Witness Reports Released Following Settlement of Emily's Bakery Sexual Harassment Lawsuit

TIMOTHY B. BRODERICK (97082)
KATRINA M. SALEEN (253706)
Broderick Saleen Law Firm
2600 El Camino Real, Suite 506
Palo Alto, California 94306-1705
Telephone: (650) 857-9000
Attorneys for Plaintiff
Savanna Halliwell
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CRUZ
SAVANNA HALLIWELL, ) CASE NO.
)
Plaintiff, ) DECLARATION OF XXXXXX
) XXXXXXX
v. )
)
EMILY REILLY; ROBERT NAHAS; and )
EMILY’S GOOD THINGS TO EAT, )
a California Corporation; and DOES 1-20, )
)
Defendants. )
I, XXXXXXXXX, declare:

1. All of the facts in this declaration come from my personal knowledge, except for those stated on information and belief and as to those facts I believe them to be true. If called upon to testify in a court of law, I could, and would, competently testify to the facts in this declaration.
2. I worked at Emily’s Good Things To Eat (“Emily’s Bakery”) for about 16 months from 2010-2011. I worked under the direct supervision of Robert Nahas.
3. During the time I worked at Emily’s Bakery, I witnessed Robert Nahas act inappropriately toward some of the female employees, including talking to them inappropriately about their boyfriends, following them around the bakery, hugging them, and touching them.
4. If a female employee was not one of Robert’s favorites, he would use bullying tactics, to belittle and humiliate the employee. I would not be charming to appease Robert Nahas when I worked at Emily’s Bakery, and he belittled me and brought me to tears and humiliation in front of customers over trivial mistakes. He would use his power as my supervisor to demean me.
5. One night while I was working there, there was a birthday celebration for a female employee after the Bakery closed to the public. Robert Nahas got extremely intoxicated, hugged female employees for prolonged amounts of time, and mumbled inappropriate remarks to some of the female employees that were there.
6. It was not unusual for Robert Nahas to drink heavily. One day at work Robert Nahas had scratches down his face and bragged to me and other employees that he had gotten really drunk and had passed out in the street in front of Emil’s Bakery the night before, and that people were having to step over him to get by.
7. I was told by co-workers that a female employee namedX X Xmade sexual harassment claims against Robert Nahas shortly before I began my employment for Emily’s Bakery. I am not aware of any changes that Emily’s Bakery put in place as a result of the sexual harassment complaints they received from XXXX. I am not aware of any steps that Emily’s Bakery took to prevent further sexual harassment by Robert Nahas.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration was executed in XXX, Texas on , 2015.


TIMOTHY B. BRODERICK (97082)
KATRINA M. SALEEN (253706)
Broderick Saleen Law Firm
2600 El Camino Real, Suite 506
Palo Alto, California 94306-1705
Telephone: (650) 857-9000
Attorneys for Plaintiff
Savanna Halliwell
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CRUZ
SAVANNA HALLIWELL, ) CASE NO.
)
Plaintiff, ) DECLARATION OF XXXXXXX
) XXXXXXXX
v. )
)
EMILY REILLY; ROBERT NAHAS; and )
EMILY’S GOOD THINGS TO EAT, )
a California Corporation; and DOES 1-20, )
)
Defendants. )
I, XXXXXXXXXX, declare:

1. All of the facts in this declaration come from my personal knowledge, except for those stated on information and belief and as to those facts I believe them to be true. If called upon to testify in a court of law, I could, and would, competently testify to the facts in this declaration.
2. I worked at Emily’s Good Things To Eat (“Emily’s Bakery”) from approximately September 2010 to January 2011. I worked under the direct supervision of Robert Nahas.
3. When I first started working at Emily’s Bakery, my supervisor, Robert Nahas, tried to get me to let him hug me, tried to get affection from me, and pushed his body up against mine and put his arms over me when he was trying to teach me how to work the register. I made sure that he knew that I was disgusted if he got too close and rejected all sexually harassing advances he made.
4. Once Robert Nahas understood that I would not put up with his sexually harassing behavior, he began to mistreat me. He began constantly yelling at me and blaming me for things that went wrong at the bakery that were not my fault.
5. Emily’s Bakery opened up a kiosk on the UC Santa Cruz campus shortly thereafter, and I got to work at the kiosk, away from Robert Nahas’s harassment.
6. Once I was away from Robert Nahas, I reported to Emily Reilly that Robert Nahas was mean to me and yelled at me all the time because I would not return his flirtations or give him hugs. Emily Reilly replied by telling me that he just has a bit of a temper, and that everything was fine. She made excuses for Robert Nahas no matter what I told her about his behavior. I am not aware of any investigation that was performed regarding my complaint. I am not aware of any steps that were taken to prevent further sexual harassment after I complained.
7. I was wrongfully terminated form Emily’s Bakery because I rejected Robert Nahas’s sexually harassing behavior. Emily’s Bakery decided to discontinue having an employee work at the kiosk, and so I expected to be transferred back to the Emily’s Bakery location, where I started my employment. Because that would mean working directly with Robert Nahas, I was planning to quit my job. However, before I had a chance to quit, a manager namedX X Xcalled me in for a meeting and told me that she had spoken with Robert and that it was “not working out” to have me at the bakery, so they were going to have to let me go.
8. I witnessed Robert Nahas sexually harass new attractive female hires. His sexually harassing behavior toward new hires included being overly flirtatious, batting his hand at female employees’ shoulders, touching female employees’ hair, asking female employees for hugs before they left the bakery, and asking female employees personal questions such as questions about their boyfriends and where they liked to socialize. I also witnessed Robert Nahas ask employees out for drinks, and ask female employees to go to the bar with him to play pool.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration was executed in Santa Cruz, CA on , 2015.


TIMOTHY B. BRODERICK (97082)
KATRINA M. SALEEN (253706)
Broderick Saleen Law Firm
2600 El Camino Real, Suite 506
Palo Alto, California 94306-1705
Telephone: (650) 857-9000
Attorneys for Plaintiff
Savanna Halliwell
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CRUZ
SAVANNA HALLIWELL, ) CASE NO.
)
Plaintiff, ) DECLARATION OF XXXXXXX
) XXXXXXXXX
v. )
)
EMILY REILLY; ROBERT NAHAS; and )
EMILY’S GOOD THINGS TO EAT, )
a California Corporation; and DOES 1-20, )
)
Defendants. )
I, XXXXXXXXXXXX, declare:

1. All of the facts in this declaration come from my personal knowledge, except for those stated on information and belief and as to those facts I believe them to be true. If called upon to testify in a court of law, I could, and would, competently testify to the facts in this declaration.
2. I worked at Emily’s Good Things To Eat (“Emily’s Bakery”) for several years, ending in or about 2005. I was a manager. I worked under the direct supervision of Robert Nahas.
3. Robert Nahas sexually harassed me. He made inappropriate sexual comments to me. One example is when he told me that people would come to Emily’s Bakery if I were naked.
4. While I was working at Emily’s Bakery in the upstairs office, Robert Nahas locked the office door and screamed at me and would not let me out. I also witnessed Robert Nahas made other female employees cry.
5. I told Robert Nahas that his behavior was inappropriate. I also complained to Emily Reilly about Robert Nahas’s sexual harassment. I told Emily Reilly that Robert Nahas should be gone from Emily’s Bakery, and she told me that he was going to stay. Emily Reilly told me to do what I needed to do to make myself feel oaky. She said if that was leaving the job, then to go, and that if it was filing a lawsuit, to file one.
6. After I complained to Emily Reilly about Robert Nahas’s behavior, his behavior got worse. I quit on a day that Robert Nahas was yelling at me because I could not take his abusive behavior any longer.
7. I filed a complaint with a California agency that investigates sexual harassment. I believe it was the California Department of Fair Employment and Housing. They opened an investigation into my sexual harassment complaints, which Emily Reilly and Robert Nahas were aware of.
8. I am not aware of any actions taken by Emily’s Bakery, Emily Reilly, or Robert Nahas to prevent further sexual harassment at Emily’s Bakery in response to my sexual harassment complaints.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration was executed in XXXX , NY on August , 2015.


TIMOTHY B. BRODERICK (97082)
KATRINA M. SALEEN (253706)
Broderick Saleen Law Firm
2600 El Camino Real, Suite 506
Palo Alto, California 94306-1705
Telephone: (650) 857-9000
Attorneys for Plaintiff
Savanna Halliwell
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CRUZ
SAVANNA HALLIWELL, ) CASE NO.
)
Plaintiff, ) DECLARATION OF XXXXXXXXX
) XXXXXXXXXXX
v. )
)
EMILY REILLY; ROBERT NAHAS; and )
EMILY’S GOOD THINGS TO EAT, )
a California Corporation; and DOES 1-20, )
)
Defendants. )
I, XXXXXXXXXXXXX, declare:

1. All of the facts in this declaration come from my personal knowledge, except for those stated on information and belief and as to those facts I believe them to be true. If called upon to testify in a court of law, I could, and would, competently testify to the facts in this declaration.
2. I worked at Emily’s Good Things To Eat (“Emily’s Bakery”) from approximately 2008-2011. Robert Nahas was my supervisor.
3. Robert Nahas would routinely and repeatedly ask me for hugs before I left work and would be physically too close to me at work. He also initiated inappropriate conversations with me nearly every day that I worked with him. Robert Nahas also repeatedly invited me to go on expense-paid trips with him.
4. Robert Nahas told me on more than one occasion that he did not get physical attention from his wife, Emily Reilly, and that he therefore had to find physical attention elsewhere.
5. I often stuck with the other female manager at Emily’s Bakery, so that neither of us had to be alone with Robert Nahas. I witnessed Robert Nahas ask the other female manager about her personal life and personal relationships.
6. On one occasion, I gave my boyfriend a kiss goodbye before I went into work. Robert Nahas told me that this was inappropriate behavior and asked me about my relationship with my boyfriend.
7. On another occasion, Robert Nahas got very drunk and told me that a girl told him that he was attractive for his age and Robert Nahas told me that he was thinking about exploring it.
8. On another occasion Robert Nahas was drunk and text messaged me asking me to pick him up, which I refused. The next day at work he was upset with me.
9. As a manager, I was part of the hiring process at Emily’s Bakery. After interviewing candidates, Robert Nahas implied that he would be in favor of hiring the more attractive females.
11. When I would perform work in the office at Emily’s Bakery, Robert Nahas would watch me while I worked, even when he had no reason to be in the office.
12. After leaving my employment at Emily’s Bakery, I got married and moved to XXXXX XXXXXXXXXX. In or about early 2014, Robert Nahas text messaged my cell phone and let me know that he had just gotten to the location that I was going to be at for a beach clean-up event that I had posted about on Facebook. I had not told him to meet me and had not spoken to him about the event. I avoided seeing him at the event.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration was executed in XXXXXXXXXXXXXX, CA on , 2015.


TIMOTHY B. BRODERICK (97082)
KATRINA M. SALEEN (253706)
Broderick Saleen Law Firm
2600 El Camino Real, Suite 506
Palo Alto, California 94306-1705
Telephone: (650) 857-9000
Attorneys for Plaintiff
Savanna Halliwell
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CRUZ
SAVANNA HALLIWELL, ) CASE NO.
)
Plaintiff, ) DECLARATION OF XXXXXXXXXXX
)
v. )
)
EMILY REILLY; ROBERT NAHAS; and )
EMILY’S GOOD THINGS TO EAT, )
a California Corporation; and DOES 1-20, )
)
Defendants. )
I, XXXXXXXXXX, declare:

1. All of the facts in this declaration come from my personal knowledge, except for those stated on information and belief and as to those facts I believe them to be true. If called upon to testify in a court of law, I could, and would, competently testify to the facts in this declaration.
2. I worked at Emily’s Good Things To Eat (“Emily’s Bakery”) approximately 7-8 years ago. Robert Nahas was my supervisor.
3. Robert Nahas sexually harassed me while I worked at Emily’s Bakery. I was always made to feel very uncomfortable by Robert Nahas. Robert Nahas often inappropriately brushed up against me and other female employees in their late teens to early twenties. Robert Nahas also would often touched the small of our backs. He also would often ask us for hugs. Robert Nahas flirted with me while I was employed at Emily’s Bakery and I witnessed him flirt with other young female employees.
4. Robert Nahas generally hired young females to work at Emily’s Bakery, aside from some male employees that worked in the back.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration was executed in XXXXXXXXXXXX_, CA on , 2015.


TIMOTHY B. BRODERICK (97082)
KATRINA M. SALEEN (253706)
Broderick Saleen Law Firm
2600 El Camino Real, Suite 506
Palo Alto, California 94306-1705
Telephone: (650) 857-9000
Attorneys for Plaintiff
Savanna Halliwell
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CRUZ
SAVANNA HALLIWELL, ) CASE NO.
)
Plaintiff, ) DECLARATION OF XXXXX
) XXXXXXXXX
v. )
)
EMILY REILLY; ROBERT NAHAS; and )
EMILY’S GOOD THINGS TO EAT, )
a California Corporation; and DOES 1-20, )
)
Defendants. )
I, XXXXXXXXXXX, declare:

1. All of the facts in this declaration come from my personal knowledge, except for those stated on information and belief and as to those facts I believe them to be true. If called upon to testify in a court of law, I could, and would, competently testify to the facts in this declaration.
2. I worked at Emily’s Good Things to Eat (“Emily’s Bakery”) in or about 2008 while I was in college. I worked under the direct supervision of Robert Nahas.
3. Robert Nahas sexually harassed me while I worked at Emily’s Bakery. He would block the back entry door to the Bakery until he got a hug from me, he repeatedly asked for hugs, and he would ask me personal questions about me and my boyfriend at the time.
4. On two separate occasions Robert Nahas gave me a $100 bill as an apology to me for asking me personal questions.
5. Robert Nahas made it clear to the staff, including me, that he had a crush on a female employee namedXXXXXXXwho was younger than me.
6. I was forced to quit my job at Emily’s Bakery because of Robert Nahas’s behavior. On Halloween, Robert Nahas called my cell phone and asked me if I wanted to hang out with him. I said no. Later that evening, I was stranded at a party in Santa Cruz. I knew that Robert Nahas had a car, and I called him to ask him if he could pick me up and drive me home. Robert Nahas came and picked me up and said he would drive me home, but when we got to my house he kept driving. I became distressed and told him I wanted to go home and eventually just had him pull the car over and I got out. The next day I called Emily’s Bakery and told Robert Nahas that the night before had crossed boundaries and that I had to quit. I was seriously upset, distressed, and disturbed by Robert Nahas’s behavior and talked about this incident with my friends and family at the time.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration was executed in __________, New York on August , 2015.


TIMOTHY B. BRODERICK (97082)
KATRINA M. SALEEN (253706)
Broderick Saleen Law Firm
2600 El Camino Real, Suite 506
Palo Alto, California 94306-1705
Telephone: (650) 857-9000
Attorneys for Plaintiff
Savanna Halliwell
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CRUZ
SAVANNA HALLIWELL, ) CASE NO.
)
Plaintiff, ) DECLARATION OF XXXXXXXXXX
)
v. )
)
EMILY REILLY; ROBERT NAHAS; and )
EMILY’S GOOD THINGS TO EAT, )
a California Corporation; and DOES 1-20, )
)
Defendants. )
I, XXXXXXXXXXXX, declare:

1. All of the facts in this declaration come from my personal knowledge, except for those stated on information and belief and as to those facts I believe them to be true. If called upon to testify in a court of law, I could, and would, competently testify to the facts in this declaration.
2. I worked at Emily’s Good Things To Eat (“Emily’s Bakery”) from in or about 2008 to 2011 when I was attending college at UC Santa Cruz. I worked under the direct supervision of Robert Nahas.
3. During the time I worked at Emily’s Bakery, I was told by one of my female co-workers that Robert Nahas had showed up at her house late at night wanting to hang out with her. She said that on other nights she had received unwanted calls from Robert Nahas in the middle of the night.
4. Another female co-workerXXXXXXXmade sexual harassment claims against Robert Nahas. When she quit, I heard her call Robert Nahas a creep and a sexual harasser. I had noticed Robert Nahas watching this female employee in a strange way when she worked. After XXXXXmade her sexual harassment complaints, an attorney came in and interviewed me and other employees. I never heard aboutXXXXXsexual harassment claims again. I am unaware of any steps that were taken as a result of XXXXXcomplaint to prevent sexual harassment at Emily’s Bakery. I am unaware of any actions taken by Emily’s Bakery to protect employees from being sexually harassed by Robert Nahas.
5. One night, Robert Nahas let a female employee celebrate her birthday at Emily’s Bakery after business hours. At this party, Robert Nahas let the employees drink, and got very drunk himself. Robert Nahas had employees each take a shot of hard alcohol, and then he lifted his head back and turned the bottle of alcohol upside down in his mouth and finished the rest of the bottle of alcohol in front of us. I saw Robert Nahas inappropriately hugging female employees in his intoxicated state.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration was executed in XXX, Texas on , 2015.
BY: XXXXXXXXX