sxc Fom (08) CHARGE OF DISCRIMINATION Charge Presented To: —_Agency(ias) Charge Note) Wis forme acid he Pracy Aol 1974. See rosea Pavan At Stem ant oer ramet bee npr nn ee oe X] FEOC AMENDED and EEOS Seaman Tae (dene Mr Me Wea) es Ms, Sarah Blaylock a — Siesta ‘ly, Sais and 2 Coe Named iste Employer. Labor Organization, Employment Agency, Apprenticeship Corvities, or ial or Local Government Agenoy That | BaTowe Diserminaied Against be or Other. (if mare tan Mo, lat under PARTICULARS below Narne | Ra Empcyenn, Manes ‘Phone Ne. (include Area Code) ‘Twin Peaks, Orland Park/Twin Restaurant Orland Park Lc 20+ 972-941-3150 Sate Cy Bam wd Cow 5151 Belt Line Road, Suite 1200 Dallas, TX 75254 — a ry or) Seana Ch Sand Coe SCRANTON REED OW (So aT TOT SITE) DECRIUNATON TOOR FE Time Caer race [TJooon [p] ex ee ee apa? Z] semamon [ps2 [7] oeeury GENET NFORUATION [omen oon cow ACTON ‘THE PARTIGULARS ARE (Vda Baers atid aaah Ora shea] During my employment at Twin Peaks, located in Orland Park, Illinois, | believe | was discriminated against based on age, sex (female) as | was sexually harassed; and additionally, | believe | was retaliated against, including constructive discharge, for objecting to said sexual harassment, protected activities in violation of the Civil Rights Act of 1964, as Amended. * PLEASE SEE ATTACHED AMENDED COMPLAINT AND EXHIBITS {want tis charge fle wah both the EEOC and te Stato or local Agony, any. 1 | NOTARY — When nachna Se wd aoa RoRray PGUTOTOT \wilatise tne agences change my aderees cr pone umber one 2operae fly with them nthe proceasng of my charge mn accordance wth thie procedures {wear o fem tat have read the above charge and tat fs hue To "Geciare under ponaity oF paqury tal he above ue and core. ‘he best of my knowlodge, formation and beet SIGNATURE OF COMPLAINANT / s/s/ is i[EEOC For § = Amended Complaint of Sarah Blaylock | wos tired as a bartnder by Twin Peaks Restaurants, located in rand Park, Minis, on or about Apr of 2016, in anticipation of He grand opening shorty thereat | signed a “Twin Peaks Job Deserbtn” employment agreement, consenting to wear an “approved Twin Posts Git Unform. Exhibit 1 The Uniform was hot fexpliy described; nowever, consist of short short a veneck ait provided by ie restaurant, knee-high Socks, and boots" Exot 2 Over he couse of my ‘employment, management proved us with dferort shins. kom tna tote, Echo The shits exposed cleavage anda vary smal ection of rif whieh | ‘id nat mind wearing. ‘Approximetely sie months into my employment, management implemented “ress-up days foreng me, and all ther female watresses and bariondere, 0 wear inappropriate clthing similar to what one would see in a stip club, Inctusing, but nt ed to, ingore and bikini: Exh 4 For spots tear tome ays, we were forced to purchase team shits thon cut them downto Inches, seen only covering Gu roasts. Exh 5, Inthe dead of winter, we were required to wear bins for “Snow Bunny Week" Exo 6 For Christmas, Iwas forced to wear underwear tht exposed the lower poran of my butlocks, Seo Exhibit We were to, Lose mora” \We were force to pay forall ofthese costumes out of our own pocket, coating ‘me hundreds cf colar. For the avoidance of doubt Twin Peaks a restaurart and sports bar is nota stip cub. Adationay, I never contractual consented wah Twin Peaks to purchase or wear any cating ther than the provised for shi, We were nat given an onion to refuse wearing these costumes; infact, i was compulsory. Management tod me, "i you dont tke i you can leave." feared | would lose my job i id nt comply wih the dressup days, despite folng Greomtonatie For the week of Valentine's Day, 2017, management initutes “Sweetheart Linger Week.” requtg al bartenders and walvesees fo purchase and wea linger that revealod the lower porlon of our buttocks. Management took Pictures of usin ingere and posted us on thew’ puble social medi beeaunt, Exit (On February 10, 2017, Orland Park palce officers vised Twin Peaks afer Teoeiing “Rumerous complains regarding. sewers a Twin Peake wearing lingerie that was very exposing in ature” Evi & I wes ot present on this oteEEOC Form 5 ~ Amended Complaint of Sarah Blaylock According to the police report, upon officers’ arrival, they “observed almost every employee dressed in lingerie that exposed their buttocks.” Officers advised managers :: (ENN a ts jrornon ere sion of the local ordinance for indecent exposure. Following a verbal waming, the managers assured the officers they understood the ordinance and promised to comply. See Exhibit 8 On February 11, 2017, the very next day, | wore the required lingerie for my ‘scheduled shift. In fact RE omancd | send pictures of myself in said lingerie to obtain his approval. Earlier in the week, on February 7, 2017, Twin Peaks posted a picture of me in said lingerie on its Instagram account. Exhibit 9. did not want to take a picture in lingerie, nor did I want it to be posted online; however, | feared retaliation if | objected. Upon my arrival to work that day, management told me about the police visit and warming but said to disregard them because the lingerie was not illegal Management insisted that | still wear the lingerie and reveal the lower half of my buttocks. Again, Orland Park police received anonymous complaints on this date. When plain clothes officers returned to Twin Peaks, they observed me, and three other female employees, with exposed buttocks. According to police, ‘Manager I (MME stated he believed all his employees were in compliance with the ordinance.” Exhibit 10. In front of patrons, the officers demanded the women go into the managers’ office. Once in the office, officers individually ticketed me and three other women for “Conduct of Licensee (waitress with exposed buttocks).” Exhibits 11-12. Humiliated and terrified, | put on a pair of shorts and completed my shift. The managers then told me, and the other female employees, they would “handle” the tickets and we did not need to appear in court. | consistently asked about the status of the ticket and we always received the same answer: “Do not worry about it. We handled it” | did not find out until recently, through my attomey Tamara Holder, that Twin Peaks hired an attorney, ‘on my behalf and without my permission, He pleaded me liable for the offense, without my consent. Exhibit 13. Additionally, INNINMI never notified me of the 35-day Tight to appeal; and as a result, this conviction is now permanently on my record. !am a nursing student and fear this will adversely affect my ability to get a job. Being criminalized for following Twin Peaks’ orders to dress like a stripper is not my only complaint. In addition to being forced to wear sexually revealing clothing, we were also Subjected to a grading system. Exhibit 14. Page 2 of 3EEOC Form 5 — Amended Complaint of Sarah Blaylock Several months after | was hired, management instituted a grading system and “Ranking Report.” Before every shift, we were ordered to line up against the wall, and then they graded us on our hair, makeup, and “tone.” The managers took Pictures of us, and degraded our appearance based on their subjective opinions of our stomach, legs, arms, and buttocks. If we were too fat, in their opinion, we received a low grade. This grade determined where we were placed in the restaurant. If we received a low grade, we were penalized and placed in a section with few customers. We were not allowed to eat during our shifts. We were only offered a free meal off of the “spa menu.” | was rarely given a break. If | attempted to eat during my shift, | was accused of being fat. IINNINNE—Moften said to us, “Somebody doesn't want a good tone grade,” if he saw us eating. After most shifts, | went home famished and dehydrated. Sometimes, frequent customers that knew we were not allowed to eat offered to buy us meals. | was rarely given a break, as required by law. But there were ways to increase your grade: For example, it was common knowledge that women who slept with [II or gave him illegal drugs, received a higher grade. | always avoided him for reason. As a result, however, my grade often suffered. Additionally, MINN often recruited strippers, who were under the age of 21, to work as bartenders, adversely affecting my bartending shifts because | was older and not a stripper. He bragged about changing the payroll codes to avoid getting caught The “dressing room” did not have a door. Exhibit 15. A video camera was installed at the entrance to the room. See Exhibit 15. NNN often closed the blinds to his office to watch video of us changing, This “dressing room” was located adjacent to the kitchen. The male cooks consistently “cat-called” and harassed us. The area was so hostile that | stopped changing at work, and instead dressed at home. There was no sexual harassment training. There was no human resources department. The managers consistently told me, “If you don't like it here, you can leave." | constantly worked in fear of degradation, as well as retaliation, Finally, in April of 2017, | stopped coming into work, as | could no longer handle the hostile and abusive work environment that caused me, and continues to cause me, extreme} nal distress. Signed: Name: Date: March 6, 2018 Page 3 of 3REASONING ABILITY Le ce ee | SRSehcermray eccrine ea CERTINCATES,UCENSES,REGSTRATIONS Creare Ces tye upsets uote nie Wn Pak sti sienna So ae Bivona ore pe ating wie SEN. FEES Secor ayant ate rubs boing ln canner oes nah ood nao Sea sven eaten om Siete menos sacoea oes reoyoa ts sceny aoe ee aie a rams Sc rrm i sca tctone eiayen tis: ered September 2010‘also expressly acknowledge that Twin Peaks maintains policies expressly reeticing Haraaa' Guo end alcoho! Sbuss. | sico xprossly sckrowledge thet Twin Peake maining a policy of performance bane. sBaduting. | understand completely and agree to abide by each of mese policies. Employee Name (Print) Employee signature Date Parent/Guardian Signature one Parent/Guardian Name (Print) (if employee is under 18) I Supervisor Signature : Date 4 ‘Supervitor Name (Print) 4 Cantamber 2010concn th ny ego th Tn sa LE nor ‘arches (Ton ea un els Ene acedeea soca lor wag st, Wer} ee ne og ‘Spyro ay sews hero on yar lca Pope She connect therewth,owasiy ome part of = ease wre Splat, ad the perp, evcable ret ie, ese btn ep, ‘Report, anvte, ingot s/o sa, nw or hp, the Wore oS ‘rvtes nny mec aa fr ny leben. Du at wa aon, ‘Stator, averting ade 2 thereby arate Twin eas, Re agents represented tgs he pret teevcaie ht to ue my rma etoral ne) andor tees, connection Wh the Wr andlor any ote wl uss nung, ut not by way Instat needa, omoton sdverngor ae, 2 herby waive any andl igs Inset approve the Ware and ary desttes thor tow orn he hate whether bat se own to mee elgew, 6 Wah “iy rah ofan gl aeons, whether in conratortort whether egy {nde statue ncn enor Keto ivason of rae Basedon ary sect. ‘Rewer ean ceriaver ere! ander erlea.| 4. thera vane geet reese, deter are olé harmless, an eenart noo Twin este, ofc, decors, pores suns, oats, fancies, predeceirs ices lege represeiatves an sins, ad thse aig with tel tory ard parm ining but ot led oar rm publsig atibting tretheruae tng photographs fe Inwhele orn pasta on pepe ovelectronic media (collectively, the "Releasee’s"), from, ' demands, damages, causes of compensation on account of, or in any | ‘harm to me which may arise or occur thereof, and any other intellectual pro| eo se Sere | Lagat arian name (nge —_____—el | eryee Sorat: = employee Name in» =p=) Orland Park Police Department ; 15100 Ravinia Ave «=2017-00021854 I Cee we conmiorume. 2102017 1826 ~ CARE REPORT sree serene. 29012017 18:24 Paning Final Ropar Review Rpprval = | 2/10/2017_15:24| Ordinance Violations Open § roms — armen me oe (* [02/10/2017 18:00] 02/10/2017 18:00 | jo1s4 LAGRANGE RD ORLAND PARK I paw Te OFFENSES: [Subject Poa : ‘Subject ant sai § Eg re — on prec ia _ aE rT c a C — r = Fitzgibbon, Krystina M. 02/10/2017Orland Park Police Department 15100 Ravinia Ave Orland Park, 1. 60e62 “°2017-00021854 (CASE REPORT Paanding Final Repon Review Approval NARRATIVE ‘On 02/10/17 at 1500 hours, | (Officer K. Fitzgibbon #706) and Officer Losurdo #749 were advised by Chief McCarthy of possible ordinance violations occurring at Twin Peaks, located at 16154 LaGrange Rd. Chief McCarthy advised us the village received numerous complaints regarding servers at Twin Peaks wearing lingerie that was very exposing in nature. We went to Twin Peaks and observed almost every employee dressed in lingerie that exposed their buttocks. The clothing the employees were wearing were in clear violation of the Conduct of Licensee village ordinance. We spoke to managers SS and ( cgarding the violations. The explained the employees were dressed in that manner for a promotion the restaurant was running for “Lingerie Wook” Neng jexplained the village ordinance in detail and advised their employees were in violation. pit hes advised to ensure all of their employees were in compliance with the ordinance by 1730 hours, Aililand were told if they were not in compliance with the ordinance at that time, they and all employees still in violation would be issued Municipal Violation citations. At 1730 hours, Lt. Sinko, Of. Losurdo, and | returned to Twin Peaks. We walked around the restaurant and observed all of the employees were now in compliance with the ordinance. All of the employees now had on larger shorts which covered their buttocks completely. We spoke to [EEE who stated he had purchased new shorts for the employees to wear so they would be in compliance. IEE assured us there would be no more violations of this ordinance in the future Ihave nothing further to report. “Fitzgibbon, Krystina M. 02/10/2017 02/10/2017 | Rosinski, Kenneth J. 02/47/2017 07:47 ‘PPO Cave Reson PapeOrland Park Police Department 115100 Ravinia Ave Orland Park, IL 60482 (CASE REPORT ending Final Report Review Approval + 2017-00022543 Penrone. 2HROIT 19:16 meson atene. 2AVQT_ 19:16 | 24/2017 ia 19:16[ Ordinance Violations nea Open eae rare [Ramo some aaa Sa a 02/11/2017 19:16] 02/11/2017 19:16 16154 LAGRANGE RD ORLAND PARK IL — = [*/2989/7-4-23 Retall Liquor Establishments; Conduct of Licensee Saenk E bir } cae pea — Arrestee TWIN PEAKS, (708)590-6293 [16154 LAGRANGE RO_ORLAND PARK, IL 60467 5 ee c Beene a ai Fitzgibbon, Krystina M, 02/11/2017 2114/2017 _| Rosinski, Kenneth J. 0 EXHIBIT 70‘Orland Park Police Department 15100 Ravinia ave Orland Park, IL 60462 CASE REPORT 2017-00022543 ertoiomeme. 24412017 19:18 suaseene. 242017 19:16 anding Final Report Review Approval eRe 2/11/2017 _19:16 PRR [22047 19:16] Ordinance Violations ‘pen NE oaisarzot7 19:16 oanti20t7 18:16] te cero ORLAND PARK iL ir = = — £ 5 BLAYLOCK, SARAH, M : ee a 5 a Fee on acta oer SAS TE i — ie J is > e a. E a 3 ae REET TO ae ne ae |Arrestee . os ieee o_o Fitzgibbon, Krystina M. 02/11/2017 02/11/2017 Tesinakt, Kenneth J, 2202017 _04:13 (PPD cae Repat Page 3.0 4Orland Park Police Department 15100 Ravinia ave Orlane Park, IL 60462 “2017-00022543 CASE REPORT Pending Final Report Review Approval NARRATIVE On 02/11/46 at 1916 hours, | (Officer K. Fitzgibbon #706) and Officer Losurdo #749 were advised by Lieutenant Sinko #102 there was an anonymous citizen complaint regarding the employees at Twin Peaks (16154 LaGrange Rd) wearing lingerie that was very exposing in nature. The same type of complaint was also received on 02/10/17, On 02/10/17, Officer Losurdo, Chief McCarthy, and { went to the restaurant and spoke to the managers on scene. The managers were advised of the Conduct of Licensee village ordinance and told to have employees change into clothing that is in compliance with the ordinance. ‘The managers were also advised the business and any employee in violation of the ordinance would be issued Municipal Ordinance citations. Ail employees changed and were in compliance later that day. See general case report 2017-21854 for further information regarding that incident. On today's date, Officer Martyn #727 and | went into the restaurant in plain clothes to see if there were any violations. When we entered, we observed an employee, later identified 2s amma (EEE at the front of the restaurant with her buttocks exposed. I was wearing underwear which only covered a portion of the top of her buttocks. As Officer Martyn and | walked throughout the restaurant, we observed three other employees with their buttocks exposed. The employees were later identified 25 Aj.—_ EE, and Sarah Blaylock. —, (GERBB and Sarah were all wearing underwear which only covered a portion of the top of their buttocks. RS GE, anc Sarah all had underwear that left the majority of their buttocks xposed, All the remaining staff were in compliance with the village ordinance. Wo spoke to SEE the manager who was advised of the village ordinance on 02/10/17. HBB tated he believed all his employees were in compliance with the ordinance. We explained to MEEEfour employees were in violation. We explained to = am MB and Sarah the reason they were in violation of the statute was due to their buttoeke Betyg exposed. WRB and MEE put on larger shorts which now covered their buttocks. Wand Sarah had garments over their underwear that they pulled down to cover their buttocks. When we initially observed [IEEEland Sarah, the garments over their underwear were pulled up leaving their buttocks exposed. All subjects were brought into the manager's office. The business was issued an MV citation for Conduct of Licensee (2989/7-4-23). The business’ citation was given to [ii i HH and Sarah were issued MV citations for Conduct of Licensee (2989/7-4-32.1). All subjects were advised of their mandatory court date of 03/14/17 at 1330 hours at the Orland Park C Cente Fitzgibbon, Krystina M. 02/11/2017 02/11/2017 | Rosinski, Kenneth J. 02/20/2017 04:13 ‘OPPO Cas eset Page OF 41 Police Daparent ont le 2017-00022543, NARRATWE CONTUATION 'A82120 nour, Offcor Logue and | returned othe business. We verified all aployees were now in complance with the vitage ordinance. hve nothing further roport Fasgbbon Kosina Mowat eatiaor7 [Rosin Kenneth canoe 69lo = ee oe make oom aera ee lo ! ee | EAT Fas ae tetse grange ta a Cs hss occa ae Oeste te saeg aera rare [mere sie sere =a 6 Sete cae | el tom Se ] . | Giiiamanmeme | OW Blaylock) Sarah 6 Fa Pet De Ba off —f sears ert Pa tna tly nin te apa | or [O[ Srrvrecticrarenteaserat seore |B c HEARING INFORMATION Maree wy ountats SA” pg tone STATUS INFORMATION