I would have absolutely no issue with a server having an active cell phone IF he/she just mentioned it. As a teacher, my phone is always on silent, but when my wife was pregnant, I told each class that until the baby was born I would have my wife's number programmed to ring and no one else.
I would do the exact same thing if I were waiting on other important news, but this sounds like it might be an ongoing issue of attitude and performance.
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