIUSZKO, a judgment against Defendant for compensatory damages. f. Grant judgment against Defendantfor punitive damages for willful and wanton conduct. h. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. i. Grant such other and further relief as this court deems just and proper.
COUNT XXIV
COMPLAINT OF MONICA MONIUSZKO FOR RETALIATION DIRECTED AT SUTTON FORD, INC. 221. That MONIUSZKO incorporates the following preceding paragraphs by reference here: ¶¶ 1-31 and ¶¶ 211-220. 222. That MONIUSZKO was terminated in or around May of 2003. 223. That Defendant’s termination of MONIUSZKO amounts to illegal retaliation for resisting conduct which MONIUSZKO in good faith believed to be sexual harassment. 224. That Defendant and its agents further subjected MONIUSZKO to inferior terms and conditions of employment for resisting conduct MONIUSZKO in good faith believed to be sexual harassment. 225. That the adverse action followed MONIUSZKO’s protected activity within such a period of time as to raise an inference of retaliatory motivation.
PRAYER FOR RELIEF WHEREFORE, Plaintiff, MONIUSZKO respectfully requests this Court provide the following equitable and legal remedies for relief: a. Advance this case on the docket, order a speedy hearing at the earliest practicable date and cause this case to be expedited in every possible way. b. Order a permanent injunction prohibiting Defendant from further acts of sex discrimination and sexual harassment. c. Award Plaintiff, MONIUSZKO, back pay, reinstatement, appropriate future earnings and reimbursement for income, and fringe benefits lost to the present with applicable statutory interest. d. Award Plaintiff, MONIUSZKO, costs of litigation, including reasonable attorneys’ fees and expert fees and expenses. e. Award Plaintiff, MONIUSZKO, a judgment against Defendant for compensatory damages.
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f. Grant judgment against Defendant for punitive damages for willful and wanton conduct. g. Enter an order requiring Defendant to implement effective steps to eliminate sex discrimination and sexual harassment from Defendant’s company. h. Grant such other and further relief as this Court deems just and proper. RESPECTFULLY SUBMITTED,
JURY DEMAND NOW COME Plaintiffs by their undersigned attorney, and demand a trial by jury in the above entitled cause of action. Uche Q. Asonye One of their Attorneys Uche O. Asonye - 06209522 Mark Pando - 6283683 Craig T. Papka - 6287051 ASONYE & ASSOCIATES 11 South LaSalle Street, Suite 2140 Chicago, Illinois 60603 (312)795-9110 (312) 795-9114 (Fax) RESPECTFULLY SUBMITTED, STACEY GRIFFIN, CARRIE BABB, JADA JOHNSON, NIKITA LOCKETT, and MONICA MONIUSZKO By Uche O. Asonye One of their Attorneys
End of Document
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 452 F.Supp.2d 842 (2006)
Stacey GRIFFIN, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszko, Plaintiffs, v.
SUTTON FORD, INC., Richard Muhammed, and Louis Minter, Defendants.
No. 06 C 931.
United States District Court, N.D. Illinois, Eastern Division.
September 15, 2006.
843*843 844*844 Uche O. Asonye, Asonye and Associates, Chicago, IL, for Plaintiffs.
Kimberly Anne Ross, Geoffrey Michael Waguespack, Cremer, Kopon, Shaughnessy & Spina, Jill A. Cheskes, Kimberly Ann Carpenter, O'Hagan, Smith & Amundsen, L.L.C., Chicago, IL, Gregory T. Mitchell, Law Office of Gregory T. Mitchell, P.C., Homewood, IL, for Defendants.
845*845 MEMORANDUM OPINION AND ORDER
BUCKLO, District Judge.
Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, and Monica Moniuszko bring multiple Title VII and state law claims against defendants Sutton Ford, Inc. ("Sutton Ford"), Richard Muhammed, and Louis Minter. Sutton Ford has filed three motions to dismiss: (i) Counts IV, IX, XVI, and XXI (Assault and Battery) and Counts V, XII, and XXII (Intentional Infliction of Emotional Distress) under Federal Rule of Civil Procedure 12(b)(1); (ii) Count XX (Lockett's retaliation claim) under Rule 12(b)(6); and (iii) Counts XXIII and XXIV (Moniuszko's hostile work environment and retaliation claims) under Rules 12(b)(1) and (6). All three of Sutton Ford's motions are addressed herein.
I. Legal Standard
In assessing defendants' 12(b)(1) and (6) motions to dismiss, I must accept all well-pleaded facts in plaintiffs' complaint as true. Moranski v. Gen. Motors Corp., 433 F.3d 537, 539 (7th Cir.2005); Johnson v. Apna Ghar, Inc., 330 F.3d 999, 1001 (7th Cir.2003) (citing Long v. Shorebank Dev. Corp., 182 F.3d 548, 554 (7th Cir.1999)). I must view the allegations in the light most favorable to the plaintiffs. Id. Dismissal under Rule 12(b)(6) is proper if the plaintiffs can prove no set of facts to support their claims. First Ins. Funding Corp. v. Fed. Ins. Co., 284 F.3d 799, 804 (7th Cir. 2002).
II. Counts IV, IX, XVI, and XXI (Assault and Battery) and Counts V, XII, and XXII
(Intentional Infliction of Emotional Distress)
Sutton Ford moves to dismiss these counts as preempted by the Illinois Human Rights Act ("IHRA"). 775 ILCS 5/8-111(C). Common law torts are not preempted by the IHRA unless they are "inextricably linked"

to the civil rights claim "such that there is no independent basis for the action apart from the Act itself." Maksimovic v. Tsogalis, 177 Ill.2d 511, 517, 227 Ill.Dec. 98, 687 N.E.2d 21, 23 (Ill.1997) cited in Naeem v. McKesson Drug Co., 444 F.3d 593, 602 (7th Cir.2006). Claims for assault, battery, and intentional infliction of emotional distress ("IIED") that rest solely on allegations of sexual harassment are preempted. See Quantock v. Shared Mktg. Servs. et al., 312 F.3d 899, 902, 905 (7th Cir.2002) (per curiam)(IIED claim preempted); Thomas v. L'Eggs Prods., Inc., 13 F.Supp.2d 806, 810 (C.D.Ill.1998) (battery claim preempted). "The distinction between claims that are preempted and claims that are not preempted turns on the legal duty that the defendant allegedly breached." Naeem, 444 F.3d at 604. The conduct at issue must be actionable independent of the IHRA. See, e.g., id. at 605 ("[plaintiff's] claim rests not just on behavior that is sexually harassing, but rather behavior that would be a tort no matter what the motives of the defendant").
Plaintiffs' state law claims against Sutton Ford are preempted by the IHRA. Illinois law dictates an employer is not liable for an employee's intentional torts, as these fall outside the scope of employment. Wright v. City of Danville, 174 Ill.2d 391, 404-05, 221 Ill.Dec. 203, 675 N.E.2d 110, 117-18 (Ill.1996); Lulay v. Parvin, 359 Ill.App.3d 653, 657, 296 Ill. Dec. 184, 834 N.E.2d 989, 993 (Ill.App.Ct. 2005). In this case, the sexual harassment provisions of the IHRA provide the duty that Sutton Ford is alleged to have breached. While Sutton Ford may have duties to 846*846 protect its employees, aside from those arising under the IHRA, see Young v. Lemons, 266 Ill.App.3d 49, 203 Ill.Dec. 290, 639 N.E.2d 610 (Ill.App.Ct.1994) ("the tort of negligent hiring [or supervision] is distinct from that of respondeat superior"), this complaint identifies none. In other words, the assault, battery and LIED claims arise solely as a result of a duty imposed under the IHRA; therefore, these are "inextricably linked." Maksimovic, 177 Ill.2d at 514, 227 Ill.Dec. 98, 687 N.E.2d at 22 (plaintiff was able to establish the necessary elements of each tort independent of any legal duties created by the IHRA when defendant restaurant was owned and operated by defendant tortfeasor). Accordingly, Sutton Ford's motion to dismiss Counts IV, V, IX, XII, XVI, XXI and XXII is granted.
III. Count XX
(Lockett's retaliation claim)
Defendant also moves to dismiss Lockett's retaliation claim for failure to exhaust administrative remedies through the filing of an EEOC charge specifically alleging retaliation. A plaintiff may bring a claim initially absent from her EEOC charge if: "(i) the claim is like or reasonably related to the EEOC charges, and (ii) the claim in the complaint could reasonably develop from the EEOC investigation into the original charges." Cheek v. Western & S. Life Ins. Co., 31 F.3d 497, 500 (7th Cir.1994). At a minimum, establishing a reasonable relationship requires that the two claims involve the same conduct and the same individuals. Id. at 501. In determining whether allegations are beyond the scope of the EEOC charge, courts construe the administrative allegations liberally. Babrocky v. Jewel Food Co., 773 F.2d 857, 864 (7th Cir.1985) (plaintiffs generally file charges with the EEOC pro se and cannot be expected to identify all possible legal theories and causes of action).
Lockett did not check the box on her EEOC charge indicating a retaliation claim. Her EEOC charge, attached as Exhibit 4 to the complaint, states in full:
I began my employment with Respondent most recently in April 2005, and my most recent position was Sales Representative. From the beginning of my employment, I and other women were subjected to sexual harassment from co-workers and management I repeatedly rejected this behavior and complained to management, but nothing was done. In addition, Respondent threw away my personal belongings.
Count XX of the complaint further alleges "Defendant confiscated and or converted her personal belongings from her desk," (Compl. § 196) and that "similarly situated employees who did not complain about sexual harassment were not subjected to such treatment." (Id. at § 197.)

Lockett's retaliation claim is reasonably related to the allegations in her EEOC charge. Read in the light most favorable to the plaintiff, Lockett's allegations establish a reasonable factual relationship among her claims. See Jenkins v. Blue Cross Mut. Hosp. Ins., Inc., 538 F.2d 164, 168 (7th Cir.1976) (requiring only that plaintiff, in layman's terms, state to the EEOC the "unfair thing that happened"). First, the complaint identifies a potential causal connection among the events described: her "complain[t] to management" triggered a retaliation in the form of conversion. Second, the complaint does not allege involvement of any unknown parties, instead identifying "management" and Sutton Ford and the alleged culprits.
Moreover, Lockett's claim could also have reasonably developed from the EEOC investigation. See Cheek, 31 F.3d 847*847 at 500 (second part of test "is difficult to apply because it requires speculation"). This claim does not involve different parties as those already identified in the charge, nor does it require additional investigation of the existing parties, as the EEOC was already aware of the incident as described in the charge. Accordingly, defendant's motion to dismiss Count XX is denied.
IV. Counts XXIII and XXIV
(Moniuszko's hostile work environment and retaliation claims)
Finally, Sutton Ford moves to dismiss both of Moniuszko's claims as time-barred. In Illinois, a complainant must file a charge with the EEOC or the appropriate state agency within 300 days of the alleged discriminatory act. 42 U.S.C. § 2000e-5. Failure to do so renders the charge untimely. Filipovic v. K & R Express Sys., Inc., 176 F.3d 390, 396 (7th Cir.1999). Thus, Moniuszko must allege that the hostile work environment (Count XXIII) and retaliatory termination (Count XXIV) occurred 300 days prior to January 12, 2005, the date of Ming of Moniuszko's EEOC charge, attached to the complaint as Exhibit 5. The complaint does not contain such allegations, however, instead dating the conduct in question from March through May in 2003. (Compl. §§ 213-17, 222). These claims, therefore, are time-barred.
Moniuszko argues the single-filing rule revives her claims, by allowing her to piggyback her suit to those of other plaintiffs who filed timely charges. Anderson v. Montgomery Ward & Co., 852 F.2d 1008, 1013 (7th Cir.1988). Under the single-filing rule, a plaintiff may be exempt from filing an EEOC charge if her claim "arises out of the same unlawful conduct" as those of other plaintiffs with timely filed charges. Horton v. Jackson County Bd. of County Comm'rs, 343 F.3d 897, 900 (7th Cir.2003). However, the single-filing doctrine cannot revive a stale claim. The rule is "inapposite to time-barred claims [of former employees]" because employers are not on notice or afforded "an opportunity to conciliate[ ] the claims of long departed employees." EEOC v. Harvey L. Walner & Assoc., No. 95-1355, 1995 WL 470233, *4, 1995 U.S. Dist. LEXIS 11239 (N.D.Ill. Aug.7, 1995); see also Movement for Opportunity & Equal. v. Gen. Motors Corp., 622 F.2d 1235, 1248 (7th Cir.1980); EEOC v. J.D. Streett & Co. Inc., No. 05CV4186JPG, 2006 WL 839444, at *2 (S.D.Ill. Mar. 29, 2006); Woodard v. Tower Auto Prods. Co., Inc., 00050459, 2002 WL 31254659, at *2, 2002 U.S. Dist. Lexis 19404, at *6 (N.D.Ill. Oct. 8, 2002). Even in class actions, identified in Horton as the context for the most liberal application of the single-filing rule, 343 F.3d at 900, "only those [class members] who could have Med a charge at or after the time a charge was filed by the class representative can be included in the class." Movement for Opportunity & Equal., 622 F.2d at 1248.
Here, the only other plaintiff who was employed by Sutton Ford during any period of Moniuszko's employment is Griffin. Griffin was employed from November 2002 through October 2004. She filed her EEOC charge on November 29, 2004; Moniuszko's termination had taken place well over a year prior. Thus, the single-filing doctrine does not revive Moniuszko's claims. Accordingly, Counts XXIII and XXIV are dismissed.

V. Conclusion
For the foregoing reasons, defendant's motions to dismiss Counts IV, V, IX, XII, XVI, XXI, XXIII and XXIV are granted. Defendant's motion to dismiss Count XX is denied.

 
 Case: 1:06-cv-931 As of: 07/31/2010 12:32 PM CDT 1 of 13
ASHMAN
United States District Court Northern District of Illinois − CM/ECF LIVE, Ver 4.0.3 (Chicago)
CIVIL DOCKET FOR CASE #: 1:06−cv−00931

Griffin et al v. Sutton Ford, Inc. et al Assigned to: Honorable Martin C. Ashman Cause: 42:1981 Job Discrimination (Race) Plaintiff Stacey Griffin
Plaintiff Carrie Babb
Plaintiff Jada Johnson
Plaintiff Louis Moniuszko TERMINATED: 05/31/2006
Plaintiff Nikita Lockett
Plaintiff Monica Moniuszko

Date Filed: 02/21/2006 Date Terminated: 10/31/2006 Jury Demand: Both Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: Federal Question
represented by Uche O. Asonye Asonye and Associates 39 S. LaSalle St. Suite 815 Chicago, IL 60603 (312) 795−9110 Email: courtfilings@aa−law.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Uche O. Asonye (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Uche O. Asonye (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Uche O. Asonye (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Uche O. Asonye (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Defendant Sutton Ford, Inc.

represented by James L. Singleton Greene &Letts 111 W. Washington Suite 1650 Chicago, IL 60602 (312) 346−1100 Email: jsingleton@greeneandletts.com

Case: 1:06-cv-931 As of: 07/31/2010 12:32 PM CDT 2 of 13

LEAD ATTORNEY ATTORNEY TO BE NOTICED

Kevin Thomas Lee Greene &Letts 111 West Washington Suite 1650 Chicago, IL 60602 (312) 346−1100 Fax: 312 346−4571 Email: ktlee@greeneandletts.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Kimberly Anne Ross Cremer, Kopon, Shaughnessy &Spina 180 North LaSalle Street Suite 3300 Chicago, IL 60601 (312) 726−3800 Email: kross@cksslaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Martin Peter Greene Greene &Letts 111 West Washington Suite 1650 Chicago, IL 60602 (312) 346−1100 Email: mpgreene@greeneandletts.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Geoffrey Michael Waguespack Cremer Kopon Shaughnessy &Spina 180 N. LaSalle St. Suite 3300 Chicago, IL 60601 (312) 726−3800 Fax: (312) 726−3818 Email: gwaguespack@cksslaw.com ATTORNEY TO BE NOTICED

Gregory T. Mitchell Law Office of Gregory T. Mitchell, P.C. 18141 Dixie Highway Suite 111 Homewood, IL 60430 (708)799−9325 Email: mitchlaw00@comcast.net ATTORNEY TO BE NOTICED

Defendant Richard Mohammed

represented by Jill A. Cheskes O'Hagan, Smith &Amundsen, L.L.C. 150 North Michigan Avenue Suite 3300 Chicago, IL 60601 (312) 894−3200 Email: jpignotti−cheskes@osalaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Case: 1:06-cv-931 As of: 07/31/2010 12:32 PM CDT 3 of 13

Kimberly Ann Carpenter CNA Insurance Companies CNA Plaza 333 S Wabash Suite 39S Chicago, Il 60647 Email: kcarpenter@osalaw.com ATTORNEY TO BE NOTICED

Lawrence Redmond Smith SmithAmundsen LLC 150 North Michigan Avenue Suite 3300 Chicago, IL 60601 (312) 894−3200 Email: lsmith@salawus.com ATTORNEY TO BE NOTICED

Defendant Louis Mentor

represented by Jill A. Cheskes (See above for address) LEAD ATTORNEY

Kimberly Ann Carpenter (See above for address) ATTORNEY TO BE NOTICED

Lawrence Redmond Smith (See above for address) ATTORNEY TO BE NOTICED

Date Filed 02/21/2006 02/21/2006 02/21/2006 03/27/2006
03/30/2006
03/30/2006 03/30/2006 03/30/2006 03/30/2006 04/20/2006

# Docket Text
1 COMPLAINT filed by Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Louis Moniuszko; Jury Demand (Exhibits).(ar, ) (Entered: 02/22/2006)
2 CIVIL Cover Sheet (ar, ) (Entered: 02/22/2006)
3 ATTORNEY Appearance for Plaintiffs by Uche O. Asonye (ar, ) (Entered: 02/22/2006)
5 MINUTE entry before Judge Elaine E. Bucklo :An initial pretrial conference is set in this case for 5/11/06 at 9:00 a.m. At least three days prior to the conference, the parties shall meet and submit to the court a Report of Parties' Planning Meeting in the form found on this court's web site. Mailed notice (mpj, ) (Entered: 03/27/2006)
6 FIRST AMENDED complaint by Stacey Griffin, Carrie Babb, Jada Johnson, Louis Moniuszko against all defendants (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5)(Asonye, Uche) (Entered: 03/30/2006)
7 ATTORNEY Appearance for Defendant Sutton Ford, Inc. by Kimberly Anne Ross (Ross, Kimberly) (Entered: 03/30/2006)
8 NOTICE by Sutton Ford, Inc. re attorney appearance 7 (Ross, Kimberly) (Entered: 03/30/2006)
9 ATTORNEY Appearance for Defendant Sutton Ford, Inc. by Geoffrey Michael Waguespack (Waguespack, Geoffrey) (Entered: 03/30/2006)
10 NOTICE by Sutton Ford, Inc. re attorney appearance 9 (Waguespack, Geoffrey) (Entered: 03/30/2006)
11 MOTION by Defendant Sutton Ford, Inc. to strike Plaintiffs' First Amended Complaint Under Rule 12(f) for Failure to Comply with Rule 8 (Ross, Kimberly) (Entered: 04/20/2006)

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04/20/2006 04/20/2006 04/20/2006
04/27/2006
04/28/2006 04/28/2006 05/01/2006 05/01/2006 05/01/2006 05/01/2006 05/03/2006
05/09/2006 05/09/2006 05/11/2006 05/15/2006
05/17/2006 05/31/2006

12 MEMORANDUM by Sutton Ford, Inc. in Support of motion to strike 11 Plaintiffs' First Amended Complaint Under Rule 12(f) for Failure to Comply with Rule 8 (Attachments: # 1 Exhibit Exhibit A)(Ross, Kimberly) (Entered: 04/20/2006)
13 NOTICE of Motion by Kimberly Anne Ross for presentment of motion to strike 11 before Honorable Elaine E. Bucklo on 4/27/2006 at 09:15 AM. (Ross, Kimberly) (Entered: 04/20/2006)
14 NOTICE by Sutton Ford, Inc. re MOTION by Defendant Sutton Ford, Inc. to strike Plaintiffs' First Amended Complaint Under Rule 12(f) for Failure to Comply with Rule 8 11 , memorandum in support of motion 12 , notice of motion 13 (Ross, Kimberly) (Entered: 04/20/2006)
15 MINUTE entry before Judge Elaine E. Bucklo : Motion hearing held on 4/27/2006 regarding defendant Ford's motion to strike 11 amended complaint heard. Responses to that motion due by 5/18/2006. Replies due by 5/23/2006. Ruling set for 6/2/2006 at 09:45 AM. Initial pretrial conferene set for 5/11/06 is also continued to 6/2/06. Counsel to note that the ruling date set in court is now changed. Individual defendants' oral motion to join in the motion to strike is granted. Mailed notice (mpj, ) (Entered: 04/27/2006)
16 ATTORNEY Appearance for Defendant Louis Mentor by Jill A. Cheskes (Cheskes, Jill) (Blank Appearance Form Attached) Modified on 5/1/2006 (gma, ). (Entered: 04/28/2006)
17 MINUTE entry before Judge Elaine E. Bucklo : Pursuant to parties' request, initial pretrial conference and ruling on the motion to strike set for 6/2/06 are reset for 6/9/2006 at 09:45 AM. Mailed notice (mpj, ) (Entered: 04/28/2006)
18 NOTICE of Correction regarding attorney appearance 16 (Blank PDF Form Attached) (gma, ) (Entered: 05/01/2006)
19 ATTORNEY Appearance for Defendant Louis Mentor by Jill A. Cheskes (Cheskes, Jill) (Entered: 05/01/2006)
20 MOTION by Defendant Louis Mentor to strike complaint 1 (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4)(Cheskes, Jill) (Entered: 05/01/2006)
21 NOTICE by Louis Mentor re MOTION by Defendant Louis Mentor to strike complaint 1 20 (Cheskes, Jill) (Entered: 05/01/2006)
22 MINUTE entry before Judge Elaine E. Bucklo : Set deadlines/hearing as to defendant, Luis Mintor's motion to strike 20 : Responses due by 5/18/2006. Replies due by 5/23/2006. Ruling set for 6/9/2006 at 09:45 AM. Mailed notice (mpj, ) (Entered: 05/03/2006)
23 MOTION by Plaintiff Stacey Griffin for leave to file Plaintiffs' Second Amended Complaint (Attachments: # 1 Exhibit 1)(Asonye, Uche) (Entered: 05/09/2006)
24 NOTICE of Motion by Uche O. Asonye for presentment of motion for leave to file 23 before Honorable Elaine E. Bucklo on 5/15/2006 at 09:15 AM. (Asonye, Uche) (Entered: 05/09/2006)
25 ATTORNEY Appearance for Defendant Richard Mohammed by Jill A. Cheskes (Cheskes, Jill) (Entered: 05/11/2006)
26 MINUTE entry before Judge Elaine E. Bucklo : Plaintiffs' motion for leave to file their second amended complaint is granted 23 . Plaintiffs' second amended complaint to be filed by 05/31/06. Defendants have to and including 06/16/06 in which to answer or otherwise plead to the amended complaint. Status hearing set for 7/7/2006 at 09:00 AM. (ar, ) (Entered: 05/16/2006)
27 MINUTE entry before Judge Elaine E. Bucklo : The status hearing previously scheduled for 6/9/2006 is stricken. Mailed notice (slb, ) (Entered: 05/17/2006)
28 Second AMENDED complaint by Stacey Griffin, Carrie Babb, Jada Johnson, Louis Moniuszko against all defendants (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5)(Asonye, Uche) (Entered: 05/31/2006)

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06/01/2006 06/06/2006 06/07/2006 06/07/2006 06/07/2006 06/08/2006 06/08/2006 06/08/2006 06/08/2006
06/12/2006 06/12/2006 06/13/2006 06/13/2006
06/13/2006 06/13/2006
06/13/2006 06/13/2006

29 ATTORNEY Appearance for Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Louis Moniuszko by Uche O. Asonye (Asonye, Uche) (Entered: 06/01/2006)
30 MINUTE entry before Judge Elaine E. Bucklo : Defendants' motions to strike 11 and 20 set for ruling on 6/9/06 are denied as moot. Mailed notice (mpj, ) (Entered: 06/06/2006)
31 MINUTE entry before Judge Elaine E. Bucklo : Ruling on motions to strike set for 6/9/06 is vacated and ruling will be made by mail. Mailed notice (mpj, ) (Entered: 06/07/2006)
32 MINUTE entry before Judge Elaine E. Bucklo : The order order entered in error, docket entry # 31, is vacated. No notice (mpj, ) (Entered: 06/07/2006)
33 TRANSCRIPT of proceedings for the following dates: 05/15/06 before the Honorable Elaine E. Bucklo (ar, ) (Entered: 06/08/2006)
34 MOTION by Defendant Sutton Ford, Inc. to strike Plaintiffs' second amended complaint under Rule 12(f) for failure to comply with Rule 8 (Ross, Kimberly) (Entered: 06/08/2006)
35 MEMORANDUM by Sutton Ford, Inc. of law in support of motion to strike plaintiffs' second amended complaint (Attachments: # 1 Exhibit 1# 2 # 3 # 4)(Ross, Kimberly) (Entered: 06/08/2006)
36 Notice of Motion NOTICE of Motion by Kimberly Anne Ross for presentment of motion to strike 34 before Honorable Elaine E. Bucklo on 6/14/2006 at 09:15 AM. (Ross, Kimberly) (Entered: 06/08/2006)
37 NOTICE by Sutton Ford, Inc. re MOTION by Defendant Sutton Ford, Inc. to strike Plaintiffs' second amended complaint under Rule 12(f) for failure to comply with Rule 8 34 , notice of motion 36 , memorandum 35 notice of filing (Ross, Kimberly) (Entered: 06/08/2006)
38 MOTION by Defendants Richard Mohammed, Louis Mentor to strike amended complaint 28 (Attachments: # 1 Exhibit 1)(Cheskes, Jill) (Entered: 06/12/2006)
39 NOTICE by Richard Mohammed, Louis Mentor re MOTION by Defendants Richard Mohammed, Louis Mentor to strike amended complaint 28 38 (Cheskes, Jill) (Entered: 06/12/2006)
40 NOTICE of Motion by Jill A. Cheskes for presentment of motion to strike, motion for relief 38 before Honorable Elaine E. Bucklo on 6/19/2006 at 09:15 AM. (Cheskes, Jill) (Entered: 06/13/2006)
41 MOTION by Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszko to Set An FRCP 16/26(f) Conference and Discovery Plan (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit A)(Asonye, Uche) (Entered: 06/13/2006)
42 NOTICE of Motion by Uche O. Asonye for presentment of motion for miscellaneous relief, 41 before Honorable Elaine E. Bucklo on 6/15/2006 at 09:15 AM. (Asonye, Uche) (Entered: 06/13/2006)
43 MINUTE entry before Judge Elaine E. Bucklo : Defendants' motions to strike 34 and 38 plaintiffs' second amended complaint are denied. Fact discovery ordered closed by 11/24/2006. Status hearing set for 7/7/07 is reset for 12/7/2006 at 09:15 AM. Mailed notice (mpj, ) Modified on 6/14/2006 (mpj, ). Modified on 7/5/2006 (mpj, ). (Entered: 06/13/2006)
44 MINUTE entry before Judge Elaine E. Bucklo : Plaintiffs' motion 41 to set FRCP 16/26 (f) conference and discovery plan is withdrawn. No notice (mpj, ) (Entered: 06/13/2006)
45 MOTION by Defendant Sutton Ford, Inc. for extension of time to file answer Defendant Sutton Ford, Inc.'s Emergency Motion for Extension of time to answer second amended complaint or to otherwise plead (Ross, Kimberly) (Entered: 06/13/2006)

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06/13/2006
06/13/2006
06/14/2006 06/23/2006
06/23/2006 06/23/2006
06/26/2006
06/28/2006 06/28/2006
07/19/2006 07/21/2006 07/21/2006 07/21/2006 07/21/2006 07/21/2006 07/21/2006 07/21/2006

46 Notice of Emergency Motion NOTICE of Motion by Kimberly Anne Ross for presentment of motion for extension of time to file answer 45 before Honorable Elaine E. Bucklo on 6/15/2006 at 09:15 AM. (Ross, Kimberly) (Entered: 06/13/2006)
47 NOTICE by Sutton Ford, Inc. re MOTION by Defendant Sutton Ford, Inc. for extension of time to file answer Defendant Sutton Ford, Inc.'s Emergency Motion for Extension of time to answer second amended complaint or to otherwise plead 45 , notice of motion 46 Notice of Electronic Filing (Ross, Kimberly) (Entered: 06/13/2006)
48 MINUTE entry before Judge Elaine E. Bucklo : Moving defendant's emergency motion for extension of time until 7/21/06 to answer or otherwise plead 45 is granted. Mailed notice (mpj, ) (Entered: 06/14/2006)
49 MOTION by Defendant Sutton Ford, Inc. to strike Plaintiffs' Interrogatories, Production Requests, and Requests to Admit Facts, or in the alternative to extend time for answering the same (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7# 8 Exhibit 8# 9 Exhibit 9)(Waguespack, Geoffrey) (Entered: 06/23/2006)
50 Notice of Motion NOTICE of Motion by Geoffrey Michael Waguespack for presentment of motion to strike, 49 before Honorable Elaine E. Bucklo on 6/28/2006 at 09:15 AM. (Waguespack, Geoffrey) (Entered: 06/23/2006)
51 NOTICE by Sutton Ford, Inc. re notice of motion 50 , MOTION by Defendant Sutton Ford, Inc. to strike Plaintiffs' Interrogatories, Production Requests, and Requests to Admit Facts, or in the alternative to extend time for answering the same 49 Notice of Electronic Filing (Waguespack, Geoffrey) (Entered: 06/23/2006)
52 RESPONSE by Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszko to MOTION by Defendant Sutton Ford, Inc. to strike Plaintiffs' Interrogatories, Production Requests, and Requests to Admit Facts, or in the alternative to extend time for answering the same 49 (Attachments: # 1 Exhibit A# 2 Exhibit B)(Asonye, Uche) (Entered: 06/26/2006)
53 ATTORNEY Appearance for Defendants Richard Mohammed, Louis Mentor by Kimberly Ann Carpenter (Carpenter, Kimberly) (Entered: 06/28/2006)
54 MINUTE entry before Judge Elaine E. Bucklo : Defendants' motion to strike 49 plaintiffs' discovery requests heard and the motion is denied. However, defendants have until 8/1/06 to respond to plaintiffs' outstanding discovery requests. Mailed notice (mpj, ) (Entered: 06/28/2006)
55 ATTORNEY Appearance for Defendant Sutton Ford, Inc. by Gregory T. Mitchell (ar, ) (Entered: 07/21/2006)
MAILED Rule 83.17 letter to Gregory T. Mitchell (ar, ) (Entered: 07/21/2006)
56 Defendant Sutton Ford, Inc's Rule 7.1 Disclosure Statement by Sutton Ford, Inc. (Ross, Kimberly) (Entered: 07/21/2006)
57 NOTICE by Sutton Ford, Inc. re other 56 (Ross, Kimberly) (Entered: 07/21/2006)
58 Answer and Affirmative Defenses to Plaintiff's Second Amended Complaint ANSWER to amended complaint by Sutton Ford, Inc.(Ross, Kimberly) (Entered: 07/21/2006)
59 NOTICE by Sutton Ford, Inc. re answer to amended complaint 58 (Ross, Kimberly) (Entered: 07/21/2006)
60 MOTION by Defendant Sutton Ford, Inc. to dismiss Assault and Battery Counts IV, IX, XVI, and XXI and Intentional Infliction of Emotional Distress Counts V, XII, XVII and XXII Under Rule 12(b)(1) (Ross, Kimberly) (Entered: 07/21/2006)
61 MOTION by Defendant Sutton Ford, Inc. to dismiss Plaintiff Nikita Lockett's Retaliation Count XX Under Rule 12(b)(6) (Ross, Kimberly) (Entered: 07/21/2006)

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07/21/2006 07/21/2006 07/21/2006 07/21/2006 07/21/2006 07/21/2006
07/26/2006 07/26/2006 07/26/2006 07/26/2006 07/27/2006 08/03/2006
08/03/2006
08/04/2006
08/16/2006

62 MOTION by Defendant Sutton Ford, Inc. to dismiss Counts XXIII and XXIV of Plaintiff's Second Amended Complaint (Ross, Kimberly) (Entered: 07/21/2006)
63 MEMORANDUM by Sutton Ford, Inc. in Support of motion to dismiss 60 (Ross, Kimberly) (Entered: 07/21/2006)
64 MEMORANDUM by Sutton Ford, Inc. in Support of motion to dismiss 61 (Ross, Kimberly) (Entered: 07/21/2006)
65 MEMORANDUM by Sutton Ford, Inc. in Support of motion to dismiss 62 (Ross, Kimberly) (Entered: 07/21/2006)
66 NOTICE of Motion by Kimberly Anne Ross for presentment of motion to dismiss 62 , motion to dismiss 60 , motion to dismiss 61 before Honorable Elaine E. Bucklo on 7/27/2006 at 09:15 AM. (Ross, Kimberly) (Entered: 07/21/2006)
67 NOTICE by Sutton Ford, Inc. re MOTION by Defendant Sutton Ford, Inc. to dismiss Plaintiff Nikita Lockett's Retaliation Count XX Under Rule 12(b)(6) 61 , memorandum in support of motion 64 , MOTION by Defendant Sutton Ford, Inc. to dismiss Counts XXIII and XXIV of Plaintiff's Second Amended Complaint 62 , notice of motion 66 , memorandum in support of motion 63 , memorandum in support of motion 65 , MOTION by Defendant Sutton Ford, Inc. to dismiss Assault and Battery Counts IV, IX, XVI, and XXI and Intentional Infliction of Emotional Distress Counts V, XII, XVII and XXII Under Rule 12(b)(1) 60 (Ross, Kimberly) (Entered: 07/21/2006)
68 ANSWER to amended complaint (Answer and Affirmative Defenses to Second Amended Complaint by Louis Mentor(Cheskes, Jill) (Entered: 07/26/2006)
69 NOTICE by Louis Mentor re answer to amended complaint 68 (Notice of Filing re: Answer and Affirmative Defenses to Second Amended Complaint) (Cheskes, Jill) (Entered: 07/26/2006)
70 ANSWER to amended complaint (Answer and Affirmative Defenses to Second Amended Complaint) by Richard Mohammed(Cheskes, Jill) (Entered: 07/26/2006)
71 NOTICE by Richard Mohammed re complaint 1 , answer to amended complaint 70 (Notice of Filing re: Answer and Affirmative Defenses to Second Amended Complaint) (Cheskes, Jill) (Entered: 07/26/2006)
72 MINUTE entry before Judge Elaine E. Bucklo : Set deadlines/hearing as to motion to dismiss 62 , motion to dismiss 60 , motion to dismiss 61 : Responses due by 8/4/2006. Replies due by 8/16/2006. Target date for ruling by mail set for 9/15/06. Mailed notice (mpj, ) (Entered: 07/27/2006)
73 RESPONSE by Nikita Lockett in Opposition to MOTION by Defendant Sutton Ford, Inc. to dismiss Plaintiff Nikita Lockett's Retaliation Count XX Under Rule 12(b)(6) 61 (Attachments: # 1 Exhibit Plaintiff's Exhibit A# 2 Supplement Case Law− Caratachea v. Homewood Industries# 3 Supplement Case Law− Jones v. City of Chicago# 4 Supplement Case Law− Mitchell v. Elkay Mfg)(Asonye, Uche) (Entered: 08/03/2006)
74 RESPONSE by Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszko in Opposition to MOTION by Defendant Sutton Ford, Inc. to dismiss Assault and Battery Counts IV, IX, XVI, and XXI and Intentional Infliction of Emotional Distress Counts V, XII, XVII and XXII Under Rule 12(b)(1) 60 (Attachments: # 1 Exhibit Exhibit 1# 2 Exhibit Exhibit 2# 3 Exhibit Exhibit 3# 4 Exhibit Exhibit 4)(Asonye, Uche) (Entered: 08/03/2006)
75 RESPONSE by Monica Moniuszko in Opposition to MOTION by Defendant Sutton Ford, Inc. to dismiss Counts XXIII and XXIV of Plaintiff's Second Amended Complaint 62 (Attachments: # 1 Exhibit 1# 2 Supplement Case Law − Toney v Rosewood# 3 Supplement Case Law − EEOC v Rymer Foods)(Asonye, Uche) (Entered: 08/04/2006)
76 RESPONSE by Sutton Ford, Inc.in Support of MOTION by Defendant Sutton Ford, Inc. to dismiss Plaintiff Nikita Lockett's Retaliation Count XX Under Rule 12(b)(6) 61 (Ross, Kimberly) (Entered: 08/16/2006)

Case: 1:06-cv-931 As of: 07/31/2010 12:32 PM CDT 8 of 13

08/16/2006 08/16/2006 08/16/2006 08/21/2006
08/21/2006 08/22/2006 08/22/2006 08/22/2006 08/23/2006 08/23/2006 08/29/2006 08/29/2006 08/29/2006 08/29/2006
08/29/2006 08/30/2006

77 RESPONSE by Sutton Ford, Inc.in Support of MOTION by Defendant Sutton Ford, Inc. to dismiss Counts XXIII and XXIV of Plaintiff's Second Amended Complaint 62 (Ross, Kimberly) (Entered: 08/16/2006)
78 RESPONSE by Sutton Ford, Inc.in Support of MOTION by Defendant Sutton Ford, Inc. to dismiss Assault and Battery Counts IV, IX, XVI, and XXI and Intentional Infliction of Emotional Distress Counts V, XII, XVII and XXII Under Rule 12(b)(1) 60 (Ross, Kimberly) (Entered: 08/16/2006)
79 NOTICE by Sutton Ford, Inc. re response in support of motion, 78 , response in support of motion 76 , response in support of motion 77 (Ross, Kimberly) (Entered: 08/16/2006)
80 MOTION by Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszko to compel production of personnel files of alleged harassers and the identities of employees charged with harassment and their victims (Attachments: # 1 Exhibit 1# 2 Exhibit 1A# 3 Exhibit 1B# 4 Exhibit 1C# 5 Exhibit 2# 6 Exhibit 3# 7 Exhibit 4# 8 Exhibit 5# 9 Exhibit 6# 10 Supplement Case Law# 11 Supplement Case Law# 12 Supplement Case Law# 13 Supplement Case Law# 14 Supplement Case Law# 15 Supplement Case Law)(Asonye, Uche) (Entered: 08/21/2006)
81 NOTICE of Motion by Uche O. Asonye for presentment of motion to compel,, 80 before Honorable Elaine E. Bucklo on 9/5/2006 at 09:15 AM. (Asonye, Uche) (Entered: 08/21/2006)
82 MOTION by Defendant Sutton Ford, Inc. to sever Plaintiffs Griffin, Babb, Johnson, Lockett and Moniuszko pursuant to Fed.R.Civ. P. 21 (Mitchell, Gregory) (Entered: 08/22/2006)
83 NOTICE of Motion by Gregory T. Mitchell for presentment of motion to sever 82 before Honorable Elaine E. Bucklo on 9/8/2006 at 09:30 AM. (Mitchell, Gregory) (Entered: 08/22/2006)
84 CERTIFICATE by Sutton Ford, Inc. of Service (Mitchell, Gregory) (Entered: 08/22/2006)
85 Re− NOTICE of Motion by Gregory T. Mitchell for presentment of motion to sever 82 before Honorable Elaine E. Bucklo on 9/5/2006 at 09:15 AM. (Mitchell, Gregory) (Entered: 08/23/2006)
86 CERTIFICATE by Sutton Ford, Inc. of Service of Re−Notice of Motion for September 5, 2006 at 9:15 am (Mitchell, Gregory) (Entered: 08/23/2006)
87 MINUTE entry before Judge Elaine E. Bucklo : Defendant's motion to 82 sever named plaintiffs is denied. Mailed notice (mpj, ) (Entered: 08/29/2006)
88 RESPONSE by Sutton Ford, Inc. to MOTION by Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszko to compel production of personnel files of alleged harassers and the identities of employees charged with harassment and their victims 80 (Ross, Kimberly) (Entered: 08/29/2006)
89 NOTICE by Sutton Ford, Inc. re response to motion, 88 (Ross, Kimberly) (Entered: 08/29/2006)
90 MOTION by Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszko to determine the sufficiency of Defendant Sutton Ford's responses to admit facts related to the discipline of employee sexual harassers (Attachments: # 1 Exhibit Exhibit 1# 2 Exhibit Exhibit 2# 3 Exhibit Exhibit 3# 4 Exhibit Exhibit 4# 5 Exhibit Exhibit 5# 6 Exhibit Exhibit 6# 7 Supplement Case Law)(Asonye, Uche) (Entered: 08/29/2006)
91 NOTICE of Motion by Uche O. Asonye for presentment of motion for miscellaneous relief, 90 before Honorable Elaine E. Bucklo on 9/5/2006 at 09:15 AM. (Asonye, Uche) (Entered: 08/29/2006)
92 MOTION by Defendant Sutton Ford, Inc. to compel Plaintiffs' Answers to Interrogatories (Ross, Kimberly) (Entered: 08/30/2006)

Case: 1:06-cv-931 As of: 07/31/2010 12:32 PM CDT 9 of 13

08/30/2006 08/30/2006 08/30/2006 08/30/2006 08/30/2006 08/30/2006
08/30/2006 08/30/2006 08/31/2006
08/31/2006 08/31/2006 09/01/2006 09/01/2006
09/05/2006

93 EXHIBIT by Defendant Sutton Ford, Inc. regarding MOTION by Defendant Sutton Ford, Inc. to compel Plaintiffs' Answers to Interrogatories 92 (Attachments: # 1 Exhibit A# 2 # 3 # 4 # 5 # 6 # 7 # 8 # 9 # 10 # 11 # 12 # 13)(Ross, Kimberly) (Entered: 08/30/2006)
94 NOTICE of Motion by Kimberly Anne Ross for presentment of motion to compel 92 before Honorable Elaine E. Bucklo on 9/7/2006 at 09:15 AM. (Ross, Kimberly) (Entered: 08/30/2006)
95 NOTICE by Sutton Ford, Inc. re exhibit, 93 , MOTION by Defendant Sutton Ford, Inc. to compel Plaintiffs' Answers to Interrogatories 92 , notice of motion 94 (Ross, Kimberly) (Entered: 08/30/2006)
96 RESPONSE by Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszko to MOTION by Defendant Sutton Ford, Inc. to compel Plaintiffs' Answers to Interrogatories 92 (Attachments: # 1 Exhibit Exhibit 1# 2 Exhibit 2# 3 Exhibit 3)(Asonye, Uche) (Entered: 08/30/2006)
97 MOTION by Defendants Sutton Ford, Inc., Richard Mohammed, Louis Mentor for extension of time to Depose Plaintiffs (Ross, Kimberly) (Entered: 08/30/2006)
98 EXHIBIT by Defendants Sutton Ford, Inc., Richard Mohammed, Louis Mentor regarding MOTION by Defendants Sutton Ford, Inc., Richard Mohammed, Louis Mentor for extension of time to Depose Plaintiffs 97 (Attachments: # 1 # 2 Exhibit A−1# 3 Exhibit A−2# 4 Exhibit B# 5 Exhibit C# 6 Exhibit D)(Ross, Kimberly) (Entered: 08/30/2006)
99 NOTICE of Motion by Kimberly Anne Ross for presentment of motion for extension of time 97 before Honorable Elaine E. Bucklo on 9/7/2006 at 09:15 AM. (Ross, Kimberly) (Entered: 08/30/2006)
100 NOTICE by Sutton Ford, Inc., Richard Mohammed, Louis Mentor re MOTION by Defendants Sutton Ford, Inc., Richard Mohammed, Louis Mentor for extension of time to Depose Plaintiffs 97 , exhibit, 98 , notice of motion 99 (Ross, Kimberly) (Entered: 08/30/2006)
101 RESPONSE by Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszko to MOTION by Defendants Sutton Ford, Inc., Richard Mohammed, Louis Mentor for extension of time to Depose Plaintiffs 97 (Attachments: # 1 Exhibit Exhibit 1# 2 Exhibit Exhibit 2# 3 Exhibit 3)(Asonye, Uche) (Entered: 08/31/2006)
102 RESPONSE by Sutton Ford, Inc. to MOTION by Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszko to determine the sufficiency of Defendant Sutton Ford's responses to admit facts related to the discipline of employee sexual harassers 90 (Ross, Kimberly) (Entered: 08/31/2006)
103 NOTICE by Sutton Ford, Inc. re response to motion, 102 (Ross, Kimberly) (Entered: 08/31/2006)
104 MINUTE entry before Judge Elaine E. Bucklo : Plaintiff's motion to compel 80 and plaintiff's motion to determine sufficiency of responses (90) set for hearing on 9/5/06 are entered and continued to 9/7/2006 at 09:15 AM. Mailed notice (mpj, ) (Entered: 09/01/2006)
105 REPLY by Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszkoin Support of MOTION by Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszko to compel production of personnel files of alleged harassers and the identities of employees charged with harassment and their victims 80 (Attachments: # 1 Exhibit 1A# 2 Exhibit 1B# 3 Exhibit 2# 4 Exhibit 3# 5 Exhibit 4# 6 Exhibit 5# 7 Exhibit 6# 8 Exhibit 7# 9 Exhibit 8# 10 Exhibit 9# 11 Supplement Case Law# 12 Supplement Case Law# 13 Supplement Case Law# 14 Supplement Case Law# 15 Supplement Case Law# 16 Supplement Case Law)(Asonye, Uche) (Entered: 09/01/2006)
106 RESPONSE by Sutton Ford, Inc.in Support of MOTION by Defendant Sutton Ford, Inc. to compel Plaintiffs' Answers to Interrogatories 92 (Ross, Kimberly) (Entered: 09/05/2006)

Case: 1:06-cv-931 As of: 07/31/2010 12:32 PM CDT 10 of 13

09/05/2006 09/05/2006 09/05/2006 09/05/2006 09/05/2006 09/07/2006
09/07/2006 09/07/2006 09/07/2006
09/08/2006 09/08/2006 09/12/2006
09/14/2006
09/14/2006

107 NOTICE by Sutton Ford, Inc. re response in support of motion 106 (Ross, Kimberly) (Entered: 09/05/2006)
108 RESPONSE by Sutton Ford, Inc.in Support of MOTION by Defendants Sutton Ford, Inc., Richard Mohammed, Louis Mentor for extension of time to Depose Plaintiffs 97 (Ross, Kimberly) (Entered: 09/05/2006)
109 NOTICE by Sutton Ford, Inc. re response in support of motion 108 (Ross, Kimberly) (Entered: 09/05/2006)
110 Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Magistrate Judge Martin C. Ashman for the purpose of holding proceedings related to discovery motions and supervision of discovery.(mpj, )Mailed notice. (Entered: 09/05/2006)
111 MINUTE entry before Judge Elaine E. Bucklo : Various motions set for hearing on 9/7/06 are referred to Magistrate Judge Ashman for resolution. This case is also referred to the Magistrate Judge for supervision of discovery. Mailed notice (mpj, ) (Entered: 09/05/2006)
112 MOTION by Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszko for protective order barring Defendant Sutton Ford from issuing subpoenas to Plaintiffs' current employers and Plaintiffs' employers subsequent to Defendant Sutton Ford (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Supplement Case Law# 5 Supplement Transcript# 6 Supplement Transcript)(Asonye, Uche) (Entered: 09/07/2006)
113 NOTICE of Motion by Uche O. Asonye for presentment of motion for protective order, 112 before Honorable Martin C. Ashman on 9/19/2006 at 10:30 AM. (Asonye, Uche) (Entered: 09/07/2006)
114 MINUTE entry before Judge Martin C. Ashman : Magistrate Judge Status hearing set for 9/18/2006 at 10:15 AM., in courtroom 1386. Mailed notice. (is, ) (Entered: 09/07/2006)
115 MINUTE entry before Judge Martin C. Ashman : Motion hearing on defendants' motion for extension of time to depose plaintiffs 97 , plaintiffs' motion to compel 80 , plaintiffs' motion to determine the sufficiency of defendant Sutton Ford's responses to admit facts related to the discipline of employee sexual harassers 90 , plaintiffs' motion for a protective order 112 and defendant Sutton Ford's motion to compel plaintiffs' answers to interrogatories 92 are set for 9/18/2006 at 10:15 AM. Mailed notice. (is, ) (Entered: 09/07/2006)
116 REPLY by Defendant Sutton Ford, Inc. to motion to compel,, 80 Surreply (Ross, Kimberly) (Entered: 09/08/2006)
117 NOTICE by Sutton Ford, Inc. re reply 116 Surreply to Stacey Griffin's Motion to Compel (Ross, Kimberly) (Entered: 09/08/2006)
118 REPLY by Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszkoin Support of MOTION by Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszko to determine the sufficiency of Defendant Sutton Ford's responses to admit facts related to the discipline of employee sexual harassers 90 (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Supplement Case Law# 4 Supplement Case Law)(Asonye, Uche) (Entered: 09/12/2006)
119 RESPONSE by Sutton Ford, Inc. to MOTION by Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszko for protective order barring Defendant Sutton Ford from issuing subpoenas to Plaintiffs' current employers and Plaintiffs' employers subsequent 112 (Ross, Kimberly) (Entered: 09/14/2006)
120 EXHIBIT by Defendant Sutton Ford, Inc. regarding response to motion, 119 (Attachments: # 1 Exhibit C Part 1# 2 Exhibit C Part 2# 3 Exhibit D−H)(Ross, Kimberly) (Entered: 09/14/2006)

Case: 1:06-cv-931 As of: 07/31/2010 12:32 PM CDT 11 of 13

09/14/2006
09/15/2006
09/15/2006 09/18/2006
09/25/2006
09/27/2006
09/27/2006 09/29/2006 09/29/2006 09/29/2006 09/29/2006 09/29/2006 09/29/2006 09/29/2006 09/29/2006 09/29/2006 09/29/2006

121 NOTICE by Sutton Ford, Inc. re response to motion, 119 Response to Plaintiff's Motion for Protective Order Barring It From Issuing Subpoenas to Plaintiffs' Current Employers and Plaintiffs' Employers Subsequent to Defendant Sutton Ford (Ross, Kimberly) (Entered: 09/14/2006)
123 MINUTE entry before Judge Elaine E. Bucklo : Defendant's motions to dismiss Counts IV, V, IX, XII, XVI, XXI, XXII, XXIII and XXIV 60 62 are granted. Defendant's motion to dismiss Count XX 61 is denied. Enter Memorandum Opinion and Order. (For further detail see separate order). (ar, ) (Entered: 09/19/2006)
124 MEMORANDUM Opinion and Order, signed by Judge Elaine E. Bucklo on 9/15/2006 123 .(ar, ) (Entered: 09/19/2006)
122 MINUTE entry before Judge Martin C. Ashman : Magistrate Judge Status hearing held on 9/18/2006. Settlement Conference set for 10/31/2006 at 02:00 PM., in chambers 1366. All clients and parties with full authority to settle are to be physically present. Failure to have parties with full authority to settle present may result in the imposition of severe sanctions. (For further details see standing order on the court's web site at www.ilnd.uscourts.gov.) Mailed notice. (is, ) (Entered: 09/18/2006)
125 MINUTE entry before Judge Elaine E. Bucklo :In response to counsel Kimberly Ross's letter to this court dated September 22, 2006, in which counsel notes that this court did not rule on the motion to dismiss count XVII against Sutton Ford, count XVII is dismissed against Sutton Ford for the reasons stated in the opinion dated September 19, 2006. Mailed notice (mpj, ) (Entered: 09/25/2006)
126 MOTION by Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica MoniuszkoFOR LEAVE TO FILE THIRD AMENDED COMPLAINT (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Supplement Case Law)(Asonye, Uche) (Entered: 09/27/2006)
127 Plaintiffs' NOTICE of Motion by Uche O. Asonye for presentment of motion for miscellaneous relief, 126 before Honorable Elaine E. Bucklo on 10/5/2006 at 09:15 AM. (Asonye, Uche) (Entered: 09/27/2006)
128 AMENDED Answer by Defendant Sutton Ford, Inc. to Plaintiffs' Second amended complaint 28 and Affirmative Defenses (Ross, Kimberly) (Entered: 09/29/2006)
129 NOTICE by Sutton Ford, Inc. re amended answer to complaint 128 Amended Answer and Affirmative Defenses Plaintiffs' Second Amended Complaint (Ross, Kimberly) (Entered: 09/29/2006)
130 RESPONSE by Sutton Ford, Inc. to MOTION by Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica MoniuszkoFOR LEAVE TO FILE THIRD AMENDED COMPLAINT 126 (Ross, Kimberly) (Entered: 09/29/2006)
131 EXHIBIT by Defendant Sutton Ford, Inc. Exhibit 1 regarding response to motion 130 (Ross, Kimberly) (Entered: 09/29/2006)
132 EXHIBIT by Defendant Sutton Ford, Inc. Exhibit 2 regarding response to motion 130 (Ross, Kimberly) (Entered: 09/29/2006)
133 EXHIBIT by Defendant Sutton Ford, Inc. Exhibit 3 regarding response to motion 130 (Ross, Kimberly) (Entered: 09/29/2006)
134 EXHIBIT by Defendant Sutton Ford, Inc. Exhibit 4 regarding response to motion 130 (Attachments: # 1 Exhibit 5)(Ross, Kimberly) (Entered: 09/29/2006)
135 NOTICE by Sutton Ford, Inc. re response to motion 130 Plaintiffs' Motion for Leave to File Third Amended Complaint (Ross, Kimberly) (Entered: 09/29/2006)
136 RESPONSE by Sutton Ford, Inc. to MOTION by Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica MoniuszkoFOR LEAVE TO FILE THIRD AMENDED COMPLAINT 126 (Ross, Kimberly) (Entered: 09/29/2006)
137 EXHIBIT by Defendant Sutton Ford, Inc. regarding response to motion 136 (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit

Case: 1:06-cv-931 As of: 07/31/2010 12:32 PM CDT 12 of 13

10/03/2006
10/03/2006 10/03/2006 10/03/2006 10/03/2006 10/03/2006 10/03/2006 10/04/2006 10/06/2006
10/06/2006
10/30/2006 10/31/2006 10/31/2006 10/31/2006
10/31/2006

5)(Ross, Kimberly) (Entered: 09/29/2006)
138 REPLY by Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica Moniuszkoin Support of MOTION by Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Nikita Lockett, Monica MoniuszkoFOR LEAVE TO FILE THIRD AMENDED COMPLAINT 126 (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Supplement Case Law# 4 Supplement Case Law)(Asonye, Uche) (Entered: 10/03/2006)
139 ATTORNEY Appearance for Defendant Sutton Ford, Inc. by Martin Peter Greene Notice of Appearance (Greene, Martin) (Entered: 10/03/2006)
140 ATTORNEY Appearance for Defendant Sutton Ford, Inc. by Kevin Thomas Lee Notice of Attorney Appearance (Lee, Kevin) (Entered: 10/03/2006)
141 ATTORNEY Appearance for Defendant Sutton Ford, Inc. by James L. Singleton Notice of Attorney Appearance (Singleton, James) (Entered: 10/03/2006)
142 MOTION by Defendant Sutton Ford, Inc. for leave to file Appearance as Additional Counsel (Greene, Martin) (Entered: 10/03/2006)
143 MOTION by Defendant Sutton Ford, Inc. for attorney fees and costs (Greene, Martin) (Entered: 10/03/2006)
144 NOTICE of Motion by Martin Peter Greene for presentment of motion for attorney fees 143 , motion for leave to file 142 before Honorable Elaine E. Bucklo on 10/12/2006 at 09:15 AM. (Greene, Martin) (Entered: 10/03/2006)
145 MINUTE entry before Judge Elaine E. Bucklo : Ruling on plaintiff's motion for leave to file third amended complaint will be made by mail. No appearance is needed on 10/5/06. No notice (mpj, ) (Entered: 10/04/2006)
146 MINUTE entry before Judge Elaine E. Bucklo : Defendant Sutton Ford, Inc.'s motion for leave to file 142 the additional appearance of Martin P. Greene, Kevin T. Lee and James Singleton is granted. Defendant, Sutton Ford, Inc.'s motion for attorney fees 143 and costs in the amount of $20,000.00 is also granted. Mailed notice (mpj, ) (Entered: 10/06/2006)
147 MINUTE entry before Judge Elaine E. Bucklo : The order entered today is amended only with respect to the granting of defendant's motion for attorney's fees and costs as follows: The order with respect to defendant's motion for fees and costs is vacated and the order is amended to read that defendant Sutton Ford's motion for leave to file memorandum of law in support of its motion for fees and costs is granted. Mailed notice (mpj, ) (Entered: 10/06/2006)
148 ATTORNEY Appearance for Defendants Richard Mohammed, Louis Mentor by Lawrence Redmond Smith (Smith, Lawrence) (Entered: 10/30/2006)
149 MINUTE entry before Judge Martin C. Ashman : Settlement conference held on 10/31/2006. Case settled. Consent filed. No notice. (is, ) (Entered: 11/01/2006)
150 MINUTE entry before Judge Martin C. Ashman : All matters relating to the referral of this action having been resolved, the case is returned to the assigned judge. Judge Martin C. Ashman no longer referred to the case. No notice. (is, ) (Entered: 11/01/2006)
152 MINUTE entry before Judge Martin C. Ashman : Enter agreed order of dismissal. It is hereby ordered: 1. The parties shall comply with the terms of their settlement agreement entered on 10/31/06, the terms of which settlement are incorporated herein by reference as if fully set forth. 2. By consent of the parties, the court shall retain jurisdiction for the purpose of enforcing the terms of the settlement agreement through 12/01/06. 3. Except as provided for in paragraphs one and two above, this case is dismissed, with prejudice, each party shall bear its own attorney's fees and costs. (For further detail see separate order). Civil case terminated. (ar, ) (Entered: 11/03/2006)
153 AGREED Order of Dismissal, signed by Judge Martin C. Ashman on 10/31/2006 152 .(ar, ) (Entered: 11/03/2006)

Case: 1:06-cv-931 As of: 07/31/2010 12:32 PM CDT 13 of 13

10/31/2006 11/02/2006 11/03/2006 11/28/2006
11/28/2006 11/29/2006
11/29/2006 11/30/2006
12/14/2006

154 JOINT CONSENT by Parties to Exercise of Jurisdiction by a United States Magistrate Judge. (td, ) (Entered: 11/07/2006)
151 MINUTE entry before Judge Elaine E. Bucklo : Parties having consented to the jurisdiction of a United States Magistrate Judge, this action is transferred to the Executive Committee for a reassignment to Judge Ashman. Status hearing set for 12/7/06 is vacated. Mailed notice (mpj, ) (Entered: 11/02/2006)
155 EXECUTIVE COMMITTEE ORDER: Case reassigned to Judge Martin C. Ashman for all further proceedings. Signed by Executive Committee on 11/3/2006. (td, ) (Entered: 11/07/2006)
156 MOTION by Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Nikita LockettPLAINTIFFS? EMERGENCY MOTION TO EXTEND THE COURT?S JURISDICTION, TO DIRECT DEFENDANTS TO COMPLETE NECESSARY DOCUMENTS BY DECEMBER 4, 2006, AND TO GRANT OTHER RELIEF TO PLAINTIFFS (Asonye, Uche) (Entered: 11/28/2006)
157 EMERGENCY NOTICE of Motion by Uche O. Asonye for presentment of motion for miscellaneous relief, 156 before Honorable Martin C. Ashman on 11/30/2006 at 10:30 AM. (Asonye, Uche) (Entered: 11/28/2006)
158 RESPONSE by Sutton Ford, Inc. to MOTION by Plaintiffs Stacey Griffin, Carrie Babb, Jada Johnson, Nikita LockettPLAINTIFFS? EMERGENCY MOTION TO EXTEND THE COURT?S JURISDICTION, TO DIRECT DEFENDANTS TO COMPLETE NECESSARY DOCUMENTS BY DECEMBER 4, 2006, AND TO GRANT OTHER RELIEF TO PLAINTI 156 (Ross, Kimberly) (Entered: 11/29/2006)
159 NOTICE by Sutton Ford, Inc. re response to motion, 158 (Ross, Kimberly) (Entered: 11/29/2006)
160 MINUTE entry before Judge Martin C. Ashman : Oral arugment held on 11/30/2006 regarding motion for miscellaneous relief 156 . Plaintiffs' emergency motion to extend the court's jurisdiction 156 is granted. The court's jurisdiction is extended to 12/15/2006. Status hearing set for 12/15/2006 at 10:00 AM. Mailed notice. (is, ) (Entered: 11/30/2006)
161 MINUTE entry before Judge Martin C. Ashman : Status hearing of 12/15/2006 is stricken. Mailed notice. (is, ) (Entered: 12/14/2006)