Paskewich vs. ESPN

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

Address et court clerk where writ arid other papers shall be filed (Number, street, wra' zip cc
Teleohoge number of clerk (with

(C. G.S. 51-346, 51-360)
area code)
20 Franklin Square, New Britain CT 06051
860 )515.5180
E Judicial District
At (Town in which writ rs reale-defile) . - .; ,51,3 4 . 51945;
GA
Housing Session
LJ Number:
New Britain
For the Plaintiff(s) please enter the appearance of:
Name and addreo(N1Wie.y. law or Oirrtiff irss3#=retzrasentee Pgmbet, to10 and zip coda)
Peter B. Prestley of MOW, Preatley Parenteau, LLC, 4 02 Asylum Street, Hartford CT 061a3
Taiephor o nurnor (wit!) area code)
( 860) 24 6- 24 66
Return Date (Masi- be a Tuesday)
Aitgust 26 ; 2 014
' Muffle Dor s'err4

Case type code (Sea fist on page 2)
T Minor: 90
Signet re of Plaintiff Of seat-r5pres&riteci' i
ilL1(10 ourribet pa be entered by ot1Dmey
14 15600
SUMMONS - CIVIL
JD-0V-1 Hey. 2-13
C- .5S. 51-348, 51-347, 51-340, 51-350, 52-45e,
52- 4 a, 52-25% P B. Secs 3-1through 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: Heather Paskewich
Address: 120- C Washington Street, Milford CT 064 60
P- 01
Additional
Plaintiff
Name:
Address:
P- 02
First
Defendant
Name: ESPN, Inc.
Addreest ESPN Ptaza, Attn: Legal Department, Bristol CT 06010
0.01
Additional
Defendant
Name:
Address:

D-02
Additional Name:
Address:

13 -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 plaintiff is making
against you in this lawsuit.
2. To be notified of further proceedings, you or your attorney must file a form called an "Appearance" with the clerk of the above- named Court at the above
Court address on or before the second day after the above Return Date, The Return Cate is not a hearing date. You do not have to come io court on the
Return Data unless you receive a separate notice telling you to come to court,
3. If you or your attorney do not file a written "Appearance" form on time, a Judgment may be entered against you by default. The "Appearance" form may be
obtained at the Court address above or at Wv141/ .jUd.Ct,Z1V under "Court Forms,'
4 . If you believe that you have insurance that may cover the claim that Is being made against you In this lawsuit, you should immediately contact your
Insurance 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 at 14/Wilvitod.agov under "Goan Rules."
6, I uestl putti i Mons and Complaint, you should talk to an attorney quickly. The Clerk of Court is not allowed to give advice on
L
i56 Commissioner at the Name et- Petsrm-:Signirtg at Loft
Superior Court
gstistan tIaerk
Peter B. Prestiey
If this Summons i rgred by a Clerk:
a. The signing h been done so .4 1 t
e
Plaintiff(s) will not be denied access to the courts
b. it is the resporia -14 .4 1f- 1 aintiff(s) to see that servIce15 made In the manner provided by law.
o, The Clerk is not permitted to give any legal advice in connection with any lawsuit.
d, The Clerk signing this Summons at the request of the Plaintiff(s) is not responsible in any way for any errors or omission
In the Summons, any allegations contained In the Complaint, or the service of the Summons or Complaint.
I certify I have read and Signed
(5'eff-Represented Plaintiff)
Understand the above: .
Nxrri r aria a dreee.orpersoh retogri.liesJ to proseo0s. iri t e.arriopT3t.$
Patricia ; 17 Karpe arenteau, LLC, 4 02 Asylum Street, Hartford CT 06103
Date
E:00Mthiteienet Pato
r--1Superior Court
07 /15/2014
L.] Assistant Clerk
(Page 1 of 2)
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:
DISCRIMINATION ON ACCOUNT OF GENDER 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. ("ESPN"), is a Delaware corporation with headquarters
located at 1 ESPN Plaza, Bristol, Connecticut, 06010,
4. On or about June 13, 2013, Plaintiff filed a Complaint with the Connecticut
Commssion on Human Rights and Opportunities ("CHRO"), alleging
discrimination and retaliation by creating a hostile work environment due to
sexual harassment, and retaliation for complaining about the discrimination,
harassment and hostile work environment, in violation of state law. Said charge
was designated as CHRC No. 1330502.
5, Plaintiff's CHRO charge was jointly filed with the U.S. Equal Employment
Opportunity Commission ("EEOC") since it implicated violation of federal anti-
discrimination laws. Said charge was designated as EEOC No. 16A-2013-
O'1316.
1
6. On or about April 28, 2014, Plaintiff requested a Release of Jurisdiction from the
CHRO to pursue her claims under state law, and the CHRO issued the Release
of Jurisdiction on or about April 30, 2014. Plaintiff has commenced this action
within 90 days of receiving the Release of Jurisdiction.
7. On or about 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 of receiving the Right to Sue letter.
8. At all times pertinent to the matters alleged in this Complaint, ESPN was art
`employer" as that term is defined in Conn. Gen. Stat. 46a-51(10),
9. At all times relevant to this Complaint, ESPN was an "employer' as that term is
defined in 2000e(b) of Title VII of the Civil Rights Act of 1964, 42 U.S.C.
2000e, et seq.
10.At all times relevant to this Complaint, Defendant employed more than 20
persons.
11. In or about February 2000, Plaintiff commenced her employment with ESPN.
Plaintiff began working as a temporary employee in the Human Resources
Department.
12. In or about June 2000 Plaintiff was hired as a permanent, full-time employee by
ESPN with the job title "Commercial 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."
2
14, At all times during her employment at ESPN, Plaintiff performed her job duties in
an exemplary manner, and was frequently commended on her ability to build
relationships with her supervisors, colleagues and direct reports. She intended
to spend the balance of her professional career with ESPN, barring unforeseen
eventualities, because this was a unique employer in the geographical area, and
she excelled at and loved what she did.
15.In 2009, Plaintiff was approached by Donna Ray ("Ms, Ray"), Manager, and Andy
Bronstein ("Mr. Bronstein"), Senior Director, of the International On-Air Marketing
Department, and offered a position as Senior Coordinator. This position included
greater responsibility at a higher salary and involved supervising three individuals
who reported directly to her.
16, Shortly after being offered the position, Plaintiff was approached by Hell Soto
("Mr. Soto"), a Director in the International On-Air Marketing Department who
warned that she shouldn't take the position. Mr. Soto did not give Plaintiff any
reason for this, merely stating that she "might not like it over [t]here."
17. Plaintiff was acquainted with Mr. Soto because several years previously, Mr.
Soto had overheard Plaintiff and Corrine Lopes, a co-worker at ESPN, discussing
modeling. In this discussion, Plaintiff told Ms. Lopes that she needed to refresh
her portfolio with some new photographs. Mr Soto offered to take the
photographs for both Plaintiff and Ms. Lopes at no charge, which they agreed to.
18.After the photo shoot, both Plaintiff and Ms. Lopes had trouble getting copies of
the photographs from Mr, Soto, Wineri Plaintiff eventually obtained a CD from
Mr. Soto containing some, but not all photographs, Plaintiff discovered that Mr.
3
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.
4
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 found 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
5
a demeaning 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 Ms. Pantoja to Plaintiff and to Mr. Bronstein.
33.
When Plaintiff reported the Ms. Pentoja's bullying and harassing behavior to Ms,
Ray, no action was taken.
34.Mr. Soto began asking Plaintiff to meet him off work premises to discuss work
matters. Plaintiff met with him several times local restaurants, where they
discussed work matters, Including Plaintiffs opinions concerning Ms. Ray's
management style.
35. Plaintiff found these off work premises meetings uncomfortable, particularly
becauseMr. 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 Mr. Soto's conversations relating to
personal matters back to business matters or end the off premises meeting.
Plaintiff made it very clear to Mr. Soto that she was in a relationship and not
interested in anything but a professional relationship with him.
37. Plaintiff agreed to these off premises meetings only because Mr. Soto was her
supervisor and Plaintiff was afraid of retaliation if she refused to meet with him as
requested.
38.
In or about February 2012, Plaintiff took medical leave due to foot surgery.
Shortly before she went out on leave, Mr. Soto insisted on another meeting at
Bertuccils, That evening Mr. Soto began discussing how he felt "down and out,"
6
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.
7
45. After rebuffing Mr. Soto's repeated attempts to insinuate himself into her personal
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 about the removal of
one of Plaintiffs direct reports.
48, Plaintiff also spoke to Mr. Soto about the change. Mr. Soto informed her that
there were going to be a number of other changes that she probably wouldn't
like, but that she just had to "deal with it."
49. in or about August 2012, Plaintiff returned to work from her medical leave. Upon
her return, the entire office was talking about an affair between Mr. Soto and Ms,
Pantoja, who were both married to other individuals.
50, In or about August 2012, Ms. Pantoja was promoted to the position of Manager,
above Plaintiff.
51.
In or about September 2012, Paulo Silva, one of Plaintiff 's remaining direct
reports, was passed over for a promotion.
52. Plaintiff was informed by Mr. Bronstein that Mr. Soto never put in the paperwork
for Mr. alva's promotion.
8
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.
9
59, Ms. Ray told Plaintiff that she was very upset about Ms. Pantoja's August 2012
promotion to Manager since Ms. Pantoja had only been working there for 6-7
years, and it had taken Ms. Ray 18 years to become Manager.
60. Plaintiff spoke to Ms. Hricisko, Director of Human Resources after her remaining
direct reports were taken away. Ms. 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 was having problems with Mr, Sato and he 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 times without a response from Ms. Hricicko.
63.0n or about January 22, 2013, Plaintiff again met with Ms. Hricisko who
confirmed that the changes in Plaintiffs job were not performance related, or
related to anything she had done. Ms. Hricisko told her the investigation was
ongoing,
64. In or about February 2013, Ms. Ray met 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 were in a romantic relationship. Ms.
Ray stated that she was worried that Mr. Soto was going to promote Ms. Pantoja
again since Mr. Soto was in the process of pushing Mr, Bronstein out so Mr. Soto
10
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
11
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.
12
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 seemed
unstable, She told Mr. Rosenthal she would provide him with additional details
during the meeting they had scheduled for Monday, March 4, 2013.
73. During the first week of March, 2013, Plaintiff had a series of conference calls
with Ms. Hricisko and Mr, 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 her why she hadn't
reported Mr. Soto for trying to kiss her the previous year. Plaintiff told him she
was afraid of Mr, Soto retaliating against her for reporting him, Mr. Rosenthal
also suggested that she call Employee Assistance Program ("EAR"), Plaintiff
stated that she just wanted to be transferred out of the department and away
from Mr. Soto. Mr. Rosenthal asked if she had applied for other positions and
Plaintiff stated that she had.
75. During this conference call, Mr. Rosenthal also asked Plaintiff if Ms. Ray or Mr.
Soto had ever talked about gossip or her performance issues with her. Plaintiff
repeated "performance?" and Mr. Rosenthal corrected himself, asking if they had
discussed the gossip with her, and that there was something on her review in
October about gossip, Plaintiff did not know what he was referring to but
responded that she would check online and check her review.
76.At the end of the conference call, Mr. Rosenthal told Plaintiff that she could talk
to her co-workers in person, on the phone or by email, and to attend meetings,
13
that Mr. Soto was not correct in isolating her as he had done. He did ask Plaintiff
not to use the Internet communication system "for now," Mr. Rosenthal then
instructed her to let him and Ms, Hricisko know if anything else happened "out of
the ordinary," and said they would be doing an investigation,
77. On or about March 6, 2013, Plaintiff attended a procedure meeting with Ms. Ray
and scheduling people. In the middle of the meeting, Mr. Soto walked in, sat
directly across from Plaintiff and stared at her through the rest of the meeting in
an intimidating manner. During this meeting, Plaintiff was hesitant about
speaking up for an associate because she was afraid 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 had ever associated with Mr. Soto outside the office other
than the dinner meetings at Bertucci's that she had told them about, Plaintiff was
also asked further questions about Mr. Soto's website, and s0-called
"performance issues" from 2008 were raised.
79.At the meeting, Ms. Hricisko and Mr. Rosenthal began talking about
"performance issues" from 2008. When Plaintiff asked about the relevance of
performance issues from 2008, Mr. Rosenthal said they had to look for
"patterns!" When Plaintiff stated that they were trying to make her the bad guy,
14
Mr. Rosenthal denied it, stating that they had to remain neutral And address Mr.
Soto's allegations,
80.This meeting was the first time Plaintiff was made aware that Mr. Soto made
allegations against her.
81, Plaintiff was extremely upset and stressed after this meeting. She made an
appointment with her doctor who, after seeing her condition, put her out on
medical leave and recommended that she seek counseling to deal with the
effects the situation at work was having on her.
82. During her medical leave, Plaintiff heard from several co-workers that a staff
meeting was held during which an investigation was held, and it was stated that
the allegations of an inappropriate relationship between Mr. Soto and Ms.
Pantoja were not true.
83. On or about June 13, 2013, while Plaintiff was out on medical leave, she
received multiple telephone calls from ESPN, despite having been told that they
were not supposed to contact her while she was on medical leave.
84. Plaintiff called Nancy Mello ("Ms. Mello") to see if she had been calling her, due
to the fact that Plaintiff was scheduled to return to work on Monday, June 17,
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 Plaintiff assured Ms. Mello that she was
returning.
85, On June 13, 2013, Plaintiff received an email from Ms. Hricisko, informing her
that she and Tim Bunnell, Vice President of Consumer Marketing/Promotions
15
("Mr, Bunnell") wanted to speak with her at 12:30pm that day. Plaintiff did not
speak with them, since she was on medical 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 employment was false.
Plaintiff was informed that two networks were being discontinued, the Atlantic
Network and the Middle East Network; however, Plaintiff's position did not
involve working on either of the two discontinued networks.
88. Defendant terminated Plaintiffs employment in retaliation for her complaints
regarding sexual harassment and a discriminatory and hostile work environment.
89, 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 Connecticut Gen. Stat. 46a-60.
90. Defendant's conduct was intentional, willful, wanton and in reckless disregard of
Plaintiff's rights.
91. 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.
92. Also as a result of Defendant's actions, Plaintiff has incurred, and continues to
incur attorneys' fees and costs.
t6
COUNT TWO: DISCRIMINATION ON ACCOUNT OF GENDER IN VIOLATION
OF Title VII OF THE CIVIL RIGHTS ACT 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.
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 CONN.
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 a result of Defendant's actions, Plaintiff has suffered damages, including, but
not limited to, lost wages, lost employment benefits, lost promotional
18
opportunities, compensatory damages, emotional distress, humiliation,
embarrassment, and loss of enjoyment of life,
90.1n addition, Plaintiff has also incurred, and will continue to incur, attorney's fees
and costs in pursuing this claim.
19
DEMAND 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
A
AlliattNIP
Peter 1, 1",stley,
Claire NiLllowardi Esq.
Madsen, Pr661 eyr&-Par
Juris No, 415600
44 Capital Ave., Suite 201
Hartford, CT 06106
(860) 246-2466 - telephone
(860) 246-1794 fax
pborestImmssjustice,com
choward@mppiustice.corn
Attorneys for Plaintiff
By:
LLC
20
RETURN DATE: AUGUST 26, 2014
HEATHER PASKEWIGH
v.
ESPN, INC,
SUPERIOR COURT
J.D. OF NEW BRITAIN
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
pbprestlev@mropiustice.cotn
chavvardmppiustice.com
Her Attorneys
21

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EXHIBIT A

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

Teleohoge number of clerk (with

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