CITY OF NEW YORK
COMMISSION ON HUMAN RIGHTS
------------------------------------------------------------------x
In the Matter of the Complaint of:
VERONICA MCILRAITH,
Complainant,
-against-

Verified Complaint
Case No. __________________

WEGMAN PARTNERS, LLC, COLBY WEGMAN, and
SCOTT LEGG,
Respondents.
-------------------------------------------------------------------x
Complainant Veronica McILraith (“Ms. McILraith”), by and through her attorneys
Emery Celli Brinckerhoff & Abady LLP, files this Verified Complaint against Respondents
Wegman Partners, LLC, Colby Wegman, and Scott Legg, and alleges the following:
PRELIMINARY STATEMENT
1.

This is a sexual harassment case. For two and a half years at the legal recruiting

firm Wegman Partners, Complainant Veronica McILraith was subjected to an astounding barrage
of groping and sexually explicit and derogatory comments, texts, emails, and signs by her boss,
Wegman’s Chairman of Partner Recruiting, Scott Legg. Just a few examples of the nearly
constant sexual harassment Ms. McILraith endured include: Mr. Legg groped her breasts, forced
her to touch him, said he wanted to “suck on her boobies,” humped and licked her office door,
and asked her to “contribute” to a drawing of an ejaculating penis, which Mr. Legg then hung in
the office, where it remained for months. It was still hanging there when CEO Colby Wegman
visited the New York office this summer—but he did not even comment on it, and it was left
hanging there.

 2.

When Ms. McILraith refused to submit to Mr. Legg’s sexual harassment, he

became violent. He called her a “bitch,” threw furniture at her office, took work and
commissions away from her, and threatened to discipline and fire her.
3.

Mr. Legg regularly appeared to be drunk and high on cocaine in the office.

Sometimes he passed out in the office hallway; other times he lashed out at Ms. McILraith.
4.

Ms. McILraith was scared of Mr. Legg’s violent behavior and desperate to keep

her job. Mr. Legg had made it clear that he was personal friends with CEO Colby Wegman, he
was the company’s highest-earner, and he had the power to hire and fire her as well as decrease
her commissions.
5.

When Ms. McILraith finally reported the sexual harassment to CEO Colby

Wegman, he sided with Mr. Legg and forced Ms. McILraith out of the company.
THE PARTIES
6.

Complainant Veronica McILraith received her law degree from Touro College in

2010 and was hired at Wegman Partners as a Managing Director in 2014. She resides in New
York City. At all times relevant to the allegations here, Ms. McILraith was employed in
Respondent Wegman Partners’ New York City office.
7.

Respondent Wegman Partners, LLC is legal recruiting company with an office at

350 Fifth Avenue, Suite 7500, New York, New York 10118, incorporated in Texas as a limited
liability company, and with its headquarters at 1700 Pacific Avenue, Suite 4900, Dallas, Texas
75201.
8.

Respondent Colby Wegman is the Chief Executive Officer and owner of Wegman

Partners, with an office at 350 Fifth Avenue, Suite 7500, New York, New York 10118, and an
office at 1700 Pacific Avenue, Suite 4900, Dallas, Texas 75201.

 9.

Respondent Scott Legg is the Chairman of Partner Recruiting at Wegman

Partners. At all times relevant to the allegations here, Mr. Legg was employed in Respondent
Wegman Partners’ New York City office at 350 Fifth Avenue, Suite 7500, New York, New York
10118.
FACTUAL STATEMENT
10.

Wegman Partners is a legal recruiting firm that describes itself on its website as “a

leading national full-service legal search firm, handling associate, partner, group, contract and
support staff placements with top international AmLaw 200 and midsize law firm clients as well
as in-house placements with Fortune 500 corporations across numerous industries and sectors.”
11.

Ms. McILraith was hired as a Managing Director at Wegman Partners at the end

of 2013.
12.

Mr. Legg joined the company around the same time.

13.

Ms. McILraith was told that Mr. Legg’s approval was required in order for her to

be hired.
14.

She started work at Wegman’s New York City office in January 2014.

15.

Ms. McILraith excelled at her job. For example, in September 2017, she was

ranked in the top five company earners and rewarded with a bonus vacation. In March 2016, she
was ranked in the top ten earners and was also rewarded with a company trip.

 Mr. Legg Exerts His Power over Ms. McILraith
16.

Mr. Legg made it clear from the beginning that he was Ms. McILraith’s superior,

even though, at the start, they nominally had the same title. He told her he had an “inside track”
with CEO Colby Wegman because of the high deliverables he brought to the company and
because of his friendship with Mr. Wegman. He also said he was in talks to become equity
partners with Mr. Wegman, that he had the power to hire and fire Ms. McILraith and the other
New York City office employees, and that he could discipline her if he was displeased with her
job performance. In 2016, Mr. Legg assumed the title of “Chairman of Partner Recruiting.”
17.

Mr. Legg also promised Ms. McILraith that if she worked with him, he would

reward her with exclusive searches that would significantly increase her bottom line, which was
heavily driven by commissions. He made it clear that any disagreement with him would drive
down her commissions and her income.
Mr. Legg Subjects Ms. McILraith to a Barrage of Sexual Harassment
18.

Almost immediately, Mr. Legg began inviting Ms. McILraith out to lunch on a

daily basis. During these lunches, Mr. Legg would drink heavily and sit inappropriately close to
Ms. McILraith. Ms. McILraith was deeply uncomfortable but felt obliged to attend these
lunches.
19.

Over time, Mr. Legg escalated his harassment.

20.

On a regular basis, both in person and via text, Mr. Legg called Ms. McILraith

“babe,” “baby,” “honey,” or “hon.”
21.

Mr. Legg wrote to Ms. McILraith: “I love you.”

22.

Mr. Legg’s harassment was physical too.

23.

Mr. Legg frequently appeared to be inebriated and high on cocaine at the office.

 24.

At times, he has passed out in the office.

25.

At other times, his apparent drug and alcohol abuse made his behavior even more

violent, erratic, and terrifying to Ms. McILraith.
26.

On July 21, 2015, Mr. Legg aggressively grabbed at Ms. McILraith’s breasts in

the office kitchen and tried to open her sweater. Ms. McILraith ran in to her office, jarred and
scared by the violent and unexpected attack.
27.

On July 29, 2015, Mr. Legg became enraged when Ms. McILraith refused to go to

lunch with him and called her a “bitch.” He talked about jerking off in front of her and of
forcing her to jerk him off. He yelled about having his “dick sucked” and pressing his head into
women’s “tits.”
28.

On August 10, 2015, Mr. Legg humped Ms. McILraith’s office door, licked it

and, showed her his tongue.

 29.

On August 11, 2015, Mr. Legg stood outside Ms. McILraith’s office and

pretended to “jerk off” using his umbrella.
30.

On August 12, 2015, Mr. Legg yelled to Ms. McILraith, who has the office next

door to his, that he was “rubbing his clit” and that a male employee was underneath his desk
“blowing” him. Ms. McILraith was disgusted and worried her clients on the phone could hear
these comments.
31.

On August 26, 2015, Mr. Legg told Ms. McILraith that the way to convince a

partner to take an interview was to “play with his balls.”
32.

On November 3, 2015, Mr. Legg texted Ms. McILraith that he was waiting for her

at a client meeting and “maybe I’ll suck on your boobies.”

 33.

Since the summer of 2016, Ms. McILraith has been the only female employee in

the New York City office. Prior to that, she was forced to hear Mr. Legg refer to her female coworker as a “fat bitch” who was “disgusting” to him. On one occasion, Mr. Legg screamed so
violently at this other woman that Ms. McILraith hid under her desk because she was so scared.
34.

In the summer of 2016, Ms. McILraith began refusing Mr. Legg’s insistent

invitations to attend boozy lunches with him. This enraged Mr. Legg. He began to call her
incessantly on her cell phone after hours, and he escalated his campaign of harassment.
35.

On September 20, 2016, Mr. Legg asked Ms. McILraith if she got a “pap smear”

when she refused to go to lunch because she had an appointment.
36.

On October 5, 2016, Mr. Legg came back from another lunch, apparently drunk,

and accused Ms. McILraith of not being his “best friend” anymore and said she had “changed.”
He demanded that she touch the side of his pants, which he had ripped. When she refused, he
grabbed her hand and forcibly pressed it against him.
37.

On December 7, 2016, Mr. Legg emailed Ms. McILraith and another female

employee (who works outside the New York office) with a photo of a headset and wrote:
“Thought you’d appreciate the phallic nature of this product…could be useful in the office.”

 38.

On December 12, 2016, Mr. Legg became irate when Ms. McILraith refused to

join him for drinks during the work day, even after he promised he would share new searches
with her if she came, and told her he had “had it with this attitude.” After drinking, he came
back to the office to scream at her because she “would have nothing without him,” or words to
that effect.
39.

On January 6, 2017, Mr. Legg barged into Ms. McILraith’s office to invite her to

lunch. He had white powder on his nose and appeared to be high on cocaine. He called Ms.
McILraith “babe” and “honey” at least half a dozen times.
40.

On February 27, 2017, Mr. Legg was angry with Ms. McILraith after she

expressed disappointment that he showed up late for a client call. He told her to “go fuck

 herself” and said he was “tired of her lip.” He then told her she was fired and should leave. Ms.
McILraith reported this incident to Mr. Wegman, and Mr. Legg later sent her an apology email
in which he blamed her for “being negative” and told her “your problem with me needs to stop.
If you would just be open and communicative with me, like you used to be, we wouldn’t be
fighting.”
41.

On March 15, 2017, Mr. Legg came back from lunch drunk and began screaming

at Ms. McILraith for having her office door shut. He told her she had to open the door or he
would punch it.
42.

On March 31, 2017, Mr. Legg came up to Ms. McILraith’s office door and asked

if she wanted to see a picture. He then showed her a picture of a hand-drawn ejaculating penis.
He asked if she wanted to “contribute” to the drawing. She told him it was disgusting and asked
him to take it away. Instead, he taped it up on his office door. That picture was still hanging
there when Mr. Wegman visited the office in August 2017. Ms. McILraith had to walk by it
every day for months.

 43.

On another recent occasion, Mr. Legg stuck a sign up on his glass office wall

(facing out into the hallway) that said “Suck my balls!!!” That sign remained hanging in the
office for over four months.

 44.

On May 3, 2017, Mr. Legg emailed Ms. McILraith to complain about the

“change” in her behavior and her lack of “camaraderie.” He threatened her: “Please think hard
about your goals and aspirations going forward and I will gladly help you achieve them, but if
you continue to close us out, it will remain awkward.”
45.

On May 15, 2017, Ms. McILraith heard Mr. Legg start yelling in his office that he

“wouldn’t be happy today unless someone got beat up and he saw blood.” He then screamed: “I
don’t care about that bitch.” Ms. McILraith was the only woman in the office and believed he
was speaking about her. Her concerns mounted when Mr. Legg picked up a heavy office chair
and threw it at her office door. Ms. McILraith was terrified.

 46.

On another occasion, Mr. Legg threw his chair against the wall separating his

office from Ms. McILraith’s; the impact was so violent it caused the pictures hanging on Ms.
McILraith’s wall to fall and break.
47.

On May 17, 2017, Mr. Legg again became enraged with Ms. McILraith because

she refused to go to lunch with him. He threw an office chair at her closed door and then began
humping her glass office door while making sexual noises. Later that day, Mr. Legg began
screaming about “sucking dick” and “body slamming” someone. A co-worker told Ms.
McILraith she should close her door for her own safety.
48.

On June 6, 2017, Mr. Legg was singing “rap” in his office about “bitches and

snitches.” He increased his volume when Ms. McILraith walked by his office to get to the
kitchen, targeting her directly with his offensive lyrics.
49.

On June 23, 2017, Mr. Legg paced up and down in front of Ms. McILraith’s door,

screaming “come and get me in my anal, anal, anal, anal.”
50.

Ms. McILraith documented many of these instances of harassment in

contemporaneous notes, in the form of emails she sent to herself on the day of each incident
(with date and time stamp).
51.

On September 7, 2017, Mr. Legg came into Ms. McILraith’s office. He was

slurring his words and appeared to be drunk. He told her she would no longer be part of the cold
calls sourced by Jeff Barken, their most valuable caller who helped them identify clients. This
decision would significantly decrease Ms. McILraith’s commissions and income. When she
asked if her performance was the reason for this demotion, Mr. Legg said her work product was
“great” (and in fact Ms. McILraith had just been named a top five earner in the company). Mr.

 Legg explained he was taking the caller away for “personal reasons” such as Ms. McILraith not
going out to lunch with him and closing her office door.
Ms. McILraith Reports the Harassment to CEO Colby Wegman; He Responds by Forcing Her
Out
52.

Ms. McILraith reported the September 7th incident to CEO Colby Wegman and

explained that she believed Mr. Legg was retaliating against her for her refusal to submit to the
campaign of sexual harassment he had inflicted on her for two years.
53.

Ms. McILraith shared the details of her harassment with Mr. Wegman.

54.

After a so-called investigation into Ms. McILraith’s allegations, Mr. Wegman and

Wegman Partners announced that Mr. Legg had been suspended for five days—which would
have no effect on his earnings, which are based solely on commissions—and would be sent to
sexual harassment training. Mr. Wegman and Wegman Partners then demanded that Ms.
McILraith return to work just a few feet away from Mr. Legg under dramatically less favorable
working conditions, including no cold caller to source candidates and clients for her and without
the files (and associated commissions) she had been working on before she raised her allegations
of sexual harassment, resulting in the loss of hundreds of thousands of dollars in commissions.
55.

Ms. McILraith is terrified of Mr. Legg, who was violent and threatening with her

even before she complained of sexual harassment. Mr. Legg, Mr. Wegman, and Wegman
Partners made it clear that they would only retaliate against Ms.McILraith and make it
impossible for her to earn a living.
56.

The working conditions Ms. McILraith was forced to endure at Wegman Partners

were intolerable. No reasonable person could have returned to work there after what she went
through. Wegman’s demands that she return to work just a few feet away from Mr. Legg, and

 accept a loss of the commissions she had in the pipeline, were openly retaliatory and calculated
to force Ms. McILraith out of her job.
Ms. McILraith Has Been Emotionally and Financially Damaged
57.

Ms. McILraith had a panic attack just thinking about going back to that office.

58.

This two-and-a-half year barrage of harassment and aggression has seriously

damaged Ms. McILraith emotionally. She is fearful, anxious, and traumatized. The
contemporaneous notes she began keeping after Mr. Legg tried to grab her breasts (comprised of
emails she sent herself, with date and time stamp) document that she felt “scared,” “jarred,”
“nervous,” and “humiliated.”
59.

On May 15, 2017, for example, she wrote: “I feel threatened like he is going to hit

me…this is so so scary …shaking as I am writing this.”
60.

On June 12, 2017, she wrote: “as always the only women in this office it is scary

– I just have to think of how I wold [sic] protect myself or how quickly I would dial 911 for help
if Scott ever jumped me…”
61.

Ms. McILraith was previously prescribed anxiety medication, making her more

vulnerable to this abuse, and she has had to increase the amount of anxiety medication she is
taking.
62.

She has panic attacks and has difficulty breathing.

63.

Working with Mr. Legg had already cost Ms. McILraith commissions and

negatively affected her income. While Mr. Legg held out the enticement of lucrative
partnerships as a way of subjugating Ms. McILraith, he ultimately lashed out and retaliated
against Ms. McILraith when she refused to submit to a sexual relationship with him. For
example, Mr. Legg removed valuable callers from her, refused to allow her to speak to partners

 when he was not present (and he was frequently absent without explanation), forced her to share
her commissions with him even when she did all the work on the file, and prevented her from
making calls by screaming obscenities and lewd comments so loudly she feared clients would
hear him and by harassing and threatening her to the point of forcing her to leave the office. On
September 7, Mr. Legg removed Ms. McILraith’s most valuable caller from her.
64.

Then, in retaliation for complaining about Mr. Legg’s harassment, Wegman

forced Ms. McILraith out of her job, so she has no income at all and no foreseeable prospects of
obtaining a new job.
CONCLUSION
65.

Respondents’ conduct, described above, constitutes unlawful discrimination

against Complainant because of her gender, sexual harassment in the workplace, and a hostile
work environment, in violation of N.Y.C. Admin. Code § 8-107(1). Ms. McILraith was
discriminated against on the basis of her gender: she was the only woman in Wegman’s New
York City office and none of the other male employees were subjected to this sort of treatment
by Mr. Legg. In addition, the groping, the many sexist and derogatory remarks Mr. Legg made
to Ms. McILraith, as well as the violent manner in which he reacted to her refusal to go drinking
with him or submit to his sexual harassment, constitute unlawful sexual harassment and created a
hostile work environment.
66.

Respondent Mr. Legg’s retaliation against Ms. McILraith over the years

(including removing Ms. McILraith’s most valuable caller, denying her partners and calls, and
trying to fire her for not acquiescing to sexual harassment) and Respondent Mr. Wegman’s and
Wegman Partners’ retaliation in forcing Ms. McILraith out of her job after she reported Mr.
Legg’s discrimination and harassment all constitute unlawful retaliation, in violation of N.Y.C.
Admin. Code § 8-107(7).

 67.

Wegman Partners is liable under the NYCHRL for allowing Mr. Legg to sexually

harass and discriminate against his female subordinate, Ms. McILraith. In addition, the sexual
harassment was so overt and so pervasive, that Wegman Partners knew or should have known of
it—yet took no steps to protect Ms. McILraith. Wegman Partners is also liable for retaliating
against Ms. McILraith and forcing her out of her job after she reported the sexual harassment to
Mr. Wegman and his attorney.
68.

Mr. Legg and Mr. Wegman are also personally liable under the NYCHRL for

their individual actions—Mr. Legg for his harassment and discrimination, and Mr. Wegman for
his acquiescence in Mr. Legg’s conduct and failure to protect Ms. McILraith from it. N.Y.C.
Admin. Code § 8-107(13).
69.

As a result of Respondents’ discrimination against Complainant on the basis of

her gender, Complainant is entitled to compensatory damages and to attorneys’ fees and costs
under N.Y.C. Admin. Code § 8-120(a).
70.

Respondents’ actions in violation of the New York City Human Rights Law were

intentional, done with malice, and/or showed deliberate, willful, wanton, and reckless
indifference to Complainant’s civil rights, for which she is entitled to an award of punitive
damages.

 71.

Complainant has not filed any other civil or administrative action alleging an

unlawful discriminatory practice with respect to the allegations of discrimination which are the
subject of this complaint.

Dated: October 25,2017
New York, New York

Respectfully submitted,

EMERY CELLI BRINCKERHOFF
& ABADY

By:

AL
ZoeSalzman

600 Fifth Avenue, 1Oth Floor
New York, New York 10020
Telephone: 212.7 63.5000
Facsimile: 212.7 63.5001
Attorneys

for Complainant Veronica MclLraith

 VERIFICATION
STATE OFNEW

YORK

couNTY oF NEV/ YORK

)

)

ss.:

)

Veronica Mcllraith, being sworn states:

I am the complainant in the within action: I have read the foregoing Verified
Complaint and know the contents thereof: the same is true to my own knowledge, except as to
the matters therein stated to be alleged on information and belief, and as to those matters I
believe it to be true.

V

Swom to before me this
of October,2017

-^5W

McILraith

ZOE A. SALZMAN

NOIARY PUBLIC.SIATE OF NEW YORI(

No. 02SAó225344

Quollfied ln New york County

otary

My Commlrclon Expires Juty 19,
20 tg