SHELTON GORDON, WILLIAM: COCK,
ERIC Gm, JEROMX MONK and
DOUGLAS VINES,
V.
HILLCREST FOQPS, INC., WAFFLE HOUSE,
INC., PURSER SECURUY AND PATROL
SERVICES, NC.,
COMPLW FOR DECLARATORY JUDGMFflT. PERMANF,NT
JN$UlWTrVll RELIEF. AND DAMAGES
NATURE OF AfllON
1. Plaintiffs, five African-American men, bring this action to redress the
injuries they suffered and continut to suffer as a result of Defendants' racially
discriminatory actions a~ the W&f'le House Restaurant located at 1304 West Roosevelt
Boulevard in Monroe, North Carob
2. On February 11,2001, on account of Plaintiffs' race, Defendants refused
TO +krvr Plaintiffs and cjccred them fc6m rbe restaurant. By these and other actions,
Defendants have (1) denied Plaintiffs the right to make and enforce conuaets on the same
basis as white citizens in vioiation of 42 U.S.C. 4; 19X1, (2) denied Plamriffs rhe full
equal enjoyment of the zoods, services, facilities, privileges, advantages and
accommodarions of the Waffle House Restaurant
on the basis of mace, in violation
U.S.C. 4 2000a and N.C.G.S. 5 99-PI, (3) committed sn unfair or deceptive act or
practice in violation of N.C.G.S. 4 75-l. 1 and (4) defamed Plai~~tiffs.
3. Plaintiffs Thus seek compensatory and ~uuitive damages and an injunction
SNIPPETS:
Plaintiffs, five African-American men, bring this action to redress the
injuries they suffered and continut to suffer as a result of Defendants' racially
discriminatory actions a~ the W&f'le House Restaurant located at 1304 West Roosevelt
On February 11,2001, on account of Plaintiffs' race, Defendants refused
TO +krvr Plaintiffs and cjccred them fc6m rbe restaurant.
Defendants have denied Plaintiffs the right to make and enforce conuaets on the same
accommodarions of the Waffle House Restaurant
practice in violation of N.C.G.S.
Plaintiffs Thus seek compensatory and ~uuitive damages and an injunction
PlainTiff Shelton Gordon is an A&icaa-American citizen of the United
At all times relevant to this Complaint, Plaintiff Gordon has been a resident of the
Plamtiff Cook has been a resident of thE:
Plaintiff Eric Graham is an ABican-American citizen of the United Srwes.
Suwanee, Georgia Upon information and belief, Hillcrest Foods, Inc. owns or operates
Wme House Restawt located at 1304 West Roosevelt Boulevard in Monroe,
Defendant Purser Security and Patrol Sewices, Inc. is a North Carolina
Plaintiffs Gordon, Graham, Monk and Vines are African-&nerican
PlaintXfs Cook, Gordon, Graham, Monk, and Vtis entered the Wdfle House restawanr
Upon entering the restaurant, Plaintiffs went to the counter and placed togo food orders with
A wlute customer was also seated at the counter,
Plaintiff Cook asked Mr. Putman why they had to leave the ca~tcr seats.
acting within tic scope of Their employment as employees,
discriminatory animus for the purpose of denying Plaintiffs equal treatmenT on the basis of
enjoyment of the public accommodations owned and operafed by ~efer&+rns Hillcresr Foods,
w&Xbn ti reckless disregard for Plaiutifi' fed&y protected rigbrs.
compensatory damages.
aed reckless disregard for Plaintiffs federally protected rights,
Plaintiffs reallege and incorporate by reference Paragraphs 1 tbrolrgh 45, as if set forth
|
