_ I Case 1:07-cv—OO129-IVIPT Document 51 Filed O2/29/2008 Page 1 013
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE 1
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SHANNON A. LAYMON, I c.A. NO. 07—I29—NET
Plaintiff, * 1
* TRIAL BY JURY DEMANDED 1
LOBBY HOUSE, INc., a *
Delaware cOrpOratiOn, I I
Defendant. * 1
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STATE OF DELAWARE * 1
* SS:
COUNTY OF KENT * 1
AEEIDAVIT OF SARAH GEESAMAN 1
COMES NOW, Sarah Geesaman, WhO being duly Swcrn dOth depOSe E
and Say aS fOllOWS: 1
l. JZ anx Over the age Of eighteen. (18) and.1Rake this 1
affidavit baSed upOn my OWn perSOnal kncwledge. 1
2. I was emplcyed by the Lcbby HOuSe Restaurant and Bar as 1
a Waitress during pOrtiOnS Of 2005 and 2006. I
3. During the periOd Of my emplcyment, I was Subjected tO i
Sexually explicit and Other inapprcpriate cOmmentS and behavicr On 1
the part Of management, and particularly ASSiStant Manager DOn 1
Wilmcnt. 1
4. On One OccaSiOn, When I Was leaving the Wcrk place With 1
a male cO—WOrker, Mr. Wilmcnt humiliated me by making Sexually 1
1 explicit Statements in frcnt Of Other emplOyeeS. Specifically, j
Mr. Wilmcnt Split a pOtatO and made a cOmpariSOn with my private I
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i Case 1 :07-014-00129-IVIPT Document 51 Filed O2/29/2008 Page 2 of 3
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parts, and stated that I and my male co—worker would be having 1
sexual relations, which was false.
5. On another occasion when I had fallen at work and broken 1
my tailbone, Mr. Wilmont told me not to move and bent down to look 1
under my skirt and made a comment about my body. Mr. Wilmont then 1
made a disgusting comment about ranch dressing that had spilled 1
onto my hair and my clothes, saying something to the effect of E
“pulling out" and getting “it†all over me.
6. On other occasions, Mr. Wilmont would tell me and other
female employees that we needed to wear revealing tops in order to I
obtain better tips. Mr. Wilmont would also make comments about my 1
physical attributes and would tell me that I needed to stuff my E
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bra. 1
7. At least two or three times a month, management would
conduct wild parties after work at the work place. Such parties 1
also took place on Halloween and New Year's Eve. I and other Q
employees were required to be present at the work place during E
these events in order to clean the restaurant and bar area, but I I
never observed Shannon. Laymon. participating‘ in any of the 1
inappropriate behavior. This inappropriate behavior consisted of
female employees stripping off their tops and lying on the bar and
doing body shots (allowing people to lick alcoholic beverages off 1
their bodies). Mr. Wilmont also told me the day after one of 1
these parties that Amanda Potts stripped to her thong and was I
dancing. Management would encourage such behavior. During these {
parties, Ms. Potts, who was under the legal age limit of 2l, was
allowed to drink alcohol by management.
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8. I saw Don Wilmont smoking marijuana after work on many I
occasions. I
9. I heard Mr. Wilmont offer to pay female employees to do I
“lap dances†(dance around him half naked). I
. . . . I
l0. On one occasion I saw Rick Anibal put a liquor bottle I
into his pants and open up the zipper, after which female I
employees knelt in front of him, and he poured alcohol into their I
mouths and all over them.
ll. I never saw or heard of Shannon Laymon participating in I
any of the aforementioned inappropriate behavior. I
l2. Amanda Potts was allowed to show deliberately the tattoo I
on her chest, while Shannon Laymon and I were reprimanded for I
accidently showing the tattoos on our backs when we bent over. I
13. Shannon Laymon was a good bartender and related well to
customers. I
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FURTHER AFFIANT sArTH Nor.
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[MCI Ig _/I: “IQ;2@/I’I’mI;@ I
SARAH GEESAMAN I
SWORN TO AND SUBSCRIBED before me this __[;__ day of
November, 2007. ,
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Case 1:07-cv—00129-IVIPT Document 51-2 Filed 02/29/2008 Page 1 of 1
CERTIFICATE OF SERVICE
I hereby certify that I have caused copies of the following:
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AFFIDAVIT OF SARAH GEESAMAN 1
to be served upon: RONALD G. POLIQUIN, ESQUIRE 1
Young, Malmberg & Howard
30 The Green
Dover, DE 19901
,r*†1 1
by electronic service on E&%%&AM%£%% QQW J 2008- 1
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SCHMITT ER’;¢§DDRIGUEZ, P.A. I
BY: X 1/‘°
NO L E. PRIMOS, ESQUIRE 1
Bar I.D. #3124 1
414 S. State Street 1
P.o. Box 497 1
Dover, DE 19903
(302) 674—0140
Attorneys for Plaintiff 1
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DATED: Z-12r:"1"¤»?’»—';{`“â€69` 191/
NEP:pmw 1
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