DRAYTON v. TOYS `R' US INC.

Patricia DRAYTON, Darwin David Rhodes, Valerie Kirk, Clyde Cones, Angela Stallings, Lia-Quana Utley, Ida Jackson, Erica Miller, Teresa Branch, Linda Loving, Patricia Weaver, Margaret High and Denise Scott, for themselves and on behalf of all similarly situated African Americans who shopped at Toys `R' Us stores since 2004, or who will shop at said Toys `R' Us stores, Plaintiffs, v. TOYS `R' US INC., Toys `R' US-NY, LLC, Toys `R' US-Ohio, Inc., John Doe # s 1-5, being individual managerial staff of Toys `R' Us Store No. 8930, Metro One Loss Prevention Group (Guard Division NY), Inc. ("Metro One"), Rocky Etienne, individually, and in his official capacity as an employee of Metro One; Mark McMahon, individually, and in his official capacity as an employee of Metro One; "Joe Sheriff," real name unknown, the person intended being a Sheriffs Deputy of the Hamilton County Sheriffs Department, Cincinnati, Ohio, who accosted Darwin David Rhodes at a Toys `R' Us store on or about January 25, 2006, "P.O. Todd," real name unknown, the person intended being a police officer of the City of Cincinnati, Ohio, who arrested Darwin David Rhodes in or about April 2006 for alleged theft at a Toys `R' Us store on January 25, 2006, City of Cincinnati, Defendants.