johnny h. smith § in the district court …files.courthousenews.com/2009/06/30/creature production...

PLAINTIFF'S ORIGINAL PETITION

NO. _____________

JOHNNY H. SMITH § IN THE DISTRICT COURTPlaintiff, §

§V. § _____________ JUDICIAL DISTRICT

§CREATURE PRODUCTION COMPANY, LLC, SHAUNA MAST AND MIKE HAMILTON

§

Defendants. § OF HARRIS COUNTY, TEXAS


TO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES Johnny H. Smith, hereinafter called Plaintiff, complaining of and about

CREATURE PRODUCTION COMPANY, LLC, Shauna Mast and Mike Hamilton, hereinafter called

Defendants, and for cause of action shows unto the Court the following:

DISCOVERY CONTROL PLAN LEVEL

Plaintiff intends that discovery be conducted under Discovery Level 2.1.

PARTIES AND SERVICE

Plaintiff, Johnny H. Smith, is an Individual whose address is 5616 Pine Street, in 2.

Houston, Harris County, Texas [77081].

The last three digits of the driver's license number of Johnny H. Smith are 837. The 3.

last three digits of the social security number for Johnny H. Smith are 499.

Defendant CREATURE PRODUCTION COMPANY, LLC, a non-resident 4.

Filed 09 June 22 P4:31Loren Jackson - District ClerkHarris CountyED101J015439456By: Sharon Carlton

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Corporation, has failed to appoint or does not maintain a registered agent in Texas.

Pursuant to Article 2.11(B) of the Business Corporation Act, or its successor statute, §

5.251(1)(A) of the Texas Business Organizations Code, service may be effected upon

Defendant CREATURE PRODUCTION COMPANY, LLC by serving the honorable

Secretary of State of Texas, Statutory Documents Section, Citations Unit, P.O. Box

12079, Austin, Texas 78711-2079. Service of said Defendant as described above can

be effected by personal delivery.

Defendant Shauna Mast, an individual who is a non-resident of Texas, may be served 5.

with process at her place of employment at the following address: Walking with

Dinosaurs Tour, at Conseco Fieldhouse, One Conseco Court; 125 S. Pennsylvania

Street; Indianapolis, IN [46204]. Service of said Defendant as described above can


Defendant Mike Hamilton, an Individual who is a non-resident of Texas, may be served 6.

with process at his place of employment at the following address: Walking with

Dinosaurs Tour, at Conseco Fieldhouse, One Conseco Court; 125 S. Pennsylvania

Street; Indianapolis, IN [46204]. Service of said Defendant as described above can


JURISDICTION AND VENUE

The subject matter in controversy is within the jurisdictional limits of this court.7.

This court has jurisdiction over Defendant CREATURE PRODUCTION COMPANY, 8.

LLC, because said Defendant purposefully availed itself of the privilege of conducting

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activities in the state of Texas and established minimum contacts sufficient to confer

jurisdiction over said Defendant, and the assumption of jurisdiction over CREATURE

PRODUCTION COMPANY, LLC will not offend traditional notions of fair play and

substantial justice and is consistent with the constitutional requirements of due process.

Plaintiff would also show that the cause of action arose from or relates to the contacts 9.

of Defendant CREATURE PRODUCTION COMPANY, LLC to the state of Texas,

thereby conferring specific jurisdiction with respect to said Defendant.

Furthermore, Plaintiff would show that Defendant CREATURE PRODUCTION 10.

COMPANY, LLC engaged in activities constituting business in the state of Texas as

provided by § 17.042 of the Texas Civil Practice and Remedies Code, in that said

Defendant contracted with a Texas resident and performance of the agreement in

whole or in part thereof was to occur in Texas, committed a tort in whole or in part in

Texas, and recruits or has recruited Texas residents for employment inside or outside

this state.

This court has jurisdiction over Defendant Shauna Mast, because said Defendant 11.

purposefully availed herself of the privilege of conducting activities in the state of

Texas and established minimum contacts sufficient to confer jurisdiction over said

Defendant, and the assumption of jurisdiction over Shauna Mast will not offend

traditional notions of fair play and substantial justice and is consistent with the

constitutional requirements of due process.

Furthermore, Plaintiff would show that Defendant Shauna Mast engaged in activities 12.

constituting business in the state of Texas as provided by § 17.042 of the Texas Civil

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Practice and Remedies Code, in that said Defendant committed a tort in whole or in

part in Texas and recruits or has recruited Texas residents for employment inside or

outside this state.

This court has jurisdiction over Defendant Mike Hamilton, because said Defendant 13.

purposefully availed himself of the privilege of conducting activities in the state of

Texas and established minimum contacts sufficient to confer jurisdiction over said

Defendant, and the assumption of jurisdiction over Mike Hamilton will not offend

traditional notions of fair play and substantial justice and is consistent with the

constitutional requirements of due process.

Furthermore, Plaintiff would show that Defendant Mike Hamilton engaged in activities 14.

constituting business in the state of Texas as provided by § 17.042 of the Texas Civil

Practice and Remedies Code, in that said Defendant committed a tort in whole or in

part in Texas and recruits or has recruited Texas residents for employment inside or

outside this state.

Venue in Harris County is proper in this cause under Section 15.020 of the Texas Civil 15.

Practice and Remedies Code because this lawsuit involves a "major transaction" as

defined in said section, and CREATURE PRODUCTION COMPANY, LLC,

Defendant herein, has agreed in writing that suit may be brought in this county.

Furthermore, because venue is proper with respect to Defendant CREATURE

PRODUCTION COMPANY, LLC, venue for this action with respect to all

Defendants is proper under 15.005 of the Texas Civil Practice and Remedies Code.

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FACTS

Your Plaintiff, Johnny Smith, is a professional theater and film customer, with 16.

nearly twenty years of experience as a costume designer, wardrobe supervisor,

dresser, movie costumer, and stage hand.

The Plaintiff was hired by Defendant CREATURE PRODUCTION COMPANY, 17.

LLC to work on the touring company of “Walking with Dinosaurs.”

The Plaintiff was hired to run and supervise the show’s “skins” department, which 18.

was (and is) the equivalent of a wardrobe department, involving the costuming of

mechanical dinosaurs, suit performers, as well as actors.

Defendant CREATURE PRODUCTION COMPANY, LLC negotiated the terms 19.

of the Plaintiff’s employment in frequent telephone calls to the Plaintiff, in

Houston, Texas.

The Plaintiff was offered his employment position with CREATURE 20.

PRODUCTION COMPANY, LLC in Houston, Texas.

The Plaintiff accepted the position, and signed an employment contract, in 21.

Houston.

The Plaintiff reported for work, in his new position on the “Walking with 22.

Dinosaurs” tour in El Paso County, Texas.

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In El Paso, he was asked to sign a revised contract.23.

On or about the time that the Plaintiff was hired to be the head and the supervisor 24.

of the “skins” department, his predecessor, Defendant Shauna Mast, was offered,

and had accepted, the precisely same position on a European tour of the show,

produced by Defendant CREATURE PRODUCTION COMPANY, LLC.

Defendant CREATURE PRODUCTION COMPANY, LLC promised that 25.

Defendant Mast would provide training to the Plaintiff, and kept her on tour, in the

United States, precisely to do so. During this period, Defendant, to facilitate this

training, paid two people to fill the same position on the tour, and delayed Ms.

Mast’s departure to Europe.

All parties understood that the Plaintiff’s training would be needed for him to 26.

perform his duties, and contribute to the success of the show.

The promised training hardly ever happened. While training sessions were 27.

frequently and even consistently promised, by Defendant CREATURE

PRODUCTION COMPANY, LLC, Defendant Mast and others, they did not

occur except on a handful of occasions. The delays and cancellations of the

training sessions were because Defendant Mast was consistently hung-over, or

inebriated, or too exhausted from the previous night’s escapades, to provide any

such training in any meaningful way.

The loss of Defendant Mass to the tour was a subject of considerable chagrin to 28.

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many male members of the touring show crew, as Defendant Mass was a reliable

party partner and reliable flirting partner for these men.

This was a role the Plaintiff could not, and did not wish to, play. 29.

The traveling crew members made no secret of their displeasure with having a 30.

male fill the “skins” supervisor position, telling the Plaintiff that he “did not fit in,”

“was not one of the boys,” and, solely because he was a gay male, that “we had a

sexual predator” on the crew.

The most frequent, but not only, source of this harassment was Defendant 31.

Hamilton.

This conduct was reported to the Company Manager, Mr. Scott Ellis, not yet a 32.

Defendant in this action, who consciously and purposefully did nothing in response

to the harassment.

While lacking the promised training, and lacking any possible substitute for this 33.

training, the Plaintiff did the best he could to perform his duties for the show.

The show, meanwhile, told him that he was “falling behind,” even though, by 34.

asking him to perform the job of a trained skins supervisor, it was effectively

asking him to make bricks without straw. See Exodus 5.

Plaintiff traveled with the tour, from El Paso, Texas, to Birmingham, Alabama, and 35.

to Bakersfield, California.

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In Bakersfield, on his third week working with the tour, the Plaintiff was informed 36.

that he was no longer of use to the tour, that he was not fitting in, that he was not

one of the boys, and, for these reasons, he was being sent home. He was sent

home.

The Plaintiff was replaced, on the theater tour, by a female.37.

The experience, and the termination of the Plaintiff’s employment, resulted in 38.

mental anguish and distress.

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PLAINTIFF JOHNNY SMITH’S CLAIM FOR DEFAMATIONAGAINST DEFENANT MAST

Defendant Mast made comments, on more than one occasion, to other members of 39.

the traveling theater company, and to individuals not with the theater company,

about the Plaintiff’s skills.

Defendant Mast made comments, one more than one occasion, to other members 40.

of the traveling theater company, and to individuals not with the theater company,

about the Plaintiff’s masculinity and sexual history.

The statements made by Defendant Mast were, and are, untrue.41.

The statements made by Defendant Mast were, and are, injurious to the Plaintiff’s 42.

professional reputation and, indeed, were made precisely because they were

intended to cause such injury.

The statements made by Defendant Mast were, and are, injurious to the Plaintiff’s 43.

professional reputation.

Plaintiff has suffered damages to his reputation in the general community, and, 44.

more importantly, in the theatrical and creative community, in which he works, and

to which he has dedicated his entire career.

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PLAINTIFF JOHNNY SMITH’S CLAIM FOR DEFAMATION

AGAINST DEFENANT HAMILTON

Defendant Mast made comments, ne more than one occasion, to other members of 45.

the traveling theater company, and to individuals not with the theater company,

about the Plaintiff’s skills.

Defendant Mast made comments, one more than one occasion, to other members 46.

of the traveling theater company, and to individuals not with the theater company,

about the Plaintiff’s masculinity and sexual history.

The statements made by Defendant Hamilton were, and are, untrue.47.

The statements made by Defendant Hamilton were, and are, injurious to the 48.

Plaintiff’s professional reputation and, indeed, were made precisely because they

were intended to cause such injury.

The statements made by Defendant Hamilton were, and are, injurious to the 49.

Plaintiff’s professional reputation.

Plaintiff has suffered damages to his reputation in the general community, and, 50.

more importantly, in the theatrical and creative community, in which he works, and

to which he has dedicated his entire career.

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PLAINTIFF JOHNNY SMITH’S CLAIM FOR INTERFERENCE WITH

CONTRACTURAL RELATIONS AGAINST DEFENDANT MAST

Defendant Mast set out to remove the Plaintiff from the theater tour, for reasons 51.

unknown, but that may have included fear of reprisal for failing to train, and fear of

unfavorable professional and skill-level comparisons.

Defendant Mast purposefully withheld training and instruction, so that the 52.

Plaintiff’s job performance would be less pleasing to his employer.

Defendant Mast urged officials of the Defendant CREATURE PRODUCTION 53.

COMPANY, LLC to remove the Plaintiff from the ‘Dinosaurs” tour.

Defendant Mast’s efforts to interfere with the Plaintiff’s contract with his employer 54.

were successful.

The Plaintiff suffered lost wages, lost benefits, and out of pocket-expenses as a 55.

result of this interference, of at least one hundred and ten thousand dollars.

PLAINTIFF JOHNNY SMITH’S CLAIM FOR INTERFERENCE WITH

CONTRACTURAL RELATIONS AGAINST DEFENDANT HAMILTON

Defendant Hamilton set out to remove the Plaintiff from the theater tour, for 56.

reasons unknown, but that may have included fear of losing a flirting partner, and

not having a female in this position.

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Defendant Hamilton purposefully engaged in sexual harassment, in the hope that 57.

such harassment would negatively affect the Plaintiff’s work performance.

Defendant Hamilton urged officials of the Defendant CREATURE 58.

PRODUCTION COMPANY, LLC to remove the Plaintiff from the ‘Dinosaurs”

tour, solely because he preferred someone in the skins supervisor position who

would, as Defendant Mast did, expose her breasts to him, sit on his lap, and

engage in similar activities with other, male, members of the crew.

Defendant Hamilton’s efforts to interfere with the Plaintiff’s contract with his 59.

employer were successful.

The Plaintiff suffered lost wages, lost benefits, and out of pocket-expenses as a 60.

result of this interference, of at least one hundred and thousand dollars.

PLAINTIFF JOHNNY SMITH’S CLAIM FOR INTENTIONAL INFLICTION OF

EMOTIONAL DISTRESS AGAINST DEFENDANT MAST

Defendant Mast purposefully engaged in conduct towards and around the Plaintiff 61.

that was exceptional, unprofessional, harassing, mean-spirited, and outrageous.

Defendant Mast engaged in this conduct for the purpose of causing the Plaintiff 62.

emotional anguish and distress.

Defendant Mast’s conduct did cause the Plaintiff emotional anguish and distress.63.

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The Plaintiff’s anguish and distress lead to, and included, sleeplessness, self-esteem 64.

challenges, and depression.

The Plaintiff is entitled to compensation for his anguish and emotional distress.65.


EMOTIONAL DISTRESS AGAINST DEFENDANT HAMILTON

Defendant Hamilton purposefully engaged in conduct towards and around the 66.

Plaintiff that was exceptional, unprofessional, harassing, mean-spirited, and

outrageous.

Defendant Hamilton engaged in this conduct for the purpose of causing the 67.

Plaintiff emotional anguish and distress.

Defendant Hamilton’s conduct did cause the Plaintiff emotional anguish and 68.

distress.





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EMOTIONAL DISTRESS AGAINST DEFENDANT CREATURE PRODUCTION

COMPANY, LLC

Representatives and agents of Defendant CREATURE PRODUCTION 71.

COMPANY, LLC, an entity that can only act through its human representatives

and agents, purposefully engaged in conduct towards and around the Plaintiff that

was exceptional, unprofessional, harassing, mean-spirited, and outrageous.

Defendant XYX engaged in this conduct for the purpose of causing the Plaintiff 72.

emotional anguish and distress.

Defendant CREATURE PRODUCTION COMPANY, LLC’s conduct did cause 73.

the Plaintiff emotional anguish and distress.




PLAINHTIFF JOHNNY SMITH’S FIRST CLAIM FOR BREACH OF

CONTRACT AGAINST DEFENDANT

CREATURE PRODUCTION COMPANY, LLC

Plaintiff was promised professional, helpful, attentive training by a professional, 76.

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experienced, and dedicated person, to learn that various tasks to contribute to the

theatrical tour.

The Plaintiff was not provided with the promised training.77.

The Plaintiff’s lack of training was then given as an actual reason, or excuse, for 78.

terminating his association with the theater tour.

The Plaintiff’s lack of training caused him to have a diminished reputation and 79.

collegiality on the theater tour.

The Plaintiff’s lack of training is a lost opportunity for knowledge that would be 80.

useful in Plaintiff’s career.

The Plaintiff performed the consideration he promised in return for this training.81.

The lack of training was a breach of the Defendant’s contract with the Plaintiff.82.

As a result of the breach of contract, the Plaintiff suffered damages, including lost 83.

wages, lost benefits, lost travel and exploration opportunities, lost professional

experience, and out of pocket expenses, equaling at least two hundred thousand

dollars.

PLAINTIFF JOHNNY SMITH’S SECOND CLAIM FOR BREACH OF


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An implicit term in the Plaintiff’s contract with Defendant CREATURE 84.

PRODUCTION COMPANY, LLC was that he would be treated with

professionalism and courtesy, and would not be the victim of sexual harassment.

Plaintiff was denied the harassment-free environment.85.

Instead, Defendant CREATURE PRODUCTION COMPANY, LLC, acting 86.

through its representatives, agents, and employees, harassed Defendant for being

male, for being gay, for not acting as coquettish as defendant Mast did and does,

for not being one of the boys.

Defendant’s harassment included taunts about his sexual orientation, his gender, 87.

and included false accusations of sexual interest in other members of the traveling

company.

The sexual harassment endured by the Plaintiff constituted a breach of the 88.

Plaintiff’s contract with Defendant CREATURE PRODUCTION COMPANY,

LLC.

The Plaintiff performed the consideration promised in return for the sexual 89.

harassment-free environment. .


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dollars.

PLAINTIFF JOHNNY SMITH’S THIRD CLAIM FOR BREACH OF



Plaintiff was promised employment by Defendant CREATURE PRODUCTION 91.

COMPANY, LLC for a fixed collection of compensation and benefits, provided he

performed his job in an able and professional manner.

Defendant CREATURE PRODUCTION COMPANY, LLC, for reasons unrelated 92.

to the Plaintiff’s skills, experience, or job performance, terminated this

employment.

The employment was not ‘at will’ because of the written and explicit contracts 93.

between the Plaintiff and this Defendant.

The Defendant’s action in ceasing to compensate the Plaintiff, ceasing to provide 94.

him benefits, and sending him home consisted a breach of the explicit and implicit

contracts between the Plaintiff and this Defendant.

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The Plaintiff performed the consideration required of him. 95.




dollars

PLAINTIFF JOHNNY SMITH’S CLAIMS AGAINST DEFENDANT CREATURE

PRODUCTION COMPANY, LLC UNDER THE TEXAS LABOR CODE

§ 21.106.of the Texas Labor Code prohibits employers from discriminating against 97.

employees “because of sex or on the basis of sex.”

Sexual harassment is a form of sex discrimination that violates Chapter 21 of the 98.

Texas Labor Code and Title VII of the Civil Rights Act of 1964.

Defendant CREATURE PRODUCTION COMPANY, LLC preferred a female for 99.

this position, and took steps to make the position of the Plaintiff untenable.

The Plaintiff has been damaged as a result of the illegal sex discrimination.100.

The Plaintiff demands back pay, out-of-pocket expenses, and reinstatement to his 101.

former position.

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JOHNNY SMITH’S CLAIMS AGAINST DEFENDANT CREATURE

PRODUCTION COMPANY, LLC UNDER THE

CALIFORNIA EMPLOYMENT DISCRIMINATION STATUTE

California law, by statute, prohibits discrimination in the terms and conditions of 102.

employment based on, both, sexual orientation, and perceived sexual orientation.

The treatment of the Defendant by all three Defendants during the course of the 103.

Plaintiff’s employment violated this statute, in that it provided a diminished and

harsh working environment because of the Plaintiff’s sexual orientation.

The termination of the Plaintiff was because he was gay, in violation of this statute.104.

All Defendants preferred a heterosexual female for this position, and took steps to 105.

make the position of the Plaintiff untenable.

The Plaintiff lost his employment because of sexual orientation discrimination.106.

The Plaintiff lost his employment because of harassment due to sexual orientation.107.

The harassment was uninvited, unwelcome, and unpleasant.108.

The Defendant replaced the Plaintiff with a heterosexual female.109.

The Plaintiff has been damaged as a result of the illegal sexual orientation 110.

discrimination.

The Plaintiff demands back pay, out-of-pocket expenses, and reinstatement to his 111.

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former position.

The Plaintiff’s termination occurred in Kern County, California, and is subject to 112.

the employment and employment termination laws of that County, and of that

State.

PLAINTIFF JOHNNY SMITH’S CLAIM FOR ATTORNEYS’ FEES

Plaintiff Smith is entitled to reasonable attorneys’ fees, and legal expenses, because 113.

his claim, in part, is based on breach of contract.

Plaintiff Smith is entitled to reasonable attorneys’ fees, and legal expenses, because 114.

his claim, in part, on statutory rights against sex discrimination and protection

against sexual harassment, with said statutes providing for an award of attorneys’

fees.

DAMAGES FOR PLAINTIFF, JOHNNY H. SMITH

As a direct and proximate result of the occurrence made the basis of this lawsuit, Plaintiff, 115.

Johnny H. Smith, was caused to suffer and incur the following damages:

A. Physical pain and suffering in the past;

B. Physical pain and suffering in the future;

C. Mental anguish in the past;

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D. Mental anguish in the future;

E. Lost wages in the past

F. Lost wages in the future

G. Lost benefits in the past

H. Lost benefits in the future

I. Damage to personal reputation

J. Damage to professional reputation; and

K. Out of pocket costs and expenses

PRAYER

WHEREFORE, PREMISES CONSIDERED, Plaintiff, Johnny H. Smith, respectfully prays

that the Defendants be cited to appear and answer herein, and that upon a final hearing of the cause,

judgment be entered for the Plaintiff against Defendants, jointly and severally, for damages in an

amount within the jurisdictional limits of the Court; together with pre-judgment interest at the

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maximum rate allowed by law; post-judgment interest at the legal rate, costs of court; and such other

and further relief to which the Plaintiff may be entitled at law or in equity.

Respectfully submitted,

TEIR & ASSOCIATES

By:/s/ Robert Teir Robert Teir Texas Bar No. 00797940 Member, College of the State Bar of Texas

Robert Teir, PLLC6750 West Loop South, Suite 460Bellaire, Texas 77401-4103Tel: 713.669.0520Fax: 2841.914.4203Electronic Mail: [email protected]

Attorney for PlaintiffJohnny H. Smith

PLAINTIFF HEREBY DEMANDS TRIAL BY JURY

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I, Loren Jackson, District Clerk of Harris

County, Texas certify that this is a true and

correct copy of the original record filed and or

recorded in my office, electronically or hard

copy, as it appears on this date

Witness my official hand and seal of office

this

Certified Document Number:

LOREN JACKSON, DISTRICT CLERK

HARRIS COUNTY, TEXAS

In accordance with Texas Government Code 406.013 electronically transmitted authenticated documents are valid. If there is a question regarding the validity of this document and or seal please e-mail [email protected]