Sage?m? Cam?? of {I?m of mm Filed D.C. Superior Court 03/19/2018 - of the Court CIVIL CIVIL ACTIONS BRANCH INFORMATION SHEET I: I. I His?If?? Case Number: 3-38 Date: 3 333'; 3.3322333;35- ?may :{Im I $3311.. One of the defmdams is bemg sued. in their Of?cial capacity. Name: {3 13mm ReIat-ionship 3:0 Lawsuit .. -- .--.-..- $3.36: 433?:- I331 :11 Name: Li it 33km?: Se) Sir?z (Ii it I Jnih ed Bz'r No.1 rm p?0313333? A: w?iw 33:33 .-: {:31 Attorney {Or Plainuff TYPE 01: CASE 3313 Non 3:.st Demand? 35 ff SISE w- I: 6 Person Jury i .- Other: SPENDING RELATED TO THE ACTION BEING FILED Case No.2 Judge: Case No; Judge! I . . 3.2?61?50113111?33 Calendar Calezida1?#: NATURE OF SUIT: (CheckOrze Box 03113.3} A. CONTRACTS GI. Braach. QfContract 02 Branch oi'Warifnamy 06 Ncgotiable 113 Pergonal I I I .13 Employmsni?Disarismination 1-5 Special. Education Fees COLLECTION CASES .14 Under $251,000 13m: Grams Consent 16 Under $25,000 ConsentDcuisd 17' OVER $25,000 Pitf. Grams-Consentiij 18 GVER $25,090 co-nsm Denied I :f 27 Insu?mucc?Su?bmgat?ion Over $23,000 Pltf. Grams Consent I I Imamance/Su-brogaiion Pltf. Grants: Consent ?28 Motion :0 Con?rm Arbitration Award {ColicctionCases Only) 26 InSura?chSubrOgation Over $25,060. Consent Denied 34 In5L:rance?uhrogation Indes- Consent Denied B. PROPERTY AutomObII-a. 02 Conversion Shoplifting, D.C. Code? 03 Destruction. ofpri?vat?e Property I: 03?: ropercy Damage 27-1.0291} [:13 05 Traspass PERSON-AL TORTS- Abuse of Process: 02 Alienation of'Afi?cci?ion 3 0.3.Assai13t and Battery 04 Automobiie Persona} Injury 05 Deceit (Mlbiepluawmaon; 06 False Ac'mlsation I: 0? False Ai'rest' {)S?Fraud :1 IO Invasion E3 11 Libeii and Sign-dei- I2 Malicious Interference- .Ej 1.3 I: I4 Maiprac-Lice Legal. i 5 (Including Wrt-ng?ii Duaiil) 16 Negl?igexwea (Not Automobile. Not Ma?ar-actica) 13618011613 Injury? {Not Automobile, Not Maipractice} ISWJonufu} IDeath {Not alpractica)? 19 WanfiiI Ewiction 20 Friendly Suit E121 CI 2? Toxio?Mass; Torts 23 Tobacco E1231 Lead Paint. cmweum 2015 SEE. REVERSE SIDE AND CHECK HERE IF USED Eafermatien Sheet? Centimed C. 01 Accounting i? Alien-{Personnel Act (OE-A) 02 Art. Before Judgment (DC. Cude?Tijtie i: Cl?iapiex? 6) 05 Ejeetment- I IE IS Freduet Liability 09 Special Writf'Warrams Code 11?94?) -E 2% Appiica'tion to Con?rm,_ Modify, .10 Traf?c Adjudication Vacate Arbitration Award (DC- Code {64401} Writ of Replevin 29 Me'ri?t Personne! Act 12 En'fbrce Mechanics Lien 1:3 31 Reusing Code Regulations 1'6 Daciamtosy Judgment 32 Qui Tam 33: Whi'stlebinwer 11. 03 Change of'Name- 15 Libe! 21 Petitiisn fer Subpoena 06 Foreign Judgment/Baum?ie j] 9-Eni?er Ac?minisimtive Order as [Rt'iie- 284 OS F0reign Judgn'ient/Injtejmationai Judgment DC. Code 53 a 2-2 Release Mechanic-s Lien 13 Cumiection chi?th Certi?cate or 32?123?! 9 .23 Rule 1'4 Correction chzi?rriege ?3 ?20 MasterMeter (DC. Code {'Perpetusate Testimony} Certi?cate 4243301, et seq.) :3 24 Petition for Settlement 26 Petitionibr CivilAsSet Forfeiture (Vehicle) 25 Petition. for Liquidation Peti'tien fer Civil Asset Forfeiture (Currency) 28 Petition for CiviiAsset Forfeiture {Other} E). REAL PROPERTY [3 0.9 Real Property?Rem Estaie 08 Quiet Ti?e i2 Speci?e Performance [3 25 Liens; Ta WMer'Consent Granted 04 Cendemnatiion {Eminent Demaih) 3f) Liens: Ta}; water Consent Denied 10 Mortgage Foreciosure?udi?ai Sale"- ?31 Tax Lien Bid Off Certi?cate Consent Granted 11 Petition forCiviI Asset Forfeimre (RPswig? {IL-kiw- if" i I Sign?i?are Date Eune 2015. SUPERIOR COURT OF THE- DISTRICT OF COLUMBIA CIVIL DIVISION Chloe Caras 2112 3th Street, NW. Washington, DC. 20001. Plaintiff, V. Civil Action No. Mike Isabella, Inc. d/b/a Mike Isabella Coneepls 401 Massachusetts Avenue, NW. Suite 705 Washingt'o'n, DC. 20001, Michael Isabella 2401 Massachusetts Avenue, NW. Suite 705 Washingtan, 20-001, ohannes A'llender 121,254 Damestown Road, Suite 621 Gaithersburg, MD 20878,. aha Ismail 708 Irving Street, NE, Apt. 102 Washington, DC. 2-0017, George Pagonis 17 00 Kalerama'Road, N.W., Apt. 405 Washington, DC, 20009, Nicholas Piagonis 1111 Street, N.W., Washington, DC. 20009, BallCant?ina, LLC 40.00 Wilson Boulevard Arlington, VA 22203., BallKap, LLC 4000 Wilson Boulevard. Arlington, VA 22203, BallNoodle, LLC 4000 Wilson Boulevard Arlington, VA 2122033 Isabella Bella LLC 707 6th St. Washington, DC. 2-000] 'Rquharf, LLC 12154 Darnestown Road, Suite 6121 Gaithersburg, MD 20878.,- Tylsa: LU: 112154 Damestown Road, Suite 621 Gaithersburg, MD 20878, Defendants. COMPLAINT FOR DECLARATORY AN 1) MONETARY RELIEF AND JURY DEMAND PRELIMINARY STATEMENT AND INTRODUCTION 1. This is a civil action against Mike Isabella, 1110., d/b/a Mike Isabella Concepts and its business entities Defendants BallCantina, BallKap, BallNeodle, Isabella Bella Rquharfi, and LLC: for declaratory, inj unctive, and monetary relief for injuries Plaintiff Chloe C'aras sustained as a-r-esul't of the sexual harassment and retaliatory termination to which she was subjected at MIC, in violation of the DC. l-luman 2 Rights Act DC. Code 241402.] l. gig} This is also an action against MlC?s owners, Defendants Mike Isabella; Johannes Allender, Chief Financial Officer; Taha Ismail, Beverage Director; George Paganis, Executive. Chef; and NicholasPagonis, Director, in their individual. capacities, for. aiding and abetting the sexual harassment, and against Defendants Mike Isabella and Johannes Allender, in their individual capacities, for aiding and abetting the retaliation, in violation of DC. Code 24402.62, Prior to. her unlawful termination, Ms. Caras was Director of Operations for the Isabella Eatery (?the Eatery?) and the highest?ranking woman ?in the MIC. organization. 2, Mr. Isabella, a celebrity chefand owner of twelve of the Washington, DC. area?s premier restaurants and his all?male "partners created a sexually hostile work environment and condoned a, climate of contempt for women at. restaurants that stands out in an industry that is notorious for sexual harassment. Mr. Isabella is well aware that male chefs have created .a ?bro. culture? thathas allowed sue-h sexual harassment to ?ourish in the restaurant industry. In ?a November 2017 open letter to male chefs, celebrity chef Torn Colicchio acknowledged the ?dick culture? created by the ?bros? in the industry. See ?An Open Letter to (Male) Chefs,? Medium (November 8, 2017). In a series of recent interviews, celebrity chef Anthony Bourdain acknowledged that male chefs create a ?meathea'd bro culture? that denigrates and .devalues women in myriad ways. and nolitics/interroaation/ZO1 7/10/anthony hourdain on 'w U.) einstein .iohn been and meath?ead restaurant MIC is a prime exemplar of this ?bro culture? that thrives on what Mr. Colic-Ohio described as ?ugly maehismo.? Mr. .Isabellaihas long been on notice about. the sexism that pervades the industry and his own establishments and has been criticised publicly for being ?a knuckle?dragging Neanderthal who disrespected women.? See: ?Mike Isabella is a (grand?nama?s boy,? Washington Post (June .21., 2011).. i3. . MIC has not been able to retainthe few women chefs it'has hired and women generally do not make it into the higher management ranks 0:an Isabella?s establishments. When Ms. Cares did, she became'the target of extraordinary sex~based hostility and ?abuse..- De?fend-ants Isabella, Allender, Ismail, George Pagonis, "and Nieliiolas Pagonis routinely subjected Ms. Cares to sexual harassment throughout her ?three?year tenure With MIC. The harassment consisted of: unwelcome touching; sexual advances; vulgar and explicitly sexual remarks and gestures; sexist insults and texts calling her a ?dumb bitch.? and a ?where?; and the dissemination o'fmaliCiousand-talse rumors about her sexual history and activities, including-that Mr. Isabella and other male executiVes had had sexual relations with her. On multiple oceasions, Mr". Isabella Ms. Cams and subjected her to degrading acts, including pulling her hair while standing behind her in .a clear pantomime ofhaving penetrative sex fromthe rear. requiredMs. Care's and other female employees to work in an environment inwhieh Mr. Isabella and the other owners ogled and on female restaurant patrons they thought were ?hot? and openly bragged about their sexual exploits with prostitutes. Mr; Isabella 'used'restaurant 4 openings and work events as opportunities to bring and show off young, attractive worn-en, whom he referred to as his ?girlfriends.? Mr. Isabella directed that managers name signature cocktails at MIC. after sexual conquests? and other inSide jokes he had with MIC partners. Mr. Isabella. and the partners named a cocktail at by Mike Isabella ?The Crossing Guard? and another .at Kapnos Taverna ?You Strong? to commemorate their sexual exploits with prostitutes in Europe. Mr. Isabella also demanded that Ms. Car-as name a signature cocktail at his Pepita restatn'ant in Arlington, Virginia, ?itchy kitty,? a crude name he used when referring to a woman?s vagina. She refused to do so. 4. Ms, Caras sought Mr. Isab'ellals assistance in responding to harassment that the other owners" and. managers direct-ed at her, to no avail. Instead, he blithely con?rmed that the partner likely mistreated her because she is a woman and he is uncomfortable working with a woman in a management position. Mr. Isabella'ignored complaints Ms. Car-as and others raised about male chefs regularly subjecting female employees, including fem-ale waitstaff, to sexual harassment, including at Kapnos Taverna in College Park, Maryland, and Yona, in Arlington, Virginia, Although on notice about the pei?tIasive sexual harassment at his ?restaurants and Ms. Caras? speci?c complaints, Mr. Isabella took no corrective measures to reform the sexist culture he created and perpetuated in his establishments. 5. The sexual. harassment and. abuse came to a dramatic end for Ms. Cares at the Isabella Eatery on December 5, 201'? when a visibly intoxicated. Mr. Isabella, in front of Ms. Caras and other employees, crudely suggested to an MIC Chef that he have sex with Ms. Caras. Ms. Caras objected to this offensive comment and attempted to leave the restaurant. Mr. Isabella chased after her, screaming that she. was a ?disrespectful bitch? and acting in a manner that she found frightening and physically menacing, When Ms. Cares reached the door, Mr.- Isabella terminated her' and told her not to return to the restaurant. After terminating Ms. Cares, MIC continued its retaliatory campaign against her by opposing her entitlement to unemployment compensation bene?ts, by falsely telling the Virginia Employment Commission that Ms. Cams abandoned her post, and thereafter by pressuring MIC employees to sign false statements to that effect. 6. Mr. Isabella has allowed Partners andother male employees, including chefs, to assault female. employees, without consequence, and has himself roughly grabbed and touched female chefs and other female employees in an aggressive, sexually degrading and unwelcome manner. Employees male and female alike have acknowledged that MIC is the worst envir-omnent for women in which they have ever worked. Jurisdiction and Venue This Court has jurisdiction over Plaintiffs claims pursuant to DC. Code 11-921 and the Districtof Columbia'Human Rights Act DC. Code 242402.11 m, to remedy Defendants? unlawful harassment of PlaintiffCaras based. on her. gender and in retaliation for her opposition to thatharassment. This Court has jurisdiction. under DC. Code .6 2-1403. 16 and DC. Code '1 l~921(a) because headquarters are located in the District of Columbia, Ms. 'Caras worked, in part, in the Districtof Columbia, and she would have continued to work in this location had she not been subjected to an wilawful termination. Jurisdiction is also proper in the District of Columbia because many sexually harassing eVentss took place in the District and the effects of discriminatory and retaliatory events were felt in the District. Monteilh V. AFSCME, 982 A261 301, 304?05 (DC. 2009). 8. The Court has jurisdiction over Plaintiff 3- common law claims against MIC: and its business entities pursuant to DC. Code 1342 because they maintain their principal places of business in. the District of Columbia. The Court has jurisdiction over Plaintiffs commonla?w claims against TyIsa, LLC pursuant to DC. Code? because the tortious injuries that occurred within TyIsa, property Were suffered by Plaintiff in the District of Columbia and the entity regularly does or solicits business and engages in other persistent courses of business- in'the District of Columbia. 9. Venue is preper as the Plaintiff resides in the District of Columbia. Defendants are. located in the District of Columbia, and. the events or omissions giving rise to Ms. Caras? claims occurred in the District of Columbia. case 10-. Ms. Cares is an adult resident- of the District of Columbia. MIC employed Ms. Cares item 2015 to S, 2017, and her last position was Director? of Operations for Isabella Eatery with additional management responsibilities at two MIC restaurants in the District of Columbia. Ms. Caras is an- employee within the meaning of DC. Code 2? 1401 ll. MIC is ajfor~pro?t private corporation. that cor-idnc?tS busineSs in the District of Columbia and is headquartered in the District of Columbia. MIC is an employer Within the meaning ofDC. Code 2~1.401.02( 10). For purposes of this" Complaint, senior executives at the Company are hereinafter referred-to as ?Partners.? MICnow has more than adozen restaurants in Washington, Maryland, and Virginia with additional outposts in Nationals 'Park and Ronald Reagan National Airport. MlC?s newest and largest. project, Isabella. Eatery, is a food emporium. in Tysons Galleria,- a. luxar?y retail outlet. in Northern Virginia. Along with its. Partners, MIC exercised oversight and control over its restaurant locations, which included the authority to hire, discipline, and terminate its employees. At all times relevant to this Complaint, MIC and its business entities maintained reStanrant locations and exercised authority-and control over the conduct of its employees and partners, including Defendants Isabella, Allender, Ismail, George Pagonis, and Nicholas Pagonis. 12. Defendant Mike Isabella is the Owner of Defendant MIC and regularly conducts business from business locations in "Washington, DC Mr. Isabella is a resident of the District of Columbia. He created a sexually hostile- ?work environment for Ms Carasin DC. restaurants. Mr. Isabella is arm-employer within the meaning of DC. Code and he aided and abetted the sexual harassment and retaliation against Plaintiff, in Violation of the. District of Columbia Human Rights Act, DC. Code 24402.62. 13.- Dei?endant Jehanne-s Allender is the Chief Financial Officer of'Defendant MIC and regularly conducts business from Washington, DC. locations, Mr. Alleuder is a resident. of the State" of Maryland. He created a. sexually hostile work environment for Ms. Cara-s at MIC restaurants in the District of Columbia. Mr. Allender is an employer Within the meaning - of DC. Code and he aided and abetted-the sexual harassmentand retaliation against Plaintiff, in Violation ofthe District ofColumbi-a Human Rights Act, DC. Code ?3 2? 1402.62. 14. Defendant Talia Ismail is the: Beverage Director of Defendant MIC and regularly conducts business from MlC?s business locations in Washington, DC. Mi?. Ismail is-a resident of the District of Columbia. "He created a sexually hostile work enviromnent for Ms. Came in DC. restaurants and participated in harassing events in "the District of Columbia. Mr. Ismail is an employer within the meaning-ot?DC. Code and he aided and. abetted the sexual harassment against Plaintiff, in Violation of the District of Columbia. Human Rights Act, DC. Code 24402.62. 15. Defendant George Pagonis is the Executive Chef of Defendant MIC and regularly conducts business from business locations in. WaShington, Mr. Pagonis is a. resident of the District of Columbia. He created a sexually hostile work environment for Ms. Cares in 9 DC. restaurants. Mr. Pagonis is an employer Within the meaning of DC. Code Zn '1401 and he aided and abetted the discrimination against Plaintiff, in violation of the District of Columbia Human Rights Act, DC. Code 2440.262. 16. Defendant Nicholas Pagonis is the Director of Operations of Defendant MIC and regularly" conducts business from business locations in Washington= DC. Mr. Pagonis is a resident of the District of Columbia. He subjected Ms. Caras to sexually harassing conduct in the District of Columbia, Mr. Pagonis is an employer within the meaning of DC. Code 2- 1401 he aided and abetted the discrimination against Plaintiff, in ?Violation of the District of Columbia Human Rights Act, DC. Code 24402.62. 17. Ball-Cantina, .LLC, d/ b/ a Pepita is a for?pro?t limited liability corporation that conducts business in Virginia and is headquartered in Virginia. Ms. Caras served as the Regional General Manager for Pepita until June 2017. For purposes of this Complaint, .BallCantina, LLC, is hereinafter referred to as "?Pepita.? 18. .Ballfliap',- LLC, d/h/a KapnOS is a for?profit limited liability cOrporation that conducts business and is headquartered in Virginia. Ms. Caras- served as the Regional General Manager for Kapnos Taverna until June 2017. For purposes of this Complaint, BallKap, LLC, is hereinafter referred to as ?iKapnos-f? 19. BallNoodle, LLC, d/b/a Yona is a for?pro?t limited liability corporation that. conducts business in Virginia and is headquartered in Virginia. Ms. Caras served as the 10 Regional. General Manager for Yona until June 2017. For purposes of-this Complaint, BallNoodle, LLC, is hereinafter referred to as ?Yona.? '20. Isabella Bella d/?b/a Graf? ato is .a for~pro?t limited liability corporation that conducts business in the District of Columbia and is headquarteredin the District of Columbia Ms. Cares served as a manager for Graf?ato from March. 2017 to November 2017, and but for her tennination, would have had ongoing managerial responsibilities at Graf?ato as directed. lsabell-a Bella, LLC, is an employer within the meaning of DC. Code For purposes of this Complaint, Isabella Bella LLC, is hereinafter referred to as "?Grafliato.? .21. 'Rquhar? LLC, d/b/a Requin is a forapro?t limited liability corporation that conducts business in the District of Columbia and is headquartered in Maryland. Ms. Cares was employed at Regain from September 2017 to October 2017, and but fer her terminat?iom Would have had ongoing managerial responsibilities at Requin as directed. Rquharf, LLC, is an employer within the meaning of DC. Code 214010200). Rquharf, LLC maintains its restaurant?s premises at 100 District S?quare SW, Washington, DC. 20024. At all times relevant to-this Complaint, 'Rquhjarf, LLC exercised authority and control over the conduct of its employees and partners,, including Defendant Isabella, during the course of its business and While on MIC-controlled premises, .For'porposes of this Complaint, Rquharf,.LLC, is hereinafter referred to as ?Requin.? ll ylsa, LLC, d/b/a Isabella Eatery is a fonpro?t limited liability corporation. that conducts business in Virginia and is headquartered in Maryland. Ms. Caras was employed at I Isabella Eatery from July 2017 until her termination. For purposes of this Complaint, T-yIsa, is hereinafterreferred to as ?lSabella Eatery?? Factual The Sexually Hostile Environment at MIC Restaurants 23. M1. Isabella gained notoriety after competing on. Season Six of Top Chef and Top Chef Duels. 11112011, Mr. Isabella was the runner-up on.iTop Chef All?Stars. I In 2012., .Food- Wine magazine name Mr: Isabella The People?s Best New Chef: Mid?Atlantic. In 201 6, the Restaurant Association of Washington named Mr. Isabella Restauratem of the Year. From 201 15 when. he opened his ?rst-restaurant, Graf?ato, to the present, Mr. Isabella has built a $30 million restaurant empire in the DC. area, Opening twelve restaurants to critical acclaim. Mr. Isabella?s rnost ambitious project, lsabellaiEatery, openedin Tyson's- .Galleria'in December 2017. 24. Mr. Isabella and his MIC partners Created a demeaning environment for women at all the restaurants they established. They directedhirlng of?Cials, like Ms. Carats, to hire women who were ?hot? or ?good looking"_? and Commented on their physical attributes. The Partners expressed their contempt for Women. by calling them ?bitches? and ?whores.? Mr. Isabella routinely referred rte-women within and outside the. Company, including restaurant patrons. and 12 business associates, as"?bitehes? and on obeasions When he lost his temper, at female employees, ealling them bite-hes, whores, and Worse. 25. Mr. :Isabellaand his Partners also subjected female employees to stories about their sexual conquests. When the Partners. returned from international Culinary t-ours,,they openly boasted about their sexual exploits with. prostitutes. At nearly every restaurant opening and work event, Mr. Isabella brought young, attractive women, whom he referred to as his ?girlfriends,? and then demanded that Ms. Cares "book a'hotel room-for him and his girlfriend for ?theinight. Mri Isabella and the other ?partnersbragged to Ms; Cares and other employees about their sexualtperibrrnanee and. regularly discussed ?taking down? or ?hanging? women, which Were euphemisms they routinely usedfor having seX.? DefendantNiok Paganis boasted that he had a ?huge? penis and regularly remarked aboUt how often he and his Wife had sex. Defendant George Pagonis graphically described his. girlfriend?s'body and bragged about his sexual exploits with her in front of Ms. Cares and other female employees. "illflien :a former female til-16f interrupted and asked birth to stop engaging in sueh-vile comments, he. mistreared'her by branding. her a and. ?crazy,? and referred to her- and other women who quit their jobs at MIC in. renglise to harassment "by those names. Mr. Nick P'ag'onis routinely referred to women as whores and used the word ?pussy? as a matter of course in the workplace. He also took delight in upsetting female employees by referring to male employees as ?malaka,? 'a word he said Was a. Greek term for. ?fat maSturbator.? 26. Mr; Isabella and the "Partners regularly referred to women they found attractive as ?corn.? This term Was a vulgar reference to a story Mr. Isabella regularly told about chef who had commented that a woman was ?so hot, [he?d] eat the corn out of her "Shit,? The partners used the term to refer to female patrons that came into the restaurants; During. meetings. at. the restaurants, the partners often gathered at the bar: and called out to each. other, ?Corn! Cor-n!? when-attractive women walked in. Defendant Isabella often sent Ms. Caras text messages with corn emoji pictures. The "Partners were aware that Ms. Caras found. this offensive and took obvious delight in taunting her with this vulgar term. The Partners often sat at the bar of the MIC restaurantslooking at pictures and/or videos of naked. orsemi-clad women on their mobile phones and commenting about-their physical attributes. 27. MlC?s Partners also named several cocktails at MIC r'eStaui'aiitS'after inside jokes- they shared, usually involving their sexual exploits with prostitutes and other worhen. They named one cocktail at Kapnos Taverna ?You ?Strong? because, they explained,- one of the prostitutes-with Page-Iris had sex on a'trip to Europehad purportedly said this to him. They named. another cocktail at by Mike Isabella ?-?The Crossing Guard,? a nickname the Partners explained Mr. Isabella had earned when they visited a brothel in Europe, and Mr. Isabella had directed eachprostitute to servicea particular partner and, told her which sex act to perform on. each'partner. Upon information and belief, the ?Unfaithful,? ?Almost There,? and ?Fuzzy Pear? cocktails at Kapnos Kouzina, the ?Eye Candy? cocktail at KapnOS Taverna, and. the 14 ?You Havea Wife?? cocktail at Graf?-ato were named after the Partners? sexual jokes and exploits. '2 Mr. Isabella routinely drank throughout the day at his r?sta?rants, and his behavior whileintoxiieated was: often belligerent, tlu?e'aztening, and sexually inap?topriate. 0a a number of such oceasions,- Mr. Isabella drunkenly leaned tOWard Ms. Car-as and aSked her to kiss him! He touched Other female employees'in the same unwelcome manner. .Ms. Cares rejected his seXual advanCes andmadte clear that she was not interested? ill-having anything-other than" a- professional relationship with him. Mr. Isabella?s perSistent adVances-Were. re?ectiveof the . eultm?e the. Partners used their positions. of'power and fame to mistreat and seXually harass. Women. Mr. Isabella grabbed. and sexually propoisitioned female. employees, promising to make at least one female chef whom he Came onto sexually ?a superstar Someday.? 29. EmpIOyees'ini MIC eStahlishments had Ito-effeetltte avenues to ehallenge the sexist andsexuallyiharassliag conduct they experienced; Although-there was an: employee handbook that mentioned sexual. harassment, MIC provided no. training for managers or Partners about what constitutes sexual harassment? or how to reSpo?n-d to complaints. The handbook . deemed-employees to comp-lain to their immediate suPerviSor, without an alternative when the supervisor was the one haraSsing the employee. Despite" having approximately. 1,000 employees, MIC did not establish a human resources department until O-e-teber2017. MIC, employees had :no internal mechanistns to seek redressfor sexual. harassment. .15 Defendants? Sexual Harassment. of Ms. Caras 3.0. Ms. Cares is a 2006 graduate of Ithaca College and has worked in the restaurant industry for thelast two decades, Before joining MIC, Ms. Cares worked as. an inaugural. General Manager for Matchbox Feed Group, another prominent local restaurant chain in Washington, DC. Ms. Caras started. working for Mr. Isabella on February 2, 2015, as the Regional General Manager for Kapnos Taverna, Yona, and Pepita, in Arlington, Virginia. MIC was expanding and Ms. Caras was an integral part of the team that opened these three new restaurants over the span often months. As part of her duties, she managed 125 employees once- the restaurants were in full operation. During the phase when these three restaurants were opening, M's. Caras ?worked with Mr. Isabella-daily as they made decisions together about menus, decor, staff, and restaurant operations in the three different concept establishments, '31. As a General Manager, Ms. .Caras regularly reported to Defendants "Isabella, Nick .Pagonis, George Pagonis, Ismail, and Allender, The higher?level management team at MIC restaurants is almost entirely male; Ms. Cares was one of a very few female managers at the General Manager level or above. The management team met on a weekly basis with various Partners, nearly always at an MIC restaurant in Washington, D.C., and general managers met with the Partners in.D.C. Ms. Caras was thus infrequent contact with all of the Partners and was routinely subjected to their sexist comments, insults, and ridicule. l6 32. When the three restaurants for which she was responsible opened, Ms. C-aras reported directly to Defendant Nick Pagonis, the Director of Operations for MIC. Mr. Pagonis reported directly to Mr. Isabella. .Beghrning in late 2101.5, Nick. Pagonis began to criticize and berate Ms. Caras, citing small errors or perceived slights as excuses for this verbal abuse. In stark contrast, Mr. Pagonis? treated male employees whom he managed respectfully. Mr. Pagenis? antipathy towards Ms. Cares was so extreme that he even berated her when he learned that she had broken her foot. He sent her text messages stating that he was ?livid with the news? about her foot. Mr. Pagon?isi? reaction to her injury baffle-d Ms. Caras, but demonstrated that Mr. Pagonis would seize upon any opportunity to criticize her unreasonably. 33. Mr. Pagonis routinely insulted M's. Cara-s? intelligence and disparaged her werk performance". He often questioned Ma. Ceres? male subordinates at Kapnos Taverna, Yona, and Pepita about how often she was at the restaurant and made negative comments about her to the team in an effort to undermine her authority. In the fall of 2015, Ms. .Caras complained to Mr. Isabella that Mr. Pagonis was mistreating her and describedhis sexist, demeaning, and undermining behavior that Was impeding her ability to do her job. Mr. Isabella agreed that Mr. 'Pagonis was in fact n?streating her and acknowledged, ?It?s probably because you?re a woman.? Mr. Isabella explained that Mr. Pagonis was not comfortable working with female management employees and that he likely felt intimidated by Ms. Gates and resentful of her authority. Rather than-take corrective action to protect M's. Caras from Mr. Pagonis? mistreatment, Mr. Isabella l7 merely told Ms. Caras that he was her ?biggest supporter? and assured her that he was the ?only one who matters.? ?Mr. Isabella ignored the concerns Ms. Caras raised about M1. Pagonis? abusive behavior and left her and other female employees to fend for themselves even though he had the ultimate authority to. set the. tone for the work. environment. at all MIC. restaurants .. 34. In early 201.5, MIC hired a new head Chef Jonah: Kim for the restaurant Yona, one of the restaurants Ms. Caras managed. Given that Mr. Kim managed the cuisine and food staff and Ms. Caras managed the front of the house operations, their positions required that they collaborate on all restaurant decisions. From the start, Mr. Kim refused to respect Ms. Caras? authority as General Manager and. ignored her requests and instructions. As a professional. in the restaurant industry, Ms. Caras was accustomed. to male Chefs treating women disre-speotfull-y and tried to work the issue out herself. However, as the months went on, Mr. Kim became increasingly hostile whenever Ms. Caras disensSed staffing, schedules, or other day?to?day operational issues with him, and threatened. to ?destroy? her. He said, ?You think Nick. [P'agonis] gives you anxiety? I could give you. so much more.? 315. After one of Mr. Kin-1?s tirades, Ms. Caras- reported .his abusive behavior to Mr. Isabella, who voiced skepticism that Mr. Kim?s behavior was as severe as Ms. Caras ?had portrayed it. Mr. Isabella only came to "believe Ms. Caras after other employees expressed concerns to him about Mr. Kim?s abusive behavior towards them. Mr. Isabella terminated him 18 eight months later, in. June 2016, but only after Mr. Kim proved to be a mediocre chef. Until his termination, Ms. Cares endured daily abuse from M1. Kim. 36. In addition to the conduct detailed above, Ms. C'aras was forced to contend with Mr. Isabella?s unwelcome. sexual. comments. On March 11,2016, Mr. Isabella struck up a conversation. with Ms. Catas about naming a new cocktail at the Pep'ita restaurant in Arlington, Virginia. He joked that Ms. Caras should name it ?itchy kitty,? a crude reference to a vagina. Ms. Cares asked Mr. lsa?be?lla to stop goading her in this manner, but Mr. Isabella found Ms. Caras" discomfort with his vulgar comments amusing and kept repeating the phrase to her throughout the day. Knowing that Ms. Caras was offended by his behavior, Mr. Isabella escalated the?joke' and teXted ?itchy kitty? to Ms. Caras. When Ms. Caras asked him. to. stop repeating the crude phrase, Mr. Isabella replied, ?What?s wrong, got one?? A few days later. Mr. Isabella texted- "Ms. Caras itoasik if she had nameda cocktail ?itchy kitty? yet. His behavior was offensive and demoralizing. '37. "throughout 2015, Defendants. ?Nick .Pagonis, George Paganis, and Talia Ismail regularly exchanged sexist and other inappropriate texts with one another and the management team, and expected Ms. Cares to join in with them. They referred to womenas ?cunts.? ?bitches,? and ?whores.? When Ms. Caras ?rst joined the Companya she occasionally used this terminology in an effort to get along with the Partners and fit in because the Partners expected their colleagues to engage in the same offensive banter. However, overtime, she stopped using 19 such offensive terms as it had always made her uncomfortable to do so and did not stop the Partners? harassing and abusive treatment. .3 8.. On June 12, 2016., Ms. Caras attended the annual RAMMY Awards Gala, which honors individuals and businesses in the Washington, DC. area?s restaurant and foodservioe community. MIC Won Restaurateur of the Year and. hosted a party after the event to Celebrate at the Graf?ato restaurant in the city. MIC provided unlimited alcohol to its attendees, and several employees, including Ms. Cares, drank excessively. Ms. Caras spoke with Juan "Rivera, the chef de cuisine of? K-apnos Taverna and Pepita, and later in the evening, he assisted Ms. Cares as she was leaving the-party. The next day, Defendant Allen-tier. sent- Ms. Cares :a textinessage, stating that he and others had heard that Ms. Caras and Mr. Rivera had sex at Graftiato during the parity. Mr. Allender followed up by staking, ?Who was better[,] Juan or Adam,? referring to another MIC employee, whom Ms. Cares had dated. Ms. Care's was offended by Mr. Allender?s question and told him that it was ?not okay.? Ms. Cares reported Mr. Allender?s remarks to Mr. Isabella, who feigned ignorance and said he had notheard the rumor. Mr. Isabella failed to take any type of Corrective measures or to prevent these types of comments from being made by MlC?s Partners and others about Ms. Caras. '39. Mr. Ismail also subjected Ms. Caras to insulting and demeaning sexual comments. On June 12-0-16,? Ms. Car-as sent him a text message asking for the name ofihe Company?s coffee vendor. When Mr. Ismail responded, he ?rst. called her ?stupid.? for notrernernbering the 20 name, and then when he gave her the name of the male vendor Mr. Ismail also added, ?Too bad he isnot a chef. [iBe]eause you only do Ms. Caras, who had already complained to Mr. Isabella about sexist. and insulting comments to and about her to no avail, knew that further complaints would be futile. 40., On August. 5, 2016, Mr. Ismail sent Ms. Caras a photo of Mr, Isabella and herself, with the eap'tiOn, ?You look like you want to fuck Mike so had.? 011 August 20, 2016, Ms. Cares sent Mr. Ismail a message 'to come to the Kapnos Taverna restaurant. Mr, Ismail responded by calling Ms, Cares :a ?Whore? twice. Mr. Ismail regularly called Ms. Caras :a whore, in person and in text messages", and found Ms. Caras? objecticin to his comments humorous, leading him to reSpond with further i-nvectives ?and insults. Similarly, he sent Ms. Caras numerous text messages calling her a ?dumb bitch.? When Ms. Caras told him not to call her that, Mr. Ismail took obvious delight in upsetting her by leveling this insult repeatedly. Inanother text message, Ms. Caras- asked Mr. lsmail for pricing information for a DJ MIC had used. for a work event. Again shitting? to sexually graphic talk, Mr. Ismail told her that the DJ ?wanted to give it to you that night.? Ms. Cara-s did not respond to this sexual reference because she knew Objecting would only encourage more of the same. 41 .l The Partners also regularly commented on Ms. Caras? body to other male employees, particularly about the size of her buttocks. Defendants George and Nick Pagonis 21 routinely commented to MIC employees that ?Chloe had. a great. butt for a white girl.? Ms. Cams found these comments to be degrading. 42. Mr. Isabella and Mr. Ismail also frequently touched Ms. Cares inappropriately. often in front of'others, in an effo? to demean and humiliate her. On two occasions including at Requin, in front of restaurant employees Mr. Isabella and. Mr. Ismail-pulled Ms. Caras? hair While standing behind her in a clear pantomime of having penetrative sex from the rear. 'Both times, Ms. Caras found the behavior demeaning and physically aggressive and made clear that this vulgar conduct was unwelcome. Both men simply laughed and joked about this behavior, which. they also did. with at least one other female employee. Mr. Ismail also slapped. Ms. Clams? forehead on numerous "occasions, causing Mr. Pagonis' to laugh and tell M17. Ismail that he could slap Ms. Caras on the forehead but ?not the ass.? Mr. Ismail. and Mr. Isabella regtilarly made Ms. Caras uncomfortable by leaning in toward her to smell her- hair and making nasty comments such as ?you smell dirty? to dem-ean her in front of others. They did not treat male employees in this manner. 43. In October: 2016, Mr. Isabella and several other employees? including Ms. Cares, had a few drinks at by Mike Isabella-after it'had closed. Mr. Isabella became very intoxicated and attempted to persuade the group to go to a strip club. Nanda Bernandes, Mr. Isabella?s ltlxecutive Assistant, intervened, and told everyone to go home While she ensured that Mr. Isabella reached. his home safely. Ms. Caras was relieved that Ms, Bernandes had managed to 22 extricate them from. the situatitin that evening. However, Ms. Car-as later learned that Mr. Isabella had boasted to the other partners-that he and Ms. Cares had planned to go home together that evening and have sex, but that. Ms. .Bernandes had prevented that from happening. Over Ms. Ciaras? objections, the Partners regularly repeated thistalsehood about Ms. Came to other male colleagues for almost a year after the incident. On other occasions, Mr. Isabella demanded that his staff come with him to Empire, a strip club in DC. When one female employee refused to- do so and attempted to leave to go home,'Mr. Isabella screamed at her and directed profanity-laced threats at her, including the threat to terminate .her ifshe did not come with him to the strip club. 44.. In March 2017,, Mr, Isabella asked Ms. Caras to help turn around the Graftiato restaurant in. Washington, D.C., which had been struggling tinder poor management ifOr several years. Mr. lsa?bella trusted Ms. Cares to rebuild the restaurant?s clientele and implement an effective- management system, which she worked diligently to do until the time of her- termi?nation. While MIC did not have a formal performance review process, Mr, Isabella made clear to Ms. Caras that his decision. to ask her to help turn around 'Graf?ato demonstrated his high regard for her performance. Despite Ms. Caras" committed effort to improve the restaurant, Mr. Pagonis intentionally :tuider'mined her to the staff by suggesting to them that she lacked a strong work ethic and was a slacker. For example, on occasions where Ms. Cares was not at Graf?ato, Mr. Pagonis immediately informed Mr..Allender that Ms." Car-as was missing, without determining ?rst; Whether Ms. Cares Was supposed "to be working at. Graftiato that day. Mr, Allender then asked Ms. Cares toprovitie him with infonnation about her whereabouts, despite the fact that Ms. Caras had consistently worked long'hours and demonstrated her strong work ethic. Mr. Pagonis and Mr. Allende?r did not serutinizemale managers in this manner. 45. Despite Mr. Pagonis? unwarranted criticisms about her performance, Ms. Caras Continued. to advance at MIC. In May 2017', Mr. Isabella promoted her to Director of Operations for the developing Isabeila Eatery (?the Eatery?), Mr. Isabella?s most ambitious venture. The Eatery is a 41,000 square foot multi?concept food hall in Tysons Galleria, which opened in stages between December "2017 and January 2018-. In this position, Ms. Car-as assumed signi?cantly greater responsibilities and duties, which made M's. Caras the highest?ranking female employee at MIC. Ms. Car-as was responsible for interviewing and hiring an Opening: team ofmore "than 75 employees, She "relationships with local businesses for potential partnership and directed the day~to~day front of the house operations. Ms. Cares also continued to oversee management at 'Graf?ato and to assist Withsome of the restaurants she had helped to open in Arlington.- While no. longer a General Manager, she still attended their meetings in DC, as well as the weekly manage-rs" meetings. 46. Once Ms. Cares of?cially transfer-red to the Eatery in July 201.7, Mi Allender, who became her new supervi-sor,_ treated her with the same animosity she had experienced working under Mr. Pagonis? supervision. Ms. Cares maintainedher oversight job duties at Graf?at'o while in her new position at the Eatery, requiring her to put in even longer hours. Mr. 24 Allende-r refused to acknoWledge Ms. Caras" workload-and insultingly asked Ms. Caras" male subordinates at the Eatery, ?What does Chloe even do here anyway?? ?When. Ms. Caras obj eeted- to Mr. Allender?s- behavior, and to the pervasive sexism at Mil-C, Mr. Allender dismissed her cameras and told her that she was Overly emotional. When M's. Caras objected. to that characterization as ?sexist,? Mr. Allender simply goaded her more. 47. Despite Mr. Allender?s hostility, M's. Caras? job performance sat'the'Eatery, Graf?ato, and theArlington restaurants remained at ahigh level. As a result, Mr. Isabella increasingly relied on her to assist with new restaurants in Virginia. and In September 20l 7, Mr. Isabella asked Ms.- C-aras to assist with opening a Requin restaurant at The Wharf in Southwest'Wash-ington, 1313., in addition to continuing to ?perform her duties at the Eater-y and: four other restaurants. The opening required Ms. Caras to work additional long hours, take on additional staf?ng duties, and travel regularly between the Eatery and The Wharf. 48. On October 20175 The Wharf opened with a four-day event, and. Mr. Isabella placed Ms. Caras. in Charge of Rectuin?s' presence at the opening, which included staf?ng and running an outdoor taco stand and bar. Twenty thousand visitors arrived at The Wharf on each of the fear days, and Ms. Caras received little to no support from the Partners. The Partners spent the ?rst three days of the opening drinking to the point of intoxication, while also ogling and commenting on the physical attributes of female patrons and Visitors at the Wharf. The Partners referred "to them as ?com?? the Vulgar term "they used for? women they found semally attractive. Ms. Caras confronted Mr. Isabella about how the Partners had behaved that day and the lack of support they gave her and her staff. Mr. Isabella told her to take a break, and then proceeded to laugh with his other Partners about Ms. Cares.? reaction.- Later that evening, while at the Requin restaurant, Ms. Caras reminded Mr. Isabella that she and the other MIC employees had been instrumental in their success, and asked him to split the tips with them. Intoxicated, Mr. Isabella erupted into: a ?t of rage toward Ms. Caras, and threw a calculator at the wall near her head. Mr. Isabella?s behavior frightened her. 49. In or around October 2017, Ms. "Cares learned that Defendant George Pa?gonis, like the other Partners, had regularly disparaged her to MIC employees and employees of. its business partners. Mr. Pago?nis told employees and business partners: that Graffiato was in ?bad shape,? and that Ms. Caras had, failed to improve the restaurant. He ?nished this critique by stating that he could not stand Ms. Cares and calling her a ?whore.? Ms. .Caras was welt aware that Mr. Pagonis regularly made sexist and demeaning remarks about her to MIC employees but was shocked to learn that he had made sueh degrading remarks about her in front of its business partners as ?well. Ms. Caras reported Mr. Pagonis?s vile comments to Mr Isabella, again hoping that he would act to put a stop to the behavior. Instead, Mr. Isabella came to Mr. Pagonis" defense and denied that Mr. Pagonis had ever made those remarks without even asking Mr. Pagonis or other employees about the incident. 50. Employees described the ?worst environment? they have seen for female employees in the restaurant industry. While very fe'wfemale managers at MIC survived more than six months in their positions, those who did experienced similar sexually harassing conduct. Mr. Isabella recently targeted a yet-mg female chef for unwelcome sexual advances. In. the few months of her employment, Mr. Isabella-approached her while intoxicated and unexpectedly kissed her declaring that he intended to ?make [her] a star.? MIC retained a male General Manager despite its knowledge thathe had preyed on countless teenage servers at the Kapnos location in College Park, Maryland; Ultimately, MIC terminated him for an unrelated reason. Defendants? Retaliatorv Termination of Ms. Cam?s" Employment 51. On December 5, 20173 Ms. Caras worked at the Eatery with Mr. Isabella and Mr. Ismail. The Eatery had a soft Opening that week and MIC scheduled its ?rst phase opening for the following week. That day, Mr. Isabella told a male MIC employee the story behind the term "teem,? explaining in {rent of other employees, including- Ms. Caras, that an MIC chef had commented that. a woman was ?so hot, [he?d] eat the corn out. of her shit.? Ms. C-aras was once. again repulsed by this story. 52. Later that evening, Ms. Cares was still at the restaurant because several employees worked until the late evening, and Ms. Cams had planned to give Chef Elliot Drew a ride home after his shift. At aronnd 8:30 p.131, Ma. Ceres was working on her laptop-while sitting on a booth in the dining room of the Eatery-?s Graftiato. M11 Ismail grabbed her legs and 27 pulled her by the ankles so that her legs fell off the bench upon which they were resting. Ms. Caras ?rmly and repeatedly said, ?Do not touch me,? until "Mr. Ismail, smirking, let her go- Ten minutes later, Mr. Ismail returned and pulled Ms. Caras by the ankles again. 53. Later in the Isabella joined Ms. Caras and Joe Palma, the Culinary Director of the Eatery, at the booth. Mr. leabella had consumed numerous alcoholic drinks throughout the day and appeared visibly intoxicated. Coming in from the kitchen, Mr. Drew approached Mr. Isabella with a question. While Ms. Caras did not hear the question, she heard Mr. Isabella respond, ?If you sleep with Chloe you can.? .Ms. Cares found the comment highly offensive and asked Mr. Isabella to stop, at which point Mr. Isabella erupted into a ?t of rage. He yelled, -?What', you don?t like that?? He then baSeleSsly accused Ms. Cares. ofseXually harassing Mr. Drew. 54. Mr. Isabella, who is physically much larger than Ms. Cares, became even more intimidating when he was angry and intoxicated and he yelledand leveled threats. Unwilling to continue to interact. with him while he was. in this state, Ms. Caras Walked away from him and went into the kitchen. Mr. Isabella got up from his chair and-moved in her direction, hurling insults at her. Ms. Car-as, who reasonably feared. for her safety, continued to ask Mr. Isabella to stop and allow her to leave. Mr. Isabella followed her. As Ms. Caras exited the kitchen, Mr. Isabella demanded that she turn around and talk with him. Ms. Cares did not. feel safe talking with Mr. Isabella given his. behavior and declined to do so. He shouted. that she was a 28 ?disrespectful bitch? and. told her, ?If you?re [going to be disrespeot?tl, then you?re done here.? He told her not to return to the restaurant. As Ms. Cares reaChed the door to exit the restaurant, Mr. Isabella chased after her and continued calling her a ?bitch? and tauntingly shouted, ?Love you, Chloe, nice working with you.? An employee hearer. Isabella yell ?I?ll {ticking fire you.? A number of employees" witnessed Mr. Isabella?s drunken-tirade but nOne intervened on her behalf. 55. The next day, Human Resources representative, Ket Raxajak, called Ms. Cams and asked if she planned to report. to work that day. When MS. Cares told Ms. Raxajak that'Mr. Isabella had terminated her, Ms. .Raxajak stated that neitheer. Isabella nor Mr. Allender had noti?ed her about this and said she Would call Ms. Cares back.- When? M-s. Raxaj ak called again, She told Ms. Carats. that she still had a position with the Company. Confused, Ms. Caras explained that Mr. Isabella himself had made the decision to terminate her. She further told MS. Raxaj ak that she had withstood sexual harassment at the Company for the past three years and questioned Whether'she could continue to work in such an environment. Ms.__RaX.ajjajk asked to interview Ms. 'Caras about" the sexual harasement and termination as part of HR protocol, to which Ms. Caras agreed. However, approximately ?twenty minutes after their call, deactivated Ms. Cares" work email, cancelled Sher direct deposit for her paychecks, and removed her from the Eatery website. MS. Caras sent Ms. RaX-aj ah an email but She did not ?reply. 29 56. Since Ms. Cares" termination, MIC has bullied employees and attempted to coerce them to lie about the events on December 2017, and to state, falsely, that Mr. Isabella had. not ?red Ms. Cares. On December 6., 2017., the partners held their weekly managers? meeting at: the Eatery. At the end of the meeting, Mr.- Isabella- announced, ?Chloe is no longer with Us.? 57.. 011 December 7, 2017, Mr; Allender responded to Ms. Ciaras? December-6, 2017 email to Ms. Raxajak. Despite the fact that MIC had already taken actions to implement'Mr. Isabella?s decision to terminate Ms. Cares, Mr. Allender wrote he was ?concerned and confused? about Ms. Caras? decision not to report to work and that she had not been terminated. Mr. Allender stated. that he had asked. Mr. lea-bella about the evening?s events "and ?it sounded like a miseommunieation or misunderstanding.? Mr. Allende-r told. Ms. Cares ?everyone [at the Eatery] was uneomfo?able about the comments you made regarding Elliot [Drew] and will investigate this further,? implying falsely that she. had sexually harassed him. Ms. Caras replied to. Mr. Allender?s email stating that she was. going to contact an attorney. Mr. Allender responded by falsely" asserting that Ms. Caras had abandoned her position. and denying her regue?st to meet alone with MlC?s HR representative, Ms. Razcajak, even though Ms. Cares made clear that she felt most comfortable speaking with her. That same day, Mr. Isabella told an MIC employee that ?Chloe is gone, and it?s myfault.? 58. MIC retaliated against Ms. 'Caras by contesting her claim for unemployment bene?ts: made on December 2017, falsely stating that she had voluntarily resigned? or had been terminated for misconduct for job abandonment. On December 219 2017,- Ms. Cares and Allen?der participated in a fact??nding interview with. the Virginia Unemployment: Mr. Allender provided a false account of Ms. Caras? termination stating that Ms. Caras had been teasing a fellow employee that evening, and Mr. Isabella had questioned her about it, which led to MS. .Caras leaving the restaurant. Mr. Allender stressed that he had been Ms. Caras? direct Supervisor and therefore only he and not Mr. Isabella could make the decision to terminate her. On December 26, 2017, the Commission determined that MIC failed to meet its burden to show that Ms. Caras voluntarily resigned. or had been terminated for job abandonment. 59'. After'be'ing put on notice by Ms. Cara-s that she intended to bring legal claims against Defendants, they have redoubled their efforts to strong-arm employees to make false statements about Ms. Carats; including to falsely state that Ms. Cares. Walked off the job and abandoned post. 60'. and the P.a1tners? treatment of Ms. Caras is part of pattern and practice of sexual harassment of female employees, many of whom have quit their positions because they found. the sexually hostile work environment intolerable. 31 61. Because of Defendants? actions, Ms. Cares has suffered and will continue to suffer economic, emotional, and professional harm, including damage to her professional reputation?. CAUSES OF ACTION COUNT I: HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF THE DISTRICT OF COLUMBIA HUMAN RIGHTS ACT, D13. CODE 24401.1 ET 3., AGAINST MIC, BALLCANTINA, BALLKAP, ISABELLA BELLA, REQWHARF, AND TYISA, AND THE DEFENDANT-S ALLEN DER, ISABELLAJSMAIL, GEORGE PAGONIS, AND NICHOLAS PAGONIS. 62. Plaintiff hereby incorporates as though restated all of the factual allegations. 63. The District of Columbia Human Rights Act prehibits discrimination on the basis of sex with respect to an eniployee?s compensation, terms, conditions, and privileges of employment. DC. Code This includes sexual harassment through the creation of'a hostile work enviromnent. 6-4. Defendants All-endear, lsabella, Ismail, George Pagoni?s, and Nick Pagonis aided, abetted, invited, compelled. and coerced the harassing conduct complained of herein in Violation of the District. of Columbia Human Rights Act. 65. Defendants created and maintained a sexually ho stile work environment by, 1mg; aha, subjecting Ms. Cares to sexualized- comments, sexual advances, and touching, and to diSGIi-minatory intimidation, humiliation, and hostility so seVere and pervasive that it affected the '32 conditions of Ms. Cares" employment. Defendants made explicit remarks about Ms. Caras? body, referred to. her as a ?whore? and a "?dumb bitch,? and grabbed her hair "in an explicit simulation of sex. Defendants were put on notice by Ms. Caras that she objected to their abusive and discriminatory treatment and-that of other male employees at MIC and its business entities, and Defendants failed to. take action, thereby condoning and ratifying their" and o?thers? discriminatory treatment. 66. Defendants? action-s directly and proximately caused Ms. Caras to suffer economic loss, including but not limited to salary and employee bene?ts, a loss of future professional opportunities and. future income, andhave caused damage to her professional reputation, humiliatiOn, indignity, personal embarrassment, and. pain and. Suffering. 67. Defendants took. the actions complained of herein with actual intent to cause injury to Ms. Caras and these actions were clone willfully and maliciously. COUNT II: RETALIATION IN VIOLATION OF THE DISTRICT OF COLUMBIA HUMAN RIGHTS ACT, D..C. CODE 2., AGAINST DEFENDANTS MIC AND TYI-SA AND DEFENDANTS ALLENDER AND ISABELLA 68. Plaintiff hereby incorporates as though restated all of the factual allegations. 69. The District of Columbia I-iutna?n Rights Act prohibits retaliation against an employee for Opposing any practice made an employment practice under the District of Columbia. Human Rights Act. 33 70. Defendants Allende!? and Isabella aided, abetted, invited, compelled, and coerced "the discriminatory conduct complained of herein in violation of the District of Columbia l?lurn,an Rights Act. '71. Ms. Caras engaged. in protected activity by opposing treatment that. constituted unlawful harassment, including objecting to the sexual or demeaning comments, instances of inappropriate touching, and sexual gestures and advances Defendants made toward her. Ms. :Carasalso engaged in protectedaetivity by rejecting Mr. Isabella?s sexual advances. Ms. .Catas also reported and opposed Jonah Kim, Mr. .Aliender, and Nick Pagonis? sexist comments and discriminatory treatment of her to Mr. Isabella, On December .2017, Ms. Cares objected to- Mr. Isabella" s. comment that Mr. Drew should ?sleep with? Ms. Cares, by asking him to stop and attempting to leave the restaurant. 72. MIC and Tylsa took. "adverse action against Ms. Caras that was causally connected to her protected activity. Mr. Isabella terminated Ms. 'Caras? employment in direct response to her request that he stop his sexist and threatening tirade. Other instances of retaliation include, inter ale, Mr. Alle?nder?s retaliatory harassment when Ms. Caras infermed him that she was contacting an attorney, and Mr. Allende-r making false statements abont'Ms. Caras? terminatiOn inan unemployment facte?nding; .interyiew before the Virginia Employment Commission in an attempt to disqualify her for unemployment bene?ts. 34 73. Defendants? conduct was: intentional, deliberate, willful, and conducted with reckless disregard for Ms. Cara-3? legally protected rights. 74. Defendants? actions directly and proximately caused Ms. ?Caras to suffer economic loss, including but not limited to salary and employee bene?ts, a loss of ?itnre pro?tssional opportunities and future" incenie, in addition to damage to her professional reputation, humiliation, indignity, personal embarrassment, and pain and: suffering. 75. Defendants took the actions complained of herein with actual intent to cause injury to Ms. Caras and "these actions were done willfully and maliciously. COUNT ASSAULT AGAINST DEFENDANTS ISABELLA, MIC, REQWHARF, AND TYISA 76. Plaintiff" hereby incorporates as though restated all. of the factual allegations. '77. I'Def-enclant Isabella engaged in physical attempts to cause a harmful or offensive contact with Ms. Caras? or to cause an. apprehension of such contact When he threw a calculator near her head on October 12 2017 and when he chased her throughl abella Eatery while shouting sexist sluts and threatening invectivcs either" during her termination on December 5., 2017. These. instances gave Ms. Clara's the apprehension of injury. 78. As a result of'Defendant Isabella?s action, Ms Caras suffered. and emotional harm, including fear, anxiety, loss of sleep, an inability to concentrate, and emotional distress. 35 79-. MIC, Rquharf, and Tylsa are liable for Mr. Isabella?s tortious conduct because he engaged: in the conduct as part of his and Ms. Caras? employment. Both .assaultive incidents occurred within the authorized time and spaee limits of their employment, while Mr. Isabella'was Supervising Ms. Cai'as? Work, and both incidents of aSSault "were in reaction to situations arising from and with their shared work and. celieagues, including Ms. Cat-as" termination from MIC. 80. As a direct and proximate result of Defendants? conduct, Ms. .Caras sustained injuries on OctOber I2, 2017 and December 5, 2017', and thereafter, including but not limited'to the harm and the continuing emotional harm of the trauma She experienced. 8'1. Defendants MIC, Rquharf, and Tylsa took the actions -c;0mplained of herein with actual intent to cause injury to. Ms. Cares and these actions were done willfully and maliciously. COUNT IV: BATTERY AGAINST DEF ENDANTS ISABELLA, ISMAIL, MIC, REQWHARF, AND TYISA 82. Plaintiff hereby incorporates as though restated all ofth'e factual allegations. 83. The District of Columbia, Virginia and Maryland prohibit as a battery the intentional, unpermitted, harmful or offensive contact with another person. 84. On many occasions within one?yea?r of today, Defendants Isabella and lsmail committed battery on Ms. Cares when they intentionally and without permission: grabbed Ms". Caras? hair and pulled her backwards to simulate p?eneti?ative sex; and touched Ms. Caras? hair or put their noses in her hair to smell it. Their physical contact with Ms. Caras was intentional, without permission, and constituted offensive contact with her body. Defendants MIC, Isabella, Ismail, Rquharf, and Tylsa tool: the actions complained of herein with actual intent to cause injury to Ms. Caras and these actions were done willfully and maliciously. COUNT V: PREMISES LIABILITY AGAINST AND TYISA 86. Plaintiff hereby incorporates as though restated all of'the factual allegations.- 87. Defendants MIC and Rquharf occupied, and/or oversaw employees who occupied, restaurant premises at Requin-at the Wharf at all times relevant. to this Complaint. Defendants acted as business invitors on October 2017, at which time Mr. Isabella assaulted Ms. Cares by throwing a calculator toward her head. 88. Defendants MIC and Tylsa occupied. and/or oversaw employees who occupied, restaurant premises. at the Isabella Eatery at all times relevant to this Complaint. Defendants" acted as business invitors on December 52 at. which time Mr. Isabella assaulted Ms. Caras by chasing her through Isabella Eatery While shouting threatening investi-ves at her and physically menacing her. 89. Ms. Caras was a: business invitee to the Requin and IsabellaEatery premises on October 12, 2017, and DeCember 5, 2017. :37 90'. As the possessors ochquin, Defendants MIC and'Rqu'harf had a special relationship with Ms. Car-as of business invitor and business invitee, giving rise to a duty to- protect her from she is upon the premises. 91. As the possessors. oflsabella Eaterya Defendants MIC and TyIsa had a special relationship with Ms. Cara's oti?busincss invitor and business invites, giving rise to a duty to protect her from assaults while she is upon the premises. 92. Defendants MIC- and TyIsa knew that MIC occupied its premises at Isabella Eatery on December 5, 2017. They also knew or should havelmown that Ml- Isabella was likely "to misuse alcohol while on the premises and hada history of erratic and aggressive behavior while ill the restaurant premiSe-s. They knew or should have known that'Mr'. Isabella had been drinking excessively on a near. daily basis in the several weeks leading up to Isabella public opening, which exacerbated his erratic and Violent behavior. 93. Defendant-s? actions directly and proximately caused Ms. Cares to suffer physical harm, substantial. and continuing emotional harm clue to the trauma she experienCed, and other injury. 94. Defendants MIC, Rquharf, and Tylsa tuck the actions complaintsd of herein with actual intentto cause injury to Ms. Cams and these actions were done willfully and maliciously. 13:8 Reg'uested Relief WHEREFORE. Plaintiff demands atrial by jury and prays this Cour-t for the following relief: 1. Enter a judgment in Ms. 'Caras? favor and against Defendants MIC, BallCantina. BallK-ap, BiallNoodle. Isabella. Bella, Rquh?arf, 'l?yI-sa. Allender, lsabella, Ismail, George- Pagonis, and Nicholas Pagonis for harassment on the basis of sex in Virilation of the District of Columbia Human Rights Act, Code 2-1401 .01 m; 2. Enter a judgment in Mr. Caras" favor and against Defendants MIC, Tylsa, Allender, and. Isabella for retaliation in-viol-ation of the District of Columbia Human Rights Act, DC. Code 3. Enter ajudgment in Ms. 'Caras? favor and against Defendants Isabella, MIC, Rquharf and Tysia for assault; 4. Enter a judgment in Ms. Caras? favor and. against Defendants Isabella, Ismail, MIC, Rquharf and. Tysia for battery; 5. Enter a judgment in Ms. Caras? favor and. against Defendants MIC, Rquharf and Tysia for premises liability; 6. Award Ms. Cal-as compensatorydamages for the pain and sullenngg damageto sateen and loss of enjoyment of life, that she has experienced as a result" of Defendants" Lmlawtill conduct; in an amount to be determined at. trial; .39 7. Award Ms. Cares punitive damages in an amount to be determined at trial; 8-. Award Ms. Caras back pay, front pay, and other amounts necessary to make her whole. for the Lmlawful actions taken against her; 9. Award Ms. Caras" reasonable attorneys? fees, litigation expenses, and costs; 10'. Enter an order enjoining Defendants, or each of them, to do all that is necessary in law or in equity to make Ms. Caras whole for the damages and injuries alleged herein; and 11. Award. Ms. Cares all other relief permitted under the above causes of action or which the court deems just and. proper. Respectfully submitted, .. f?f? Debra s. Katz (Baero. 41.1861") Kata, Marshall 86 Banks, LLP 1 71 8' Connecticut Avenue, Sixth Floor Washington, DC. 20009 P11: (202) 2299-1 140 Fax: (202) 299-1148 Email: katz@kmblegal.com 40 Dated: March 19, 21018 Lisa Banks (Bar No. 47094-8) Katz, Marshall Banks, LLP 1718 Connecticut Avenue, NW. Sixth Floor ?Washington, DC. 20009 Ph: (202.) 29941140 Fax: (202) 299?1148 Email: banks@kmblegal.com {?ww?vxf?g?zy'v?m?? Harini .Srinivasan (Bar No, 1032002) Katz, Marshall Banks, LLP 1718 Connecticut Avenue, NW. Sixth Floor Washingtom DC. 20009 Ph: (202) 299?1140 Fax: (202) 299?1148 Email: Attorneys for Plaintiff Chloe Cams 41 DEMAND Plaintiff requasts trial by jury as to all issues in this case. Date: March 19, 2018 if 133% s. Katz (Bar Nb. 4118-61) Katz, Marshall Baigksi LLP 17'] 8' Connecticut Avenue, Sixth F1001: Washington, DC, 20009 - P11: (202) 299?1140 Fax?: (202) 299-1148 Email: katz@kmblegal;com Attorney for Plaintiff Claras 42 Sueerim? Court of the Bistrie?: of Coiumbia CIVIL EEVKSEON. {Si-vii Aet?nne Branch 598 Endiene Avenue, DE. meal. Teiepimoe: {20:N8.- . . rxieii?w? Chloe Cares ?Piain?ff. Case Number Mike Babe-11a. Inc. Defend-am STUEWIMONS To the above named Defendant: You are Etaerem? summoned and required :0 serve an. Anewer to the attached either personaily or through an attomey, within twenty one (21) day's after? sewioe of this summons upon you?, exciusive of the day of Service. If you are being sued as an of?cer or agency ofthe United States Government or-the District of Columbia Government, you have sixty days. after service ofthis sumo'lone ?to serve your Answer. A copy of the Answer must be mailed to the attorney for the plaintiff who is suing you. The attorney?s name and address. appear below. If plaintiff has no attorney; a copy ofthe Answer: inns?: be maiied to the plaintiff at the address stated on this Summons. You are also required- to .?ie the original Answer with the Court in Suite 5000 at 509 Endiann Avenue, between 8:33 am. and 5:00 33mg, Mondays through Fridays or between 9:00 am. and 12:00 noon on Saturdays. You may ?le the original. Answer with the. Cour-t either: before you serve a copy of the Answer on the plaintiff or within seven days a?ea? you have serve? the plaintiff. If you faii to ?le an Answer, judgment by default may be entered against you for {he in the eompiaint. Debra K3132, Cfer?'c eff-.118 Com-"2? Name ofF] aintii?f?s Alterne'y Kate, Marshall Banks, By Address 171.8 Connecticut. Ave, Washington. DEC, 20009 203m299m1140 Date Deputy TC erk Teiephone See (202,) 879-4828 Veumez appeEer an (202) 8'19-4828pourune {reduction e? co me ha; den, hay goi (2'02) Ma?s?4826 bee?ng ewe-e? Mm?" More (202) (em-43828 exam-m YOU FAIL TO FILE ANS ANSWER WITHIN THE TIME ABOVE, OR if, AFTER YOU ANSWER, YOU FAIL TO APIJ-EAR AT ANY COURT YOU TO DO SO. A JUDGMENT BY DEFAULT MAY BE ENTERED AGAINST YOU FOR THE MONEY DAMMEES OR OTHER RELIEF DEMANDED IN THE COMPLAINT. IF THIS OCCURS. YOUR WAGES MAY BE XVIIA-CI-IED OR OR. PERSONAL PROPERTY OR EAL YOU OWN MAY BE TAKEN AND SOL-D TO PAY THE IUDGMENT. YOU TO THIS Act'r?IoN. no TO ANSWER if you wish to talk to a lawyer and fee! that. you can-not affofd? to pay- a fee to a 23mm; promptb-r contact one of me of?ces of the Legal Aid Society (202-628?1161) or the Neighborhood Legal Services for help or come 1'0 Suite 5000 at 500 Indiana Avenue, N.W., for more information concerning places where you may? ask for Such help. See reverse side for Spanish o?ensiation Vea a] dorso Ea a} espa?ol Super- Ct? Civ- R- 4 Superior Come of ihe District of Columbia CTVIL DEVESEON Civii. Actions. Branch 506 indiams Avenue? Suite sees Washington, DJC. 2-8983." Telephone: 87'9?1133? ?Website: . .9- ?"352? i 23?? ch15; Cares Plaintiff VS. Case Member Mike Tsabeiia Defendant To the above named Defendant:- You are hereby- summooed and. required to serve or: Answer to the attaci'ied Cmnpiaim, either personaiiy or through an att'or 1e}; within twenty one {21) days after service of this summons upon you, exclusive of the day of service. ?you are being sued as an of?cer or agency of the Unite? States Government or the District of Columbia. Govemn?ieoe. you have sixty days after service of?t?ois sun'o'noos- to serve your Answer. A copy of the Answer must be maiied to the attomey for the piaintiff Who is suing you. The ai?tormy?s name and address appear below. If piaio?ff has no attorney, a copy of the Answer must be maiied to the piaiotiff at the. address stated on this Summons. You *_re 3350 required to .?ie the. original Answer with the Court in, Suite 5000- at 5.630 iodiaoa Avenue: N.-W., beiweeo 8:30 am. and 5:289 pox, Mondays through Fridays or between 9:00 am. and i-2200 noon on, Saius?days. You may ?le the origioai Answer with the Court either before you serve. a copy of the rim-saver on the piaimiff or. within seven days after you have served the plaintiff; if you faii to .?ie ale Kinsmen judgment by default may be entered against you for the :reiief demanded in the eompiaim. Debra. S. Katz CIErkOfE?fre Cour: Name of iaifui ff?s Attorney Katz? Marshal}. 8.1 Banks, LLP Address 171-8 Connecticut Ave? X?v??S?hington, DC. 20009 202?? .299 ?114-0 Date Deputy Clerk 'I?elephone .113 (262') 879.4828 Veuiliez appeler em. {2702.) 879?4828 pour {reduction Be at) mot {xii dice, hay goi {202) 8?9~4828 wen-mo Marie (202)879?4828 eew?n? IMPORTANT: IF YOU FAIL. TO- FTLE AN ANSWER WITHIN THE TIME STATED ABOVE. OR IF, AFTER YOU ANS WEE. YOU FAIL TO APPEAR AT ANY TIME THE COURT NEYHHES YOU TO DO A JUDGMENT BY LT MAY BE ENTERED AGAINST YOU FOR THE- MONEY DAMAGES OR OTHER RELIEF DEMANDED IN THE IF THIS OCCURS, YOUR WAGES MAY BE ATTACH-ZED OR OR PERSONAL- OR REAL ESTATE YOU OWN MAY BE TAKEN AND SOLD TO PAY THE JUDGIVIENT. IF YOU MTEND TO OPPOSE THIS A CTION, DO NOT E415 TO THE REO HIRED Y?Li?i'. i?f?y?ou wish to talk to a loo-yer and {be} that-3'01! cannot afford to p23,)" a. fee [0 a lax-?oer, prompti?y contact; one ofthe of?ces oft?oe Legal Aid Society (2026284161) or the Neighborhood Legai Services (20%2796160} for help or come to-Suite 5000. at. 500 indiena Avenue, NAM, for more. information places where you may ask for such help. See side for Spanish translation Vea a1 dorso Ia traduecion a1 espa?oi [Rem June 2017?] Ct- PC 4 S-o oerior Court of she Bistriet o-f-Coiombia. CEVEL DEVESEON Civil Actions Bria och. 589 Indiana Arsenal-e, Suite S806Washingmn, ENC. 28061 Telephone: (2-32.) 87941333 Website: ww?wxl-ccout?gov In? #535 . Chloe Cams mama-3s? \3 Case Number Johannes Allender Defendant somssoss To the above named Defenc?iant: You are hereby summoned and. required to serve an Answer to the estate-bed Complaint, e'ltl-zer personally or through an attorney, Within. {?vs'ienty one days after sewioe of. this summons upon you, exclusive of the (lay of service. If you are 'belmg sued as an of?cer or agency of the Uniteo States Goyemmenrt or the District of Columbia Government, you have sixty days. after service of this summons to serve your Answer. A copy of the Answer must be mailed to the attomey for the plaintiff who is suing you. The attomey-?s name and address appear below. If. plaintiff has no attorney, a copy of the Answer must be mailed to the plaintiff at the address stated; on this" Summons. You are also required. to file the original Answer with the Court in, Suite 50-00 at 500 Indiana Avenue, N.W., between 3:30 am, and 5:06 p.311, Mondays through Fridays or'between 9:80 am. and 12:90 noon on Saturdays. You: may ?le the original Answer with the Court eii'her before you serve a copy of the. on the plaintiff or. within seven days after you. have served the plaintiff. lf yOu fail to ?le an Answer, judgment by default may be entered against you. {Or the relief demanded? in rho complaint. Kati? (jerk. of?zs Cour! Name of?Plalntifi?S Attofi'ley? I I I Katz, Marshall. Banks, LLP Address Deputy Clerk l?TIS-Com?leciicul Ave, Washington, DC. 2000le 202 2-99 M1140 Ba, Telephone (202)- 879-4?628 Veuiilez appeier so (202) 879.4828 pourune traduolion De to me? 153i dich, hay goi (202) 8?9'?4828 135mm saw mayo (5302) Ens?4326 mm: IF YOU. FAIL TO. AN ANSWER Wl'l?lvll'N THE-31 'l?lMlZ-I. ABC 0R IF, AFTER YOU ANSWER, YOU FAIL TO APPEAR AT ANY TIME THE YOU TO DO 30', A. JUDGMENT BY DEFAULT MAY ENTERED AGAINST YOU FOR THE MONEY DAMAGES OR OTHER. DEMANDED IN THE ll? THIS OCCURS, YOUR WAGES MAY BE OR OR PROPERTY OR REAL YOU CWVN MAY BE 1 AKEN AND SOLD TO PAY THE JUDGMENT.- IF YOU lbl'l?ENEl TO OPPOSE ?E?l-llS ACTION, DO NOT MIL To {ll-ifl?HKN THE HM. lfyo'u wish to talk to a lawyer and feel that you cannot affm'd to paya foe to a lawyer, contact one ofthe of?ces o?f'the Legal-Aid Society {202628-1'161) or the Neighborhood Legal Services (202?279-5100} for help or ?some to Suite 5000 at 500 Indiana Avenue, NAM, for more information concerning places where you may ask tor-such help. See reverse side for Spanish translation Vea aldorso la ??a'o'ucoi?n a} ospai?loi 10 {Res}. June 2017] Supsr- Cir Ci 4- Superior Coast of the District of Cohambia CIVIL {fivii Actions Branch" 598 {noises Avenue, N.W., Suite 5998 Washing?on, DIS. 28801 Teiephone: (2132) 8794133 Website: smvw?ccom?tsgev Ch be Cares Plaintiff Ease Nmnber Taha Ismail. De?fe?dmit To the above named.? Defenosnt: You are hereby summoned. and required to serve an Answer to the attached Con'ipiaint, either persona?y or through an attorney, Within twenty one (21} days after service of this summons upon you, exclusive ofth-e day of. service. If yes arebeisg sued as an of?cer or sgeoey? of the United States Government or ?le District. of Columbia Government, you have sixty days after service ofithis summons to serve your Answer. A copy of the Answer must be mailed to the attorney for the p?iaimiff who is suing you. The a?ome5-I?s- name and address appear below. If piaiuti??i?has no attorney, a copy of, the Answer must be maiied. to the p'iaiotiff at the address stated on this Summons. You are 21130 required: to. ?ie? the o-xi'igioai Answer with the Court? in So?re 5000 at 560 {noises Avenue, between 8:30 am. and. 5:09 through Fridays or bet-ween 9:00 21.31}. and 12:00 noon on Saturdays. You may ?fe the originai Answer with the Courteither before you serve a. copy of the Answer on. the plaintiff. or Within seven (7) days after you have served the plaintiff. if you fsii to ?le an Answer, judgment by default may be entered against you fOr the re?t-3f demanded in {he complaint. Debra 8 Kate Clerk-qf?fhe Cow? arse oi?LP] aimifi?is- Ka-tz, Marshall ?2 Ban-ks, LLP Address 1.??18 ConnecticuL Washingmn. DC. 20009? Dep my Clerk Telephone (2,02) $94828 Veuiifaz appeisrau {202) 879-4828 pourune goi (202} $944828 was? acme news (-202) 379?4328 :5st IF YOU FAIL. TO. FILE AN ANSWER STATED ABEWEI. OR YOU AN YOU FAIL TO APPEAR AT ANY TIME- THE COURT NOTIFIES YOU DO 30, A JUDGMENT BY MAY BE ENTERED AGAINST FOR THE MONEY DAMAGE-S OR OTHER RELEEF DEMANDED ZN 131E COMPLAINT. 1F THUS {3&1le; YDUR. WAGES MAY BE ATTACHED OR 0R PERSONAL. OR REAL ESTATE YOU. OXVN MAY BE. TAKEN AND SOLE TO THE JUDGMENT. VOU INTEND T0 UPPOSE THIS ACTION, ?4112 TO :41 WHEN THE RED WEED Hts-{E Ifyou wish ?to talk to a lawyer and feel theta-'01; cannot afford to pay a foe to a lawyer, contact one ofthe of?ces of the Legal Aid Society {202628-1161} or the Neighborhood Legs} Services {202?279-5100} for help or some to Suit-e 5000 at 500 Indiana Avenue, NW ., for more information concerning pieces where. you may ask for such help. See-reverse-side for Spam-sh translation Vea a} dorso [a tradu?ocion a} elsps?ol CV6 HO. [Rev June 201?] Super. C1. Civ. R. =1 S-nperior Coert of the 'Bistr'iet of Celembia CIVIL DEVES EON. Actions. Branch. 582?} Endiana Avenue, N.VV., Suite. 59.00 washiogton, EMS. 2&001 'I?ei?eyht?nie: (262) 877-94133 W'e?hsite: -thw.-deeourts.gov Plaintiff . Case umber Georgei?gynus Defendant To the above named- Defendant: You are hereby summoned and. required to serve as} Answer to the. attached Com'piaitit, either or through an attorney,. within twenty? one days after ?service of this summons upon you, exeiusive of'the day of service; if you are being sued as an officer or agency of the United States Govemment or the District- of Coium?oia Govemment, you have sixty (60) days after service ofthis summons to serve your Answer. A copy of the Answer must be mailed to the attorney for the piaintiff who is suing you. The a?ttomey?s name and. address appear below. if piaintiff has no attoniaey? a; copy of the Answer must be maiied to the piaii'iti'ff at the address stat-ed. onthis Summons. I I You are. also required to ?le the original Answer with the Court in Suite 5000- at 500 tedious Avenue, N.W., better-cert 8:30 3331. and 5":00 $1.111;j Mondays through Fridays or between 9:00 am. and 12:00. noon on Saturdays. You may ?ie the original Answer with the Court either before. you serve a copy of the Answer on the piaintiff or within. seven (7) days after you. have served the plaintiff. if you faii to ?i?e an Answer, judgment. by default may be entered against you for the relief demanded io "the eompiaiut. . - - 8. ., Katz Cheek of?ie Court Name of-Pi'aiotif? Attm'ney I I I I Kate, Marshall {it Banks, LLP By Ad dress ?Deputy Clerk 1718 Connecticut Ave, 2000(5-j Date Teiephone (202) 879?4828 Veumez appeier am (202)- 879?4828 pour une traduetion o? as me: be dgch. hay goi (202) 8794482- ri?e?? (202) 8794828 exam? IMPORTANT: 1? YOU FAIL TO FILE AN. THE ABOVE, GR iF, AFTER YOU ANSWER. YOU FEEL TO APPEAR AT ANY TEME THE COURT YOU TO DO A. JUDGMENT BY DEFAULT i?v-iA?r' Bi} ENTERED AGAINST YOU FOR THE MONEY DAMAGES OR RELIEF IN THE 1? THIS OCCURS, YOUR WAGES MAY BE ATTACHED OR OR FIBRSONAL PROPERTY OR REAL. ESTHIE YOU OWN MAY BE TAKEN AND SOLD TO PAY THE JUDGMENT. ii?" YOU INTEND l?i?i-i?iEI-S ACTION, DD 1591115 TO Livi?fin?N THE REQIHRED TIME. it?you wish to taik to a iawye'r and fee} that? you cannot afferd to pay a fee? to a iowyet, contact one oi?the of?ces ot'the Legal Aid Society {202-629-1168 or' the Neighborhood Legai Services (202?279-5108) for heip or come to Suite .5000 at 500 Emotions Avenue, for more'iniin'mation concerning places \s-?here you in gay ask for suoh'heip. See reverse side for Spanish transiotion Vea 3i dorso la traduoc-ion a1 espa?ol '10 [Rev June 2017] Super. Ct. Civ. R. 4 Superior Court of the District of Coiumhia (31V EL DEVESEGN Civil Actions Bra rich SGG'izi'di-aua Avenue, NAM, Suite 5999 Washington, DAG. 26801 "feiegizone: (202-). 879-1 133 Website: 'Piairitiff vs, . . Case Number Nicholas Pagoms SUMMONS To the above named De feudmzt: You are hereby- summoned and required to serve an Answer to the attached Complaint. either or through an attomey, within twenty one days after service of this summons upon you, exclusive of'the day of service". if "you are being sued as an of?ce-r- or agency of the United States Goveuu?uei?it or the District of Coiumbia you have sixty days; after service of'this summons- to serve your Answer. A copy of the Answer must lie maiied to the attorney for the. piaiutiff who is suing you. The attorney?s name and address appear beiow. priaiutit?f has no attorney, a copy of?ie Answer must be maiied to the plaintiff at the address started outhis Summons. You are ais-o required to "file the original Answer with. the Court in Suite 5000 at 500 findiaua Avenue, N.W., between. 8:30 am. and 5:00 p.111, Monday-s through Fitidaye or. between 9:00 am. and" 12:00 on Saturdays. You may ?ie the originai Answer with the Court either before you serve a copy ofthe Answer on the plaintiff of within "seven days after you have served the piaintiff. If you faii to ?le an Auswe?r, judgment by ciefauit may be euteregi againstyou for the 'i'elie'f demanded in the. oompiaint. a itXatZ Cferkof?ie Cozm? Name of Plaintiff 55- Attorney Kate, Marshall 81 Banks, Address 17?18 Cmmocticut Av=e., DC. 20009 202w299m1140? mm Deputy ietk Teiephoue ill} $15.5 {292). $94828 appeier an (202) 8?9-4828 pour une traduotion Be- ed 3116;; goi (202?) Wise? rim?? {New (202.) Miro-m IMPORTANT: YOU FAEL TO FELE AN WITHIN THE STATE-D ABOVE, OR IF, AFTER YOU ANSWER, YOU FAIL TO APPEAR AT ANY TiiviE- COURT YOU TO DC.) 80, A. JUDG MENTBY DEFAULT BE ENTERED AGAENST YOU FOR THE MONEY DAMAGES OR CHEER RELIEF REMANDED 3N THE THEE OCCURS. YOU-R WAGE-S MAY BE OR \B?ITiinii-Shi) OR PERSGNAL OR REAL YUU OWN MAY BE- TAKEN AND SOLD TO PAY THE JUDGMENT. IF YOU T0 OPPOSE THIS ifyou wish to talk to a iax-vyer and feei that you cannot afford to pay a fee to a- iawyer, promptiy contact one of the offices of the Legal Aid Society (202628-4165) or the iiN-?eighborhood Legal Sen-ices .{202~279~5100) for help or come to-?Suite- 5008 at 500 Indiana. NEW, for; more information concerning pieces where- you may ask for such help, See reverse side for Spanish u?an'sizuion \z?ea aldm?so 1a u-aducciien a} es'pa?oi CV 31 10 [Rev Jun-:? 2017] Super. Ct. Civ. R. 4 Superior Coert of the Districtof Cqumbia. CIVIL DIVISIGN Civii Actions Branch S'G?'Indiana Avenue, NAM, So?e 5990' Washington, 33.8. zoom Teiepho-ne: (262} 879-1133 ?Webeite?: ChIoe Cares Plaintiff VS. Case Number . BailCantioa, LLC Defendant SUNIIYIGNS To the above named Defendant: You are hereby summoned and required to serve an Answer to the attached Compiaint- either person-211?: 3' or through an? attorney Within twenty one {21} (1633?s after service- of this summons uoon {.033 exeiusive of the {1213' of service. If vou are being sued as 211'} officer or agency of the United States Government or the Distr iet of Cqurn'nia Government, you, have six}; {68} 513.35 after service of this summone to serve your Answer A copy of the Answer must be mailed to the attorney for the plaintiff who is suing you. The attorney's name and. address appear beIow. If plain??' has no attorn ey, a copy ofthe Answer must be maiied to the plaintif'? "at tIte address stated on this Summons. You are aIso required to take the original ?yer with the 00:1 in Suite 5000 at 500 Indiana Avenue between 302?: and 5: '00 m. Mondays throw 10th Frida3s 01' be tween 9:00. am. and 12:00:10013 on 523361512135. ou 111.543er the or igioai Answer with the Court either betore you serve a copy of the Answer on the pIaintiff or within se?ren (7) days. after you have served the plaintiff. If you fail to ?le an Answer, judgment by defauit may be entered against you for the .reIief demanded in the complaint. Debra 5 KEIZ Cleric office Court Name ot?PIaintiI?f mics-nay Kate. Mar-eha?. Bank 1-3.3 Address I Deputy ?1'718, Connecticut Ave, NARA, DC. 20009 202m299-j140 Date 'I?eIephone {202) V'euil'iez ap-peier an (202') 879-4828 pour one traduetion Be ed dich, 11-55ng} {202} 879-4828 ear-?223' imam New (202)879-4828. Yam-:3 IMPORTANT: YOU TO FII AN ANSWER WITHIN THE TIME STATED ABOVE OR IF, AFTER YOU ER. YOU FA TO APPEAR AT ANYTIME COURI IES YOU TO DO S0 A DGIVIE .YB DEEAU IT MAY BE. ENTEREE) AGAINST GU TOR THE MONEY MAGES GR OI RE I DEMANDS-D IN THE COMPLAINT IF THIS OCC URS YOUR AY BE ATTACI OR I) OR PERSONAL QR, REAL ESTATE YOL I OWN AY BE TAKEN AND SOLD TO PAY THE JU DGIVIENT IF YOU OPPOSE THIS ACTION. DO A-OT FAIL TO 4 IHEREOUIRED TIME. you wish to 13-114 to a. 1513 Jyer- and tool that you cannot afford to {32333 at?ee? to a Imwer. contact; one oi the of?ces of the Legei Aid Society (202 628- or the Neighborhood Lego} Servi ees (202 279- 510.0) for heIp or .5. eome to Suite 5{ 000 at 503 Indiana, tor more infomm?on concerning p'Iaees ?here 3031 11.18.35.- 5x tor- such] telp See reverse side for Spanish translation Yea aI dorso Ia tradueei'on aI espa?ol I0 [Reva June 20?] Super. Ct Civ. E. II Superior Cam?? 0f the {Bis/iris: 0f Col-ambia Civii Actions Branch 500 En?ian?a Avw 139, NW. Suite 50.00 0.6 2000.1 Te?iephon?e: (-202) 879?1133 Website: ?11100 Caras Piaintiff VS. Case Nu BaHKap, LLC Defendant To the: abmi'e- named- Defandam: You. are 'hercb 1' 31111111101160 anci required to serve an Answer 01 the a?ached Compiaim, either 1361301121113? 01' ?uough an 311011.163, 11111101 {went}. one (21) days after service 01? this summons upon you. exclusive of the 01? 36.111106. If you are: Wing sued as an Of?ce; (3'1 agency of the United Stat?s m" the you have sixty (60} days aftm service of this 13111111119115 10 serve you: A'nswa; A cepy of the A115 1811111151 be. ma?ed to the 211120111632 for the plaint?'f who is suing 3/00 The attorney- 5 name and address appear below if plaintiff has 110 a?orney, a copy of the. Answer must be maiied to the plaiht-iffaf the address Stated 011 this 3111;311:0115; You 31 a. 21.330 1001.111 ed 10- f0 6 the original; Answer with the Court 111 Suiie 5000 at 500 diana Avenue NW. between 8: 30 a 111. 311515 :00 13111.,Mo1 day-s through 1? 1166.33 or between 9: 00 {1.1114110 12: .00 11001.1 on Saturdays. You ma3'1??e the originai Answer with the Cou? either befme. you serve a copy of the. on the piaimiff 01' within seven days 306:1" you. T121111: served the plaintiff. if 3100'. faii to P01: an Answer. judgment by default may be. entered against you 011' the"reliefdemanded1?11. the. campiaim. DSbe C?ZeI-kofrfze Cox-{rt Name of'PTaim.iPPsAttorney Kat'z, Marshall ?Banks, LLP Address I I I Deputy Cierk 1718 (jenneci'icm Ava, Washington, DC. 20009 Cd *4 Talia-phcme 3&1? {202) 82?9-4828 V'euiliez appeier 311. {202'} 879-4828 pour une Vaduz-?an ?13 11161 b?i dick, hay gg? (202) 879?4828 5% i?hd?lcif' (202)879-4828 mm- IMPORTANT: IF YOU FAIL TO FILE AN ANSWER WITHIN THE TIME STATED ABOVE, OR IF, AFTER YOU ANSWER, YOU FAIL TO APPEAR AT ANY TEME THE COURT NOTTFTES YOU TO DO 80, A JUDG MENT BY MAY BE ENTERED AGAINST YOU FQR THE IVJIGNE-Y DAMAGES. OR OTHER RELIEF TN THE COMPL TP YOURNVAGES MAY BE ATTACHED OR WITHHELD OR PERSONAL PROPE i OR REAL ESTATE YOU OWN MAY BET '1 4?1 KEN AND SOLT TO PAY THE- IF YOL.I INTE ND TO QPPOSE THTS ACTION. DO OT E411you wish 110 talk 10 a ?31 391* and 166 i that you cannot afford 10 pay a fee to 11' {1111:3613 contact one ofthe of?ces ofih?: Legal Aid Society (2023.28 1161) the Neighborhood Legai Services- {202279-5100) for help 01' come- to Suite 5000 211.500 Indiana. Avenue. for mere inibrmation consuming plaeas where 3-1111- may ask for such help. See reverse side! for Spanish translation Yea. a! dorsola Lraducci?n. ai 631361-001 10 [Rev 111115 20.17] Super. CL Ci?e? R. 4 Superior Court of the Disiriet 9f Ceiambia 131912 1919191019 Civil Actions Branch Rex 569' Eadiana Avem1e,N .WW. Suite 56% WW ashington, 31C 2680} ?g (282) 879 M33 Website; ts. gev a? w" \M25-c" Chloe Ca r-a Plaintiff Y3- Case Number BaHNoodle, LLC Defendant the above named Defendant: You are hereby san'zmoeed and required to serve an Answer to the attached Complaint either pe1sonaiiy or through an aaomey within twe nty one 1? days aftei service of this summons upon me eeroSiVe of the dav of service. 31? yea are being sued as an of?ce: 01' agency the United States Gave mmeat the District of CoEum 31a Goaermneat; you have sixty (60) days after service of this summons to serve 50111" Answer. A copy of the Answe; must be mailed (a the attorney .1o1' the plaintiff who is swag you, The attorney?s name and address anpear beiow. 'Efplaintiff has 110 attorney, a copy o-Fthe Answer must be maiEed to The plaimiff at the address state-d on {i119 Summons You are also. required to If?; Ee the originai Answer with the Cour-t 1'11 Suite 5000-91. 500 {Indiana (avenue between 8: 30 3.11:. and 5: 00 p. 1115950116399 three-Uh indays or between 9 a. and 12:00 noon on Satuxdays. You 111ay1?13e?1e 'ori?inal Aaswe 1' with the C0111: eithet before you. servea copy of the Anse- er en the piaiatiff 01'? Within seven (I days aftel you have served the piainti'f'f. if you ital} to ?le an Aaswex judgment by defauf it may be eatered against 90 1 for the demeaded 111 the complaint Debra S. Kata (:29 I2 ofae Cams: Name of fFEaintiff? .I-thomey Kate, Marshall 8: Banks, LLP 3, Address Deputy Clerk '3718Com'1eeit'ioui NW. Washington DC. 292 299 1140 am 1919?1911099 931 (202) 879?4828 Veuiliez ap-peler an (232} peur-un?a U?aducfjon Br?: matbai dieh, hay - (2192') 8.794828 ,esiai-n- YOUF FAIL TO. FELE AN ANSWER WITHIN THE TIME STATED ABOVE, QR IF, AFTER YUU ANS WER, YOU FAEL A1 ANY TIME THE COURT NOTIFEES YOU TO DO S0. A JUDGMENT B. BE ENTERED AGAENST YOU 7OR THE. MONEY DAMA ES OR OTHER RELEEF DEMANDED TE 1'1) COMPLAINT. EF TI {18 OCCUR S, OE- IR WAG-FHHE.-D OR PERSON .IXL FRUFERI UR REAL ESTATE YOU OWN MAY AREN AND SOLD TO. PAY THE IF YOU INTEND T1) OPPOSE TRIS ACTIUN, DOINOT FAIL TOAFWZSIIVER THEREOUIRED 2195213. Ifyou wish to talk to a lam-yer and fee} that you cannot afford. to pay :1 Fee .11) a lawyer arompdy contact one of the eihees of the Lega! Aid Society E61) 01' the TI-leighborhood. Legal Sewices (202?279~5 fer help or come to Seize 5000 at 500 {adiana.A.-Ven11e, 19,191,191 more information concerning places-where you may ask for such heip. See reverse side for Spanish transiai'ion Vea al 1101130 Ia a! espa?el June. 2017] Super. Ct. Civ. A Sis-eerie? Conn of the District of Columbia. CIVIL Civii Actions. Branch 58%} india?a Avenue, NWK, Suite 583.9 washing?on, 1M1 20881 Teieghone: 87943.33 Website: Plaintiff VS, CaseNumber lsabe?a Belle, Defendant To the above named Defendant: You are hereby summoned and required to serve an, Answer to the aiteehed Compiaim; either persona?y or through an attorney? within twenty one days after sewiee of this Summons upon, you, exclusive ofthe day of Service. If you are being sued as an of?cer or agency of the United States Government or the District of'Coi'umbia Govemmeng you have sixty (68) days after service of'this summons i0 Serve your Answer. A copy of the Answer must be mei'ied to the attorney "for :?the- piaintiff who is suing you. The attorneys name and" address appear below." If piaintiff has no attomey, a copy of the Answer must be maiied :o the plaintiff at the address stated on this Summons. I You are also required to ?ie the original Answer with the Court in Suite. 5-000 at 500 iodiana Avenue, between 8:30 am. and 5:00 pm, Mondays through Fridays or between 9:00 am.- and 12:00 noon: on Saturdays. You may ?ie the originai Answer with the Courteither before you serve a copy of the Answer on, the piain?ff or within. seven days after you. have served the piainti-f? if you fail to ?fe an Answer, judgment by default may be entered against you for the: relief demaraded in ?the compiaint. 1)be a S. Kati? ('33er ofrhe Cow? I?Name ofiPleimist Attorney I I I Katz, Mar-shall anks, LLP Address Deputy Clerk 1-7718 Connecticut Ave? Washington. 20005! 202~299m114o Em Te?aephooe SEE 33.3 (202) 879?4828 Veuiliez ?appeier au (202} 8799-4828 pour une iraduetion new met bei dish, hay 3:01 {202) "87954828 '7?:ij mag-Tar (202)879-4828 1F YOU FAIL TO FILE AN ANSWER WITHIN THE STATED ABOVE, OR US, AFTER YOU ANSWER, YOU FAIL TO APPEAR AT ANY THE COURT YDU TO DO SO, A JUDGMENT BY MAY BE ENTERED AGAINST YOU FOR THE MONEY DAMAGES OR OTHER RELIEF DEMANDED IN THE OCCURS, YQUR WAGES MAY BE ATTACHED OR WETHHELD OR FERSQNAL PROPERTY OR REAL ESTATE YOU OWN MAY BE TAKEN AND SOLD TO- THE JUDGMENT. IF YOU INTEND TO OPPOSE THIS ACTION, DO NOT Fix-1H; TO 1' BEN THE REOMRED 3115. ?You wish to taik to a lawyer and fee] that you cannot a?brdbuyer, contact one of the of?ces af?ne Legal} Aid Society (202-628?1161) or the Neighborhood Legal Services (202?279-?510m for help or comegto Suite 5008 at 500 Endiena Avenue, NW ., for more information cone-emi?g pieces where you may as}: for such help. See reverse side for Spanish translation Vea a} dorso {a traducci?n a} 'espe?o} CV61 10 {Rev June 2817} Super. Ct. Civ. R. 4