Jump to full article: Las Vegas Sun, 2009-07-22
Intro: 54. The Defendant has breached this duty by failing to take reasonable precautions to protect its employees from exposure to second-hand smoke, a recognized hazard.
55. Specifically, the Defendant has breached this duty in the following ways:
a. failing to designate certain sections of the gaming area as smoke-free;
b. failing to restrict the times in which smoking is permitted in the gaming area;
c. failing to physically separate certain parts of the gaming area and designating them as smoke-free;
d. failing to install effective air filtration/purification systems which act to minimize the amount of second-hand smoke in the air;
e. failing to monitor the health and welfare of its employees who are exposed to second-hand smoke, and failing to take steps to assist those adversely affected by second-hand smoke; and
f. failing to take any other necessary steps to mitigate the dangers posed by second-hand smoke.
56. As an actual and proximate result of Defendant’s breach, Plaintiff, and other members of the class have suffered, and continue to suffer damages.
WHEREFORE, Plaintiff respectfully requests that this Court grant the following relief:
a. Enter an order requiring the Defendant to take reasonable measures to protect its employees from second-hand smoke;
b. Enter an order requiring the Defendant to make informational pamphlets detailing the dangers of second-hand smoke available at Defendant HARRAH’S Health and Wellness Center;
c. Enter an order awarding Plaintiff and the class costs and reasonable attorney’s fees associated with the prosecution of this action;
d. Award any and all further relief provided by law that this Court deems equitable and just.
Jump to full article » |