In the United States District Court for the Northern District of Illinois Eastern Division
Case: 1:12-cv-00660 Document #: 35 Filed: 07/16/12 Page 1 of 20 PageID #:272 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION JAVIER ROSAS, SERGIO VASQUEZ, OSCAR PEREZ, SANTOS PEREZ-SANDAJ, JOEL E. NAZARENO DONIS, EDWIN ALFONZO CRUZ, CHARLES BUNTING, JULIAN HERNANDEZ, ANTONIO MORALES, RAUL GUTIERREZ and RODRIGO CRUZ, Case No. 12 C 660 Plaintiffs, Judge Feinerman v. Magistrate Judge Schenkier CAPITAL GRILLE HOLDINGS, INC. d/b/a THE CAPITAL GRILLE, GMRI, INC. and DARDEN RESTAURANTS, INC., Defendants. SECOND AMENDED COMPLAINT Plaintiffs Javier Rosas, Sergio Vasquez, Oscar Perez, Santos Perez-Sandaj, Joel E. Nazareno Donis, Edwin Alfonzo Cruz, Charles Bunting, Julian Hernandez, Antonio Morales, Raul Gutierrez and Rodrigo Cruz, (collectively “Plaintiffs”), for their Complaint against Defendants Capital Grille Holdings, Inc. d/b/a The Capital Grille (hereafter “Capital Grille”), GRMI, Inc. and Darden Restaurants, Inc. (hereafter “Darden”) (collectively “Defendants”), state as follows: I. INTRODUCTION 1. Darden, along with its network of subsidiary companies, is an international conglomeration of restaurant chains which includes, among others, Olive Garden, Red Lobster, Bahama Breeze, Seasons 52, Longhorn Steakhouse and The Capital Grille restaurant concepts. The Capital Grille is Darden’s fine-dining brand and operates in cities across the United States, 1 Case: 1:12-cv-00660 Document #: 35 Filed: 07/16/12 Page 2 of 20 PageID #:273 including Los Angeles. Plaintiffs work or have worked as Servers, Cooks and Dishwashers. As described more fully herein, Darden, along with its subsidiary companies GMRI, Inc. and Capital Grille, have implemented policies at its Capital Grille restaurants in Los Angeles and across the U.S.
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