Case 1:11-cv-02052-RBW Document 5 Filed 02/06/12 Page 1 of 8

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA
Briggitta Hardin,

v.
Mick Dadlani
and
Red Line DC, LLC

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)
Plaintiff, )
)
) Civil Action No. 1:11-cv-02052 (RBW)
)
)
)
)
)
)
)
Defendants. )
ANSWER
TO THE COMPLAINT

Defendants Mick Dadlani (hereinafter, Dadlani) and Red Line DC, LLC (hereinafter,
Redline), by and through counsel, hereby Answer the allegations contained in Plaintiff Briggitta
Hardins (hereinafter, Plaintiff) Complaint as follows:
RESPONSES TO INDIVIDUALLY NUMBERED PARAGRAPHS
Nature of Action
1. Defendants deny that Plaintiff was employed by Redline. Defendants admit that Dadlani
is an owner and a manager of Redline. The remainder of Paragraph 1 states a legal conclusion to
which no response is required but, to the extent that it can be construed as alleging facts, it is denied.
2. Defendants admit that Plaintiff is African-American. Defendants deny the remaining
allegations contained in Paragraph 2 of the Complaint.
3. Defendants deny the allegations contained in Paragraph 3 of the Complaint.

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4. Paragraph 4 of the Complaint constitutes a prayer for relief to which no response is

required. To the extent a response is necessary, Defendants deny these allegations and further aver
that Plaintiff is not entitled to any relief whatsoever.

Jurisdiction and Venue

5. Paragraph 5 states a legal conclusion to which no response is required.
6. Paragraph 6 states a legal conclusion to which no response is required.
Parties
7. Defendants admit that Plaintiff is African-American. Defendants admit that Plaintiff
was and is currently employed at Bar Louie, an establishment that is located across the street from
Redline. Upon information and belief, at all times relevant to the allegations contained in the
Complaint, Bar Louie employed Plaintiff as both a bartender and a server. Defendants deny that
Plaintiff was employed by Redline. Defendants are without knowledge or information sufficient to
admit or deny the remaining allegations contained in Paragraph 7, so it is denied.
8. Defendants admit the allegations contained in Paragraph 8 of the Complaint.
9. Defendants admit that Dadlani is the primary owner and operational manager of
Redline and that he is responsible for day-to-day operations and management decisions regarding
Redline. Defendant admits that Dadlani is also responsible for hiring and terminating employees,
but that this responsibility is shared among other Redline manager(s). Defendants admit that
Dadlani is the registered agent of Redline. Defendants deny any remaining allegations contained in
Paragraph 9 of the Complaint.
Factual Allegations
10. Defendants deny the allegations contained in the first two sentences of Paragraph 10 of
the Complaint. Defendants are without knowledge or information sufficient to admit or deny the

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allegations contained in the last two sentences of Paragraph 10 of the Complaint, so it is denied.
Upon information and belief, Plaintiff worked for approximately a year and a half at Bar Louie as a
bartender and server before seeking a position with Redline.
11. Defendants are without knowledge or information sufficient to admit or deny the
allegations contained in the first sentence of Paragraph 10 of the Complaint, so it is denied. With
respect to the second sentence of Paragraph 11 of the Complaint, Defendants admit that they were
looking for experienced servers; however, they had a full cadre of bartenders. With respect to the
third sentence of Paragraph 11, Defendants aver that, like any new small business, they hoped that
they would be successful.
12. Defendants deny the allegations contained in Paragraph 12 of the Complaint.
13. Defendants deny the allegations contained in Paragraph 13 of the Complaint.
14. Defendants deny the allegations contained in Paragraph 14 of the Complaint.
15. Defendants deny the allegations contained in Paragraph 15 of the Complaint.
16. Defendants deny the allegations contained in Paragraph 16 of the Complaint.
17. Defendants deny the allegations contained in Paragraph 17 of the Complaint.
18. Paragraph 18 states legal conclusions to which no response is required but, to the extent
that it can be construed as alleging facts, these allegations are denied.
19. Defendants deny the allegations contained in Paragraph 19 of the Complaint.
20. Defendants deny the allegations contained in Paragraph 20 of the Complaint.
21. Defendants deny the allegations contained in Paragraph 21 of the Complaint.
Defendants Discriminatory Polices and Practices
22. Defendants deny the allegations contained in Paragraph 22 of the Complaint.
23. Defendants deny the allegations contained in Paragraph 23 of the Complaint.
24. Defendants deny the allegations contained in Paragraph 24 of the Complaint.

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25. Defendants deny the allegations contained in Paragraph 25 of the Complaint.

26. Defendants deny the allegations contained in Paragraph 26 of the Complaint.
27. Defendants deny the allegations contained in Paragraph 27 of the Complaint.
28. Defendants deny the allegations contained in Paragraph 28 of the Complaint.
29. Defendants deny the allegations contained in Paragraph 29 of the Complaint.
30. Defendants deny the allegations contained in Paragraph 30 of the Complaint.
31. Defendants deny the allegations contained in Paragraph 31 of the Complaint.
32. Defendants deny the allegations contained in Paragraph 32 of the Complaint.
33. Defendants deny the allegations contained in Paragraph 33 of the Complaint.
Injury to Plaintiff
34. Defendants deny the allegations contained in Paragraph 34 of the Complaint.
35. Defendants deny the allegations contained in Paragraph 35 of the Complaint.
Claims for Relief
Count I
Discrimination under Section 1981 of the Civil Rights act of 1866
36. Defendants repeat and incorporate by reference their responses to each and every
allegation contained in the preceding paragraphs as if set out in full.
37. Defendants deny the allegations contained in Paragraph 37 of the Complaint.
38. Defendants deny the allegations contained in Paragraph 38 of the Complaint.
Count II
Discrimination under the District of Columbia Human Rights Act
39. Defendants repeat and incorporate by reference their responses to each and every
allegation contained in the preceding paragraphs as if set out in full.
40. Defendants deny the allegations contained in Paragraph 40 of the Complaint.

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41. Defendants deny the allegations contained in Paragraph 41 of the Complaint.

42(a)-(f). With respect to Plaintiffs Prayer for Relief, a response is not necessary. To the
extent that a response is necessary, Defendants deny these allegations and further aver that
Plaintiff is not entitled to any relief whatsoever.

AFFIRMATIVE DEFENSES
FIRST DEFENSE
The Complaint fails, in whole or in part, to state a claim on which relief may be granted.
SECOND DEFENSE
Plaintiff never made any complaints to Redline, Dadlani or any Redline manager or
employee about any discriminatory treatment.
THIRD DEFENSE
Defendants acted properly, professionally and without malice at all times towards Plaintiff
such that Defendants are not liable for punitive damages in this case.
FOURTH DEFENSE
Defendants did not discriminate against Plaintiff in violation of the D.C. Human Rights Act
or 42 U.S.C. 1982, et seq.
FIFTH DEFENSE
Defendants actions with respect to Plaintiff were taken for legitimate, non-discriminatory,
non-prohibited reasons and/or for good cause.
SIXTH DEFENSE
Plaintiff failed to make reasonable efforts to mitigate his damages.

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SEVENTH DEFENSE
The claims are barred, in whole or in part, by the applicable statutes of limitation and/or
filing periods.
EIGHTH DEFENSE
The claims are barred, in whole or in part, by the principles of waiver and/or estoppel.
NINTH DEFENSE
The claims must be dismissed against Defendant Dadlani because he did not aid, abet, ratify,
condone, encourage or acquiesce in any alleged discriminatory conduct.
TENTH DEFENSE
The claims must be dismissed against Defendant Dadlani because he does not qualify as an
employer under the D.C. Human Rights Act.
ELEVENTH DEFENSE
The claims are barred, in whole or in part, by Plaintiffs failure to satisfy the statutory and/or
administrative prerequisites to the bringing of an action under D.C. Human Rights Act or 42 U.S.C.
1982, et seq.
TWELFTH DEFENSE
Plaintiff did not suffer a tangible employment action in connection with any of the
circumstances relevant to this lawsuit.
THIRTEENTH DEFENSE
Defendants intend to rely upon such other and further defenses as may become available or
apparent during the proceedings in the action and hereby reserves the right to amend its Answer
and/or to assert any such further defense or claim.

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Date: February 6, 2012

Respectfully Submitted,
/s/ Sundeep Hora______________
Sundeep Hora (D.C. Bar. No. 472944)
ALDERMAN, DEVORSETZ & HORA PLLC
1025 Connecticut Ave., NW
Suite 615
Washington, D.C. 20036
Tel. 202.969.8220
Fax 202.969.8224
E-mail: shora@adhlawfirm.com
COUNSEL FOR DEFENDANTS

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CERTIFICATE OF SERVICE
I hereby certify that, on this 6th day of February 2012, I caused a copy of the
foregoing Answer to the Complaint to be served upon the following by electronic mail in
.pdf format to:
Jennifer Klar
RELMAN, DANE & COLFAX, PLLC
1225 19th Street, NW, Suite 600
Washington, DC 20036
jklar@relmanlaw.com
and
Emily Read
Washington Lawyers
Committee for Civil Rights and
Urban Affairs
11 Dupont Circle, NW
Suite 400
Washington, DC 20036
Emily_Read@washlaw.org
Attorneys for Plaintiff

/s/____________
Sundeep Hora