Paskewich vs. ESPN

8/12/2019 Paskewich vs. ESPN

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EXHIBIT

Case 3:14-cv-01129 Document 1-1 Filed 08/05/14 Page 1 of 23


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Address et court clerk where writ arid other papers shall be filed

(Number, street, ra' zip

eleohoge number of clerk (with

(C.

G.S. 51-346, 51-360)

rea code)

20 Franklin Square, New Britain CT 06051

60 )515.5180

E Judicial District

At (Town in

which

writ

rs reale

defile)

- . ; 5 14 . 5 945;

GA

Housing Session

Number:

ew Britain

For the Plaintiff(s) please enter the appearance of:

Name and addreo(N1Wie.y. law

r Oirrtiff irss3#=retzrasentee Pgmbet,

o10 and

z ip coda)

Peter B. Prestley of MOW, Preatley Parenteau, LLC, 402 Asylum Street, Hartford CT 061a3

Taiephor o nurnor

(wit ) area code)

( 860) 246-2466

Return Date

(Masi

be a

Tuesday)

Aitgust

6 ;

2 014

' Muffle or 'err4

Case type code (Sea fist

on page 2)

T

inor: 90

Signet re of Plaintiff

Of seat

5pres riteci'

i

ilL1 10 ourribet pa

be entered by ot1Dmey

1415600

SUMMONS - CIVIL

JD-0V-1 Hey. 2-13

C-

5S. 51-348, 51-347, 51-340, 51-350, 52-45e,

52-4a,

52-25% P B. Secs 3-1 through 3-21, 8.1

ri

X

if amount, legal interest or property in demand,

costs is less than $2,500.

X if amount, legal interest or property in demand,

costs is $2,500 or more.

15 X if claiming other relief in addition to or in lieu of

STATE OF CONNECTICUT

SUPERIOR COURT

WINW pc:i.Gt,gutV

not including interest and

not including Interest and

money

or

damages.

See page 2 for instructions

TO: Any proper officer, BY AUTHORITY OF THE

STATE OF CONNECTICUT, you are hereby

commended to make due and legal service of

this Summons and attached Complaint.

Number of Plaintiffs, 1

Number of Defendants:

Form JD

CV

2 attached for additional parties

Parties

Name (Last,

First, Middle initial) and Address of Each party

(Number; Street; P.O. Box;

Town;

State; 21,o; Country, if not USA)

First

Plaintiff

Name:

eather Paskewich

Address: 120-C Washington Street, Milford CT 06460

P-01

Additional

Plaintiff

Name:

Address:

P-02

First

Defendant

Name: SPN, Inc.

Addreest

ESPN Ptaza, Attn: Legal Department, Bristol CT 06010

0.01

Additional

Defendant

Name:

Address:

D-02

Additional

Name:

Address:

-03

Additional

Defendant

Name'

Address:

13.04

Notice to Each Defendant -

1,

YOU ARE BEING SUED. This paper is a Summons In a lawsuit , The complaint attached to these papers states the claims that each plaintif f is making

against you in this lawsuit.

2.

To be notified of further proceedings, you or your attorney must f i le a form called an Appea rance with the clerk of the above-nam ed Court at the above

Court address on or before the second day a fter the above Return Date, The Return Ca te is not a hearing date. You do not ha ve to come io court on the

Return Data unless you receive a separate notice tell ing you to come to court,

3. f

you or your attorney do not f i le a written Appeara nce form on t ime, a Judgment ma y be entered against you by default . The Appeara nce form may be

obta ined a t the Court address above or a t

Wv141/ .jUd.Ct,Z1V

under Court Forms ,'

4.

f you believe that you have insurance that may cover the claim that Is be ing made a gainst you In this lawsuit , you should imm ediately contact your

Insuran ce representative, Other action

you may have to take

is described in the Connectleut Practice Book

which

may be found in a superior court law

It r

t

14/Wilv i tod.agov

under Goan Rules.

6, I

estl

utti

Mons

and

Complaint, you should talk to an attorney quickly. The Clerk of Court is not allowed to give advice on

L

i56 Commiss ioner

at the Name et

Petsrm

-:Signirtg at Loft

Superior

Court

gstistan t

aerk

eter B. Prestiey

If this Summons i rgred by a Clerk:

a.The signing h been done so

41 t

e

Plainti ff(s) wi l l not be denied

access

to the courts

b. t is the resporia

-

14.41f-1 int if f(s) to see that s ervIce15 m ade In the ma nner provided by law.

o, The Clerk is not perm itted to give any lega l advice in connection with any laws uit .

d, The Clerk signing this Sum mons at the request of the Plaintif f(s) is not respons ible in any way for any errors or omiss ion

In the Summons , any allegations conta ined In the Compla int, or the service of the Summons or Complaint.

I certify I have read and Signed

(5'eff-Represented Plainti ff)

Understand the above: .

Nxrri r aria a dreee.orpersoh retogri

liesJ to proseo0s

iri t e.arriopT3t.$

Patricia ;1

Karpe

renteau, LLC, 402 Asylum Street, Hartford CT 06103

Date

E:00Mthiteienet

ato

r--1 Superior Court

7/15/2014

L.] Assistant Clerk

(Page 1 of 2)



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SUPERIOR COURT

RETURN DATE: AUGUST 26 2014

HEATHER PASKEWICH

v.

ESPN INC.

SUPERIOR COURT

J D OF NEW BRITAIN

AT NEW BRITAIN

JULY 16 2014

COMPLAINT

COUNT ONE:

ISCRIMINATION ON ACC OUNT OF GE NDER IN VIOLATION

OF CONN. GEN. STAT. 46a-60 et

seq

1.

Plaintiff, Heather Paskewich, is an individual presently residing in Milford,

Connecticut.

2.

Plaintiff is female.

3.

Defendant, ESPN , Inc. ( ES PN ), is a Delaware corporation with headquarters

located at 1 ESP N P laza, Bristol, Connecticut, 06010,

4.

On or about June 13, 2013, Plaintiff filed a C omplaint with the Conn ecticut

Com mssion on Hum an Rights and Opportunities ( CH RO ), alleging

discrimination and retaliation by creating a hostile w ork environment due to

sexual harassm ent, and retaliation for co mplaining about the discrimination,

harassm ent and hostile work environme nt, in violation of state law. Said charge

was designated as CHRC N o. 1330502.

5, Plaintiff s CHRO charge was jointly filed with the U.S. Equal Employment

Oppo rtunity Comm ission ( EEO C ) since it implicated violation

of federal anti-

discrimination laws. Said charge was designated as EEOC No. 16A-2013-

O'1316.

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6.

On or about April 28, 2014, Plaintiff requested a Release of Jurisdiction from the

CHR O to pursue her claims under state law, and the CHRO issued the Release

of Jurisdiction on or abou t April 30, 2014. Plaintiff has comm enced this action

within 90 days o f receiving the Release o f Jurisdiction.

7.

On or abou t May 29, 2014 , Plaintiff requested a Right to Sue letter from the

EEOC to pursue her claims under federal law. The EEOC 's Right to Sue letter,

dated May 30, 2014, was received on June 2, 2014, Plaintiff has commenced

this action within 90 days o f receiving the Right to S ue letter.

8.

At all times pe rtinent to the matters alleged in this Comp laint, ESP N wa s art

`employer as that term is defined in Conn. Gen. Stat. 46a-51(10),

9.

At all times relevant to this Com plaint, ESP N was an emp loyer' as that term is

defined in 2000e(b) of Title VII of the C ivil Rights Act o f 1964, 42 U.S.C.

2000e

et seq

10.At all times relevant to this Complaint, Defendant em ployed mo re than 20

persons.

11.

n or about February 2000, Plaintiff comme nced her employm ent with ESPN.

Plaintiff began working as a temporary employee in the Hum an Resources

Department.

12.

n or about June 2000 Plaintiff was hired as a permanent, full-time em ployee by

ESPN w ith the job title Com mercial Operations Assistant.

13.Over the subsequent years, Plaintiff was transferred to the Broadcast Promotions

Department, now known as Consumer Marketing/Promotions, and was promoted

to the position of Supervisor.

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Soto had edited the photos, distorting them to make them appear sexually

provocative.

19.

Plaintiff also discovered that Mr. Soto uploaded these distorted photographs,

without her knowledge or consent, to a website that he maintained. This website

contained photographs of other young women who worked at ESPN as well,

20.

Mr. Soto assured Plaintiff that there was nothing wrong with the photos on the

website, and that there was nothing she needed to worry about.

21.

At the time of Mr. Soto's warning not to take the position, Plaintiff had already

agreed to take the position, because it meant more responsibility, status and

greater compensation,

22.

When Plaintiff started working in the International On-Air Marketing Department,

she reported to Ms. Ray, Mr. Soto and Mr. Bronstein, Ms. Ray was her

immediate supervisor.

23.

When she first started in the International On-Air Marketing Department, Plaintiff

mentioned Mr. Soto's warning to Ms. Ray, Ms. Ray told Plaintiff that Sandra

Pantoja ( Ms. Pantoja ), who worked directly for Mr. Soto as an entry level

coordinator, was unhappy about Plaintiff's promotion because Ms. Pantoja had

been expecting a promotion, and Plaintiff had come over to the department in a

higher level position than Ms, Pantoja. Ms. Ray commented to Plaintiff that if she

ever got on Ms. Pantoja's bad side, Ms. Pantoja would take her down.

24.

Shortly after Plaintiff started in the International On-Air Marketing Department,

Ms. Pantoja began harassing, demeaning, and, ordering her around, despite the

fact that she was Plaintiff 's junior in rank.

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25.

Plaintiff went to Human Resources to report Ms. Pantoja s unprofessional

behavior. Plaintiff spoke with Terrisita Seeberger, of Human Resources about

the problems, Ms. Seeberger claimed to document the issues, however no

action was taken to resolve them,

26.

Eventually, problems with Ms. Pantoja were temporarily resolved when Plaintiff

and Ms. Pantoja moved into different internal networks and no longer routinely

interacted with each other.

27, When Plaintiff began working in the International On-Air Marketing Department,

Juan Alfonso, the head of the department, told Mr. Soto to remove the distorted

photographs of Plaintiff from his website, since it was unprofessional, Mr,

Bronstein also told Mr. Soto that the photographs should be removed.

28.

Mr. Soto assured Plaintiff that the photographs would be removed.

29.

When Plaintiff subsequently checked on the website that Mr. Soto maintained,

which had previously contained photographs of her distorted to appear sexually

provocative,

she foun

that a second, password-protected website had been set

up, Although she was unable to access it, Plaintiff saw her own photograph on

the home page of the second website,

30: Plaintiff did not report her photograph on the secondary website to anyone,

including Human Relations, because at that point Mr. Soto was her boss and she

was afraid of retaliation.

31. Shortly thereafter, Ms. Pantoja and Plaintiff s work responsibilities began to

intersect once more, Ms. Pantoja began harassing Plaintiff again, treating her in



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a deme aning manner and ordering her around, despite the fact that Ms. Pantoja

was several levels below Plaintiff.

32

Two of Plaintiff 's direct reports, Ashley Finkel and Kendra Horn, also complained

about bullying by M s. Pantoja to Plaintiff and to Mr. Bronstein.

33

Wh en Plaintiff reported the Ms. Pentoja's bullying and harassing beh avior to Ms,

Ray, no action was taken.

34.Mr. Soto bega n asking Plaintiff to meet him off work premises to discus s work

matters. Plaintiff met with him several times local restaurants, where they

discussed w ork m atters, Including Plaintiffs opinions concerning Ms. R ay's

managem ent style.

35. Plaintiff found these off w ork premises meetings uncom fortable, particularly

becauseM r. Soto would steer the conversation off work topics, and discuss his

beliefs about monogamy and marriage.

35. Plaintiff, to the best of her ability, would steer M r. Soto's conversations relating to

personal matters back to business matters or end the off premises meeting.

Plaintiff made it very clear to Mr. So to that she was in a relationship and no t

interested in anything but a p rofessional relationship with him .

37

Plaintiff agreed to these off premises m eetings only because M r. Soto was her

supervisor and Plaintiff was afraid of retaliation if she refused to m eet with him as

requested

38

In or about Feb ruary 2012, Plaintiff took medical leave due to foot surgery.

Shortly before she we nt out on leave, Mr. Soto insisted on another m eeting at

Bertuccils, That evening Mr. Soto began discussing how he felt down and out,

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that he was having trouble with his wife, and that he enjoyed meeting with

Plaintiff because she 'made him laugh.

39.

Plaintiff was very uncomfortable about the tenor of this personal discussion. She

became even more uncomfortable when Mr. Soto attempted to kiss her when

they said goodnight. Plaintiff stepped back, brushed him away, said goodbye

and left.

40.

Plaintiff did not discuss the events of that night with Mr. Soto or go to Human

Relations about it, since she again was afraid that Mr. Soto might retaliate

against her if she reported his actions.

41.

Shortly after the meeting at Bertucci's with Mr. Soto, Plaintiff had surgery on her

foot and then went out on medical leave.

42.

While Plaintiff was cut on medical leave, Plaintiff stayed in constant

communication with Nancy Mello ( Ms. Mello ), who worked directly with Donna

Hricisko, (Ms. Hricisko ), Director of Human Relations,

43.

During her medical leave, Plaintiff received constant texts from Ms, Ray and Mr.

Soto about when she was coming back to work, although they were not

supposed to be contacting her according to Ms. Mello. Mr. Soto also texted

Plaintiff about meeting her for dinner or coming over to her house, but she

refused, using her foot problems as an excuse so as not to anger him.

44.

Plaintiff returned from medical leave in March 20

l2, but continued to experience

problems with her foot, which resulted in her having to take further medical leave.

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45.

After rebuffing Mr. Soto's repeated attempts to insinuate himse lf into her persona l

life, Plaintiff found herself subjected to hostile and retaliatory treatment by Mr.

Soto and Ms, Pantoja.

46.

During her second medical leave, Plaintiff was informed by one of her three

direct reports that one of her direct reports would now be reporting to Ms.

Pantoja. Soon thereafter Plaintiff received a call from Ms. Ray informing her of

the change, Ms. Ray did not give her any reason for the change.

47.

Plaintiff spoke to Terista Seeberger in Human Resources abo ut the removal of

one of Plaintiffs direct reports.

48, Plaintiff also spoke to M r. Soto about the chan ge. Mr. Soto informed her that

there were going to be a num ber of other changes that she probably wouldn't

like, but that she just had to dea l with it.

49. n

or about Aug ust 2012, Plaintiff returned to wo rk from h er med ical leave. Upon

her return, the entire office was talking abou t an affair between M r. Soto and M s,

Pantoja, who w ere both m arried to other individuals.

50, In or about August 2012, Ms. Pan toja was promoted to the position of Manager,

above Plaintiff

51.

In or about S eptember 2 012, Paulo Silva, one of Plaintiff 's remaining direct

reports, was pa ssed over for a promotion.

52.

Plaintiff was informed by Mr. Bronstein that Mr. So to never put in the paperw ork

for Mr. alva s promotion.

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53. In or about November 2012, Bryan Metzger, another individual in the department,

left the department because he felt extremely uncomfortable with the favoritism

and the obvious personal relationship between Mr. Soto and Ms, Pantoja,

54, At a going away party for Mr. Metzger, at a dance club called the Cadillac Ranch,

Mr. Soto and Ms. Pantoja made no effort to hide their relationship, eating from

the same plate, and constantly touching each other. When Ms. Pantoja left, Mr.

Soto left, stating that he was going to walk her to her car. Mr, Soto was gone

for over an hour, a fact that everyone commented on.

55. in or about November 2012, Mr. Soto and Ms. Ray met with Plaintiff and

removed her remaining two direct reports from under her supervision, despite

previous commendations for Plaintiffs supervisory skills.

56.At the meeting Mr, Soto assured Plaintiff that it was not a performance issue and

that they had no problems with her job performance, but he felt that she should

focus on financial matters.

57, At the meeting, Plaintiff was also told she would retain her title and position,

despite no longer having anyone to supervise.

58. During this time period, members of the department were making frequent

observations about the relationship between Mr. Soto and Ms, Pantoja. Ms. Ray

told Plaintiff that she saw Mr. Soto and Ms. Pantoja kissing, they would disappear

for long periods of time behind closed doors in Mr. Soto's office, and they would

show up late and disheveled for meetings.



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59, Ms. Ra y told Plaintiff that she was very upset about M s. Pantoja s Augu st 2012

promotion to Manager since Ms. P antoja had only been w orking there for 6-7

years, and it had taken Ms. Ray 18 years to become M anager.

60. Plaintiff spoke to Ms. Hricisko, Director of Human R esources a fter her remaining

direct reports were taken away. M s. Hricisko told Plaintiff that there would be an

investigation of the matter since Plaintiff did not have performance issues.

61.0n or about December 4, 2012, Plaintiff met with Ms. Hricisko. They discussed

the fact that Ms. Ray w as having problems w ith Mr, Sato and h e was constantly

yelling at Ms. Ray. Piaintiff told Ms. Hricisko that Mr. Soto seemed ofr and

unstable. Mr. Soto's temper was beginning to flare up frequently. Ms. Hricisko

reiterated that matters were being investigated, and she would follow up with

Plaintiff.

62. Over the next few weeks, Plaintiff emailed Ms. Hriciskc twice and called her

several t imes without a response from Ms. H ricicko.

63.0n or about January 22, 2013, Plaintiff again met with Ms. Hricisko who

confirmed that the chan ges in Plaintiffs job we re not performance related, or

related to anything she had do ne. Ms. H ricisko told her the investigation was

ongoing,

64. In or about Febru ary 2013, M s. Ray m et with Plaintiff and told Plaintiff that she

was worried about her own job and confirmed she had seen Mr. Soto and Ms.

Pantoja in circumstances that revealed they we re in a romantic relationship. Ms.

Ray stated that she was w orried that Mr. Soto was going to promote M s. Pantoja

again since Mr. Soto was in the process of pushing M r, Bronstein out so Mr. Soto

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could take his position. Ms. Ray told Plaintiff that she had decided, at Mr,

Bronstein's insistence, to go to Human Resources about the relationship

between Mr. Soto and Ms. Pantoja.

65. On or about February 27, 2013, Plaintiff met with a new head of the Department,

Andre Quadra ( Mr. Quadra ).

66, At the meeting with her new department head, Mr. Quadra told Plaintiff that she

was not to talk to any of her co-workers and to run everything through Ms. Ray.

He also suggested that in a few months she take her colleagues out to lunch and

get to know them on a personal level. Mr. Quadra stated that he knew that it had

been a hard year for her and that her medical condition had affected her job.

Plaintiff was not able to get him to explain how he felt her medical condition had

affected her job. Mr. Quadra then told her he would get feedback from Ms. Ray

and get back to her,

67.0n or about February 28, 2013, Ms. Ray requested a meeting with Plaintiff.

When Plaintiff asked if anyone else would be present, Ms. Ray said no, When

Plaintiff asked what the meeting was about and whether it was related to her

meeting with Mr, Quadra, Ms. Ray told the Plaintiff cryptically that Hell had

gotten to Andre and told her she would meet the Plaintiff later. Plaintiff asked if

she needed a representative from Human Resources to be there, and was told

she should just show up.

68, When Plaintiff arrived at the conference room for the meeting, she found both

Ms. Ray and Mr, Soto present. Plaintiff left the door open because she did not

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feel comfortable with Mr. Soto in the room, Mr. Soto insisted that the door be

shut

69.

At the meeting, Mr. Soto informed Plaintiff that people didn t like her, that he had

received complaints against her. When she asked who had complained because

nobody had said anything to her, Mr. Soto informed Plaintiff that they were

putting her on a performance plan. Plaintiff then requested that someone from

Human Resources be brought into the meeting. Mr. Soto appeared very angry

and yelled at Plaintiff. He told her he would make it worse for her if she went to

Human Resources and if she was smart she would finish the conversation

without Human Resources present. He told her she should listen to Ms. Ray,

and not to talk to anyone by phone, internet communication, or in person. All

communications for business purposes were to be done by email. Plaintiff left

the conference room in tears.

70.

Plaintiff immediately called Ms. Hricisko from another conference room. Ms.

Hricisko told her she should go home, but Plaintiff told her that Mr. Soto would

retaliate against her if she left. Plaintiff stayed in the conference room for

approximately one hour until she was calm enough to return to her desk.

71.

When Plaintiff returned to her desk, she immediately received multiple emails

from Ms. Ray asking for information and reports that were not due until the next

day, telling her she wanted them now, and asking if Plaintiff had forwarded

information to a cc-worker requested earlier in the day. Plaintiff sent Ms. Ray an

email stating that she would stay late and get everything to Ms, Ray, and that she

had forwarded the requested information earlier.

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72, After she returned to her desk, Plaintiff emailed Heath Rosenthal, Senior

Manager, Employee Relations about the meeting, In the email she requested to

be moved to another building because Mr, Soto frightened her and see med

unstable, She told M r. Rosenthal she wo uld provide him w ith additional details

during the meeting they had scheduled for Monday, M arch 4, 2013.

73

During the first week of Ma rch, 2013, Plaintiff had a series of con ference ca lls

with Ms. Hricisko and M r, Rosenthal during which they discussed the series of

events and issues Plaintiff had been subjected to.

74

During the third conference call, Mr. Rosenthal asked he r why she hadn 't

reported M r. Soto for trying to kiss her the previous year. Plaintiff told him she

was a fraid of Mr, Soto retaliating aga inst her for reporting him, Mr. Rose nthal

also suggested that she call Em ployee Assistance Program ( EAR ), Plaintiff

stated that she just wanted to be transferred out of the department and away

from Mr. Soto. Mr. Rose nthal asked if she had a pplied for other positions and

Plaintiff stated that she had.

75 During this conferen ce call, Mr. Rosentha l also asked Plaintiff if Ms. Ray or M r.

Soto had e ver talked about gossip or her performance issues w ith her. Plaintiff

repeated performanc e? and Mr. Rose nthal corrected himself, asking if they had

discussed the gossip with her, and that there was so mething on her review in

October abo ut gossip, Plaintiff did not know what he was referring to but

responded that she would check online and check h er review.

76.At the end of the conference call, Mr. Rosenthal told Plaintiff that she cou ld talk

to her co-workers in person, on the phone o r by email, and to attend meetings,

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that Mr. Soto was not correct in isolating her as he had d one. He did ask Plaintiff

not to use the Internet commun ication system "for now," M r. Rosenthal then

instructed her to let him an d M s, Hricisko know if anything else happened "out of

the ordinary," and said they w ould be d oing an investigation,

77. On o r about March 6, 2013, Plaintiff attended a p rocedure me eting with Ms. R ay

and sch eduling people. In the middle of the mee ting, Mr. Soto walked in, sat

directly across from Plaintiff and stared at h er through the rest of the me eting in

an intimidating manner. During this meeting, Plaintiff was hesitant about

speaking up for an associate becau se she was a fraid it would result in further

retaliation. She reported this incident by email to Mr. Rosenthal, who set up

another phone call with her.

78.0n or about March 13, 2013, Plaintiff again met with Ms. Hricisko in her office

with Mr, Rosenthal on speaker phone. During this meeting, Plaintiff was asked

by Ms, Hriscisko all the same questions she had already answered, For

instance, whether she h ad ever associated with Mr. Soto outside the o ffice other

than the dinner meetings at Bertucci's that she had told them about, Plaintiff was

also asked further questions abou t Mr. Soto's website, and s0-called

"performance issues" from 2008 w ere raised.

79.At the meeting, Ms. Hricisko and Mr. Rose nthal began talking about

performance issues from 2008. When Plaintiff asked about the relevance of

performance issues from 200 8, Mr. Rosenthal said they had to look for

"patterns " Whe n Plaintiff stated that they were trying to m ake he r the bad g uy,

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Mr. Rosenthal denied it, stating that they had to remain neutral And address Mr.

Soto s allegations,

80.This mee ting was the first time P laintiff was made aw are that Mr. Soto made

allegations against her.

81, Plaintiff was extremely upset and stressed after this meeting. She m ade an

appointment w ith her doctor who, after seeing her condition, put her out on

medical leave and recomm ended that she seek counseling to deal with the

effects the situation at work was ha ving on her.

82.

During her m edical leave, Plaintiff heard from seve ral co-workers that a staff

meeting w as held during which an investigation was held, and it was stated that

the allegations of an inappropriate relationship betwee n Mr. So to and M s.

Pantoja we re not true.

83.

On or abo ut June 13, 2013, wh ile Plaintiff was out on m edical leave, she

received multiple telephone calls from ESP N, despite having been told that they

were not suppose d to contact her while she was on me dical leave.

84.

Plaintiff called Nancy M ello ( M s. Mello ) to see if she had bee n calling her, due

to the fact that Plaintiff was scheduled to return to wo rk on Mo nday, June 1 7,

2013. Ms. Mello indicated that she had not called Plaintiff, and went on to

discuss her return to work. Ms, Mello pointedly asked Plaintiff if she was truly

returning to work on June 17, 2013, and P laintiff assured Ms. Mello that she was

returning.

85, On June 13, 201 3, Plaintiff received an em ail from M s. Hricisko, informing her

that she and Tim Bun nell, Vice President of Consumer M arketing/Promotions

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( M r, Bunnell ) wan ted to speak with her at 12:30pm that day. Plaintiff did not

speak with them, since she was on med ical leave

86.0n or about the evening of June 13, 2013, Wendy Kemp, Defendants attorney,

called Plaintiffs counsel, and informed him that Plaintiff was being laid off due to

her position being eliminated,

87.

Defendant's stated reason for the termination of Plaintiffs employm ent was false.

Plaintiff was informed that two networks were being discontinued, the Atlantic

Network and the Middle E ast Network; however, Plaintiff 's position did not

involve working on e ither of the two discontinued n etworks.

88.Defendan t terminated Plaintiffs employme nt in retaliation for her comp laints

regarding sexual harassment and a discriminatory and ho stile work environmen t.

89, Base d on the foregoing, Plaintiff was discriminated against in the terms and

conditions of her employm ent and her employm ent was terminated on the basis

of her gende r in violation of Co nnecticut Gen. Stat. 46a-60.

90.Defendant's conduct w as intentional, willful, wanton an d in reckless disregard o f

Plaintiff s rights.

91.

As a result of Defendants actions, Plaintiff has suffered dam ages, including, but

not limited to, lost wages, com pensatory damag es, economic dam ages, loss of

employm ent benefits, damage to reputation, em otional distress, loss of

enjoymen t of life and loss of enjoymen t of profession.

92.Also as a result of De fendant's actions, Plaintiff has incurred, and continues to

incur attorneys fees and costs.

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COUNT TWO:

ISCRIMINATION O N ACCO UNT OF GENDER IN VIOLATION

OF Title VII OF THE CIVIL RIGHTS AC T OF 1964 AS

AMENDED 42 U.S.C. 2000E

1-85, Paragraphs 1 through 85 of Count One are incorporated herein as Paragraphs 1

through 85 of Count Two as if fully set forth herein.

86.

Based on the foregoing, Plaintiff was discriminated against in the terms and

conditions of her employment and her employment was terminated on the basis

of her gender in violation of Title VII of the Civil Rights Act of 1964,

87.The aforementioned conduct on the part of Defendant was intentional in that it

was willful, wanton, and/or was taken with reckless disregard of Plaintiff s rights.

88.As a result of Defendants actions, Plaintiff has suffered damages, including, but

not limited to, lost wages, compensatory damages, economic damages, loss of

employment benefits, damage to reputation, emotional distress, loss of

enjoyment of life and loss of enjoyment of profession.

89,Also as a result of Defendant s actions, Plaintiff has incurred, and continues to

incur attorneys fees and costs.

COUNT THREE: SEXUAL HARASSMENT IN VIOLATION OF CONN. GEN. STAT.

46a-60 et

seq

1-85. Paragraphs 1 through 85 of Count One are incorporated herein as Paragraphs 1

through 85 of Count Three as if fully set forth herein.

90. As set forth above, Plaintiff was subjected to sexual harassment by supervisor,

which created an intimidating and hostile working environment.



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91.

Despite Plaintiff s complaints, Defendant failed to conduct an adequate

investigation of said sexual harassment and hostile work environment, and failed

to adequately remedy said harassment and hostile work environment,

92.

Defendant s conduct constitutes a violation of Connecticut General Statutes

46a-60(a)(8).

93.As a result of Defendant s conduct, Plaintiff has suffered damages including, but

not limited to, loss of wages, loss of benefits, loss of enjoyment of life, emotional

distress and attorneys fees and costs.

COUNT FOUR: RETALIATORY DISCHARGE ON THE BASIS OF PLAINTIFF S

EXERCISE OF HER RIGHTS UNDER THE CONNECTICUT FAIR

EMPLOYMENT PRACTICES ACT IN VIOLATION OF C ONN.

GEN. STAT. 46a. 58

et seq

AS TO DEFENDANT ESPN

1-85. Paragraphs 1 through 85 of Count One are incorporated herein as Paragraphs 1

through 85 of Count Four as if fully set forth herein.

86. Based on the foregoing, Defendant retaliated against Plaintiff because she

complained about harassment and discriminatory employment practices in

violation of Conn. Gen. Stat. 46a-59

et seq

87,

Defendant retaliated against Plaintiff by inter alia harassing her, subjecting her to

disparate treatment, removing her supervisory responsibility over three direct

reports, and ultimately terminating her employment.

88,

Defendant discriminated against Plaintiff with malice or reckless indifference to

Plaintiff s rights under the law,

89.As

result of Defendant s actions, Plaintiff has suffered damages, including, but

not limited to, lost wages, lost employment benefits, lost promotional

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opportunities, compensatory dam ages, em otional distress, humiliation,

embarrassm ent, and loss of enjoyment of life,

90.1n addition, Plaintiff has also incurred, and will continue to incur, attorney s fees

and costs in pu rsuing this claim.

19



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DEM ND FOR RELIEF

WHEREFORE, Plaintiff claims A TRIAL BY JURY and:

1, Compensatory damages, including but not limited to, lost wages, lost benefits,

uninsured medical costs, emotional distress, mental anguish, humiliation, and

embarrassment;

2.

Back pay;

3.

Front pay;

4

Interest and costs;

5.

Punitive damages;

6.

Statutory attorney s fees and legal costs;

7.

Such other relief as in law or equity that may pertain.

Plaintiff,

Heather Paskewich

liatt

P

Peter 1, ,stley,

Claire NiLlloward iEsq.

Madsen, Pr661eyr

ar

Juris No, 415600

44 Capital Ave., Suite 201

Hartford, CT 06106

(860) 246-2466 - telephone

(860) 246-1794 fax

pborestImmssjustice,com

choward@m ppiustice corn

Attorneys for Plaintiff

By

LLC

20



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RETURN DATE: AUGUST 26 2014

HEATHER PASKEWIGH

v.

ESPN INC

SUPERIOR COURT

J.D. OF NEW B RITAIN

AT NEW BRITAIN

JULY 15 2014

STATEMENT OF AMOUNT IN DEMAND

The amount in demand is greater than $15,000,00, exclusive of interest and

costs of suit

Plaintiff,

Heather Paskewich

By:

Pete EL Prestley, -sq.

Clair NLHowardsq.

Madsen, P festleY, & Parenteau LLC

Juris No, 415600

44 Capital Ave., Suite 201

Hartford, CT 06106

(860) 246-2466 - telephone

860) 246-1794 fax

[email protected]

chavvardmppiustice.com

Her Attorneys

21


Paskewich vs. ESPN

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