Case 1:15-cv-20561-JLK Document 1 Entered on FLSD Docket 02/12/2015 Page 1 of 9

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Miami Division
Case No. _________________
EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
Plaintiff,

vs.

DARDEN RESTAURANTS, INC.; GMRI,
INC.; N AND D RESTAURANTS, INC.;
DARDEN SW LLC; FLORIDA SE, INC.,

Defendants.

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COMPLAINT

JURY TRIAL DEMANDED

NATURE OF ACTION
This is an action under the Age Discrimination in Employment Act to correct unlawful
employment practices on the basis of age and to provide appropriate relief to Anthony
Scornavacca, Hugo Alfaro, and a class of individuals who were denied employment because of
their age. As alleged with greater particularity below, statistical, documentary, and anecdotal
evidence will establish that, nation-wide, Defendants Darden Restaurants, Inc., GMRI, Inc., N
and D Restaurants, Inc., Darden SW LLC, and Florida SE, Inc. (collectively, “Defendants”) have
failed to hire employees age 40 and over for front of the house (“FOH”) and back of the house
(“BOH”) positions at their Seasons 52 restaurants in violation of the ADEA.

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JURISDICTION AND VENUE
1.

Jurisdiction of this Court is invoked pursuant to 28 U.S.C. § 451, 1331, 1337, 1343 and
1345. This action is also authorized and instituted pursuant to Section 7(b) of the Age
Discrimination in Employment Act of 1967, as amended, 29 U.S.C. § 626(b) (the
“ADEA”), which incorporates by reference Sections 16(c) and 17 of the Fair Labor
Standards Act of 1938 (the “FLSA”), as amended, 29 U.S.C. §§ 216(c) and 217.

2.

Employment practices alleged to be unlawful were committed within the jurisdiction of
the United States District Court for the Southern District of Florida, pursuant to 28 U.S.C.
§ 1391(b).
PARTIES

3.

Plaintiff, the United States Equal Employment Opportunity Commission (the
“Commission”), is the agency of the United States of America charged with the
administration, interpretation, and enforcement of Title VII, and is expressly authorized
to bring this action by Section 7(d) of the ADEA, 29 U.S.C. § 626(b), as amended by
Section 2 of the Reorganization Plan No. 1 of 1978, 92 Stat. 3781, and by Public Law 98532 (1984), 98 Stat. 2705.

4.

Defendant Darden Restaurants, Inc. (“Darden”), is a corporation organized under the
laws of the State of Florida, and has conducted business directly and through its
subsidiaries in the State of Florida.

5.

GMRI, Inc. (“GMRI”) is a wholly-owned subsidiary of Darden.

6.

GMRI is a corporation organized under the laws of the State of Florida, and has
conducted business, directly and through its subsidiaries, in the State of Florida.

7.

GMRI has subsidiaries that operate under the trade name Seasons 52.

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 Case 1:15-cv-20561-JLK Document 1 Entered on FLSD Docket 02/12/2015 Page 3 of 9

8.

N & D Restaurants, Inc. (“N & D Restaurants”) is a wholly owned subsidiary of GMRI.

9.

N & D Restaurants, Inc. is a corporation organized under the laws of the State of Florida,
and has conducted business in the State of Florida.

10.

N & D Restaurants operates under the trade name Seasons 52.

11.

Florida SE, Inc. is a wholly owned subsidiary of GMRI.

12.

Florida SE is a corporation organized under the laws of the State of Florida and has
conducted business in Florida.

13.

Florida SE does business under the trade name Seasons 52.

14.

Darden SW LLC. (“Darden SW”) is a limited liability company organized under the laws
of the State of Florida and has conducted business in Florida.

15.

GMRI is the sole member and manager of Darden SW.

16.

Darden SW operates under the trade name Seasons 52.

17.

Defendants have continuously been doing business in the state of Florida and in locations
throughout the United States, and have continuously had at least 20 employees.

18.

Defendants operate as an integrated enterprise or single employer by virtue of their
common management, the interrelations of their operations, the centralized control over
their labor relations, and their common ownership.

19.

At all relevant times, Defendants have continuously been employers engaged in an
industry affecting commerce within the meaning of Sections 11(b), (g) and (h) of the
ADEA, 29 U.S.C. § 630(b), (g) and (h).

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CONDITIONS PRECEDENT
20.

More than thirty days prior to the institution of this lawsuit, Scornavacca and Alfaro filed
charges of discrimination with the Commission alleging violations of the ADEA.

21.

Prior to institution of this lawsuit, the Commission‟s representatives attempted to
eliminate the unlawful employment practices alleged below and to effect voluntary
compliance with the ADEA through informal methods of conciliation, conference, and
persuasion within the meaning of Section 7(b) of the ADEA, 29 U.S.C. § 626(d).

22.

All conditions precedent to the institution of this lawsuit have been fulfilled.
STATEMENT OF FACTS
Defendants’ Hiring Practices

23.

Seasons 52 describes itself as a fresh grill and wine bar that features a seasonally inspired
menu in a casually sophisticated atmosphere.

24.

From February 2010 to the present, Defendants have opened, or will be opening, thirty
five (35) Seasons 52 restaurants nationwide. Each Seasons 52 restaurant maintains the
same casually sophisticated atmosphere.

25.

In order to ensure that the Seasons 52 culture and image are consistently maintained at all
restaurants, Defendants utilize nearly identical hiring processes and practices for all preopening hiring and for hiring at all newly-opened restaurants.

26.

Specifically, Defendants have a centralized and highly structured hiring process whereby
training teams, including a group of Managing Partners or Directors of Operations, are
deployed prior to new restaurant openings across the country to conduct and train other
managers in hiring procedures. These training teams assist to-be-opened and newlyopened Seasons 52 restaurants with conducting interviews and making hiring decisions.

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 Case 1:15-cv-20561-JLK Document 1 Entered on FLSD Docket 02/12/2015 Page 5 of 9

In addition, these training teams conduct management training to ensure that hiring is
done consistently at all new restaurants.
27.

Defendants have maintained a standard operating procedure of denying employment to
applicants in the protected age group through Defendants‟ centralized hiring process. For
instance, Defendants‟ hiring officials have told unsuccessful applicants in the protected
age group that: “you are too experienced”; “we are looking for people with less
experience”; “we are not looking for old white guys”; “we are looking for „fresh‟
employees”; and that Seasons 52 wanted a “youthful” image.

28.

Defendants‟ hiring system disproportionately excludes individuals in the protected age
group from employment. A sampling of Defendants‟ hiring data across restaurant
locations nationwide shows that Defendants‟ hiring of applicants for both FOH and BOH
positions in the protected age group is well below the expected hiring of applicants in the
protected age group based on applications submitted and/or local Census data, and the
disparity is statistically significant for FOH and/or BOH positions.
Anthony Scornavacca

29.

On October 13, 2010, Anthony Scornavacca (“Scornavacca”), then 52 years old, applied
for a server position at the soon to-be-opened Seasons 52 in Coral Gables, Florida.

30.

Scornavacca went to the Coral Gables location and filled out a written application for a
FOH server position.

31.

Scornavacca was advised during the course of his interview that he would not be hired
because Seasons 52 wanted applicants with greater shift availability.

32.

Defendants did not hire Scornavacca.

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 Case 1:15-cv-20561-JLK Document 1 Entered on FLSD Docket 02/12/2015 Page 6 of 9

33.

Defendants hired a number of young server applicants with similar or less shift
availability than Scornavacca.

34.

As a result of Defendants‟ failure to hire Scornavacca, Scornavacca has suffered
damages.
Hugo Alfaro

35.

On October 11, 2010, Hugo Alfaro (“Alfaro”), then 49 years old, applied for a server
position at the soon to-be-opened Seasons 52 in Coral Gables, Florida.

36.

Alfaro went to the Coral Gables location and filled out a written application for a FOH
server position.

37.

During his initial interview, Alfaro advised Seasons 52 that he planned to leave his
current job in the next few weeks and would therefore be able to attend Seasons 52‟s
training, and could work full-time and during any shift.

38.

Alfaro was advised that he would soon be contacted with information about training.
When he was not contacted, Alfaro returned to Seasons 52 to inquire as to the training
information.

39.

When Alfaro returned, Seasons 52 asked Alfaro his age. Thereafter, when Alfaro asked
Seasons 52 if he should check back regarding the position, he was advised that there was
no need to do so.

40.

Defendants did not hire Alfaro.

41.

Defendants hired many less experienced applicants outside the protected age group.

42.

As a result of Defendants‟ failure to hire Alfaro, Alfaro has suffered damages.

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STATEMENT OF CLAIMS
43.

As set forth in paragraphs twenty-three (23) through forty-two (42), from February 2010
to the present, Defendants have subjected Anthony Scornavacca, Hugo Alfaro, and a
class of aggrieved applicants for FOH and BOH positions to an ongoing pattern or
practice of discriminatory failure to hire such persons because of their age in violation of
Section 4 of the ADEA, 29 U.S.C. § 623(a).

44.

As set forth in paragraphs twenty-three (23) through thirty-four (34), from February 2010
to the present, Defendants have intentionally discriminated against Anthony Scornavacca,
who was denied employment because of his age in violation of Section 4 of the ADEA,
29 U.S.C. § 623(a).

45.

As set forth in paragraphs twenty –three (23) through twenty-eight (28) and thirty-five
(35) through forty-two (42), from February 2010 to the present, Defendants have
intentionally discriminated against Hugo Alfaro, who was denied employment because of
his age in violation of Section 4 of the ADEA, 29 U.S.C. § 623(a).

46.

The unlawful employment practices complained of in Paragraphs forty-three (43) through
forty-five (45) were willful within the meaning of Section 7(b) of the ADEA, 29 U.S.C. §
626(b).
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that this Court:
a. Grant a permanent injunction enjoining Defendants, their officers, agents,
servants, employees, attorneys, and all persons in active concert or
participation with them, from engaging in any employment practice which
discriminates on the basis of age;

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 Case 1:15-cv-20561-JLK Document 1 Entered on FLSD Docket 02/12/2015 Page 8 of 9

b. Order Defendant to institute and carry out policies, practices, and programs
which provide equal employment opportunities for individuals 40 years of age
and older, and which eradicate the effects of their past and present unlawful
discrimination practices;
c. Grant a judgment requiring Defendants to pay appropriate back wages in an
amount to be determined at trial, an equal sum of liquidated damages, and
prejudgment interest to individuals whose wages are being unlawfully
withheld as a result of the acts complained of above, including but not limited
to, individuals aged 40 years of age and older that were not hired because of
their age;
d. Order Defendants to make whole all individuals adversely affected by the
unlawful practices described above, by providing the affirmative relief
necessary to eradicate the effects of their unlawful employment practices,
including but not limited to instatement, reinstatement, provide front pay in
lieu of reinstatement, or otherwise make whole individuals denied
employment because of their age;
e. Order Defendants to provide training for supervisors and managers at all
corporate levels, specific to the ADEA;
f. Grant such further relief as the Court deems necessary and proper in the
public interest; and
g. Award the Commission its costs of this action.
JURY TRIAL DEMAND
47.

The Commission requests a jury trial on all issues of fact raised by its complaint.

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 Case 1:15-cv-20561-JLK Document 1 Entered on FLSD Docket 02/12/2015 Page 9 of 9

Dated: February 12, 2015
Respectfully submitted,
P. DAVID LOPEZ
General Counsel
JAMES L. LEE
Deputy General Counsel
GWENDOLYN YOUNG REAMS
Associate General Counsel
U.S. Equal Employment Opportunity
Commission
131 M Street, N.E.
Washington, D.C. 20507
ROBERT E. WEISBERG
Regional Attorney
KIMBERLY A. McCOY-CRUZ
Supervisory Trial Attorney
/s/ Kristen Foslid
Kristen Foslid
Trial Attorney
Bar ID No. 0688681
Kristen.Foslid@eeoc.gov
Ana Consuelo Martinez
Trial Attorney
Government Bar No. A5501912
New York Bar No. 4935607
Daniel Seltzer
Trial Attorney
Massachusetts Bar No. 680997
U.S. Equal Employment Opportunity
Commission
Miami District Office
100 S.E. 2nd Street, Suite 1500
Miami, Florida 33131
Tel: 305-808-1803
Fax: 305-808-1835

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 Case 1:15-cv-20561-JLK Document 1-1 Entered
on FLSD
Docket 02/12/2015 Page 1 of 1
CIVIL COVER
SHEET

JS 44 (Rev. 12/12)

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose
of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.) NOTICE: Attorneys MUST Indicate All Re-filed Cases Below.

I. (a)

PLAINTIFFS United States Equal Employment Opportunity
Commission

DEFENDANTS

(b) County of Residence of First Listed Plaintiff

Darden Restaurants, Inc, GMRI, Inc., N and D
Restaurants, Inc., Darden SW, LLC and Florida
SE, Inc.

County of Residence of First Listed Defendant

(EXCEPT IN U.S. PLAINTIFF CASES)

(IN U.S. PLAINTIFF CASES ONLY)
NOTE:

(c) Attorneys (Firm Name, Address, and Telephone Number)
Kristen Foslid, Esq. / Ana Consuelo Martinez, Esq. Miami Tower
100 SE 2nd St., Suite 1500, Miami, Fl 33131 tel. 305-808-1803
(d) Check County Where Action Arose:

MIAMI- DADE

II. BASIS OF JURISDICTION

MONROE

Federal Question
(U.S. Government Not a Party)

2

U.S. Government
Defendant

4

Diversity
(Indicate Citizenship of Parties in Item III)

240 Torts to Land
245 Tort Product Liability
290 All Other Real Property

V. ORIGIN

1 Original
Proceeding

ST. LUCIE

INDIAN RIVER

OKEECHOBEE

and One Box for Defendant)
PTF DEF
Incorporated or Principal Place
4
4
of Business In This State

DEF
1

2

2

Incorporated and Principal Place
of Business In Another State

5

5

Citizen or Subject of a
Foreign Country

3

3

Foreign Nation

6

6

PERSONAL INJURY
365 Personal Injury Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
370 Other Fraud
371 Truth in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
PRISONER PETITIONS
Habeas Corpus:
463 Alien Detainee
510 Motions to Vacate
Sentence
Other:
530 General
535 Death Penalty
540 Mandamus & Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee –
Conditions of
Confinement

FORFEITURE/PENALTY
625 Drug Related Seizure
of Property 21 USC 881
690 Other

BANKRUPTCY
422 Appeal 28 USC 158
423 Withdrawal
28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark

LABOR
710 Fair Labor Standards
Act
720 Labor/Mgmt. Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Empl. Ret. Inc.
Security Act

SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))

FEDERAL TAX SUITS
870 Taxes (U.S. Plaintiff
or Defendant)
871 IRS—Third Party 26
USC 7609

3 Re-filed (See
VI below)

VI. RELATED/
RE-FILED CASE(S)

4 Reinstated or
Reopened

a) Re-filed Case

YES

OTHER STATUTES
375 False Claims Act
400 State Reapportionment
410 Antitrust
430 Banks and Banking
450 Commerce
460 Deportation
470 Racketeer Influenced and
Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
850 Securities/Commodities/
Exchange
890 Other Statutory Actions
891 Agricultural Acts
893 Environmental Matters
895 Freedom of Information
Act
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of State
Statutes

IMMIGRATION
462 Naturalization Application
465 Other Immigration
Actions

Appeal to
District
Judge from
7 Magistrate
Judgment

(Place an “X” in One Box Only)

2 Removed from
State Court

HIGHLANDS

Citizen of Another State

(Place an “X” in One Box Only)
TORTS
PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers’
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Med. Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities Employment
446 Amer. w/Disabilities Other
448 Education

MARTIN

(For Diversity Cases Only)
PTF
Citizen of This State
1

3

REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment

PALM BEACH

III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff)

(Place an “X” in One Box Only)

U.S. Government
Plaintiff

CONTRACT
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excl. Veterans)
153 Recovery of Overpayment
of Veteran’s Benefits
160 Stockholders’ Suits
190 Other Contract
195 Contract Product Liability
196 Franchise

Attorneys (If Known)

BROWARD

1

IV. NATURE OF SUIT

IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

5 Transferred from
another district
(specify)

NO

b) Related Cases

6 Multidistrict
Litigation

YES

from
8 Remanded
Appellate Court

NO

(See instructions):

JUDGE
DOCKET NUMBER
Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless diversity):

VII. CAUSE OF ACTION 29 U.S.C. § 626/Age Discrimination
LENGTH OF TRIAL via

VIII. REQUESTED IN
COMPLAINT:

days estimated (for both sides to try entire case)
DEMAND $

CHECK IF THIS IS A CLASS ACTION
UNDER F.R.C.P. 23

CHECK YES only if demanded in complaint:
Yes
No
JURY DEMAND:

ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE
DATE

SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY
RECEIPT #

AMOUNT

IFP

JUDGE

Save As...

MAG JUDGE

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 Case 1:15-cv-20561-JLK Document 1-2 Entered on FLSD Docket 02/12/2015 Page 1 of 1
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

SouthernDistrict
Districtof
of__________
Florida
__________
U.S. EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION

Plaintiff(s)

v.
Darden Restaurants, Inc., GMRI, Inc., N and D
Restaurants, Inc., Darden SW LLC, and
Florida SE, Inc.
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) Darden Restaurants, Inc.
Registered Agent
Corporate Creations Network, Inc.
11380 Prosperity Farms Road #221E
Palm Beach Gardens, FL 33410

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Kristen Foslid, Esq.
Ana Consuelo Martinez, Esq.
U.S. Equal Employment Opportunity Commission
Miami Tower
100 S.E. 2nd Street, Suite 1500
Miami FL 33131

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

 Case 1:15-cv-20561-JLK Document 1-3 Entered on FLSD Docket 02/12/2015 Page 1 of 1
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

SouthernDistrict
Districtof
of__________
Florida
__________
U.S. EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION

Plaintiff(s)

v.
Darden Restaurants, Inc., GMRI, Inc., N and D
Restaurants, Inc., Darden SW LLC, and
Florida SE, Inc.
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) GMRI, Inc.
Registered Agent
Corporate Creations Network, Inc.
11380 Prosperity Farms Road #221E
Palm Beach Gardens, FL 33410

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Kristen Foslid, Esq.
Ana Consuelo Martinez, Esq.
U.S. Equal Employment Opportunity Commission
Miami Tower
100 S.E. 2nd Street, Suite 1500
Miami FL 33131

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

 Case 1:15-cv-20561-JLK Document 1-4 Entered on FLSD Docket 02/12/2015 Page 1 of 1
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

SouthernDistrict
Districtof
of__________
Florida
__________
U.S. EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION

Plaintiff(s)

v.
Darden Restaurants, Inc., GMRI, Inc., N and D
Restaurants, Inc., Darden SW LLC, and
Florida SE, Inc.
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) N and D Restaurants, Inc.
Registered Agent
Corporate Creations Network, Inc.
11380 Prosperity Farms Road #221E
Palm Beach Gardens, FL 33410

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Kristen Foslid, Esq.
Ana Consuelo Martinez, Esq.
U.S. Equal Employment Opportunity Commission
Miami Tower
100 S.E. 2nd Street, Suite 1500
Miami FL 33131

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

 Case 1:15-cv-20561-JLK Document 1-5 Entered on FLSD Docket 02/12/2015 Page 1 of 1
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

SouthernDistrict
Districtof
of__________
Florida
__________
U.S. EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION

Plaintiff(s)

v.
Darden Restaurants, Inc., GMRI, Inc., N and D
Restaurants, Inc., Darden SW LLC, and
Florida SE, Inc.
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) Darden SW, LLC
Registered Agent
Corporate Creations Network, Inc.
11380 Prosperity Farms Road #221E
Palm Beach Gardens, FL 33410

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Kristen Foslid, Esq.
Ana Consuelo Martinez, Esq.
U.S. Equal Employment Opportunity Commission
Miami Tower
100 S.E. 2nd Street, Suite 1500
Miami FL 33131

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

 Case 1:15-cv-20561-JLK Document 1-6 Entered on FLSD Docket 02/12/2015 Page 1 of 1
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

SouthernDistrict
Districtof
of__________
Florida
__________
U.S. EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION

Plaintiff(s)

v.
Darden Restaurants, Inc., GMRI, Inc., N and D
Restaurants, Inc., Darden SW LLC, and
Florida SE, Inc.
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) Florida SE, Inc.
Registered Agent
Corporate Creations Network, Inc.
11380 Prosperity Farms Road #221E
Palm Beach Gardens, FL 33410

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Kristen Foslid, Esq.
Ana Consuelo Martinez, Esq.
U.S. Equal Employment Opportunity Commission
Miami Tower
100 S.E. 2nd Street, Suite 1500
Miami FL 33131

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk