UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA Gretchen E. Cooper; Barbara M. Herold; and Lisa E.

Boutelle; Case File No._________ Plaintiffs, vs. COMPLAINT AND DEMAND FOR JURY TRIAL

Prince Abdul-Rahman bin Abdul-Aziz, solely in his individual capacity; Mohamed A. Elbashir, d.b.a. Crown Prince Limousine; Premier Crescent Services, LLC; and Highland International Transportation Services, Inc.; Defendants.

INTRODUCTION Plaintiffs Gretchen E. Cooper, Barbara M. Herold, and Lisa E. Boutelle were hired by Defendants in October 2010 to serve as limousine drivers for a number of Saudi Arabian citizens who were visiting Rochester, Minnesota. Shortly after they were hired, however, all three Plaintiffs were fired, expressly because they are women. This discriminatory action violated American law. Plaintiffs bring these claims against Defendants for violations of the Minnesota Human Rights Act, Title VII of the Civil Rights Act of 1964, and/or Minnesota tort law, to recover appropriate compensation for the humiliation and economic damages they have suffered and to enforce their right to equal opportunity in the American workplace.

PARTIES 1. Plaintiff Gretchen E. Cooper is a female individual who resides in Olmsted

County, Minnesota. 2. Plaintiff Barbara M. Herold is a female individual who resides in Olmsted

County, Minnesota. 3. Plaintiff Lisa E. Boutelle is a female individual who resides in Olmsted

County, Minnesota. 4. Plaintiff Gretchen E. Cooper, Plaintiff Barbara M. Herold, and Plaintiff

Lisa E. Boutelle are collectively referred to as Plaintiffs. 5. Defendant Prince Abdul-Rahman bin Abdul-Aziz is an individual who Prince Abdul-

resides, on information and belief, in Riyadh, Saudi Arabia. Rahman is named as a party solely in his individual capacity. 6.

Defendant Mohamed A. Elbashir is an individual registered to do business

in Minnesota under the name Crown Prince Limousine. 7. Defendant Premier Crescent Services, LLC, is a limited liability company

registered to do business in Minnesota. Premier Crescent Services had an office in Rochester, Minnesota. 8. Defendant Highland International Transportation Services, Inc. is a New

York corporation.
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Defendant Prince Abdul-Rahman bin Abdul-Aziz, Defendant Mohamed A.

Elbashir, Defendant Premier Crescent Services, LLC, and Defendant Highland International Transportation Services, Inc. are collectively referred to as Defendants. 10. Defendant Mohamed A. Elbashir, Defendant Premier Crescent Services,

LLC, and Defendant Highland International Transportation Services, Inc. are collectively referred to as U.S.-Based Defendants. 11. At all relevant times, Plaintiffs were employees of Defendants as defined

by Title VII, 42 U.S.C. 2000e et seq., and the Minnesota Human Rights Act, M.S.A. 363.01 et seq. 12. At all relevant times, Defendants were employers as defined by Title VII,

42 U.S.C. 2000e et seq., and the Minnesota Human Rights Act, M.S.A. 363.01 et seq. 13. In the alternative, at all relevant times, one or more of the U.S.-Based

Defendants were employment agencies as defined by Title VII, 42 U.S.C. 2000e et seq., and the Minnesota Human Rights Act, M.S.A. 363.01 et seq.

JURISDICTION 14. This Court has original jurisdiction over Plaintiffs claims arising under the

Civil Rights Act of 1964, as amended, 42 U.S.C. 2000e et seq. Jurisdiction over these claims is appropriate under 28 U.S.C. 1331. 15. Plaintiffs remaining claims are so related to those over which this Court

has original jurisdiction that they form part of the same case and controversy. Supplemental jurisdiction is therefore appropriate under 28 U.S.C. 1367. 16. The Court has personal jurisdiction over all Defendants, including those

who are foreign corporations or nonresident individuals, because Defendants transacted business within Minnesota and committed acts in Minnesota causing injury to the Plaintiffs. ADMINISTRATIVE CHARGE AND RIGHT TO SUE 17. On March 31, 2011, Plaintiffs filed charges for sex discrimination with the

Equal Employment Opportunity Commission against Defendant Mohamed A. Elbashir, d.b.a. Crown Prince Limousine; Defendant Premier Crescent Services, LLC; and Doe respondents including Saudi Arabian visitors and/or an agency located in New York City. Plaintiffs amended their charges to specifically name Defendant Highland International Transportation Services, Inc. as a respondent on April 4, 2011. Plaintiffs amended their charges to specifically name Defendant Prince Abdul-Rahman bin Abdul-Aziz as a respondent on June 30, 2011.
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Plaintiffs received a Right to Sue against Defendants from the EEOC on

June 21, 2012. FACTUAL ALLEGATIONS 19. Premier Crescent Services LLC is a company that provides transportation

services. 20. At all relevant times, Nabil K. Hanna acted as and held himself out to be a

representative of Premier Crescent Services, LLC. Premier Crescent Services, LLC had an office in Rochester, Minnesota. 21. Crown Prince Limousine is a company that provides transportation

services. 22. At all relevant times, Mohamed Elbashir acted as and held himself out to be

a representative of Crown Prince Limousine. 23. Highland International Transportation Services, Inc. (Highland) is a

company that provides transportation services. 24. A person identified as Mr. Ahmed acted as and held himself out to be a

representative of Highland in Rochester, Minnesota during Plaintiffs employment. 25. A group of Saudi Arabian nationals visited Rochester, Minnesota in

October 2010.

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This group was led by Prince Abdul-Rahman bin Abdul-Aziz (Prince

Abdul-Rahman) and included his family and friends. 27. Prince Abdul-Rahmans visit to Rochester, Minnesota in October 2010 was

for personal medical treatment. 28. At the direction of Prince Abdul-Rahman, the U.S.-Based Defendants

employed individuals to serve as drivers to transport Prince Abdul-Rahman and his party while they were in Rochester, Minnesota. 29. Upon information and belief, the U.S.-Based Defendants hired at least forty

drivers to transport the Saudi nationals. Defendant Premier Crescent Services accepted applications for the positions and hired drivers and Defendant Elbashir d.b.a Crown Prince Limousine issued their paychecks. The U.S.Based Defendants provided the cars the drivers used, required the drivers to wear a uniform, gave the drivers their assignments and determined the hours they worked. Plaintiffs Employment as Drivers 30. In September 2010, Plaintiffs learned that drivers were being hired to work

as drivers for Saudi visitors. Plaintiffs inquired about the job and were told that the drivers would be required to be available on-call every day, 24 hours a day, for the duration of the visitors stay, which would be at least a month. 31. Plaintiff Gretchen Cooper had successfully worked as a driver for a Saudi

visitor, Princess Nura bint Abdallah bin Muhammad Al Saud al-Kabir, in 2008. Upon learning of the opportunity to serve as a driver in September 2010, Plaintiff Cooper applied for a position and was hired.
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On or about September 28, 2010, Barbara Herold filled out an application

for employment with Crown Prince Limousine. 33. On September 30, 2010, Lisa Boutelle filled out an application for

employment with Crown Prince Limousine. 34. 35. On or about Friday, October 1, 2010, Plaintiffs accepted the driving jobs. On information and belief, Plaintiffs were the only women among the

drivers hired. 36. On the night of October 1, 2010, Plaintiffs and the other drivers drove to

the airport and picked up some of the Saudi Arabian visitors. The drivers brought the visitors to the Kahler Hotel in Rochester. 37. An individual introduced as Mr. Ahmed and identified as an employee of

Defendant Highland International and Defendant Elbashir gave directions to Nabil Hanna of Defendant Premier Crescent Services regarding individual driver assignments. Hanna passed these directions on to the drivers. 38. On the following day, Saturday, October 2, 2010, Plaintiffs refueled and

washed their assigned vehicles, and waited on-call to continue with their job duties along with the other drivers. Plaintiffs Termination 39. A witness present at the Kahler Hotel heard an unidentified male tell Nabil

Hanna that Prince Abdul-Rahmans party wanted no women drivers.

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Plaintiffs Boutelle and Herold were at the Kahler Hotel that morning, ready

to resume driving their assigned Saudi nationals. Plaintiff Cooper waited for several hours until she was asked to report to the Kahler, which she did. 41. When Plaintiff Cooper arrived at the Kahler, Defendant Elbashir told her to

remove her belongings from the car. After Cooper did so, a male driver got into the car. Shortly thereafter, the Saudi princess whom Cooper was assigned to drive arrived at the car with several others, and the car departed with the male driver. 42. Plaintiff Cooper waited in the Kahler lobby seeking an explanation. When

she inquired of Defendant Elbashir why the princess had left with another driver, he told her to report to the office. 43. Plaintiff Cooper was driven to the office, where she spoke with Nabil

Hanna. Hanna told her that he was going to have to let her go because they didnt want any women drivers. 44. Plaintiff Boutelle received a cell phone call from Nabil Hanna summoning

her to the office. 45. When Plaintiff Boutelle got to the office, Hanna told her they needed her

keys. Hanna told Boutelle that they didnt need her to drive because they didnt want women drivers. 46. Plaintiff Barbara Herold had also been summoned to Nabil Hannas office

and was waiting outside while Hanna spoke with Plaintiff Boutelle. Plaintiff Herold heard Hanna tell Boutelle that they didnt want women drivers.

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Hanna called Plaintiff Herold into his office next and told her that her

services were no longer needed because the princesses did not want any women drivers. 48. 49. Plaintiffs Boutelle and Herold were also replaced with male drivers. Male drivers continued to drive the Saudi nationals for the remainder of

their visit to Rochester. Defendants have not offered any of the Plaintiffs any other driving assignment. 50. On information and belief, new visitors from Saudi Arabia have come to

Rochester and drivers have been hired, but since Plaintiffs terminations, no women have been hired to serve as drivers for Saudi visitors. COUNT I SEX DISCRIMINATION Title VII 51. 52. Plaintiffs reallege the foregoing paragraphs as though fully set forth herein. Defendants termination of Plaintiffs employment because they are women

subjected Plaintiffs to discrimination because of their sex within the meaning of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. 2000e-2(a) or 2000e-2(b). 53. As a result of their discriminatory terminations, Plaintiffs have suffered and

continue to suffer lost compensation and emotional anguish. 54. As a result of their discriminatory terminations, Plaintiffs have incurred and

will continue to incur attorney fees and costs.

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COUNT II SEX DISCRIMINATION Minnesota Human Rights Act 55. 56. Plaintiffs reallege the foregoing paragraphs as though fully set forth herein. Defendants termination of Plaintiffs employment because they are women

subjected Plaintiffs to discrimination because of their sex within the meaning of Minn. Stat. 363A.03, subd. 13 and 42. Defendants actions, therefore, constitute unfair employment practices against Plaintiffs in violation of Minn. Stat. 363A.08, subd. 2 or subd. 3. 57. As a result of their discriminatory terminations, Plaintiffs have suffered and

continue to suffer lost compensation and emotional anguish. 58. As a result of their discriminatory terminations, Plaintiffs have incurred and

will continue to incur attorney fees and costs. COUNT III TORTIOUS INTERFERENCE WITH CONTRACT 59. 60. Plaintiffs reallege the foregoing paragraphs as though fully set forth herein. Plaintiffs had a contract with one or more of Defendants to serve as drivers

for the Saudi Arabian visitors. 61. 62. Defendants had knowledge of that contract. Defendants intentionally and improperly interfered with the performance of

that contract. 63. As a result of Defendants improper interference with their contract,
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Plaintiffs have suffered and continue to suffer lost compensation and emotional anguish.

JURY DEMAND 64. Plaintiffs demand a jury trial on all claims for which a jury trial is available.

PRAYER FOR RELIEF A. That the practices of Defendants complained of herein be adjudged, decreed and declared to be violative of the rights secured to Plaintiffs by 42 U.S.C. 2000e-2 et seq. and Minnesota Statute 363A.01 et seq. B. That a permanent mandatory injunction be issued requiring that Defendants adopt practices in conformity with the requirements of 42 U.S.C. 2000e-2 and Minnesota Statute 363A.01 et seq. C. That a permanent prohibitory injunction be issued prohibiting Defendants from engaging in the practices complained of herein. D. That the Court order Defendants to pay a civil penalty to the State of Minnesota pursuant to Minn. Stat. 363A.29 and 363A.33. E. That Plaintiffs be awarded compensatory damages in an amount to be established at trial. F. That Plaintiffs be awarded punitive damages for their claims under 42 U.S.C. 2000e-2 et seq. and Minnesota Statute 363A.01 et seq in an amount to be established at trial.
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G. That the Court issue an order enjoining Defendants and their officers, agents and employees from subjecting Plaintiffs to differential treatment and from any retaliation against Plaintiffs for prior actions, or for bringing this action. H. That the Court retain jurisdiction until such time as the Court is satisfied that the Defendants have remedied the practices complained of herein and are determined to be in full compliance with the law. I. That the Court order Defendants to pay counsel for Plaintiffs their reasonable attorneys fees and the costs and expenses of this action. J. That Plaintiffs be awarded such other and further legal and equitable relief as may be found appropriate, just, and equitable.

Dated: September 19, 2012

Respectfully submitted, GENDER JUSTICE By: s/ Lisa C. Stratton

Lisa C. Stratton (MN No. 236858) Jill R. Gaulding (MN No. 388751) Minnesota Womens Building 550 Rice Street St. Paul, MN 55103 Phone: 651-789-2090 Fax: 651-789-2093 lisa.stratton@genderjustice.us jill.gaulding@genderjustice.us ATTORNEYS FOR PLAINTIFFS

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