An African American cashier Wednesday filed a discrimination suit against the sandwich shop Pret a Manger, alleging that her co-workers and manager used the N-word around her unceasingly and that, rather than stop its use, her manager made excuses for it, telling her, "People don't mean anything by it. We all grew up in the 'hood."

"Jairo's gonna make the [N-word]s work like Mexicans," the plaintiff and former cashier at Pret a Manger's 60 Broad St. location in Manhattan claims she heard a co-worker say at one point during her six-month stretch at the busy outpost.

On other days, alleges plaintiff Shaquana Battle in her complaint, she'd listen in frustration and pain as the shop's general manager, Jairo Ramos, would regularly "admonish, summon, and express disbelief to subordinates with the following phrases, respectively: 'Stop playing, [N-word],' 'Come here, my [N-word],' and 'F__k outta here, my [N-word].'"

At another point, claims Battle, who no longer works for the ubiquitous British-owned sandwich chain, she sat with a chef over lunch as he complained about how he was being treated at work, when he suddenly said to her, "My [N-word], you know what I'm talking about, because they be doing it to you, too." After Battle then asked him to stop using the racial slur, he allegedly shot back, "I can say that. I'm not changing the way I'm talking."

In her lawsuit lodged in Bronx Supreme Court, Battle names both Pret a Manger (USA) Limited  and Ramos, individually, as she makes claims for both punitive and compensatory damages, including for damages stemming from mental anguish and emotional distress. The action, which is brought under the New York City Human Rights Law and which focuses on hostile work environment and retaliation claims, focuses largely on Battle's numerous alleged attempts to get her store's manager and a corporate human resources manager to put an end to the daily N-word use inside her shop.

The legal theory underlying the complaint, according to a statement by Battle's lawyers at the Manhattan firm of Arenson, Dittmar & Karban, is that the city's human rights law makes companies "accountable for their managers' discriminatory conduct, including participation in a racially hostile environment and the failure to prevent such an environment when the manager knows about it."

Pret a Manger did not respond to request for comment on Wednesday, and an effort to locate and contact Ramos was not successful.

In Battle's case, contends the complaint, once she complained to Ramos and her co-workers about how hearing the N-word slur offended her, its use at the Pret became only more prevalent—seemingly as a way for colleagues to attack or bother her, she alleges.

After she complained, "if a group of coworkers were working wordlessly and Plaintiff approached their area, one of them would make a comment addressing his coworker as 'My [N-word]' just to make sure Plaintiff heard it," the complaint says.

Battle's suit further contends that even before she complained to Ramos about the rampant use of the slur around her, he'd begun discriminating against her and other Black employees once he was installed as the shop's general manager in January 2018.

"[Ramos] cut Plaintiff's [Battle's] hours to less than 30 per week, despite her full-time status," the complaint alleges, and "he empowered Hispanic Team Leaders to give Plaintiff work assignments" and he "passed Plaintiff over for promotions in favor of newly-hired Hispanic employees."

Later in 2018, Ramos allegedly "harassed and discriminated against [Battle] in many smaller ways that cumulatively degraded the conditions of her employment." For example, states the complaint, Battle and another employee were "ordered by supervisors, usually Ramos, to take out the garbage a disproportionate number of times.

"This was especially remarkable because female workers at 60 Broad were not usually tasked with dragging the heavy trash bags to the garbage dump," the complaint continues, and "seeing Plaintiff dragging these bags to the garbage dump, the garbage man asked her, 'What are you doing back here? I never heard of them sending a female to do garbage pickup.'"

Battle also allegedly made complaints on multiple occasions, over a period of months, to a corporate human resources supervisor. In the end, after Battle continued to allege the N-word was being used daily, the supervisor eventually, in August 2018, wrote in an email to Battle that "she was able to substantiate Plaintiff's allegations that racial slurs are used in the shop" and that "she would transfer Plaintiff to the shop at 350 Hudson Street as of August 6, 2018." But Ramos was still not fired, noted the complaint.

"The N-word has been used by non-African Americans to denigrate and degrade African-Americans, to remind them of their enslavement and perpetrate the stigma that has allowed them to be treated less equally in countless ways, large and small," said Avi Mermelstein of the Arenson law firm on Wednesday in a news release about Battle's lawsuit. "No employee should have to listen to people at work degrade her and her race every day."