9mm CHARGE OF DISCRIMINATION Charge Pressman To Agencyilefl Charge NOW: ramminmwm. Secondde my rmm. nam- admpr Mm IE EEOC AMENDED and EEOC Sim armaer iluiy m, mm. mm, WW Ms, amen swear -- -- mum." Cny,51amundll9EURod= Named is Employer, Labor Organlzallun, Employmenl Agency. Appremmnip Cummings, or sun or Local GovemmenlAuunq aelrev- Lalsaiminilnd Malnsl M- or 0mm mm marl Mu. list unflw FARVICULARS bslow) Nam um" Flam u: (imam- cm; Twin Peaks, Orland Perk/Twin Restaurant Orland Park LLC 20+ 972-541-3150 sum Marv:- cm, 5m: 1w cm. 5151 Bell Line Road, Suile 1200 Dallas. TX 75254 Tm. m. mm pm. Ma (mum. cm, ram mm any1cm Hawaii-re mm>> was. DISCRIMINAYION 700K me: mm ms COLOR I RELIGION wromdmew 4/23/17 Rmumon AGE Drsasluw ammo mmxumon ems>>? (Sp-cw! '3 minimum ACYION in: marrow>>: An: (ifmmnonalpapuit mam, men erm- mum) During my employmem at Twin Peaks. located in Orland Park. Illinois, I believe I was discriminated against based on age, sex (female) as I was sexually harassed; and addilionally, I believe I was retaliated againsl, including constructive discharge, fol objecting lo said sexual harassment, prolecled activities in violation at me Civil Rights Ad of 1964, as Amended. PLEASE SEE ATTACHED AMENDED COMPLAINT AND EXHIBITS mm <EEOC Form 5 - Amended Complaint of Sarah Blavlock was hired as a bartender by Twin Peaks Restaurants, located in Orland Park, Illinois, on or about April of 2016, in anticipation of its grand opening shortly thereafter. I signed a ?Twin Peaks Job Description? employment agreement, consenting to wear an ?approved Twin Peaks Girl Uniform.? Exhibit 1. The Uniform was not explicitly described; however, it consisted of short shorts, a v-neck shirt provided by the restaurant, knee-high socks, and boots.1 Exhibit 2. Over the course of my employment, management provided us with different shirts, from time to time. Exhibit 3. The shirts exposed cleavage and a very small section of midriff, which I did not mind wearing. Approximately six months into my employment, management implemented ?dress-up days,? forcing me, and all other female waitresses and bartenders, to wear inappropriate clothing similar to what one would see in a strip club; including, but not limited to, lingerie and bikinis. Exhibit 4. For sports team theme days, we were forced to purchase team shirts then cut them down to inches, essentially only covering our breasts. Exhibit 5. In the dead of winter, we were required to wear bikinis for ?Snow Bunny Week.? Exhibit 6. For Christmas, I was forced to wear underwear that exposed the lower portion of my buttocks. See Exhibit 6. We were told, ?Less is more.? We were forced to pay for all of these costumes out of our own pocket, costing me hundreds of dollars. For the avoidance of doubt, Twin Peaks is a restaurant and sports bar. It is not a strip club. Additionally, I never contractually consented with Twin Peaks to purchase or wear any clothing other than the provided-for shirts. We were not given an option to refuse wearing these costumes; in fact, it was compulsory. Management told me, ?If you don?t like it, you can leave.? I feared I would lose my job if I did not comply with the dress-up days, despite feeling uncomfortable. For the week of Valentine?s Day, 2017, management instituted ?Sweetheart Lingerie Week,? requiring all bartenders and waitresses to purchase and wear lingerie that revealed the lower portion of our buttocks. Management took pictures of us in lingerie and posted us on their public social media accounts. Exhibit 7. On February 10, 2017, Orland Park police of?cers visited Twin Peaks after receiving ?numerous complaints regarding servers at Twin Peaks wearing lingerie that was very exposing in nature.? Exhibit 8. I was not present on this date. 1 Picture taken on opening day in the ?Twin Peaks Girl Uniform.? Page 1 of 3 EEOC Form 5 --Amended Complaint of Sarah Blaylock According to the police report, upon officers' arrival, they "observed almost every employee dressed in lin erie that exposed their buttocks." Officers advised managers dam: --that the women were in violation of the local ordinance for indecent exposure. Following a verbal warning, the managers assured the officers they understood the ordinance and promised to comply. See Exhibit 8. On February 11, 2017, the ve next day, I wore the required lingerie for my SChedUled Shift. In factfl'lemanded I send pictures of myself in said lingerie to obtai his approval. Earlier in the week, on February 7, 2017. Twin Peaks posted a picture of me in said lingerie on its lnstagram account. Exhibit 9. I did not want to take a picture in lingerie, nor did I want it to be posted online; however, Ifeared retaliation if I objected. Upon my arrival to work that day, management told me about the police visit and warning but said to disregard them because the lingerie was not illegal. Management insisted that I 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- -- 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, I 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. I consistently asked about the status of the ticket and we always received the same answer: "Do not worry about it. We handled it." I did not find out until recently, through my attorney Tamara Holder, that Twin Peaks hired an attorney,-- on my behalf and without my permission. He pleaded rne liable for the offense, without my consent. Exhibit 13. Additionally, _never notified me of the 35-day right to appeal; and as a result, this convrotion is now permanently on my record. I am a nursing student and tear 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 i 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." I was rarely given a break. attempted to eat during my shift, I was accused of being fat. --often said to us, "Somebody doesn't want a good tone grade." if he saw us eating. After most shifts. I went home tarnished and dehydrated. Sometimes, frequent customers that knew we were not allowed to eat offered to buy us meals. lwas 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 -- or gave him illegal drugs, received a higher grade. I always avoided him for this reason. As a result, however, my grade often suffered. Additionally, -- 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. --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 I 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." I constantly worked in fear of degradation. as well as retaliation. Finally, in April of 2017, I stopped coming into work, as I could no longer handle the hostile and abusive work environment that caused me, and continues to cause me. extreme t' nal distress. Signed: Name: Date: March 6. 2018 Page 3 of 3 . Peaks Girl to interact with entertai n! and I - . on female sex appeal. it is addition"l ally. - to the guests. The Twin PeaksGirllmagg - . 1'1 chars star is what makes . theTW ea . guestwho Visits will bsentem lned m?Pby? 25.9 .. 'I-rbesedonfemaiesex his appeal. When-tan: -z [Wmn?al that each mncPeah-gl?s ul go and Costume Standards that demand-"a: RESPONSIBILITIES . .. responsibilities eta Twin PeaksGirlincluderm 1.. 1 'me ??399 and Cosmme Standard 7 s. mm mermwm .1 . . andspeclaigitgg 'yf .. 44} Modeling? withg t- - and/or EXPERIENCE - prior experience or training required. Modeling or acting experience may be helpful. LANGUAGE SKILLS Ability to effectively communicate in the English language. Must be able to read and understand tin men write ring in tickets. and utilize a computerized register system. Must be able to suggestiveiy sell menu items. :l?iust mime ly with guests in order to entertain. to communicate effective ut simple one- or two-step instructions. Ability to deal with at change and REASONING ABILITY onsense understanding to carry 0 bias. Ability to mathematically compute prop Ability to apply comm standardized situations with only occasional or no varie accurately settle checks. tiined in the Twin Peaks Girl training book. Must rior to working a shift without supervision. LICENSES, REGISTRATIONS to policies and procedures as ou nos with local and state Must attend Orientation and agree attend and successfully complete the Twin Peaks Girl training program late any and all other required training in compile Must successfully attend and comp vnglations, such as food and/or alcohol service certi?cations. those that must be met by an employee to successiuliy do to enable individuals with DEMANDS dations may be me the pr. [$1533 demands described here are the representative of ?from the essential functions of this role. Reasonable accommo hesitates to perform the essential functions. Employee initials: lit-vised September 2010 EXHIBIT (CONTINUED) Irudum muTwln tarry onsets. wound. or oonhuh' ma mm. The Mn Peak! EH II ma Employee Name (Print) -- 5pm.: 515mm. w: Parent/Guarth Sllnatura Du: Parent/Guardian Name (Print) (If emulayee is undzr 13) Supervilm' Name (Print) Supervisor Signature Di'l I .. nun-uh>> M10 EMPLOYEE COPYRIGHT ACKNOWLEDGEMENTME . FULL RELEASE or CLAIMS at?? Mill FEMS in connection with my employment with Twin Res taurant and or a A . - A franchisees ('Twrn Peaks") as a Twin Peaks Girl I ny af its affi photographs and/or images (collectively, "Works") taken of me during my employment?? tr; Sinai-ts agents, representatives, parents, af?liates, successors or franchise??sand for Whiczidvefegts and representatives, are the sole and exclusive property qr? a? copyright thg?weiks holds the perpetual, irrevocable right, title, interest and. ow" in . any derivatives thereof, and any other intellectual prom?; connection therewith, individually or as part of a collective work or ii perpetual. irrevocable right to use, reuse, publish, republish, incorporatesdis'i and/or sell, in A whole or in part, in any media and for any lawful use?jeeinelqgi it were I acknowledge. andagreei?i limitation, illustration, promotion, advertisingand trade. -- in consideration 0* my employment, and for . l. 15., we, repmse 1 I. ?azm-Ing own behalfandoniuehg?ge?q 1, 1. To the extent any are ever determinedto belongtto'me; undenany'?n .t 54?? . revocabe rig to copyright, the Works, any derivatives thereof, and any other intellectual property rights arising in connection therewith, individually or as part of a collective work or compilation, and the perpetual, irrevocable right to use, reuse, publish, republish, incorporate, distribute, import and/or sell, in whole or in part, the Works and its derivatives in any media and for any lawful uses, including, but not by way of limitation, illustration. promotion, advertising and trade. 2. I hereby grant to Twin Peaks, its agents, representatives and assigns, the perpetual, irrevocable right to use my name (or ?ctional name) and/or likeness in, connection with, the Works and/or any other lawful business use including, but not by way of limitation, in media, promotion, advertising or trade. 3. hereby waive any and all rights to inspect or approve the Works and any derivatives thereof now or in the future, whether that use is known to me or unknown, and i waive any right to file any legal actions, whether in contract or tort; whether at law, in equity or under statute, including claims for libel or invasion of privacy, based on any use of the Works or any derivatives thereof under this release. 4. I hereby voluntarily agree to release, defend and hold harmless, and covenant not to sue Twin Peaks, its officers, directors, parents, subsidiaries, affiliates, franchisees, predecessors, successors, legal representatives and assigns, and those acting with their authority and permission, including but not limited to, any ?rm publishing, distributing or otherwise using photographs of me in whole or in part, whether on paper or via Electronic media (cnIIet'meM the "Mhiae's'i. demands, damages, tauses i mpensafion on account of. or ln'w all Guardian signatura: fl Gunman Mm (Print): Date: "Harlem's; Date:_ Date: I Data: . I Data: (also acknowledge thatStandards, Makeup, Hair. Fitness. a Healthy Glow. and Nutrition a? mrouuhout my employment. Fallun to adhero to Image Standards will load to dhcipllnary action up to and Including termination. IFTH PLO ElLegal Guardian Signature: Date: Legal Guardian Name (Print): Date: . Employee Signature:_ Datez_ Employee Name (Print): Date: Manager Signature: Date: Date: Iguana! Name (Print): - .- Orland Park Pouce Department man Ravlnr- Ave Orland Fm. IL 50432 CASE REPORT Pending Final Rayon Rwlaw Approval "92017410021854 2110/2017 15:14 mnmm. 2110/2017 45:14 n'umlvr: 15:24 Ordinance Violatians Open semiannual: TWIN FEAKS 02/10/201715100 02/10/2017 15:00 15154 RD gamma 1L OFFENSES mm a (us SUBJECT 1 "Mm Subiec! . Auun (mum Mme ms wwu a 26 a "mm mm): umm mm mm mm: mm wwva :2 an Ala-mm>>? [a Jug mam: MI) 0 In a mg. mwm,m stun/Ant: IAVKOC mm av Fiugibbon ergilnu M. 02/10/2017 02/10/2017 Rosinski Kenneth J. Orland Park Police Department I 5100 mini. Ave Orland Park. II. amz "2017-00021854 CASE REPORT Pending Report Review 522mm NARRATIVE .J On DZI1DI17 at 1500 hours, 1 (Officer K. #706) and Officer Losurdo #749 were advised by Chief McCarthy of possible ordinance violations occurring at Peeks, 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 wearan were in clear violation ol the conduct of Licensee village ordinance. We spoke to managers --and the violations. The explained the employees were dressed in that manner tor a promotion the restaurant was running for "Lingerie Week' aWexplained the village ordinance in detail and advised their employees were In vIolalion. and-were advised to ensure all of their employees were In compliance with the ordinance by 1730 hours. -and _rvere told if they were not In compliance with the ordinance at that time, they and all employees still in vlolation would be Issued Municipal Violation cltatlons. At 1730 houre, Lt. Sinko, Oto. Loeurdo, and returned to Twin Peaks. We walked around the restaurant and observed all of the employees were now in compliance with the ordinance. All at the employees now had on larger shorts which covered their buttocks completely. We spoke to _who stated he had purchased new short: for the employees to wear so they would be in compliance. -assured us there would be no more violations of this ordinance In the future. I have nothing lurther to report. HEMWW am new Fitzgibben, M. 0211 0/2017 02/10/2017 Rosinski, Kenneth J. 07:47 am emu a-mon w..me Orland Park Police Department 15m NaviniaAvu "92017410022543 omna Pam. IL am: :11 "2011 15:15 EV m1m17 1II1S F-- vapor: Ram mum: 2I11I2017 19:16 Ordinance Violations Open 5 um;;?fi? TM a 02/1 1/2017 19:16 13154 LAGRANGE RD ORLAND PARK IL mm mic:ch 1 29391144: Recall Liquor Conduct of Licensee "mm" I a a A I 15mm: Wm .m mix.>> Arreslee TWIN PEAKS, (705)590-6293 16154 LAGRANGE RD ORLAND PARK, IL 50457 m- <>: I: {mm-Mme man a mums-mt ms! mummy" 3 mamaqu m'mmumx wallet 2 mm wwiwueumm Wme in Wm numavmms . 02I11l2011 lenski ulna M. 02/11/2017 Kenneth J. Orland Park Police Department man manta Ave "32017-00022543 0mm 9am IL M45: 2/11/2017 10:19 2/11/2l117 (5:16 P-naiwLanI Roam Rem mm mum. 2/11/2017 19:16 Ordinance Vlolatlons Open .. Mummy. (mwuwvu' Wfim i 02/11/201719:16 02/11/201719z16 15154 menus: RD ORLAND PARK IL mm Any/M 1 2 a A run: Mum." mama-m BLAYLOCK, SARAHmumumam GBP50 WK thus m102/11/2017 02/11/2011 Kenneth J. 01/20/2017 04:13 mu Cum-m mum Orland Park Police Department 15109 anlnla AW omna Pm. IL 50452 Pending FIMI Egon Revlem Approval NARRATIVE On 02/11/16 at 1916 hours, I (Officer K. #705) and Officer Losurdo #749 were advised by Lieutenant Sinkc #102 there was an anonymous citizen complaint regarding the employees at Twin Peaks (16154 Lee range Rd) wearing lingerie that was very exposing in nature. The same type of complaint was also received on 02/10/17. On 02/10/11, Officer Losurdo. Chiei 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 their employees change lnto 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. All employees changed and were in compliance later that day. See general case report 2011-21854 for in rther Information regarding that incident. On today's date, Officer Martyn #127 and i went into the restaurant in plaln clothes to see It there were any violations. When we entered, we observed an employee, later Identified as-- --at the trout of the restaurant with her buttocks exposed. -was wearing underwear which only covered a portion oi the top of her buttocks. As Officer Martyn and I walked throughout the restaurant, we observed three other em Io ees with their buttocks exposed. The emiloyees were later identified as --, and Sarah Blaylock. - and Sarah were all wearing underwear which only covered a portion oi the top of their buttocks. - - -, and Sarah all had underwear that left the majority of their buttocks exposed. All the remaining staffwere In compliance with the village ordinance. We spoke to --iha manager who was advised or the village ordinance on 02/10/17. .tated he believed all his employees were In compliance with the ordinance We explained to _iour employees were in violation. We explained to - and Sarah the reason they were in violation oi the statute was due to their buttoc emg exposed. -- and put on larger short: which now covered their buttocks. -and Sarah had garments over their underwear that they pulled down to cover their buttocks. When we initially observed-no Sarah, the garments over their underwear were pulled up leaving their buttocks exposed. All subjects were brought into the manager's ofllco. The business was Issued an MV citation for Conduct of Licensee The business' citation was given to - - - and Sarah were Issued MV citation: for Conduct of Licensee (295917-4421). All subjects were advised of their mandatory court date omit/14117 at 1330 hours at the Orland Park civic Center. memo when our: s~ M. 02/11/2017 02111I2017 Roelnski, Kenneth J. 02/20/201704fl: mu Clea mm m-zc: . Orland Park Police Department 15100 Ravlnia Ave Orland Park. IL 80482 cm'201 7.0002 2543 CASE REPORT Pending Final Report Review Approval NARRATIVE CONTINUATION At 2130 hours, Of?cer Losurdo and I returned to the business. We veri?ed all employees were now in compliance with the village ordinance. have nothing further to report. WM OFFICER DATE Fitzgibbon, M. 02I11I2017 02I11I2017 Rosinski, Kenneth J. 0212012017 04:13 OPPD Case Report Page 4 OF 4 030110117011 VIOLATION 7m 0P (1an 11. 000mm 01" 000ml Incident No.? ?Dhte Tie ??otation Unifi MVO3884O 17-22543 02/11/2017 7:16 16154 Lagrange Rd 0 Report No. Section Number 1 Violxtiomiption - HEARING 317?22543 1010 Chap: 0.000 Sec: 0 Par: 1 05 09 2017 3% 1 Conduct Of Licensee Date Th: undamgned hasyamona} howica?ge?afrhc toirh? rr'a?l?edfam'. Time 1300 P111 ?5 Complainant Name Issued by (:ignamn) 1d a 1-. .1. ?0 Fitzgibbon 706 Location #4750; i Sex ace~ 551mm . Social Securitv ?15110013150an4! ?State' Tele aneNum?ber Orland-Park, ?hm? FINE (If Paid-?1241- Dua Date) Q5 D05 D11: Police Fame Ib'appaar a! :50 hearing or pay rke?ne (if qucabie) will read! in. the imposf?un [a '5 d1 Maii $971154 Wort-421m decadence With applicabk 1am cm - Finding Decision Liable 05/09/201 7 Fine Assessed 100.00 Judgement Total 100.00 Paid: 100.00 Duo: 0.00 09:09:36 Full Compliance by 06/13/2017 05/25/2017 Payment Received 02/02/2018 Finding, Decision and Order Prepared. 05/09/2017 Finding, Decision and Order Prepared. 04/11/2017 Continuance Date Requested. 03/14/2017 Continuance Date Requested. EXHIBIT