Free Affidavit - District Court of Delaware - Delaware

_ 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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y ° Case 1:07-cv—0O129-IVIPT Document 51 Filed 02/29/2008 Page 3 of 3
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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"¤»?’»—';{`“”69` 191/
NEP:pmw 1
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