At all relevant times, upon information and belief, Defendant STUDENT TRANSPORTATION OF AMERICA, LLC (“STA”) was and is a foreign Limited Liability Company with a principal place of business in Erie County.
At all relevant times, Defendants knew of and contributed to the hostile work environment Plaintiff was forced to endure by encouraging, condoning, aiding, abetting, and failing to prevent Williams’ behavior described herein.
At all relevant times, STA, STI, and/or STANY negligently failed to train and supervise Plaintiff’s supervisors including, but not limited to, Peoples, Bratt, Higgins, Thompson, and Smith on how to protect Plaintiff from Williams’ behavior described herein.
At all relevant times, STA, STI, and/or STANY negligently failed to train and supervise Plaintiff’s supervisors including, but not limited to, Peoples, Bratt, Higgins, Thompson, and Smith on how to properly respond to Plaintiff’s complaints regarding Williams’ behavior described herein.
At all relevant times, Defendants’ negligence unreasonably endangered Plaintiff by exposing him to sexual harassment, abuse, assault, and battery by Williams, as well as retaliation against him for complaining about it to his supervisors and reporting it to the police.