MARK MULICK, ESQ., P.A.

50 CHURCH STREET MONTCLAIR, NEW JERSEY 07042 (973) 746-7400 Fax (973) 746-9430 Attorney for Plaintiff LANISE JACKSON Plaintiff

v.
THE BROWNSTONE HOUSE, INC., ALBERT MANZO, TOMMY MANZO, ROBERT MANGER and JOHN DOES ONE THROUGH TEN Defendants

:
: : : : : : : :

Plaintiff, Lanise Jackson residing at 142 North 7th Street, in the City of Paterson, County of Passaic, and State of New Jersey by way of Complaint hereby states:

Th
are presently unknown.

eW
COUNT ONE Broadway, Paterson, New Jersey. 2. owner of The Brownstone House, Inc. 3. part owner of The Brownstone House, Inc. a manager at The Brownstone House, Inc.

1. Defendant, The Brownstone House Inc. conducts business in New Jersey with offices at 351 West

Defendant, Albert Manzo at all times resided in the State of New Jersey and was the manager and part

Defendant, Tommy Manzo at all times resided in the State of New Jersey and was the manager and

4. Defendant, Robert Manger at all times was a resident of the State of New Jersey and was employed as

5. John Does One through Ten represent persons responsible for plaintiff's injuries and whose identities

ra p
COMPLAINT AND JURY TRIAL

: : : :

SUPERIOR COURT OF NEW JERSEY LAW DIVISION: PASSAIC COUNTY DOCKET NO.: PAS-LCIVIL ACTION

6. Plaintiff, Lanise Jackson was first hired by defendant, The Brownstone House, Inc. on or about October 2011. She stopped working for The Brownstone House, Inc. in April 2012. Plaintiff left the employment of The Brownstone House, Inc. because her

7. In September 2013, plaintiff returned to reside in New Jersey and resumed employment

with defendant, The Brownstone House, Inc. because she could not find other employment, given the high unemployment rate in northern New Jersey at that time.

8. Plaintiff continued to work for defendant, The Brownstone House, Inc. until November

9, 2013 when she was constructively terminated as she could no longer endure the racial, sexual, ethnic and country of origin epithets hurled at her hourly.

Th

eW
seq. at plaintiff and other employees: a. "Bitch" c. "Spic bitches"

9. During all periods of employment for defendant, The Brownstone House, Inc. plaintiff

worked as a waitress/server. During all times that plaintiff was employed by defendant, The Brownstone House, Inc. she experienced a hostile work environment and disparate treatment in violation of New Jersey's Law Against Discrimination N.J.S.A. 10:5-1 et

10. During the period of time that plaintiff was employed by The Brownstone House, Inc. Mr. Tommy Manzo, Mr. Albert Manzo and Mr. Manger directed the following epithets

b. "fucking stupid bitch"

d. "Lazy motherfuckers" e. "Stumbling motherfuckers"

ra p
2

residence changed to Pennsylvania.

f. "Fucking screw up." 11. Defendants spoke to plaintiff and other employees in this manner on hundreds of occasions. On one occasion defendant, Tommy Manzo said to plaintiff, "Are you

12. Plaintiff was forced to endure the above mentioned epithets on an hourly basis during

the course of her employment. Plaintiff was also forced to work in a filthy unhygienic atmosphere as defendant, The Brownstone House, Inc.'s facilities were roach-infested.

13. Defendants' conduct constitutes LAD prohibited hostile work environment based upon ethnicity, race, sex, country of origin, and

14. disparate treatment in violation of N.J.S.A. 10:5-12(d).

Th
.

eW
distress. violated N.J.S.A. 34:11-56 a4.

common law torts of constructive discharge and the intentional infliction of emotional

15. Plaintiff reasserts the contents of Paragraphs 1-13 as if set forth at length herein.

16. During the course of her employment plaintiff worked in excess of forty hours per week. However, plaintiff was never paid time and half overtime. Defendants' conduct

WHEREFORE plaintiff demands judgment against defendant for all damages

compensable under N.J.S.A. 10:5-1 et seq., including but not limited to, compensatory and punitive damages, lost wages, emotional distress, legal fees, etc.

ra p
Defendants also violated COUNT TWO 3

blind? What are you, Chinese? Open your eyes."

R.4:5-1 CERTIFICATION 1. The matter in controversy in this case is not the subject of any other action

pending in any court or of any pending arbitration proceeding.

3. 4.

I do not know the names of any other parties who should be joined in this action.

I certify that the foregoing statements made by me are true. I am aware that if any

of the foregoing statements made by me are willfully false, I am subject to punishment.

Dated: December 2, 2013

Th
4

eW
Dated: December 2, 2013

Plaintiff demands trial by jury on all issues between the parties. _______________________________ Mark Mulick, Esq. Attorney for Plaintiff

ra p
_______________________________ Mark Mulick, Esq. Attorney for Plaintiff JURY DEMAND

2.

No other action or arbitration proceeding is contemplated by me.