BUREAU OF LABOR AND INDUSTRIES Civil Rights Division Complaint of Unlawful Practice COMPLAINANT: Commissioner Brad Avakian Bureau of Labor and Industries 800 NE Oregon Street, #1045 Portland, OR 97232 Case RESPONDENT: Frehoo, Inc. DBA Stars Cabaret Steak House 4570 SW Lombard Beaverton, OR 97075 Contact: Lisa Amato Wyse Kadish LLP 621 SW Morrison Ste 1300 Portland OR 97205 Jeff Struhar 25989 Butteville Rd Aurora, OR 97002 County: WA of Employees: 15+ Headquarters: Frehoo, Inc. 4570 SW Lombard Beaverton, OR 97075 Phone ORS 1, Commissioner Brad Avakian, being ?rst duly sworn, do depose and say as follows: Allegations: In order to protect the interests of vulnerable minors, and to ensure that the public?s interest in this and similar matters is protected, the Commissioner of the Bureau of Labor and Industries hereby sets forth the following allegations: 1. During 2012, Respondent, directly or through an agent, employed a female individual under 16 years of age; her employment was explicitly conditioned on engaging in sexual acts with Respondent?s customers . 2. On or about December 10, 2013, police arrested one of Respondent?s managers based on charges including sexual abuse and compelling prostitution of a minor. Those offenses occurred within Respondent?s establishment and in the course of the minor?s employment, and that manager subsequently pled guilty to those charges. Continued on reverse side PORTLAND SALEM 800 NE Oregon St., Suite 1045 Portland, Oregon 97232-2180 Salem, Oregon 97305?1268 3865 \v'volverine Ave. E-i EUGENE 1400 Executive Parkway, Suite 200 Eugene, Oregon 97401?2158 3. Subsequent to the sexual exploitation of the above minor employee, Respondent?s president Jeff Struhar did not take appropriate corrective action to prevent the future sexual exploitation of other minor employees. 4. During the period from July to September, 2014, Respondent, directly or through an agent, employed another female individual under 16 years of age; that child?s employment was explicitly conditioned on the lewd exhibition of her sexual or other intimate parts to Respondent?s customers. 5. The conditions of employment for these minors constituted sexual harassment under OAR 839-005- 0030. The Commissioner believes Respondents have a continuing practice of unlawful employment discrimination based on sex, in that Respondents subject female minors to sexual harassment, in violation of ORS 7.23.15 I swear (or af?rm) that I know and understand this complaint and that it is true to the best of my knowledge, information and belief. I understand that this complaint is a public record and that the information herein may be disclosed to any person, at any time. Your signature: Veri?cation upon Oath orAf?rmation State of OREGON County of Signed and sworn to (or af?rmed) before me this Day of 20L by 1'0ka I on (name of person making statement). rim Notary Public State 0 REGON ?ax/9016? Date on winch commission expires FFIGIAL STAM SHANNON LYNN WILLIS NOTARY PUBLIC - OREGON COMMISSION NO. 924990 MY COMMISSION EXPIRES arm-comm i "t i 18