Panda Restaurant Group
Attn: Guest Relations
P. O. BOX 1159
Rosemead, CA 91770
Panda Express, Inc.
143 Pasadena Ave.
South Pasadena, CA 91030
Panda Restaurant Group, Inc.
1683 Walnut Grove Ave.
Rosemead, CA 91770
RESIDENT AGENT: for Panda Restaurant Group, Inc.
The Corporation Trust, Inc.
2405 York Rd.
Suite 201
Lutherville, MD 21093-2264
Panda Express
Jonathan Jim-General Manager & Steven Ng-Server/Worker
7351 Assateague Dr.
Jessup, MD 20794
Howard County Office of Human Rights
3430 Court House Drive
Ellicott City, MD 21043
The Maryland Commission on Civil Rights
6 Saint Paul Street, Suite 900
Baltimore, MD 21202-1631
U.S. Department of Justice
Civil Rights Division
950 Pennsylvania Avenue, N.W.
Office of the Assistant Attorney General, Main
Washington, D.C. 20530
NOTICE OF DISCRIMINATION CLAIM AND CLAIMS FOR PERSONAL INJURY-DENIAL TO REFUSAL TO SERVE OR COMPLETE CUSTOMER ORDER @PANDA EXPRESS ##1436
Dear Panda Express/Panda Restaurant Group
-Owners/Management & Staff:
Comes now the Petitioner Dr. Keenan Cofield, a regular customer at Panda Express Maryland locations, specifically the Jessup, MD Store #1436.
The acts, actions or inactions relating to denial and/or refusal of an Asian employee against or towards a Black professional man regarding service described herein below violated Federal Civil Rights Acts-1981 of the Civil Rights Act of 1866, Title II of the Civil Rights Act of 1964, known as the Public accommodations Act, The Howard County, MD Health & Social Services Title 12 Sections 12.210 and 12.211, MD Commission on Civil Rights MD State Government Article 20-304, whereas each in whole or in part says: Public accommodations means any place which holds itself out as inviting the public to utilize its goods and services, whether or not for profit. Unlawful Practices: It shall be unlawful if, because of discrimination, an owner or operator (or his/her agent) of public accommodations denies any person any of the accommodations, advantages, facilities or privileges of such accommodations.
COMPLAINT AND STATEMENT OF THE CASE AND FACTS
On 12/09/2017, I placed an Order under Order #161090 at the Jessup, MD location at 8:48:32 pm. I placed my normal to regular orders in. The BIG order was completed. However, when it came to the second order, my food, the server of Asian descent named Steven Ng, once passed the rice, refused to place any more requested foods meaning the chicken to my order. I asked Steven and told him I order this and come in at least 2 times a week. That I had the money cash and credit cards to pay for my order. He just looked at me. I said was this about race, I know you have to pay extra, and I know what this food costs extra for. Steven stepped back hunched his shoulders, and refused to serve me further or complete my order. The female store Clerk named, Fides N. came over told Steven that I came in all the time and that I order extra. Steven did not move to assist her and still and continued to complete my order. Server N. Fides, did complete my order with patience and kindness. But “before and after” the incident, I watched Steven serve whites and others without any delays or questions.
Once I exited the store, I had to go to another store to purchase other items. In fear of lies about who did what, I returned back to the store, took pictures of the front outside sign, and pictures of Steven and the Store Clerk who completed my order. Attached are copies of those pictures.
The next day, I contacted Jonathan Jim the General Manager who investigated the matter. The following day I met with him to discuss this situation.
The General Manager concluded the server Steven Ng was not properly trained, on what to do when you have a situation like that. But clearly, Panda Express may not have trained its management staff to supervisors on this concerned that must be resolved.
The actions of Steven Ng, though misunderstood are not acceptable. without any doubt Panda Express failed to properly train and supervisor but its management and all staff on this subject of extra foods requests, what to do and how to handle the matter with the customer. One should never refuse or not complete an order unless the customer is unruly, belligerent, nasty trouble maker, disruptive behavior, hostile person. I was neither. Steven Ng and/or Panda Express at that moment to arbitrarily deny, refuse and not complete my order by Steven Ng were not reasonable and unjustified. I stood outside once I returned back before I went into the store to get the pictures and watched Steven and all other staff complete orders involving whites without question or resistance. My personal rights under the state and federal equal protection clause were violated. The actions of Steven Ng and Panda Express were unduly excessive I saw myself a victim of race discrimination.
The illegal to unlawful acts described herein were malicious and reckless indifferent conduct, as I had a right to enjoy all the benefits, privileges, advantages given to other store restaurant patrons, before, during and after my order, I personally saw.
I am preparing a civil lawsuit in courts to be filed in days. Also, I feel others should be aware of this incident, so I shall issue a Press Release to make postings on Facebook, twitter, and other social media outlets, immediately.
Requested Relief
I demand damages for the humiliation, emotional distress, and other damages caused by Steven Ng and Panda Express in the amount of $ 750,000 dollars or BEST OFFER. If I file suit, damages including Punitive damages shall be very high considering these types of cases.
I do recommend that General Manager Jonathan Jim retrain Steven Ng. That Steven NG not be fired, he just did not know what to do, nor how to respond to his experience or skill set, training. But as a Bishop, this is holidays and I am a forgiving man of God.
If you have any questions, please email me or give me a call.
Respectfully Submitted,
Dr. Keenan Cofield, JD/Ph.D/Psy.D/D.D
The Supreme GRAND Bishop
4109 Cutty Sark Rd.
Baltimore, Maryland 21220
443-554-3715