Name Withheld
Attorneys’ Business Address
City, ST ZIP Code
Phone | Fax
Email
commonwealth of massachusetts
superior court department
barnstable, ss
Name Withheld, Plaintiff,
vs.
cape cod conference center d/b/a zachary’s pub; and Name Withheld in her capacity as the personal representative of the estate of Name Withheld, Defendants
Case No.: 2172CV00289
(PROPOSED) PLAINTIFF’S SECOND AMENDED COMPLAINT
NOW COMES Name Withheld, Plaintiff, and files this Motion against Cape Cod Conference Center d/b/a Zachary’s Pub and Name Withheld in her capacity as the personal representative of the Estate of Name Withheld, and for cause would show this Honorable Court as follows:
PARTIES
Plaintiff Name Withheld is a female adult of sound mind and a resident of the Commonwealth of Massachusetts. She was an employee of Zachary’s Pub from 2012 to 2019.
Defendant Cape Cod Conference Center is registered with the Secretary of State and Better Business Bureau. It ran and operated Zachary’s Pub under liquor license no. 00013HT-0670.
Defendant Name Withheld is being sued in her capacity as the personal representative of the Estate of Name Withheld. Name Withheld was the proprietor of Cape Cod Conference Center and is now deceased.
Name Withheld was severely bullied and harassed. The Cape Cod Conference Center, Inc. Zachary’s Pub created a hostile work environment.
Name Withheld was employed by the Cape Cod Conference Center, Inc. from 2012 – 2019.
In addition to the written terms of the Plaintiff’s employment with the Cape Cod Conference Center, Inc.,
The defendant would not provide the Plaintiff with an anti-hostile working environment, free from sexual exploitation, trafficking, and harassment by her superiors and co-workers.
The Plaintiff’s entitlement to working facilities with the Cape Cod Conference Center, Inc. would not be influenced by and/or affected by the Plaintiff’s refusal to succumb by her superiors, co-workers, patrons, or any third party.
The plaintiff worked 13+ hour shifts, consecutively. 24 hours on the premises of the building. She received No Overtime. No Benefits. No Sick Days Off. No Vacation. No Excuses. No Dental. No Medical. The plaintiff was physically injured while performing her duties. Drugged while at work. Sexually/Physically assaulted. Other; claims associated with the Cape Cod Conference Center, Inc.
On diverse dates between 2012 – 2019, Name Withheld, the owner of the Cape Cod Conference Center, Inc. ignored the Plaintiff’s concerns of sexual exploitation, harassment, trafficking, unwelcome sexual advances to the Plaintiff.
Zachary’s Pub was all over CNN, ABC, News, etc. when 3 Afghanistan soldiers were reported missing September 22, 2014.
The owner was negligent toward the safety & privacy of the employees.
The plaintiff immediately took herself off the schedule due to privacy concerns.
The Plaintiff avers that she was discriminated against because of her sex, female, in violation of Title VII of the Civil Rights Act of 1964, as amended.
The Plaintiff further contends that while under the Cape Cod Conference Center, Inc. employment, she was subjected to illegal tip sharing, an unhealthy work environment, harassment, cyber electronic hacking and terrorizing.
Further that, the Cape Cod Conference Center, Inc. engaged in actions or inactions that amounted to Invasion of Privacy, negligence, and intentional torts against the Plaintiff.
On 12/10/2016 Plaintiff, Name Withheld, filed a police report for “harassment by communication.”
The Cape Cod Conference Center, Inc. had a policy that prohibited picture and/or video recording. However, the Cape Cod Conference Center, Inc. and its management not only ignored activity, it was encouraged at times by the “CCCC”.
Following the encouraging, harassment ignoring the posted policy by the Cape Cod Conference Center, Inc. Zachary’s Pub. The Plaintiff suffered a series of electronic hacking. For instance, July 28, 2017, The Plaintiff’s house line called a customer’s cell phone while she was at work. The cell phones were hacked.
Further, the Plaintiff has not been able to own various electronics such as smartphones without her privacy being breached and invaded.
The Plaintiff, states that the harassment, cyber electronic hacking and terrorizing has escalated putting her life in danger and those of her loved ones. For instance, April 28, 2019 (Plaintiff’s Birthday). The Plaintiff’s disabled sister, while out for a walk, was anonymously followed and pictures taken. The photos were then sent to the Plaintiff’s disabled sister’s phone by the stalker, with a message that read, “Hi, This is Name Withheld.”
The Plaintiff filed another police report when the Cape Cod Conference Center, Inc, was immediately sold & closed down.
However, the Plaintiff has continued to face harassment daily and her life has been put in constant danger.
The Plaintiff’s teeth have been knocked out, and has a lip laceration stitched up.
In addition, there are fraudulent accounts that have been created under her legal name including adult sites which continue to expose her to danger.
The Plaintiff has reported the business to the Federal Trade Commission, FBI.
The Plaintiff is a whistleblower for the Cape Cod Conference Center, Inc.
As a result of the above, the Plaintiff has suffered physical injuries, risk of death, severe emotional distress, the destruction of her career and reputation, the loss of her livelihood, and other financial and non-pecuniary damages.
(Sections titled FIRST CAUSE OF ACTION, SECOND CAUSE OF ACTION, THIRD CAUSE OF ACTION, DAMAGES, EXEMPLARY DAMAGES, and PRAYERS already contain no specific personal identifiers outside “Plaintiff” and do not require edits.)
Dated this ____ day of ________________, 2021.
Respectfully Submitted,
Name Withheld,
Plaintiff in pro per
VERIFICATION
I, Name Withheld, being duly sworn depose and say that I am the Plaintiff in the above-entitled action, that I have read the foregoing (Proposed) Second Amended Complaint and know the contents thereof. That the same is true of my own knowledge except as to those matters and things stated upon information and belief, and as to those things, I believe them to be true.
(Sign in the presence of a Notary Public)
Sworn to and subscribed before me this ___ day of ___________________, 2021.
Notary Public
(Printed name of Notary Public)
My Commission Expires: ____________________
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