(d) Oftentimes when a large-breasted female would enter the club, Mr. Black would call over another male employee directing him to look at the large-breasted patron saying, “Hey, there ya go; did ya see those?” and similar such comments regarding female patrons’ breasts.
(e) There is a swinging door entering the bar area. A female employee inquired as to if she could go over the swinging door and Mr. Black responded, “No but you can be under…” sneering and indicating a sexual position.
14. Defendants’ Nighthawk Bar created a continual hostile, offensive environment for Ms. Williams. As another example, there was a private evening lingerie party on October 21, 2008, open only to selected VIPs where women from a lingerie store paraded around in see-through lingerie. This party included a menu of sex toys that could be bought by the VIP patrons. The sex toy menu was printed by Nighthawk and inserted into their regular menu so that the sex toys could be considered and purchased.
15. Ms. Williams has been extremely damaged by the treatment she has been subjected to. She has been humiliated, emotionally unsettled and has felt anxiety and depression as a result of being regarded as unsightly by management and denied her usual work post. Further, the sexual harassment by Defendant Black and the sexually-charged environment has caused her to feel a lack of self-esteem, emotional distress and depression.
FIRST CAUSE OF ACTION
(Gender Discrimination in Violation of Gov’t Code 12940 et seq. Against Defendant HBZT and DOES 1-50)
16. Plaintiff repeats and realleges the allegations set forth in paragraphs 1 through 15 and incorporates the same by reference as though fully set forth herein.
17. Defendants subjected Plaintiff to gender discrimination by treating her as a sexual stereotype, directing her to lose weight, treating her as a sex object and treating her differently than her male counterparts, as described hereinabove, in violation of the California Fair Employment and Housing Act, California Government Code § 12940, et seq. No males were directed to lose weight or be slim.
18. At all relevant times herein Plaintiff was an employee of Defendants within the meaning of California Government Code § 12926.
19. Plaintiff is informed and believe and based thereon alleges that in addition to the practices enumerated above, Defendants may have engaged in other discriminatory practices against her which are not yet fully known. At such time as such discriminatory practices become known to her, Plaintiff will seek leave of Court to amend this Complaint in that regard. (See Part 5 of 8.)
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