IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

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Morgan Haynes
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1 Randall K Rathbun Depew Gillen Rathbun & McInteer LC st 8301 E. 21 Street, Suite 450 Wichita, KS Telephone: ( Fax: ( randy@dpewgillen.com IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS AMANDA K. QUALLS, Plaintiff, vs. Case No. FRANCHISE STRATEGIES, INC., Defendant. COMPLAINT Comes now the plaintiff, by and through her counsel, Randall K. Rathbun of Depew Gillen Rathbun & McInteer, LC, and for her cause of action against the defendant, alleges and states as follows: 1. The plaintiff is a resident of Sedgwick County, Kansas. 2. The defendant is a corporation organized and existing under the laws of the State of Nevada. The defendant has been registered under the laws of the State of Kansas, but is, however, currently shown as being delinquent in its registration requirement with the State. Defendant may be served with process upon its registered

2 agent, Wayne L. Sanchez, 3161 W. Maple, Wichita, KS This action is brought pursuant to Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C et seq. and the Kansas Act Against Discrimination K.S.A The jurisdiction of this Court is invoked to secure protection of and redress deprivation of rights guaranteed by federal law, which rights provide for injunctive and other relief for illegal discrimination in employment. 4. The plaintiff has fully complied with all prerequisites to the jurisdiction of this Court under Title VII. The United States Equal Employment Opportunity Commission has issued a Notice of Right to Sue letter to the plaintiff. 5. This Court also has jurisdiction over plaintiff s claims pursuant to 28 USC 1331 and 29 USC 216(b. 6. Venue is proper in this Court under 28 USC 1391(b because a substantial part of the events giving rise to the claim occurred in this judicial district. 7. The defendant is a major contractor involved in building fast food restaurants across the United States. On information and belief, the defendant employs between 15 and 20 full time employees. 8. The plaintiff was hired by Stanley K. Stover, who is the defendant s president. Ms. Qualls job was to do the bookkeeping for the company. Shortly before her termination, Stover had promised plaintiff a promotion to executive assistant and a bonus to take care of her factory worker look. 2

3 9. The plaintiff actually met Stover at the Jehovah Witness church in Kingman, Kansas. To Stover, church membership in the Kingdom Hall was mandatory. Stover told Ms. Qualls that if she stopped coming to church, she would not be paid. 10. In March 2010, the plaintiff stopped attending the Jehovah Witness church and became uninvolved with the church. She was informed by Mr. Stover that if she didn t start going to church and marry her fiance, she would be disfellowshipped. Stover was a church elder in the Kingman Kingdom Hall. 11. Also in March, Stover repeatedly called her a filthy fornicator and told her that she needed to keep her pants on. The following month, Stover s treatment became more and more outrageous. At one point he told her that if she didn t get a job done on time, I will strip you naked and make you dance for the men in the shop. 12. On August 11, 2010, Stover told Ms. Qualls that his wife was getting upset with him for playing inappropriately with his foster daughters. As a result of this information, the plaintiff s fiance reported Stover to Child Protective Services on September 1, Ms. Qualls was fired two days later on September 3, As a result of Stover s conduct, the plaintiff has suffered lost wages, emotional distress and humiliation. She is currently unemployed. WHEREFORE, the plaintiff prays for a judgment in excess of $75,000 in actual damages, plus her attorneys fees, costs and any other and further relief as this Court might deem just or equitable. 3

4 Respectfully submitted, Randall K. Rathbun #09765 st 8301 E. 21 Street N., Suite 450 Wichita, KS Telephone: ( Fax: ( DESIGNATION OF PLACE OF TRIAL COMES NOW the plaintiff and designates Wichita, Kansas, as the place of the trial of this action. Respectfully submitted, Randall K. Rathbun #

5 REQUEST FOR JURY TRIAL COMES NOW the plaintiff and respectfully requests a trial by jury with regard to the above-captioned action. Respectfully submitted, Randall K. Rathbun, #

Case 5:15-cv SAC-KGS Document 1 Filed 08/06/15 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

Case 5:15-cv SAC-KGS Document 1 Filed 08/06/15 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS Case 5:15-cv-04918-SAC-KGS Document 1 Filed 08/06/15 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS COURTNEY L. CANFIELD, ) ) Plaintiff, ) ) vs. ) ) OFFICE OF THE SECRETARY