INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 COURT SUPREME COUNTY OF THE STATE NEW YORK OF NEW YORK OF --------------------- GINA G. --------X Index : RIGGI, No.: : : Plaintiff, SUMMONS : -against- CHARLIE ROSE ROSE JR. : CHARLES INC., CHARLIE a/k/a BLOOMBERG, PEETE and ROSE, : Date : September Index No. Purchased: 2019 19, : : L.P, : Defendants. : ------------------------------- To the above You your not of summoned hereby or, the if the day of to complaint Plaintiff's answer is not (or to you served within within or answer, judgment will basis of venue is N.Y. the within attorney service delivered personally appear Defendants: on the appearance, exclusive named are answer, -------------------X the be taken with 20 30 complaint State this after after against the you to of default in for summons failure demanded to in the complaint. The part Dated: of the New events York, September or omissions New 19, C.P.L.R. giving rise which § 503(a), to the claim is the county in which occurred. York 2019 & Broach By: /s/ LLP Stulberg, Patrick J. Walsh Patrick J. Walsh Robert B. Stulberg Attorneys for One Plaza, Suite NY 10119 New (212) Penn York, 268-1000 pwalsh@brostul.com 1 of 29 Plaintiff 2601 of of if this relief a copy summons, of your case the to serve a notice this is complete and York); by and serve service service the New of action summons, days days in this a substantial is FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 To: Rose Charlie 781 Fifth New 781 New New Peete Fifth New 10022 Rose New York, 10022 L.P. Lexington York, York, Avenue, York, Bloomberg, 731 Inc. Avenue, York, Charles INDEX NO. 159167/2019 Avenue, New York 10022 2 of 29 INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 SUPREME COURT COUNTY OF NEW ---- OF THE STATE YORK ----- GINA G. NEW YORK OF -------------X : RIGGI, : Index Plaintiff, COMPLAINT : -against- : : CHARLIE ROSE ROSE JR. CHARLES INC., CHARLIE a/k/a BLOOMBERG, No.: : PEETE and ROSE, Trial Jury Demanded : : : L.P., : : Defendants. ____.._____ _________-------X Plaintiff Stulberg, and L.P. brings LLP, Charles Gina Peete this Rose upon and Riggi, Complaint and by against Rose" ("Charlie through or "Mr. information belief and Plaintiff employed formerly Show"), and working on department, a related Show the cancelled had As on the G. Rose") (collectively Plaintiff in For 1995. to the greatly harassed sexually Mr. in the Rose than his Inc. ("CRI") and with alleges, Bloomberg, knowledge 22 to for she managed the to widely staff, for a pattern 1 3 of 29 and the the as to Ms. the Public other more of misogynistic, Show ("the Riggi first started Show's makeup Service allegations women, than Rose Broadcasting publicized two artist, makeup Charlie Week"). ("the until success below, her Artist Week" years, female Award-nominated Emmy in response allegations subjected The Show's 2017, & Rose "Rose"), hereby Makeup Rose: more Charlie Broach STATEMENT is a 62-year-old "Charlie counsel, as follows: otherwise, as Head/Key program, detailed Show, Riggi Defendants it in November and abused 2. worked by contributing ("PBS") Rose Gina undersigned employers, PRELIMINARY 1. her former her "Defendants"). (collectively ("Bloomberg") herself G. for that Mr. decades. decades that Ms. abusive behavior, Riggi INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 demeaning, embarrassing appearance, and herself him. from 3. and physically ground. sexual Mr. insisted on hosting sexually harassing related travel, Rose's own toward him, and female and made explicit 5. journalism discussions" them staff sexual harassment of Rose also and other women hunting Sherry-Netherland where restaurants trendy Mr. CBS at the at work against engaged he in this work- during at Mr. studio, broadcasting and late-night hugged questions phone calls. kissed down physical unwanted their In many them and shirts, Mr. Rose personal and as detailed instances, and pulled them, their contact. about groped routinely them, looked breasts, inappropriate Rose Mr. events, them, at their stared ears, asked with and himself to inappropriate In particular, Rose female at the to protect it as a sexual at his studio, mirror as an instrument Show he recorded and belief, with physical commented romantic he below, overtures. sexual with Mr. in their appearance, careers, and toward workday, pressed them barraged lives, where York, in limousines, airplanes, the at Bloomberg's New a hand to use using her ridiculing suffused staff, studio staff, Bellport, her environment Bloomberg conduct the whispered physical in gender, forcing female the her elsewhere. staff, subjected otherwise their abusive on work female of set, On information events. Throughout at his careers, staff on the and the his home because a toxic Riggi and Hamptons offices, pawed Ms. upon at hotels, 4. on for preyed and her created behavior, Rose at his apartment, also abuse predatory her degrading accosting Rose Mr. gender-based his and Mr. dangling him, treated often them Rose targeted internships and over and drinks as sexual jobs to lure dinner. targets, using 2 4 of 29 women attractive young, them But, his far to from power just "interviews" being and and "career an advocate influence their beginning to serve for their his INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 personal desires. When he did hire assignments and to Mr. executive When 6. him or disappointed physically, questioned criticism, At them. worked them Mr. times, on the against Show, fashion 8. Vega Rose's inappropriate female waited, their of Mr. many female stories 9. became in Riggi's of he treated Rose from Rose. On information did not and with degraded women toward to who their wrists, same abusive backing at her. swatting treat men in the her Ms. often unwelcome and female sexual belief, all herself, room felt Riggi came was personally abuse makeup behind employee, of misogynistic who Rose Riggi harassment used Rose's Mr. them demeaned grabbing basis. to appeal showered menacing fashion, a regular failed overtures, them, these assistants, on Show otherwise physically physically longest-tenured Ms. of whom colleagues, Mr. third and Mr. and subjected personal the at his and women. himself, Rose's abused an aggressive case, belief, he them, and in Rose's Rose assignments on at all. unpleasant to Mr. harassed to Mr. way, humiliated also worked who endured Such Rose other threatening and Show's Mr. employment any deliveries making companions." some them often they negatively in over Ms. conduct as a refuge younger the Mr. and a victim staff, Rose that As Yvette being intelligence, On information 7. degrading their and walls, reacted him looming homes, women these Show, women other staff female the advances. and producers offered "travel inappropriate assistants, on Rose's Rose's as Mr. Rose's to work at Mr. off-site serving he never instances, women young working residences, women In many to her and the Ms. the a maternal, in tears, overtures, of staff 5 of 29 on Riggi protective and and visibly toward shaken, abuse. worked for where Room, instinct Mr. Despite as a resource Green distraught observed, occasions. served adjoining who and to, countless misogyny supervisors 3 subjected Producer Executive only on the Show, other guests her sharing INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 Ms. including Mr. Rose's staff about were Vega, on behavior Mr. harassment themselves. Bloomberg refused the In years. Despite and some it, Mr. female experienced for behavior in words it, dismissing from supervisors Rose's observed personally complaints Bloomberg of notice or remediate numerous received instances, substantial to address On or about 10. terminated by occasions, supervisors Bloomberg years, many or effect, the Charlie as "Just Charlie." being Mr. countless over Rose employees. Bloomberg Ms. Rose's own her denying despite her 22 not unlawful and the modest years of service on due to any behavior. deplorable payment severance the Show of fault her has not caused was but own, Ms. as a consequence compounded consider Ms. staff, her Riggi Defendants cancelled, to other provided did they conduct the Defendants they Show, unlawful when 2017, harm Riggi's her telling to be of that, an employee. emotional incalculable and harm. 12. detailed November employment, Defendants' 11. financial Riggi's late below, 107; Article and quantum Riggi Ms. VI seeks under the of the New New damages York and City Human Law Labor York equitable Rights ("NYLL") relief for Law the ("City harm and for as endured, Admin HRL"), 190-199-c; §§ she has unjust Code § enrichment meruit. PARTIES Plaintiff 13. times she relevant, New worked Defendant 14. York, Ms. York and having Riggi, for a 62-year-old Defendants Bloomberg a principal female, as a makeup is a foreign place limited of business York. 4 6 of 29 is a resident of New Jersey. At all artist. partnership, and/or doing address business in New York, 8- in New New INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 15. New York, New York. New 16. New Charlie Defendant York and New York, 17. is a foreign a principal having information Upon Inc. Rose and place business doing of business and/or address in New Charlie Rose, an adult male, Defendant belief, corporation, in York, in resides York. Defendants are jointly and liable severally and herein, are also liable herein as over Plaintiff employers." "joint 18. within the of N.Y. at all Defendants, of meaning 19. the L. § 190 relevant, exercised relevant, were 20. a court of This general at all times limitation without 22. has jurisdiction jurisdiction, has Court has jurisdiction C.P.L.R. N.Y. is proper Venue Section limitation, AND 503 23. television Ms. Rigni's Ms. Riggi industry. to commencing She the within the meaning HRL and, over §§ 301 New claims York under the and statutory to New pursuant Defendants and/or City common York law law, as claims. including 302. to New pursuant County VENUE Plaintiff's over jurisdiction in this of the over York law, without including, C.P.L.R. STATEMENT A. "employer," Plaintiff's et seq. Court This 21. control supervisory HRL. City Defendants, Lab. times JURISDICTION prior business OF ADDITIONAL FACTS Career has had studied employment a distinguished Theatrical with career 30-year Makeup at the and Bloomberg 5 7 of 29 as a makeup Boston Rose, Conservatory worked for some artist of in the Music, of the most and well- INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 shows known Good on and MSG, on the almost Food individuals, Prime Ministers Hillary Clinton, States Senator Bernie Parks, Bill for of the 26. of New peer for the Creative such Riggi and NBC, provided Hard ABC, Geraldo, Her Copy. BBC, Ariel work WTN, Reuters, United Condoleezza also provided has makeup for Clinton such DiCaprio Israeli of United as Rosa personalities and John State and Kissinger; Henry and Gorbachev; Secretaries States and Leonardo Jolie, Bill Mikhail Rice well-known countless Obama, President Sharon; for makeup Barack Soviet Blair; Angelina Buffet, has as: Presidents Tony and She Women sponsorship which for before she started for work on 1995, Award NATAS her of teaches in Film and membership, requires Arts Daytime Crafts Riggi Ms. York ("IATSE"), for figures of Television Academy a Judge Governor Show CBS, including Albright, Sanders. an Emmy National been Ms. Madeline In or about 25. has Elliott Nightline, Minutes, Mikhail Baryshnikov, others. many nominated career, Netanyahu Warren Gates, network, Minister Prime Benjamin Kerry, the her political English Carter; major Gordon the O'Brien, 60 Live, Network. including Jimmy of every Throughout 24. among Conan Night Saturday including America, Morning appeared has television, passing NATAS seminars Television and the and for working the Sally Sciences She Show. and ("NATAS"), Awards. Emmy Raphael Jesse was Riggi Ms. Defendants, also for is a member She the was past a two-time 25 years, elected NYC. for NATAS ("NYWIFT"), International an examination and NYC, which Alliance demonstrating membership. 6 8 of 29 is a member requires of Theatrical requisite in good accreditation Stage professional standing and Employees skills INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 Defendants' The B. as an 27. In 28. For Joint of Ms. Riggi and Misclassification of Her Contractor Independent hired Defendants 1995, Employment Ms. Riggi to serve as Head Artist Makeup for the Show. first at 499 Park 29. the Show was her the Bloomberg personnel Ms. Riggi's on 36. of the As Ms. denied Vega, belief, Riggi Ms. her hire Ms. Riggi that they did other staff payroll, they until not attend same with "orange" them them trainings. and who supervisors employees. Bloomberg provided employees all paid alia, that benefits them providing Bloomberg producers inter on the working providing to contractors, Show's were paying accounts, assigned including, the York. from most email Bloomberg benefits, New Avenue, continuously informed treated of the all Riggi Bloomberg's that requiring including and on badges belief, Bloomberg Defendants 34. unemployment and work, assortment 35. and Lexington headquarters, contractor." Bloomberg "green" to On information 33. them assigning On information 32. Defendants them at Bloomberg 2017. 21, Defendants belief, placing manuals, Ms. an "independent and taped at 731 employed November rather, was 2004, cancellation, as opposed badges, employees but checks, Bloomberg valuable Show's Show or around jointly or about employees, Bloomberg-issued in Rose On information as Bloomberg directed on cancelled, the tenure, since and "employee," an entire and Avenue, Upon 31. Show Riggi's Bloomberg 30. deem Ms. on the Show a leave. they provided to all other Show. of a consequence benefits During after her she tenure was with this Ms. misclassification, Riggi was unable receive any to obtain terminated. the Ms. Show, 7 9 of 29 Riggi did not of the supposed INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 benefits that to work for an independent other 37. Riggi's performed both it. control This (a) the with (c) assigning (e) directing (f) instructing (g) over every the ability environment. control complete and the manner for Ms. Riggi; schedule schedule at Mr. and Rose's to whom in as to which and shadow her with means of Ms. aspect which by or in convenience, must she provide was she accordance the brushes, use; other and cosmetics, tools, necessary work; cleansers, should she the work; applicators, materials services; makeup to perform performed she cosmetics, other these she which in which manner her providing schedule, alia: sequence the eye of demands; the combs, the individuals the determining work work production (d) of work her changing (b) exercised inter a fixed setting work Rose results included, her as flexibility such receive, over and Bloomberg directing might or control employers, Rather, work, contractor equipment; and (h) 38. work for If Ms. reason, she had 40. Rose Ms. 41. Ms. a professional wardrobe and perform issues, any to get approval was beverages and artist. troubleshoot all for tasks to by performed tasks, Defendants guests. requested Ms. Production and Riggi of her at she had at risk Rose, and wished, asked expected Defendants. 8 10 of 29 a day off for of to work in illness the to accommodate her losing Defendants' television was by herself. could not or any Manager. requests and frequently computers supplies as she off or take schedule studio, Mr. purchased or time to accommodate of the she hours. her the from when time work change demanded also expenses vacation take expected outside Riggi makeup provide needed Riggi for scheduled Riggi changes scheduling not during interviews conducted minute could employers 39. other Riggi Ms. other her reimbursing Ms. monitors, when frequent Mr. last job. request, in Riggi, inter secure to comply field, with addition alia, car to her work to assist with services these for requests, guests, and as INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 42. services work for otherwise her for Defendants of many to her was Riggi on the of her each to perform Charlie that in November terminated Rose normal week makeup for schedule she the from worked, 2017. This Show. Ms. the Riggi did work. this Riggi Ms. indicia same work tasks misclassified the Ms. outside tasks, additional she until 2013, compensation Defendants email of when and Ms. provided her to contractors. Vega as an indepêñdent employment to take an office that they off for system; contractor, afforded other premises with assigned her employee Bloomberg whenever speak with Ms. Riggi they paid leave, a doctor's inquired a Resources than office. Riggi or to care appointment, name as to any Ms. however, her rather badge, Human Bloomberg's received illness, Bloomberg's computer an orange who employees a day to on internal Further, her directed other Unlike she had Riggi Ms. to Bloomberg's access account; matter, 45. provided provided badge personnel her granted door; green paid these in directed employees. Bloomberg the performed Week" Vega addition additional Although 44. the in to perform She afforded Bloomberg on Week," Riggi additional 43. Ms. 2013, "The Show. of "The receive or about show, Ms. Rose inception not a new required Charlie in Starting was for her not disabled mother. In March 46. knee replacement 47. surgery. The required ordinarily contributions 48. 2017, for Ms. She Defendants of employers Social Riggi Security, suffered for example, was not also failed by Ms. Riggi compensated federal, Workers' substantial to make state for any and Compensation harm forced was of local any the as a result 9 11 of 29 of this including, Unemployment of this off substantial time for time. contributions law, and to take on Ms. inter Riggi's alia, Insurance. misclassification. behalf INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 C. 49. Rose Mr. harassing, sexually unwanted sexual attractive; and unwanted attention. 51. remediate to abuse, Mr. flirt Ms. with, Rose on tenure also harassment aiding and and men, abuse if he found or if they but Show, did them subjecting comments not, the reacted them to his negatively to prevent nothing to or it. abetting demeaned bullied, degraded and Ms. Riggi of her because Show. the observed personally demean inappropriate on working of reprisal. he treated if he did of this specifically Riggi harass, humiliation and knew than and touching fear without them, differently women for environment diminishing groping, bullying Misogyny work women condoning, her throughout 53. and advances, of a toxic treated Rose instead, 52. gender created Bloomberg it, Culture dominating Mr. 50. ogle, Defendants' The and/or Mr. other degrade Rose use women on his the position Show of power for more to touch, than two decades. Ms. 54. them grabbing by Riggi their observed waists, conversations, and whispering 55. Ms. Riggi seemed to take 56. Ms. Riggi's than the and perverse Rose his arms around close uncomfortably female to him, staffers' shoulders, them holding during ears. their observed pleasure draping them pulling into also Mr. in Rose that Mr. the discomfort, appeared to enjoy and shame women, intimidating humiliation that he caused them. different who floor congregated there makeup staff's to take offices) refuge room and served from the adjacent as a hub Mr. Rose's 10 12 of 29 for Green the Room female Show's harassment (which and abuse. were staff and on a interns, INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 57. the and harassing From unwanted and and through Show's the to Ms. inappropriate to complain Riggi about Mr. to her, Rose's about questions numerous cancellation, about: his comments; inappropriate to her came them. toward 1990s women countless observations, elsewhere, complained his touching; Room late to producers, invasive asking the personal Riggi's behavior degrading 58. interns to Ms. Green the room, makeup from addition In Mr. phone their Rose's sexual at all calls personal hours staff, overtures; his of the and lives; female his often night, verbal and abuse. emotional 1. Mr. Rose's Demeâñing, Gender-Based Degrading, of Ms. Abuse Riggi were on for occasions and minute when guests regularly Ms. Riggi were nonetheless while physically Rose simply swat Ms. hurting Riggi for was responsible to apply his own makeup. for air. and makeup visual abused verbally physically to hold at her entailed This out Ms. for to provide was Mr. Rose applied. properly also responsibilities In Mr. Rose's their guests addition on of the to on-air Looks" "Last appraising and Show applying set to ensure appearances even appearance, and that Mr. last- making appearance. Riggi as she on attempted for a hairbrush an almost to comb Mr. Rose basis daily his hair to use during this or adjust his but Mr. himself, process, makeup. Rose hand. while occasion, applied was makeup that ensuring she Show, at her On one 62. their ready swatted would that to hair, Mr. learned responsible of her adjustments and was chose he One 61. upset and of the guests 60. Rose air," for "ready makeup Riggi Ms. 59. his on taping makeup, and location forcefully her. 11 13 of 29 outside grabbed of the and studio, twisted Mr. her Rose arm, became in INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 Ms. 63. a number of Riggi protested immediately this conduct to Mr. and Rose, reported later it to supervisors. Bloomberg 64. On information 65. Eventually, and belief, did Bloomberg not do in response anything to her reports. resorted Soon became even Riggi's complaint no a large to using 66. do these up" placed her how Show's 69. Mr. to Ms. and looked when Mr. Rose and Mr. also and Riggi in front could not Ms. Ms. them and female that he did her. he for in retaliation staff not need as her instead. experience sabotaged professional or visual and taping to perform Ms. Riggi's which reputation, of some efforts Ms. ridiculed Riggi Ms. about was to tied to publicly colleagues. 12 14 of 29 additional needed Riggi to go on to a new round of Riggi's her appearance Ms. instruct Ms. with such responsibility, Riggi makeup and assault worsened, young Riggi's Riggi Ms. makeup, physically belief, asking Ms. told Riggi and started do no makeup staff, Rose's taping. during subjected other with stellar comments of Rose position, her of were could staff the routinely inappropriate staffers ask Rose Mr. times, Rose Mr. On information set that on Mr. treatment Mr. Rose's interrupt Rose set. a difficult in guests would upset derisive comments friends and to maintain Invariably, which At and properly on the tasks decision women Rose's female young Rose's Mr. behavior, air. before his producers adjustment, making Rose host Rose's to perform these work 68. problem, Mr. Mr. perform the Mr. her or adjusting so that as a shield incident, toward about because tasks tasks hostile Looks" "Last doing mirror this in makeup 67. these hand after more background "touching when physical his set to fix abuse. in particular, appearance, weight. Mr. Rose often shaming and humiliating the made her these before to INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 70. Mr. gender-based, and not did Rose's arose to him appeal abusive, from Mr. Ms. Riggi's of abuse experienced unlawful the Show's studio, often tears. After 1 publicly all of her Mr. stories women she not her of Ms. rejected of all over Riggi his was or who advances, Mr. Rose criticism and room Riggi after to repair The years. other are following of by the women of Mr. Rose's statement conduct which Ms. Riggi victims. berate repeatedly berated this personal these for informed a complete Rose often of many course distress. or was the by the as a resource unlawful the Women¹ Other emotional to be observed Personal attacks. attacks, makeup so as to her belittle Assistant Personal shaken visibly one in the Assistant The personal and avoid exposing came into and in Rose. an Executive that Mr. Rose Assistant Mr. describes Rose's in abuse this demeaned an attractive her of women privacy Assistant had was underco,11po,1sated of women witnessed, directly mid-2000s, the of serving great intended Mr. Ms. Executive and to respect their the ask the the mistreated share who Abuse experience Riggi Riggi makeup complaining Although time, Ms. Riggi's from Ms. informed unwarranted would her recitation was and numerous caused are Assistants. with Ms. upset, In order that 1990s, In or about appearance. Rose late abuse Room Makeup it, examples she she crying, 73. Mr. in to further herself suffered harassment her refuge and Personal demeaning took abuse, which first Harassment of this an exhmative In the 72. of or Rose's harassed These or about observed, to women hostility and who and it. conduct, overall abused Rose staff female examples who Mr. observation distraught his treatment demeaning physically. 2. 71. and degrading because who and have harassment, Complaint. 13 15 of 29 he not regularly her intelligence young did not physical woman, she claimed consider her to be his voluntarily Ms. and the Riggi come does forward not name, that to at this INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 physical her type. and She From to Ms. complained Riggi that called Mr. Rose inquired about her love uñhappy with Mr. Rose's the the In the Associate work Riggi at all hours and saw the her whether told of the night, criticizing no substantial Mr. Rose was that in engage an Executive had that her Rose was at night to avoid her required regularly behavior Riggi saw with Mr. Katherine and and then-boyfriend off told She duties. "handsy" Assistant; her. a boyfriend cellphone Mr. in particular: staffers, harassed she work Ms. cancelled, regularly sexually her shutting Riggi Assistant Riggi Ms. to Ms. had Show McNeal, Sydney and she began she female young abusively asked complained where before her Assistant that a Personal 2015, at night, Personal also trips three Producer; late routinely months with inappropriately her calls, She on Ms. Show. her called through treated Rose This late-night him 75. Rose Mr. 2012 Mr. life. harassment. to accompany that approximately that Riggi complained her. berating 74. Ms. also Rose Brooks Chelsea on women behaving an Harris, a Broadcast Wei, Assistant. On numerous 76. them, putting his keeping back hand while to invasive 77. about conduct this his arm around on them for walking with physical contact Ms. inappropriate with an Assistant, numerous and waist, pulling the duration of and during a number in general, commiserated behavior. Ms. female of other Mr. observed them close conversations, Rose to him their violating work during hand his placing his draping personal arms conversations, small of their subjecting them on the and space around work. often other Riggi their them, Riggi Ms. occasions, with Riggi observed employees female Ms. over producers 14 16 of 29 Harris Mr. the and and Rose years, Ms. McNeal, engage in including, assistants who in particular, similar Kyle have inappropriate Godfrey-Ryan, not yet come INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 forward publicly observe Mr. to report Rose inappropriate staff" beautiful most Ms. Riggi not make as adornments, for the studio, and guests. He Ms. McNeal Mr. Rose staff Harris, did rolls" when forced Mr. about not called Ms. Ms. boasted made Vega Wei such his girls," "his to male Ms. sexist, and guests that Ms. McNeal Harris, comments. "I have and Rose Mr. did men. with to travel on Rose them giving and Angels." Charlie's my are, remarks a number claw," each with of Senior numerous Mr. even trips occasions, 2015, complained Rose when their that presence was them he treated not necessary residence awful" behavior, forcing her in to the abandon makeup to her. She and came her into the was office, room. regularly to hide This observed Mr. from so rattled which near told to Ms. room Mr. Ms. Riggi Riggi about shaken visibly 15 17 of 29 office, that Mr. after session to "the and berate crusty that her on Room. treatment Rose's to When menace Green Rose's reference inappropriately. Rose in the Mr. make staff Mr. Rose by was Producer complained makeup Riggi Producer Room Room" "Green one During female grab or Green room makeup a Senior to Ms. in the behavior. heard propensity an intern, Producer Riggi Rose's Riggi was Another she had Mr. Ms. Rose's Ms. joined about staff, to Mr. Producer 81. other female a reference often staff Female commiserate same Riggi work. 80. with in the physique. presence their demanding and "eye were who of Ms. they demeaning Women of women front in called "here Ms. experienced. they fashion. beauty and of kinds 79. He exchanged frequently these he used their on harassment deprecatingly Monroe." commented and in this spoke which Marilyn regularly the Rose names, "Mexican men treating Mr. 78. abuse the Mr. Rose's encounters of her and Rose that, take up had done sexist, with in or around a make-shift "something misogynistic Mr. Rose. The INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 Producer too told Ms. Riggi that she believed Mr. Rose to wanted get of her rid because she of interns "knew much." 3. 82. with to his advance Rose's Rose homes, of As to his apartment. having to make such interns at his required being drop off at Mr. emerging from the shower, Gordon later publicly Mr. Apartment, Rose the would that an intern packages Rose's her for female deliver interns delivered get women. attractive young, often complained often in the told scene to him She Mr. in Mr. this directly, her asked the show his other and about a about in a towel as possible. Rose's and greeted Riggi Riggi greeted at Mr. about room. Ms. as quickly Riggi Rose to Ms. told young to Ms. makeup Rose a movie to lure that complained 2002, drop-off from her the apartment a particular visits heard near which to flee a sex these apartment. during during used women Show Rose's her watch Riggi experiences the apartment that, interns Sometimes at Mr. prompting often Ms. years, these discussing Rose female or towel. reported made Mr. show's Over Gordon, particular were scores attractive young, packet preparatory the a bathrobe off his Interns encountered of whom majority that reported, widely In turn, to drop vast Riggi Ms. Show, Female Young shooting. women Sarah 85. of demanded a daily been in the the regularly deliveries. overheard she times, home on ventures, day's has Treatment time including next the 84. women Mr. Mr. 83. items her Throughout associated Rose's Mr. her after Ms. Netherland Sherry whether it aroused her. 86. that hand she felt deliver In August "uncomfortable" him information. of 2017, a young going When to Mr. Ms. woman employed Rose's Riggi apartment asked 16 18 of 29 why, on at the she confided in to answer, Riggi Hotel Sherry-Netherland declined Ms. but made to a INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 facial the RECEIVED NYSCEF: 09/19/2019 expression woman appeared suggested The that staffer could work in her 87. Ms. in one Mr. interns Riggi also Rose's Rose met she she hoped had the package that neither Ms. or career such Reah Bravo, who Ms. it would be. Mr. Bravo were Rose's Frej waiting reported on her 89. and Mr. Rose and/or Ms. that "gross," been Riggi inform and viable, had huh." "uh Vega. Ms. them pursuing then Room Rose Riggi and to the tell at his for waiting in the Green experience never saw of any Rose used lunch with set of the Show or over home Mr. Room 17 19 of 29 and Riggi 2014. Mr. Rose applicants for Ms. for that for interviews him there their encountered Riggi Frej on the to impress regularly Ms. June of job wait belief, met Willa subsequently employment. positions not Young jobs Room and taping "interviews." with male Ms. Attractive Green the Rose was dangled of One Mr. by pretense the in tasks. internship Lure and information such "interviewing" purported used her to under during or around in position, a meal. for Rose his him, upon women, Lunch Rose Mr. Jobs and such to and functions harassed that time, assigned were assignments to perform and Dinner their sexually at the Internships belief, the being Riggi, who at office shrouding men hire interns appeared rarely reported Mr. and female them, not Home, belief, come to would negative Ms. were young Ms. of his dinner to be conducted for Mr. concierge options did later Use to having them Rose Green in the hotel's mentioned told On information telling Mr. interviews women into discussions. interviews. if saying women Rose Mr. home. women women, the young rarely belief, On information to lure affirmatively, with These Women Show, asked Riggi encountered Vega and 4. 88. head of those regularly homes. and was in his working her Ms. termination. On information secrecy. what leave concern of Mr. and while intern expressed result parties, the the shook and tense, When disgust. communicating on the Show for INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 for waiting Mr. would think such applicants Riggi Ms. promised the This Personal Ms. Riggi him massages. Mr. that area that and Rose caused Riggi Ms. very Riggi French models, his 92. the and did who had been French Ms. pro had told had her BMW office, Riggi that job not to speak her to avoid in the that Rose Mr. did and as he travelled with use of She his and give room, and that made Ms. her car, told him Room, want not who Manhattan, Jersey. Green women Show. Rose the makeup room met any and to avoid Riggi very which there, be jeopardized. Riggi observed their found three presence the curious, normal presence in the studio, referred to Mr. Rose by a prominent heard Mr. Rose boasting 2017, shortly she attractive young, to perform Riggi sex the makeup appear Ms. the in her New to have in him given seeing on the to Mr. with her had to guests presence might She her she Street Hoboken, her asked instructed from Ms. Rose in when time 57th bring Rose Mr. ever vacancies on and recall Assistant dealership in the Mr. Assistant's learning a Personal hired not known women, unsuspecting could of the no were apartment quo, Rose Show. Subsequently, three told 2014, not at a assistant her as to their inquired acquaintance. about well, on her Mr. upon that Defendants she most fact, there these seeing since In Show. a condominium Personal or around as interns English her Vega to feel In 91. met that especially Ms. working said The uncomfortable, had as a quid Ms. entirely. the rented the interviews, Assistant in return, She such personal his had and with upon Riggi, dashed," dream 2004, Rose Mr. her card both that another for or around to make world. a credit Room Ms. Room. a position Green In Green "here's receive 90. told in the to herself, in the waiting Rose was duties told because they required of by producers French on the women French did When interns. that speak not were they celebrity set to his male guests models. On or about October 10, 18 20 of 29 before the Show was cancelled, Ms. Riggi INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 and RECEIVED NYSCEF: 09/19/2019 several female accusations Mr. colleagues leveled Weinstein's very what you're were you women with this conducting for going Ms. thought Riggi pool Ken Mr. at his for departing Netherland his female events drank widely CBS regularly Bellport home, employees Ms. Riggi At staff excess reported, employee, that realizing about Mr. it was actually, a script an advance that assent, his private, and annual Rose was [in] a ruse. It's you've been . . . and, you." on concluded, they and stayed at a 2011 who then for holiday parties at the and 2 the out Salvation Taco, whom he had she would be told until 3 or 4 a.m., holiday part at the reported the incident and example, Mr. actually, of the One person wrong drank invited. to be Pig, to a CBS 2See https://charlierose.com/videos/31048 19 21 of 29 alia, annual summer going-away operated by Restaurateur parties at his Sherry- each held Though requiring Events events. and heavily, Ms. day following Spotted and sometimes these and restaurant/bar, Pig generally Rose the inter owned to attend for room, party Spotted restaurants party, Parties including, staff, trendy pressured felt women Work-Related parties holiday top-floor other at hosted at other apartment. before in Rose Breslin Pig's Spotted a meeting Describing so humiliating about shaming . . . make could, Harassment as the 94. to going is "[s]omething that, about Weinstein. Harvey finding deeply to general Sexual such Friedman, were he commented, and Brown Tina interview. parties parties so that was 5. 93. you there meeting something journalist misogynist, that observed a business interview serial accused . . . there's . . . you that, for going Rose Mr. Brown Ms. humiliating. deeply snookered, another against conduct, that believing watched Riggi at work to get Mr. forcibly executive at the touched inappropriately assistance Rose December producer. typically that Mr. to his kissed car left Rose these had service. a female As INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 On or about 95. the Breslin insert himself greeted them as "his shoulders. their which her 96. party for Riggi observed a different ogling again inserted Rose, who wrapped or them, the in hand and pulled and repeatedly late 2017, July Ms. a speech, Producer, at the sat down his across arms stumbled he into friends, with Ms. her on over during body, her on the stared Ms. noticed Mr. Harris, and Rose as at the prior stared at her and cheek, Mr. When shoulders. and words, away going then at cheek. Rooftop. Brooks the He arms his and backs his his Taco by their a bench. at another Salvation at upon intoxicated, kissed over kissed repeatedly her on draped behavior accompanied McNeal seated and a Producer immediately appearing repeatedly shirt, party, were for party Rose, appearance, inappropriate spreading gave who sexually at the drinking, drink away Mr. observed physical her a going McNeal, waist, about When around their down threw Riggi Ms. a speech, dancing between an arm on similar on Rose Ms. and Harris exhibited been Mr. Producer's inappropriately. had Hotel. to look McNeal himself Ace gave the Producer, Ms. her Rose later around Rose 2017, Ms. determined Mr. June commented Rose appeared chest, party, girls," arm his the between Mr. he put Mr. within restaurant, arrival, early chest. 97. Mr. Mr. Bellport. At advances. other Ms. colleague artist that noting At state, in her asked 98. inebriated Ms. a party held typically often Rose makeup Riggi Rose drank heavily Riggi attended she attendance, female Mr. another grabbing coworkers Rose was summer an annual at these the to join pool at an attractive only her in party female woman for Riggi to swim the staff staff were noticed with second floor producer when she of his observed attempted in home of his aside that, declined, Riggi at his wary they Ms. 22 of 29 the Rose's Bellport, 20 for in Mr. a swim, from party female Ms. 2016, them watching and parties, in August was pool summer from When pool. one one female home. Mr. Rose, to leave, in an INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 Rose became visibly 99. Ms. at which home, for to spend her imploring a female avoided and to rescue the Mr. woman, Rose for she did as long a female holding was in not want to be perceived as she Rose intern kitchen the Mr. on his with Ms. subjected to possible Sherry-Netherland at his When lap. to Riggi, such Mr. come join him, and she treatment, without drawing Rose his called the ire. have discriminated against privileges of her employment, because younger and Ms. treated Riggi less Riggi Ms. of her in gender well, differently, discrimination, inter and compensation, terms, age. and and the less than favorably male employees. in this engaged and directly, by in which abuse her subjecting she witnessed alia, to a toxic, treating misogynistic abuse ongoing by and Ms. culture in Riggi of gender- harassment gender-based women. Ms. 103. ratified, intervened for party Defendants harassment to address Rose fashion discriminatory numerous colleague a birthday who that Defendants 102. remedial stated Defendants 101. of a male Summary and employees Mr. Assistant, Mr. 100. conditions attended also observed Executive D. based Riggi she joining When night. upset. Assistant Executive the Riggi reported the unlawful conduct, but Defeñdants failed to take any action. 104. Defendants retaliated 105. Bloomberg knew it, aided and and instead, abetted engaged against or should in, Riggi Ms. have caused, known perpetrated, it. 21 23 of 29 for her of the protected unlawful committed, activity. discrimination, authorized, but condoned, failed INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 106. provide her Defendants all afforded they the Defendants' harm opportunity, to which benefits contributions was she entitled Social for of Plaintiff Complaint with 110. This 111. At entity" "covered realleges force and effect all and is brought relevant a times "person" to which under herein, within to her state and the career law, to make inter including, Unemployment Insurance. HARASSMENT) in paragraphs herein. N.Y.C. Admin. and of the and obligation local set forth NYCHRL, meaning of OF ACTION allegation fully the and AND Bloomberg the shifted CAUSE as though loss compensation wages, Compensation every substantial her, losses. federal, - DISCRIMINATION and Count and to cause of reputation, valuable and by continues loss Riggi A FIRST repeats same the Ms. Workers' FOR and non-monetary employers Security, (NYCHRL failed as an employee, entitled Riggi, as an employee, AS AND 109. denied have was humiliation, other and required ordinarily contributions alia, also Ms. caused anxiety, anguish, Defendants she and contractor, Show. has embarrassment, lasting as an independent to which the conduct emotional and 108. on employees Riggi Ms. compensation valuable other 107. physical misclassified Rose were 1 through Code each and NYCHRL, an are 108 § 8-101 of this et seq. "employer," liable as "joint employers." 112. the At of the meaning 113. practices, unlawful all times conduct, discrimination and Mr. herein, Rose and Ms. Riggi were each a "person" NYCHRL. Defendants' unlawful aiding relevant abetting as alleged based thereof, on herein, gender in violation constituted and/or of the 22 24 of 29 age, unlawful unlawful NYCHRL. discriminatory harassment, and within INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 Defendants' 114. or recklessness to amount an such "employer" disregard. of the rights liable for each are and § 8-107(1) amounts herein, disregard Defendants NYCHRL under NYCHRL a conscious or involves to as alleged conduct, under the or wanton to willful of the others or unlawful conduct so reckless herein conduct abetting" and "aiding negligence both provisions as as of § 8-107(6). 115. a result As to suffer injury, with limitation, lost of Defendants' and lost bonuses, Plaintiff conduct, economic monetary, resulting wages unlawful and damages, interest lost benefits, other has continues without including attorneys' attorneys' and and suffered and fees costs. As a further to suffer, among 116. continues reputation, emotional enjoyment of damages for damages, and lasting injuries such 117. other the is entitled and 118. Complaint meaning Plaintiff with the 119. This 120. At of N.Y. Lab. such costs force and effect times § 190(3), to her suffering, suffered and name good is entitled and loss inconvenience, Plaintiff under the of to recover LAW herein, and Defendants are 23 25 of 29 punitive damages, ACTION - ARTICLE VI VI) in paragraphs set forth fully Article Defendants OF allegation as though other Defendants. CAUSE every the and monetary from LABOR realleges relevant L. YORK is brought pain, humiliation. FOR A SECOND and Count all and repeats same and damage has Defendants. fees AS AND and emotional anguish, Plaintiff conduct, irspairment injury, to recover attorneys' (NEW unlawful embarrassment from Plaintiff interest, items, mental distress, life, Defendants' of result of N.Y. 1 through 117 of this herein. Lab. were Plaintiff's liable as "joint L. §§ 190- "employer," employers." 199. within the INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 121. At all relevant 122. By misclassifying Plaintiff times, was within an employee the N.Y. meaning L. Lab. § 190(2). Riggi wages, Labor Law. compensation N.Y. Lab. L. provisions. L. Defendants' 124. violated which are New York "wages' within the denied of meaning Ms. the the Law Labor and its substantive 198. 193, 191, §§ benefits Defendants contractor, 1980c. § 190(1), thereby Lab. N.Y. as an independent Riggi other and Defendants 123. Ms. violations willful were within the of N.Y. meaning Lab. § 190 L. et seq. 125. damages, monetary attorney's fees Defendants' of a result As unlawful without including, AS AND FOR A THIRD ENRICHMENT (UNJUST Plaintiff with the As 127. direction and/or and 128. the benefit Riggi's other and realleges force and effect above, Ms. in set forth which as an "employee," Defendants Ms. expense, lost wages, interest, Riggi's inter alia, performance the valuable QUANTUM allegation every Riggi and services performed all other was entitled wages and/or employees. 24 26 of 29 125 of this herein. for under Defendants, to receive their valuable the wages employees. as an "independent as an employee, 1 through in paragraphs set forth fully as such, to Riggi MERUIT) QUASI-CONTRACT) as though afforded Ms. By misclassifying of IN repeats same control, benefits unpaid substantial suffered OF ACTION CAUSE AND/OR (SOUNDING Complaint for damages limitation, has costs. and 126. Plaintiff conduct, but other contractor," retained for compensation Defendants received themselves, at Ms. that afforded they all INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 129. for retaining Ms. and entitled, not order be unjustly from that upon they close injustice, of retained unjustly A. Enter a judgment B. Award Plaintiff without including result of damages Award for losses Award D. reputation, limitation Defendants' C. damages requests Plaintiff for, among emotional as against unlawful as against from resulting Plaintiff items, distress, of the and wages, Ms. wages for Insurance, contributions. and and which good were they Ms. Riggi employee to to which she obligated. require that should and/or benefits compensation, as their compensation conscience that behalf alia, Unemployment these Riggi's inter including, to Defendants relationship her on Defendants be entitled to other themselves. FOR on of all RELIEF on Plaintiff Defendants, pay, front as follows: Counts, her claims against jointly and severally, pay, bonuses, Defendants; benefits, the amount and interest of wages, lost as a conduct; Plaintiff other back wages, law, value expense, for favor contributions and equity judgment in local behalf PRAYER WHEREFORE, the on her Riggi's all and to afford them value of the expense, at Ms. any Compensation contributions, enriched the state federal, Riggi's to prevent Defendants expenditures the make a sufficiently reliance to make In 131. recover her had not Workers' at Ms. Riggi cause sufficiently by Security, themselves, 130. should employers Social for contributions was of required ordinarily did Defendants Further, Defendants, Defendants' as against injury, mental jointly unlawful anguish, severally, consequential severally, compeñsatory conduct; Defendants, impairment and jointly and emotional 25 27 of 29 and damage pain, to her suffering, good name inconvenience, and loss of INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 enjoyment of life, lasting embarrassment and other and humiliation, and pecuniary nonpecuniary losses; by E. Award F. As Labor N.Y. Plaintiff to the Second as against Defendants, of Action, Cause and jointly award Plaintiff severally, punitive liquidated damages pre-judgment damages; as provided Law. G. Award Plaintiff as against Defendants, jointly and severally, H. Award Plaintiff as against Defendants, jointly and severally, with reasonable Award Plaintiff any Award Plaintiff such Dated: September interest; action, together I. applicable law; J. attorneys' and the York, New 19, of this fees; all other damages provided by the applicable and proper. and New costs further legal relief as may be just 2019 York BROACH & STULBERG,LLP for Attorneys Plaintiff By: Patrick J ÅValsh Robert B. Zachary One New (212) Penn York, 28 of 29 Bergman Plaza, New Suite 2601 York 10119 268-1000 Attorneys 26 Stulberg Russell for Plaintiff statutes and INDEX NO. 159167/2019 FILED: NEW YORK COUNTY CLERK 09/19/2019 07:43 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2019 DEMAND Plaintiff, above-captioned by and through her FOR A JURY_TRIAL above-signed counsel, action. 27 29 of 29 hereby demands a trial by jury in the