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

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

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

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: : : : : : : : COMPLAINT AND JURY TRIAL

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: COUNT ONE 1. Defendant, The Brownstone House Inc. conducts business in New Jersey with offices at 351 West Broadway, Paterson, New Jersey. 2. Defendant, Albert Manzo at all times resided in the State of New Jersey and was the manager and part owner of The Brownstone House, Inc. 3. Defendant, Tommy Manzo at all times resided in the State of New Jersey and was the manager and part owner of The Brownstone House, Inc. 4. Defendant, Robert Manger at all times was a resident of the State of New Jersey and was employed as a manager at The Brownstone House, Inc. 5. John Does One through Ten represent persons responsible for plaintiff's injuries and whose identities are presently unknown.

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

residence changed to Pennsylvania. 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. 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 seq. 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 at plaintiff and other employees: a. "Bitch" b. "fucking stupid bitch" c. "Spic bitches" d. "Lazy motherfuckers" e. "Stumbling motherfuckers"

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 blind? What are you, Chinese? Open your eyes." 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). Defendants also violated

common law torts of constructive discharge and the intentional infliction of emotional distress. COUNT TWO 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 violated N.J.S.A. 34:11-56 a4. 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. .

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. 2. 3. 4. No other action or arbitration proceeding is contemplated by me. 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

_______________________________ Mark Mulick, Esq. Attorney for Plaintiff

JURY DEMAND Plaintiff demands trial by jury on all issues between the parties. Dated: December 2, 2013 _______________________________ Mark Mulick, Esq. Attorney for Plaintiff