Hotshots Petition

IN THE CIRCTIIT COURT OF THE COUNTY OF ST. LOUISSTATE OF MISSOURI

TWENTY-FIRST JUDICIAL CIRCUIT

LESLIE DELEON, PERCY GREEN, )RUSSELL GREEN, ANGELA MILLSTONE, )MICHELE SCOTT and MICHAEL SHELTON, ) Case No.

Plaintiffs. Div. No.

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12L54 ROCK ROAD, INC., 215 O'FALLONPLACE. L.L.C.. 730 HSBG. LLC. 950-952SOUTH HIGHWAY. L.L.C.. I3I9 CENTRALPARK, L.L.C., 1636 COUNTRY CLUBPLAZA,, INC., 3333 RIDGEWAY, INC.,4021 UNION, L.L.C., 12664 DORSETTROAD, L.L.C. and 14051 MANCHESTER,INC, together d/b/a "HOT SHOTS SPORTSI}AR & GRILL,''

Defendants.

Serve: Daniel Volmert, Registered Agentfor 12154 Rock Road, Inc.

3333 Ridgeway DriveSt. Charles. MO 63303

Daniel Volmert, Member of215 O'Fal lon Place, L .L.C.

3333 Ridgeway DriveSt. Charles, MO 63301

Daniel Volmert, Registered Agentfor 730 HSBG, LLC


Daniel Volmert, Member of13l9 Central Park, L.L.C.


JURY TRIAL DEMANDED -

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Daniel Volmert, Registered Agent )for 1636 County Club Plaza, lnc. )

3333 Ridgeway Drive )St. Charles, MO 63303

Daniel Volmert, Registered Agent )for 950-952 South Highway, LLC )

3333 Ridgeway Drive )St. Charles, MO 63303

Daniel Volmert, Registered Agent )for 3333 Ridgewav, Inc. )

3333 Ridgeway Drive )St. Charles. MO 63303 )

)Daniel Volmert, Rcgistered Agent )

for 4021 Union, L.L.C. )3333 Ridgeway Drive )St. Charles, MO 63303 )

)Daniel Volmert, Registered Agent )

for 12664 Dorsett Road, L.L.C. )3333 Ridgeway Drive )St. Charles, MO 63303

Daniel Volmert, Registered Agent )for lr l051 Manchester, Inc. )

3333 Ridgeway Drive )St. Charles, MO 63303 )

PETITION

Clome now Plainti f fs l-esl ie Deleon. Percy Green, Russell Green, Angela Mil lstone,

Michele Scott and Michael Shelton, by and through their attorneys, and for their preliminary

allegations state:

Parties

1. Plainti f f Lesl ie Deleon is an adult Afi ican-American cit izen of the United

States and a resident of the Countv of St. Louis. State of Missouri.

2. Plaintiff Pero' Green is an adult Alrican-American citizen of the ljnited States

and a resident of the County of St. Louis. State of Missouri.

3. Plaintiff Russell Green is an adult African-American citizen of the United States

and a resident of the County of St. Louis. State of Missouri.

4. Plainti f f Angela Mil lstone is an adult resident of the County of St. Louis. State of

Missouri. At the time of the relevant events, Plaintiff Millstone was attending Defendants' place

of business with her fianci, Plaintiff Russell Green and with Plaintiff Shelton. who are both

Afiican-American. She has thereby been "associated with" African-Americans within the scope

and meanine of R.S. Mo. S 213.070.

5. Plaintiff Michele Scott is an adult resident of the Countv of St. Louis. State of

Missouri. At the time ol-relevant events. Plaintiff Scott was attending Del'endants' place of

business with I']laintifl's Itusscll Grecn and Michael She lton. She has thereby been "associated

with" Ali ican-Americans within the scope and meaning of R.S. Mo. $ 213.070.

6. Plainti l '1 'Michael Shelton is an adult Afi ican-American cit izen of the United

States and a resident of the Clounty of St. l-ouis, State of Missouri.

7. Dcfendant 12154 Rock Road, Inc. is a Missouri corporation which operates a

"Hot Shots" restaurant and bar at 12154 St, Charles Rock Road. Bridgeton. Missouri, 63044,

which is located within the County of St. Louis. State of Missouri.

8. Def'endant 215 O'Fallon Place. I-.L.C. is a Missouri l imited l iabi l i tv comDany

which operates a "Hot Shots" restaurant and bar at215 O'F'allon Plaza, O'Fallon, Missouri,

63366, which is located within the Countl' of St. Charles, State of Missouri.

9. Defbndant 730 HSBG. LLC is a Missouri l imited l iabil i ty company which

operates a "Hot Shots" restaurant and bar at730 South Broadway, St. Louis, Missouri, 63102,

which is located within the City of St. Louis, State of Missouri.

10. Defendant 950-952 South Highway, L,L.C. is a Missouri limited liability

company which operates a "Hot Shots" restaurant and bar at 950 South Highway Drive, Fenton,

Missouri, 63026. which is located within the County of St. Louis. State of Missouri.

1 1. Defendant 1319 Central Park. L.L.C. is an I l l inois l imited l iabi l i ty company

which operates a "Hot Shots" restaurant and bar at 1 3 19 Central Park Drive, O'Fallon, Illinois,

62269. which is located within the County of St. Clair. State of lllinois.

12. Dcf'endant 1636 Country Club Plaza,lnc. is a Missouri corporation which

operates a "Hot Shots" restaurant and bar at 1316 Country Club Plaza Drive, St. Charles,

Missouri.63303. which is located withinthe County of St. l ,ouis. State of Missouri.

13. Dcf-cndant 3333 Ridgcway. Inc. is a Missouri corporation which operates "[Iot

Shots" rcstaurants and bars and maintains its primary place of business aI 12664 Dorsett Road,

Maryland l leights, Missouri, 63043. which is located within the County o1'St. Louis. State of

Missouri.

14. Defendant 4021 Union, L.L,C. is a Missouri l imited l iabi l i ty company which

operates a "Hot Shots" restaurant and bar at 4021 Union Road. St. Louis. Missouri, 63129, which

is located within the County o1'St. Louis, State of Missouri.

15. Del-endant 12664 Dorsett Road, L.L.C. is a Missouri l i rnited l iabi l i ty company

which opcrates a "Iiot Shots" rcstaurant and bar at, 12664 Dorsett Road. Maryland Heights,

Missouri. 63043, which is located within the County of St. Louis. State o1'Missouri.

16. Defendant 14051 Manchester, Inc. is a Missouri corporation which operates a

"Hot Shots" restaurant and bar at 14051 Manchester Road, Ballwin, Missouri, 6301 I , which is

located within the County o1'St. Louis, State of Missouri.

17. Defendants constitute joint employers and a single integrated enterprise as they

share an intenelation of operations, common management, centralized control of labor relations,

common ownership and common financial control, including the following:

a. Upon information and belief, Daniel and Julia Volmert, husband and wife

are the majority owners of all Defendants.

'l'he Missouri Secretary of State's records rellect that, during times

relevant. Det'endants 12154 Rock Road, Inc., 1636 Country Club Plaza,

Inc..333 Ridgeway. Inc. and 14051 Manchester. Inc. share common

officers as Daniel Volmert was the President of all four of these

corporations, Mark Pearlstone was the Vice President of two of these

corporations, and Julia Volmert was the Sccretary of all lbur o1'these

corporations.

-l-he Missouri Secretary of State's records reflect that, during times

relevant, Def-endarrts 12154 Rock Road, Inc., 1636 Country Club Plaza,

Inc.. 333 Ridgeway'. Inc. and 14051 Manchester. Inc. share common

directors as Daniel and Julia Volmert were directors of all fbur of these

corporations and Mark Pearlstone was the director of two o1'these

corporatiolls.

Upon infbrmation and belief, Daniel and Julia Volmert were the members

and managers of Defendants 215 O'Fallon Place, L.L.C., 730 HSBG,

LLC. 950-952 South Highway. L.L.C. , 1319 Centra l Park, L .L.C. ,4021

LJnion. L.L.C.. and 12664 Dorsett Road, L.L.C. during t imes relevant.

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The Missouri Secretary of State's records reflect that, during times

relevant, the "principal place ofbusiness or corporate headquarters of

Defendants 12154 Rock Road, Inc., 1636 Country Club Plaza,lnc., 333

Ridgeway. Inc. and 14051 Manchester, Inc. was 12664 Dorsett Road,

Maryland I{eights, Missouri, 63043," which is also the location of

Defendant 12664 Dorsett Road. L.L.C.'s "Hots Shots" restaurant and bar,

"Hot Shots" website lists the address of the "corporate ofl-rce" fbrall "Hot

Shots" restaurants as 12664 Dorsett Road, Maryland Heights, Missouri,

63043.

Thc Missouri Secrctary of State's records reflect that during al l t imes

relevant, Daniel Volmert served as the registered agent o1'Del-endants

12154l{ock Road. Inc., 730 HSBG. LLC, 950-952 South I{ ighway,

L.L.C. , 1319 Centra l Park, L .L.C, ,3333 Ridgeway, Inc. ,402l Union,

t.. l- .C.. 12664 Dorsett Road. L.L.C., and 14051 Manchester. Inc.

Def-endants share and transfer store managers and employees.h .

Venue & Jurisdict ion

18. Matcrial cvcnts and occurrences underlvins Plaintiffs' claims occurred within the

C)ounty o1'St. Louis, State o1'Missouri.

22. 'l 'his

Court maintains venue and jurisdiction over Plaintifl-s' claims brought herein

pursuant to R.S. Mo. Sec. 213. I I 1 .

Relevant Facts

23. On the evening of October 22,2011, Plainti f fs were customers of Defendants'

"Hot Shots" restaurant and bar located at 12154 St. Charles Rock Road, Bridgeton, Missouri,

63044.

24. That night. Defendants' server (hereinafter "Server 1") refused to wait on

Plaintiffs Russell Green. Millstone, Scott and Shelton, but Server 1 waited on caucasian

customers.

25. When Server I eventually waited on Plaintiffs Russell Green, Millstone, Scott and

Shelton, she was rude and abrupt to Plaintiffs Green and Shelton.

26. Server I did not retum to that table fbr an unreasonably long period of time,

therefore Plaintiff Russell Green repeatedly waived his arms at Server 1 in an effort to obtain

service.

?7 . I lach t imc that Scrvcr 1 lookcd at Plainti f f Russcll Grccn waiving his arms at hcr,

she quickly turned away fiom him.

28. Plaintiff Millstone then waived her arms at Server I as if Plaintiff Millstone was a

ground crew member waiving an airplane into an airport terminal.

29. Server 1 looked away when Plaintiff Millstone caught her attention by waiving

her arms.

30. Server 1 then sat down with caucasian patrons rather than waiting on Plaintifl's

Russcll Grccn. Mil lstonc. Scott and Shclton.

3l . Plaintiff Russell Green told Defendants' manaser thal the server would not wait

on his table even though they repeatedly obtained her attention.

32. In response, Def-endants' manager told Plaintiff Russell Green that he was having

problems with the waitresses.

33. Defendants' manager replaced Server I with another server (hereinafter'oServer

2") as the server for thc table occupied by Plaintiffs Russell Green, Millstone. Scott and Shelton.

34. Server I then rolled her eyes, huffed and pouted as she passed the table occupied

by Plaintiffs Russell Green, Millstone, Scott and Shelton.

35. Defendants' manager said that he does not know why the second server was any

better than the first servers because shc is "just as racist as the first one.,'

36. Later than night. Server I refused to wait on Plainti f fs Deleon and Percy Green

fbr an unreasonably long period of tinre afier they arrivecl at the restaurant,

37. When Plaintiff Deleon attempted to approach Server 1 to obtain service, Server l

ducked behind a pole to avoid Plaintiff Deleon.

38. Plainti f fs Deleon reported Servcr 1's conduct to Defendants' rnanager.

39. In rcsponse. Def'endants' ntanager infbrmed Plaintifls Deleon and Percy Green

that the servers would not serve them because they were "racist," that the servers were "so racist

here." and that "al l white people are racisl."

40. Del-endants' ntanager told Plaintills Deleon and Percy Green that he had been

dealing with the same problem all night, then Defendants' manager pointed to the table where

Plainti f f-s Russell Green, Mil lstone. Scott and Shelton were sitt ing.

41. Servcr 2 apologized to Plainti f fs Deleon and Percy Green for Server 1's actions.

42. Defbndants' rnanager then told Plaintiffs Deleon and Percy Green that he did not

know why Server 2 apologized to them because she is 'Just as racist" as Server l.

43. A man who had bccn talking to Def-endants' servers walked by Plaintilf Deleon

and said, "'l 'hese black bitches are messing with us."

44. Server 1 then repeatedly pestered Plaintiffs Percy Green and Michael Shelton in a

sarcastic and insincere tone about whether they wanted ntore drinks.

45. About a month prior to October 22,2011, Defendants displayed a sign at the same

restaurant which announced "Ghetto Specials."

Count I: Lesl ie Deleon - Discrimination in Public Accommodation

Comes now Plaintiff Deleon, by and through her attorneys, and states the fbllowing fbr

Count I of this Petit ion against De1'endants:

46. Plaintifl.Deleon realleges and incoqporates by reference each and every allegation

contained in paragraphs I through 45 above as if fully set fbrth and restated herein.

47. On or about October 28,2011, Plainti f f Deleon f i led a t imely charge of

discrimination with the Missouri Commission on Human Rights ("MCHR") al leging

discrimination in public accommodation on the basis of race.

48. On or about November 14,2012, the MCHR issued Plainti f f Deleon a Notice of

It ight to Sue and Plainti l l 'Dcleon thereafier f i led this action in a t imely manner. See copy of

Notice of Right to Sue issued by the MIICR attached hereto as "Exhibit 1."

49. Plaintiff Deleon is a "person" within the scope and meaning of R.S. Mo. $

213.010(14) and a "person within the.iurisdict ion of the state of Missouri" within the scope and

mean ing o f R .S . Mo . $ 213 .065 .1 .

50. Del'endants' "Hot Shots" restaurant and bar located aI12154 St. Charles Rock

Road, Bridgeton, Missouri, 63044 is a "place of public accommodation" within the scope and

meaning of R.S.Mo. $ 2 1 3.01 0( 1 5) .

51. By the conduct alleged above, Defendants denied I'}laintifl'Deleon full and equal

use and enjoyment of a place of public accommodation based on her race, and Defendants

discriminated against Plaintiff Deleon in the use of a place of public accommodation based on

her race.

52. Def-endants'conduct, as afbresaid, violated R.S. Mo. $8 213.065.1 &213.065.2.

53. As a direct result of Defendants' unlawful actions. Plaintiff Deleon has been

damaged in the form of emotional distress and humiliation.

54. Def-endants' actions werc outrageous because of Defendants' evil motive or

reckless indifferencc to the rights of others, and therefbre entitle Plaintiff Deleon to an award of

punitive damages.

WHEREI"ORIT. on Count I of this Petition. PlaintifT Deleon prays this Court enter its

order, judgment and decree all'arding her:

a) relief making Plaintitf Deleon whole for the harm caused, including an order to

pay her such sums as are.just and reasonable as compensatory damages, including damages for

emotional distress and hurl i l iat ion:

b) punitive damages in such amounts as 1o punish and deter Del'endants and others

fiom like conduct;

c) an award of attorney's fees;

d) costs of l i t igation:

e) prc-judgment interest on all monetary sums awarded; and

1) such other equitablc and furtlier relief as this Court deems just and proper.

Count II : I 'ercv Green - Discrimination in Public Accommodation

Comes now Plaintilf Percy Green, by and through his attorneys, and states the following

for Count II of this Petition asainst Defendants:

55. Plaintiff Percy Green realleges and incorporates by reference each and every

allegation contained in paragraphs I through 54 above as if fully set forth and restated herein.

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56. On or about October 3 1, 201 I , Plaintiff Percy Green frled a timely charge of

discrimination with the MCHR alleging discrimination in public accommodation on the basis of

race.

57 . On or about November I 4. 201 2, the MCHR issued Plainti f f Percy Green a

Notice of Right to Sue and Plaintiff Percy Green thereafter filed this action in a timely manner.

See copy of Notice of Right to Sue issued by the MHCR attached hereto as "Exhibit 2."

58. Plainti f f Percy Green is a "person" within the scope and meaning of R.S. Mo. $

213.010(14) and a "person within the.jurisdict ion of the state of Missouri" within the scope and

meaning of R.S. Mo. $ 213.065.1.

59. Defendants' "Hot Shots" restaurant and bar located aL 12154 St. Charles Rock

Road, Bridgeton, Missouri, 63044 is a "placc of public aocommodation" within the scope and

mcaning o1 ' R.S.Mo. s \ 2 I 3 .0 I 0(1 5) .

60. By the conduct alleged above, Def-endants denied Plaintifl'Percy Green lull and

equal use and enjoyment of a place of public accommodation based on his race. and Def-endants

discriminated against Plainti f f Percy Green in the use of a place of public accommodation based

on his racc.

61. Det 'endants ' conduct , as a lbresaid, v io la ted R.S. Mo. S$ 2 l 3 .065 .1 & 213.065.2.

62. As a direct result of Defendants' unlawful actions, Plaintiff Percy Green has been

damaged in the fbrm o1 emotional distress and humiliation.

63. Defendants' actions were outrageous because of Det-endants' evil motive or

reckless indifference to the rights of others. and therefore entitle Plaintiff Percy Green to an

award o1' punitive damages.

WIIEREI-ORE. on C'ount II of this Petition. PlaintiffPercy Green prays this Coufl

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enter its order, judgment and decree awarding him:

a) relief making Plaintiff Percy Green whole for the harm caused, including an order

to pay such sums as arc'iust and reasonable as compensatory damages. including damages for

emotional distress and humil iat ion:

b) punitive damages in such amounts as to punish and deter Defendants and others

fiom like conduct:

c) an award o1'attorney's fees;

d) costs of l i t igation;

e) pre-.judgrnent interest on all monetary sums awarded; and

1) such other equitable and further rel iel 'as this Cor,rr l deems.iust and proper.

Count II I : Russell Green - Discrimination in Public Accommodation

Comes now Plaintiff Russell Green. bv and throush his attornevs. and states the

tbl lowing lbr Clount l l l of this Petit ion against Def'endants:

64. I'}laintilf Russell (ireen realleges and incorporates by refbrence each and every

allcgation contained in paragraphs 1 through 63 above as if fully set forth and restated herein.

65. On or about October 3 I . 201 1 , Plainti f f Russell Green f i led a t imely charge of

discrimination with the MCHR alleging discrimination in public acconrmodation on the basis of

race.

66. On or about Novenrber 14,2012, the MCHR issued Plainti lTRussell Green a

Notice of Right to Sue and Plaintiff Russell Green thereafter filed this action in a timely manner.

See copy of Notice of Right to Sue issued by the MHCR attached hereto as "Exhibit 3."

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6l . PlaintifT Russell Green is a "person" within the scope and meaning of R.S. Mo. $

213.010(14) and a "person within the jurisdict ion of the state of Missouri" within the scope and

meaning of R. S. Mo. $ 2 1 3.065. I .

68. Defendants' "Hot Shots" restaurant and bar located at 12154 St. Charles Rock

Road. Bridgeton, Missouri. 63044 is a "place of public accommodation" within the scope and

mean ing o f R .S .Mo . $ 213 .010 (15 ) .

69. By the conduct alleged above. Defendants denied Plaintitf Russell Green full and

equal use and enjoyment of a place of public accommodation based on his race. and Defendants

discriminated against Plainti f f RLrssell Green in the use of a place of public accommodation

bascd on his race.

70. Defbndants ' conduct , as aforesaid, v io la ted R.S. Mo. $$ 213.065 .1 &213.065.2.

7l. As a direct result of Del-endants' unlawtul actions, Plainti l l 'Russell Green has

been damaged in the lbrm o1'cmotional distress and humiliation.

72. Del'endants' aclions were outrageous because of Defendants' evil motive or

reckless indifference to the rights of others, and therefore entitle Plaintiff Russell Green to an

award o1- punitivc damages.

WIIEREITORL,. on Counl II I of this Petit ion, Plainti l l .Russell Green prays this Court

enter its order, judgment and decree awarding him:

a) relief making PlaintifTRussell Green whole fbr the harm caused, including an

orderto pay him such sums as are just and reasonable as compensatory damages, including

damages for emotional distress and humiliation;

b) punitive damages in such amounts as to punish and deter Def-endants and others

from like conduct:

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c) an award of attorney's fees;

d) costs of litigation;

e) pre-.judgment interest on all monetary sums awarded; and

1) such other equitable and further relief as this Court deems just and proper.

Count [V: Angela Mil lstone - Discrimination in Public Accommodation

Comes now Plaintiff Millstone, by and through her attorneys, and states the fbllowing for

Count IV of this Petition asainst Def-endants:

73. Plaintilf Millstone realleges and incorporates by reference each and every

allegation contained in paragraphs I through 72 above as if fully set forth and restated herein.

74. On or about Dccembcr 27,2011, Plainti f f Mil lstone f i led a t imely charge of


her association with Atiican-Americans.

15. On or about December 6.2012. the MCHI{ issued Plainti f l 'Mil lstone a Notice of

Right to Sue and Plaintif f Millstone thereafter llled this action in a timely manner. See copy of

Notice of Right to Sue issued by the MHCR attached hereto as "Exhibit 4."

76. Plainti f l 'Mil lstone is a "person" within the scope and meaning of R.S. Mo. $

213.010(14) and a "person within the jurisdict ion of the state of Missouri" within the scope and

mcaning of R.S. Mo. $ 213,065. I .

77. Del'endants' "Hot Shots" restaurant and bar located at 12154 St. Charlcs Rock


mean ing o f R .S .Mo . { 213 .010 (15 ) .

78. By the conduct alleged above, Defendants denied Plaintiff Millstone full and

equal use and enioyment of a place of public accommodation based on her association with

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African-Americans, and Defendants discriminated against Plaintiff Millstone in the use of a

place of public accommodation based on her association with African-Americans.

79. l )e fendants 'conduct , as aforesaid, v io la ted R.S. Mo. 88 213.065.1:213.065.2 &

213.070(4).

80. As a direct result of'Def-endants' unlawful actions. Plaintiff Millstone has been

damaged in the lbrm of emotional distress and humiliation.

81. Defendants' actions were outrageous because of Defendants' evil motive or

reckless indiff-erence to the rights of others. and therefore entitle Plaintiff Millstone to an award

of punitive damages.

WHERE,FORE, on Clount IV of this Petit ion, Plainti f f Mil lstone prays this Court

enter its order, judgment and decree awarding her:

a) relief rnaking Plaintitl'Millstone whole fbr the harm caused, including an order to

pay her such sums as are just and reasonable as compensatory damages, including damages fbr

emotional distress and humil iat ion:


from like conduct:

c) an arvard of attorney's f-ees;


e) pre-judgment interest on all monetary sums awarded; and

0 such other equitable and further relief as this Court deems just and proper.

Count V: Michele Scott - Discrimination in Public Accommodation

Comes now Plaintiff Millstone, by and through her attorneys, and states the following for

Count V of this Petition asainst Defendants:

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82. Plaintiff Scott realleges and incorporates by reference each and every allegation

contained in paragraphs I through 81 above as if fully set forth and restated herein.

83. On or about December 27 .201 1, Plainti f f Scott f i led a t imely charge of


her association with Afiican-Americans.

84. On or about December 6.2012, the MCHR issued Plainti f f Scott a Notice of

Right to Sue and Plaintill ' Scott thereafier llled this action in a timely manner. See copy of

Notice of Right to sue issued by the MHCR attached hereto as "Exhibit 5."

85. Plainti f f Scott is a "person" within the scope and meaning of R.S. Mo. $

213.010(14) i tnd a "person w' i th in the. jur isd ic t ion o1- the s tate o l -Missour i " wi th in the scope and

mean ing o f R .S . Mo S 213 .065 . L

86. Delbndants' "Hot Shots" restaurant and bar located aL 12154 St. Charles Rock


mean ing o f R .S .Mo . S 213 .010 (15 ) .

87 . By the conduct alleged above, Defendants denied Plaintiff Scott full and equal use

and enjoyment of a place o1'public accommodation based on her association with African-

Americans, and Dcl 'endants discrirninated against Plainti f f scott in the usc of a placc of public

accommodation bascd on her association with African-Americans.

88. Def 'endants 'conduct , as afbresaid, v io la ted R.S. Mo. $$ 213.065.1;213.065.2 &

2r3 .070(4 \ .

89. As a direct result of Defendants' unlawful actions. Plaintiff Scott has been

damaged in the form of emotional distress and humiliation.

90. Defendants' actions were outrageous because of Defendants' evil motive or

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reckless indifference to the rights of others, and therefore entitle Plaintiff Scottto an award of

punitive damages.

WHEREFORE. on Count V of this Petition. Plaintiff Scott pravs this Court

enter its order. judgment and decree awarding her:

a) reliel making l']laintiff Scott whole fbr the harm caused. including an order to pay

her such sums as are just and reasonable as compensatory damages. including damages fbr

emotional distress and humiliation;


from like conduct:

c) an award of attorney's l'ees;


e) pre-judgment interest on all monetary sums awarded; and

f) such other cquitable and turther rclicf as this Court deems.just and proper.

Count V[: Michael Shelton - Discrimination in Public Accommodation

Comes now Plaintiff Shelton, by and through his attorneys. and states the lbllowing for

Count VI of this Petit ion asainst Def'endants:

91. Plaintiff Shelton realleges and incorporates by reference each and every allegation

contained in paragraphs I through 90 above as if fully set lbrth and restated herein.

92. On or about l)ecember 28,201l, Plaintiff Shclton filed a timely charge of


race.

93. On or about November 14- 2012- the MCHR issued Plainti f f Shelton a Notice of

Right to Sue and Plainti t f Shelton thcreaftcr f i led this action in a t imely manner. See copy of

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Notice of Right to Sue issued by the MHCR attached hereto as "Exhibit 6."

94- Plainti f f Shelton is a "person" within the scope and meaning of R.S. Mo. $

213.010(14) and a "person within the jr-rr isdict ion of the state of Missouri" within the scope and

mean ing o f R .S . Mo . $ 213 .065 .1 .

95. Def'endants' "Hot Shots" restaurant and bar located at 12154 St. Charles Rock

Road, Bridgeton, Missouri. 63044 is a "place of public accommodation" within the scope and

mcan ing o f R .S .Mo . r s 213 .010 (15 ) .

96. By the conduct alleged above, Defendants denied Plaintiff Shelton full and equal

use and enjoyment of a place of public accommodation based on his race. and Defendants

discriminated against Plainti l f Shelton in the use of a place of public accommodation bascd on

his racc.

97. Dcf 'endants 'conduct . as a lbresaid, v io la ted R.S. Mo. $$ 213.065. l &213.065.2.

98. As a direct result o1'Def.endants' unlawful actions. Plaintiff Shelton has

been damaged in the form of emotional distress and humiliation.

99. Def-endants' actions were outrageous because of Defendants' evil motive or

reckless indiff-erence to the rights of others, and therefore entitle Plaintiff Shelton to an award of

pLrnit ive damages.

WFIEREITORE, on Clount VI o1'this Petit ion, Plainti f f Shelton prays this Court

enter its order, judgntcnt and decree awarding him:

a) relief making Plaintiff Shelton whole fbr the harm caused, including an order to

pay him such sums as are.iust and reasonable as compensatory damages, including damages for

emotional distress and humiliation:

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from like conduct:

c)

d)

e)

1)

an award of attorney's fees;

costs o1' l i t igation;

pre-judgment interest on all monetary sums awarded; and

such other equitable and further relief as this Court deems just and proper.

Respectfully submitted,

WEINHAUS & POTASHNICK

1 1500 Ol ive l l lvd. . Sui te 133St, Louis. Missouri 63141Plrone: (314) 997-9150 ext , 2Fax: (3 14\ 997 -9170

m arkp (r)up- attornc)'s. co rn

and

RIGGAN LAW FIRM, LLCItussell C. Riggan, #530602000 South 8t" StreelSt. Louis, Missouri 63 104Phone: (314) 771-5555Fax: (314)735-1054rus s (@ri g ganlawfl rm. com

Attorneys for Plaintffi

I 9

MISSOURI DEPARTMENT OF LABoR AND INDUSTRIAL RELATIoNS

LAWRENcE G. REBMAND E P A R T M E N I D R r c r o H

Ai-vrr! ClntenCoMMrssroN CHATRPERSoN

ALISA WARREN, PH.D,EXECUTIVE DIRecron

MrssouRr CoMMrssroN oN HUMAN RtcHTSJEREMTAH W. UAY) NrxoN

GovERNoR

Leslie Deleon3507 Sugarcrest, Apt. AFlorissant, MO 63033

RE: Leslie De|eon vs. ,12154 ROCK ROAD D/B/A HOT SHOTS SPORTS BAR AND GRILL, ET AL.P-10/1 1-03510

The Missouri Commission on Human Rights (MCHR) is terminat ing i ts proceedings and issuing this not ice of your r ight to sueunder the Missouri Human Rights Act because you have requested a not ice of your r ight to sue.

You are hereby notified that you have the right to brrng a civil action within 90 days of the date of this letter against therespondent(s) named in the complaint. Such an action may be brought in any state circuit court in any county in which theunlawful discriminatory practice is alleged to have occurred, either before a circurt or associate circuit judge. Not only mustany action brought in court pursuant to this right to sue authorization be filed within 90 days from the date of this letter, anysuch case must also be filed no later than two vears after the alleoed cauge occurred or your reasonable discovery of thealleged cause.

IF YOU DO NOT FILE A CIVIL ACTION IN STATE CIRCUIT COURT RELATING TO THE MATTERS ASSERTED IN YOURCoMPLATNT WrrHrN 90 DAYS OF THE DATE OF TH|S NOTTCE (AND WITH|N TWO YEARS OF THE ALLEGED CAUSE,OR THE DISCOVERY OF THE ALLEGED CAUSE, OF YOUR COMPLAINT), YOUR RIGHT TO SUE IS LOST.

You are also notified that the Executive Director is administratively closing this case and terminating all MCHR proceedingsrelat ing to your complaint You may not reinstate this complaint with the MCHR or f i le a new complaint with the MCHRrelating to the same act or practice, but rather if you choose to contrnue to pursue your complaint, you must do so in court asdescribed in this letter This notice of right to sue has no effect on the suit-fil ing period of any federal claims.

In addition to the process described above, if any party is aggrieved by this decisron of the MCHR, that party may appeal thedecision by fil ing a petition under $ 536 1 50 of the Revised Statutes of Missouri in state circuit court. Any such petition .mustbe filed in the circuit court of Cole County

Respectfully,

Alisa Warren. Ph.D.Executive Director

12154 ROCK ROAD D/B/A HOTSHOTS SPORTS BAR AND GRILL,ET AL12154 St, Charles Rock RdBridgeton, MO 63044ATTN: Daniel & Julie Valmert

tTzLAI

3315 W. IRUMAN 8TVD,P . O B o x 1 1 2 9

JEFFERSoN CtTY, MO 651 02 .1 129

PHONET 573-751-3325FAx: 573-751-2805

Donna HarperSedey Harper PC2711 Cl i f ton AveSt . Louis , MO 63139

I 1 1 N,7rH SrREEr. SurrE 903 P.O. Box 1 300Sr Lou rs . MO63101 -2100 OZARK, MO65721 -1300

PHoNE 314-340-7590 FM.417-485'6024FAx:3 '14.340-7238

SamuelW. MooreRiggan Law Firm LLC132 W Washington AveSte 100Kirkwood, MO 63122

Novem.ber 14, 2012Date

nu14' t0 GENESSEE, SurrE 260KrNs.cs Ctrv, lVlO 64102

FM 816-889-3582

T-lt t

1 06 ARTHUR STR€El:iUITE U

SrKESroN, MO 63801-5454F,.)..573472-5321

EXHIBITRelayMissour l 1-800-735-2966(TDD) 1-800-735-2466(Voice)wlwv.labor.mo.gov/hr [email protected],gov

t-t__

Mrssounr DEpARTMENT or LReon lNo Inousrntal Rellrrons

LAWRENCE G, REBMAN

DepeRrmErur DrnectonALVIN CARTER

CoMMtss oN ChATRPERScNALIsA WARREN, PH,D.ExE0u i lvE DTRECIoR

MrssouRr CoMmrssroN oN HUMAN RTGHTSJEREMIAH W. {JAY) NIXoN

GovERNoR

Percy Green3507 Sugarcrest, Apt. AFlorissant, MO 63033

331 5 W. TRUMAN BLVOP O . 8 0 x 1 1 2 9

JEFFERSON CITY, MO 65102-1 129PHoNE:5/3-751-3325FAX. 573-75'1-2905

RE: Percy Green vs, 12154 ROCK ROAD D/B/A HOT SHOTS SPORTS BAR & GRILL, ET AL,P-10111-03511

The Missouri Commission on Human Rights (MCHR) is terminat ing i ts proceedings and issuing this not ice of your r ight to sueunder the Mrssouri Human Rights Act because you have requested a not ice of your r ight to sue.

You are hereby notified that you have the right to bring a civil action within 90 days of the date of this letter against therespondent(s) named in the complaint. Such an action may be brought in any state circuit court in any county in which theunlawful discriminatory practice is alleged to have occurred, either before a ctrcuit or associate circuit judge. Not only mustany action brought in court pursuant to this right to sue authorization be filed within 90 days from the date of this letter, anysuch case must also be filed no later than two vears after the glleqed cause occufred or your reasonable discovery of thealleged cause.

IF YOU DO NOT FILE A CIVIL ACTION IN STATE CIRCUIT COURT RELATING TO THE MATTERS ASSERTED IN YOURcoMpLAtNT WtTHtN 90 DAYS OF THE DATE OF TH|S NOTTCE (AND WTTHTN TWO YEARS OF THE ALLEGED CAUSE,OR THE DISCOVERY OF THE ALLEGED CAUSE, OF YOUR COMPLAINT), YOUR RIGHT TO SUE IS LOST.

You are also notified that the Executive Director is administratively closing this case and terminating all MCHR proceedingsrelating to your complaint. You may not reinstate this complaint with the MCHR or file a new complaint with the MCHRrelating to the same act or practice, but rather, if you choose to continue to pursue your complaint, you must do so in court asdescribed in this letter. This notice of right to sue has no effect on the suitfil ing period of any federal claims.

In addition to the process described above, if any party is aggrieved by thrs decision of the MCHR, that party may appeal thedecision by fil ing a petition under $ 536.150 of the Revised Statutes of Missouri in state circuit court. Any such petition mustbe filed in the circuit court of Cole County.

Respectfully,

(a

Alrsa Warren, Ph.D.Executive Director

12154 ROCK ROAD D/B/A HOTSHOTS SPORTS BAR & GRILL, ETAL.12154 St. Charles Rock RdBridgeton, MO 63044ATTN: Daniel & Julie Volmert

Donna HaroerSedey Harper PC271'1 Cli f ton AveSt . Louis , MO 63139

1 1 1 N. 7rH STREEI, Sl i tE 903 P.O. Box 1 300Sr Lou rs MO63101 -2100 OZ^RK MO65721 -1300

PHONE:314-340-7590 F^x 417-485'6024FAXr 314-340-7238

SamuelW MooreRiggan Law Firm LLC132 W Washington AveSuite 100Kirkwood, MO 63122

November 14 20'12Date

l TIt__J

J410 GENEsst t , Su l rE 260KANSAS CrrY l\,'lO 64102

FAX 816-889-3582

r--'lt_t

' l 06 ARTtsuR STREEI

SU|lE DstKEsToN, Mo 63801 -5454

Rslaylv l issour i 1-800-735"2966(TDD) 1-800-735-2466(Voice)www.labormo.gov/hr [email protected]

EXHIBIT

2

Mrssounr DeplnruEnT oF LABoR AND lNDUSTnret ReuttoHs

LAWRENCE G, REBMANDEPARTMENl D RECIOR

ALVIN CARTERCowtr,trss oru CrernpEnsor

ALrsA WARREN, PH.D.ExEcurrve Drnrc-roR

SamuelW, MooreRiggan Law Firm LLC132 W Washington Ave, Ste1 00,Kirkwood, MO 63122

Alisa Warren, Ph.D.Executive Director

12154 ROCK ROAD D/B/A HOTSHOTS BAR AND GRILL, ET AL.12154 St. Charles Rock RdBridgeton, MO 63044ATTN: Daniel & Julie Volmert

|\7IZ-\I

3315 W. TRUMAN BLVD.P O B o x 1 1 2 9

JEf T .ERSON C|TY, MO 851 02-1 129PHONE 573751-3325

FM: 573-751-2905

Donna HarperSedey Harper PC2711 Clif ton AveSt . Louis , MO 63139

1 1 1 N . 7 T H S r R E E i , S u i l E 9 0 3 P . O . B o x 1 3 0 0

S T L o u l s , l \ , ' 1 O 6 3 1 0 1 - 2 1 0 0 O z R K , M O 6 5 7 2 1 - 1 3 0 0P80NE 314-340-7590 FAX:417-485-6024

FAX. 314-340-7238

November 14,20'12Date

tr nt_J

141 O GENESSEE, SUITE 260Kerusns Ctrv, l\4O 64102

FAX: 816-8893582

t--lL_t

1 06 ARTHUR STREETS U T E D

stKESrON, Mo 63801-5454Fl'r..573-472-5321

RelayMissour i 1-800-735-2966(TDD) 1-800-735-2466(Voice)wwwlabor.n logov/hr [email protected]

MrssouRr CoMMrssroN oN HUMAN RtcnrsJEREMTAH W, (Jnv) Nrxon

GovERNoR

Russell Green3423 San Sevilla CourtBridgeton, MO 63044

RE. Russell Green vs, 12154 ROCK ROAD D/B/A HOT SHOTS BAR AND GRILL, ET AL.P-12t11-03534

The Missouri Commission on Human Rights (MCHR) rs terminat ing i ts proceedrngs and issuing this not ice of your r ight to sueunder the Missouri Human Rights Act because you have requested a notice of your right to sue.

You are hereby notified that you have the right to bring a civil action within 90 days of the date of this letter against therespondent(s) named in the complaint. Such an action may be brought in any state circuit court in any county in which theunlawful discriminatory practice is alleged to have occurred, either before a circuit or associate circuit judge. Not only mustany action brought in court pursuant to this right to sue authorization be filed within 90 days from the date of this letter, anysuch case must also be filed no later than two.vears after the alleqed cause occurred or your reasonable discovery of theal leged cause.

IF YOU DO NOT FILE A CIVIL ACTION IN STATE CIRCUIT COURT RELATING TO THE MATTERS ASSERTED IN YOURcoMpLAtNT WtTHtN 90 DAYS OF THE DATE OF TH|S NOTTCE (AND WtrHtN TWO YEARS OF THE ALLEGED CAUSE,oR THE DISCOVERY OF THE ALLEGED CAUSE, OF YOUR COMPLAINT), YOUR RIGHT TO SUE lS LOST.

You are also notified that the Executive Director is administratively closing this case and terminating all MCHR proceedingsrelating to your complaint. You may not reinstate this complaint with the MCHR or file a new complaint with the MCHRrelating to the same act or practice, but rather if you choose to continue to pursue your complaint, you must do so in court asdescribed in this letter. This notice of right to sue has no effect on the suit-fil ing period of any federal claims

In addition to the process described above, if any party is aggrieved by this decisron of the MCHR, that party may appeal thedecisron by frling a petition under $ 536 1 50 of the Revised Statutes of Missouri In state circuit court. Any such petition mustbe filed in the circuit court of Cole Countv.

Respectfully,

/ , \-:24/''-\l<,'\---=t/' l-->**

l '

?01?-1?-06 07:51 Human Rights - KC 8168893582 >> 351054

MIS$OURI DEPARTMENT OF LABOR AND INDUSTNINL REUTIOruS

P 4/6

JERCMTaH W, (Jav) NrxoNG0vERNoR

Alvrn CeRtcnCOMMrSsroN ChArRpEr{sON

AUsA WARREN, PH,0,Exccutrvc Ornccton

r.1 06 AEIHUR STRIET

SutrE 0

Respectfully,

,, '''.|

. , , - . . - . ' ' \/ '- /, '

Alisa Warren, Ph.D.Executive Director

C; addit ional respondents on nexl pages

t \11|l:t

3315W TtruuevBrvoP.O. Box 1 129

J!t'H:rrggru CLIy, M0 95102-,1 1 20PHoNEi 57o.7bt-332sFrx: 573.75 1 -2905

I 1 1 N. 71H STREET. SutTr 903 P.O. Box 1 300Sr. Lcuts, MO 0C101-2100 oZARX. M0 657?1.1300

PHoNcr 314-34&7580 FAx:417-,188,60a4FAx: c14-34F7?38

D e c e m b e r 6 , 2 0 1 2Date

Dl T

1410 GTNEGSEt: , SurrE 2d0K,^Ns^:; CrrY, MO 84102

F^x:810.880.950?

Ralayf \4 ls3ouf i 1.d00.735.2906(TDD) 1.800,73$.2480(Voico)wwvy i0bor nto 0oy/hr mchrdlibor mo.Oov

MIssouRI CoMMISSIoN oN HUMAN RlcnrsLAWfleNce G, RcoMAN0cplntuctrr D necron

Angela Mil lstone3423 San Sevil la CourtEridgoton, MO 63044

RE: Angela Mi l ls tonevs. 12154 Rock Road d/b/a HotShots Spor ts Bar& Gr i [e tatP-12t11-03542

The Missouri Commission on Human Rights (MCHR) is terminating its proceedings and issuing this notice of your r ight tosue under the MrssouriHuman Rights Act becau$e you have requesied a notice of !our r ight to sue

You aro hereby notified that yOu have the right to bnng a civil action wrthin 90 days of the date of this letter against therespondent(s) named in the compJaint ' Such an action may be brought In any state cir iuit court in any county in whjch theunlawful discriminatory practico is alleged to have occurred-, either b6fore a ckcuit ol. urit.irt" oircuit,ludge, Not only rnustany action brought in court pursuant to this r ight to sue authorization be f i ted within gO days from the lat i ot this tetrer, anys u c h c a s e m u S t a | S o b e f i l e d n o l a t e r t h " n o ' y o , , r e a s o n a b | e d i s c o v e r y o f t h eatleged oause,

IF YOU DO NOT FILE A CIVIL ACTION IN STATE CIRCUIT COURT RELATING TO THE IVIATTERS ASSERTED INYOUR COMPLAINT WITH|N 90 DAYS OF THE DATE OF THts NoTtcE (AND WtTHtN TWO YEARS OF THE ALLEGEDcAusE, oR THE DlscovERY oF THE ALLEGED cAUsE, oF youR corupmtruri, Voun RTGHT To suE rs LosT.You are also notif ied that the Executive Director is administratively closing this cese and terminating atJ MCHR proceeotngsrelating to your complaint You may not rejrrstate this complaini wrth the MCHR or f i te a new comp/6int with the MCHRrelating to the same act or practice but rather, i f you choose to contrnue to pursue you;. .orpr"int, you must do so in court asdescribed in this lotter. This notice of right to sue has no effect on the surt-filing peri'oO of any federal claims.

In addition to the process described above, if any pgrty is ag_grieved hy this decision of the MCHR, that party may appeet thedec]sion by filing a petition under $ 536,I 50 of the Reviseo -Siatutes

o? Missouri in state circuit court, nny sLcn fetitiorr rnustbe fr lod in the circuit court of Colo Countv,

EXHIBIT

/

?01? 17-06 07=5? Human Rishts - KC

12154 Rock Roadd/b/a HotShots Sports Bar & Griil12154 St, Charles Rock RoadBridgeton, MO 69044

Daniel & Julie Volmert12664 Dorsett RoadMaryland Heights, MO 63043

Donna Harper2711 Clifton AvenueSt, Louis, MO 63139

SamuelW, Moore132 W, Washington Avenue, Suite 100Kirkwood, MO 63122

12154 Rock Roadd/b/a HotShots Sports Bar & Grillc/o Daniel & Julie Volmert, Owners3333 Ridgeway DriveSt. Charles, MO 63033

215 O'Fal lon Place. LLCdibla HotShots Sports Bar & Grilldo Daniel & Julie Volmert, Owners3333 Ridgeway DriveSt. Charles, MO 63033

730 HSBG, LLCd/h/a HotShots Sporls Bar & Griltdo Daniel & Julie Volmert, Owners3333 Ridgeway DriveSt. Charles, MO 63033

950-952 South Highway LLCd/b/a HotShots Sports Bar & Gritlc/o Daniel& Julie Volmert, Owners3333 Ridgeway DriveSt. Charles, MO 63033

1319 Central Park, LLCd/b/a HotShots Sports Bar & Gritlc/o Daniel & Julie Volmert, Owners3333 Ridgeway DriveSt, Charies, MO 63033

8168893582 >> 351054 P 5 t6

Michele scott vs, 12154 Rock Road dllla Hot$hots $ports Bar & Griil et alP_12t11-03543

?012 1?-06 07:5? Human Rishts - KC 8168893582 >> 351054 P 6/6

Michele scott vs' 12154 Rock Road d/b/a _Hotshots sports Bar & Grill et alP-12t11-03543

1636 Country CJub plaza, Inc,dibia Hotshots Sports Bar & Gritlc/a uaniel & Julie Volmert, Owners3333 Ridgeway DriveSt. Charles, MO 63033

3333 Ridgeway, Inc.d/b/a HotShots Sports Bar & Griilc/o Daniel & Julie Volmert, Owners3333 Ridgeway DriveSt. Charles, MO 63033

4021 Union LLCd/b/a HotShots Sports Bar & Grilldo. Daniel & JuJie Volrneft, Owners3333 Ridgeway DriveSt. Charles, MO 69039

12664 Dorsett Road, LLCdibla HotShots Sports Bar & Grjllc/o_Daniel & Julie Volmert, Owners3333 Ridgeway DriveSt. Chartes, MO 63033

14051 Manchester, Inc,d/b/a HotShots Sports Bar & Griilc/o Daniel & Julie Volmert, Owners3333 Ridgeway DriveSt, Chartes, MO 63098

?012 12-06 07:50 Human Rights - KC 816889359? >> 351054 P 1 /6

JEREi4AH W. (JAY) NIXoNGovenruofi ALVrN CaRr[R

CotttutssrOl CxlrnpcnsOnALISA WARRENT PH,O.ExLCulvE DtREcioF

IF YOU DO NOT FILE A CIVIL ACTION IN STATE CIRCUIT COURT RELATING TO THE MATTERS ASSERTEO INYOUR COMPLAINT WITHIN 90 DAYS OF THE DATE OF TH|S NOTICE (AND Wrrxrru rwo YEAR$ OF THE ALLEGEDcAUsE' oR THE DlscovERY oF THE ALLEcED cAUsE, oF youR coupLairlrt, ioun RTGHT To suE ts Losr.You are also notif ied that the Executive Director ls administratively closing this case and terminating al l MCHR proceedrngsrelating to your complaint, You may not reinstate this complaini wilh the l\4CHR or f i te a now comptatnt with the MCHRrelating to the same act or practice, but father i f you choose to continue to pursue your complaint, you must do so in court asdescribed rn this letter. This notrce of right to sue has no effect on the suit-fiirng peribO of any feOeral ctaims

In addit ion to the process described above, i f any pany 1s aggrieved by this decision of the MCHR that party may appeat thedec i s ionby f i l i ngape t i t i onunder$536 ,1500 f t heRev isedSta tu teso iM issou r j i ns ta tec i r cu i t cou r t . nnys l c r r pe t i r i onmus tbo filed in the circuit court of Cole Countv,

Respectfully,

/ - ' t - , "

\

1 , . , { / ' /' * - t \*--* ' / . ! - ,//

Al isa Warren, Ph.D,Executive Director

C: addit ional respondents on next pages

3315W Tl tuvuruBlvoP .O . Bax 1129

JF.FFEhS0N CrrY, M0 05102-1120PH0NE:573-751-3325FAX 573.751-2905

' l 1 ' 1 N T lHS l (n r ; r ,Su r r r 903 pO Box1300Sr . Lou S , M0 e0101 -2100 0 r r r x , M0 05721 -1300

PHoNE 314-34G75S0 FAX] 417.d85-60?dFAx.314-340-7238

December6 ?012Date

lI

1410 Gexceg re , Su TE .200l(ANsAs CrrY, [4o 6d 1 02

F^x: I 16-889,358?

RoloyMisFour i 1.$00.735-2000(TDO) 1,09A.709-?400(Voica)www l0bor rno oov/hr [email protected]

MISSOURI DCPANTUEIIT OF LABOR AND INDUSTRIAL RELATIONSMtssouRt CoMMtsstoN oN HuMAN RrcHrs

'lS-r.( , , . . , [ ' . ;

t i " ' - l'l-'MCl.lR'' --'---7,i

LAwRcNcC G, RcnNlxDEp^FTMINr DrRecron

Michele Scott2440 Brown RoadSt . Louis , Mo 63114

RE: Michele Scott vs. 12154 Rock Road d/b/a HotShots Sports Bar & Gri l ot alP-12t11_03s43

The Missouri commission on Human Rights (McHR) is terminating its proceedings and rssurng this notice of your rrght tosue urrder the Missouri Human Rights Act because you have requesieo a notice of lour r,gt,t to sue.

:HA:j:,:1tl:tj,l,:1 ll^",^1.j^ll1:.. $ils_lt lg.!rl.e a civir action within e0 days or the date or this tetter againsr theu u 9 r r 9 1 i l t 9

::"t,LTi":,f1,:il:^1.lt-jl:.??'ll:,li! S_":l,an action iray be.brousht in any stai"'ri'-"uir.oru in any counry in which rhe::5y:Tt.":tl1l?1,"-'lti1.1i:g_i:_Slfggg lo !ly: occurred', either b6rore

".il.,lt J'. urio.iri. .i,.;i'jlo* "idiffi#::llJ":|i!::l?"1sj:I^:tYtlJ:,:r,-t1,.':"1'..i,.s_h.ll?"t^'g.^lltl.oiitqlon be rired within e0 grvr t.* ir.'u ort,i or in,s r.tiJ'., ,rysuch case must also be f i led no I cause occurred or yOUr reasonable discovery Of thealleged cause

I Og ARThUR SIRCTT

?012 12-06 07:51 Human Rights - KC 8168893582 >> 351054

Angela Millstone vs. 12154 Rock Road d/b/a HotShots $por1s Bar & Gril l et alP-12t11-03542

1?154 Rock Roadd/h/a HotShots Sports Bar & Grill12154 St. Charles Rock Roadtsridgeton, MO 63044

Daniel & Julie Votmert12664 Dorsett RoadMaryland Heights, MO 63043

Donna Harper2711 Clifton AvenueSt, Louis, MQ 63139

SamuelW, Moore132 W, Washington Avenue, Sui te 100Kirkwood, MO 63122

12154 Rock Roadd/b/a HotShots Sports Bar & Grilldo Daniel & Julie Volmerl, Owners3333 Ridgeway DriveSt, Charles, MO 63033

215 O'Fal lon Place, LLCd/b/a Hotshots Soorts Bar & Grillc/o Daniel & Julie Volmeft, Owners3333 Ridgeway DriveSt, Charles, MO 63033

730 HSBG, LLCd/b/a HotShots Sporls Bar & Gritldo Daniel & Julie Volmert, Owners3333 Ridgeway DriveSt. Charles, MO 63033

950-952 South Highway LLCd/bia HotShots Sports Bar & GriJlc/o Daniel & Julie Volmert, Owners3333 Ridgeway DriveSt. Charles, MO 63033

1319 Central Park, LLCd/b/a notShots Sports Bar & Grillc/o Daniel & Julie Volmert, Owners3333 Ridgeway DriveSt. Charles, MO 63033

P 2/6

201? 12-06 07:51 Human Rishts - KC 8168893582 >> 351054 P 3/6

Angela Millstone vs, 12154 Rock Road d/b/a Hotshots sports Bar & Gril l et alP-12t11-03542

1036 Country Cluh ptaza, inc.d/bia HotShots $ports Bar & Gritldo Daniel & Julie Volmert, Owners3333 Ridgeway DriveSt, Charles, MO 63093

3333 Ridgeway, Inc,d/b/a HotShots Sports Bar & Griilc/o Daniel & Julie Volmert, Owners3333 Ridgeway DriveSt, Charles, MO 63033

4021 Union LLCd/b/a Hot$hots Sports Bar & Gritlc/o Daniel & Julie Volmert, Owners3333 Ridgeway DriveSt. Charles, MO 63033

12664 Dorsett Road, LLCd/b/a HolShots Sports Bar & Grilldo Daniel & Julie Volmert, Owners3333 Ridgeway DrjveSt, Charles, MO 63033

14051 Manchester, lnc.d/b/a Hot$hots Sports Bar & Grillc/o Daniel & Julie Votmert, Owners3333 Ridgeway DriveSt, Charles, MO 63033

MtssouRr Depenrmexr or Laeon exo lNousrRrAL RELATIoNS

ALVIN CARTER

Co[,,1MrssioN CHA RPERSoN

ALISA WARREN, PH,O.ExEcutvE 0TRFCToR

MIssouRI CoMMISSION ON HUMAN RIGHTSJEREMnH W, (JAY) NIxoN LAWRENCE G. REBMAN

GoVERNoR DEPARTMENT DIRECTOR

Michael Shelton12766 Spanish Village DriveBridgeton, MO 63044

lvrtat

3315 W TRUMAN BLVD,P O. Box 1 129

JEFFERSoN C|TY, MO 651 02-1 1 29PHoNE. 573-751.3325

FAx:573-751-2905

RE: Michael Shelton vs. 12154 ROCK ROAD D/B/A HOT SHOTS SPORTS BAR AND GRILL, ET AL.P-11t11-03523

The Missouri Commission on Human Rights (MCHR) is terminating its proceedings and issuing this notice of your right to sueunder the Missouri Human Rights Act because you have requested a notice of your right to sue.

You are hereby notifred that you have the right to bring a civil action within g0 days of the date of this letter against therespondent(s) named in the complaint. Such an action may be brought in any state circuit court in any county in which theunlawful discriminatory practice is alleged to have occurred, either before a circuit or associate circuit judge. Not only mustany action brought in court pursuant to thrs rrght to sue authorization be filed within 90 days from the date of this letter, anysuch case must also be filed no later than two vears after the alleqed cause occurred or your reasonable discovery of thealleged cause.

IF YOU DO NOT FILE A CIVIL ACTION IN STATE CIRCUIT COURT RELATING TO THE MATTERS ASSERTED IN YOURcoMpLAtNT WtTHtN 90 DAYS OF THE DATE OF TH|S NOTTCE (AND WITHTN TWO YEARS OF THE ALLEGED CAUSE,oR THE D|SCOVERY OF THE ALLEGED CAUSE, OF YOUR COMPLATNT), YOUR RIGHT TO SUE lS LOST.

You are also notified that the Executive Director is administratively closing this case and tefminating all MCHR proceedingsrelating to your complaint You may not reinstate this complaint with the MCHR or file a new complaint with the MCHRrelating to the same act or practice, but rather if you choose to continue to pursue your complaint, you must do so in court asdescribed in thrs letter. This notrce of rrght to sue has no effect on the suit-fil ing period of any federal claims.

In addition to the process described above, if any party is aggrieved by this decision of the MCHR, that party may appeal thedecision by fil ing a petition under $ 536.150 of the Revised Statutes of Missouri in state circuit court, Any such petition mustbe filed in the circuit court of Cole Countv

Respectfully,

1 ' ',- :/7-tL-t..'.--Oz' //-->--/{

Alisa Warren, Ph D.Executive Director

12154 ROCK ROAD D/BiA HOT Donna HarperSHOTS SPORTS BAR AND GRILL Sedey Harper PCET AL. 2711 Clif ton Ave

St . Louis , MO 6313912154 St. Charles Rock RdBridgeton, MO 63044ATTN: Daniel & Julie Volmert

November 14 ,2012Date

SamuelW. MooreRiggan Law Firm LLC132 W Washington AveSuite 100Kirkwood. MO 63122

n1 1 1 N. 7rH STREET, SurrE 903 P.O. Box 1 300Sr Lours, MO 63101-2100 ozAnK MO 65721-1300

PHoNE: 314-34c-7590 FAX 417-485.6024FAX: 314-340'7238

1410 GENESSEE, SUITE 260KANSAS Clft, MO 64102

FAx 816-88s-3582

1 06 ARTHUR STREETSutre D

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8 A

Hotshots Petition

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Transcript of Hotshots Petition