Gages of 3) eB & BEE en 8 Cea anaes 10 n 12 3 4 15 16 7 18 19 a 4 25 a 28 OR’ 3INAL Lauren Mayo-Abrams SBN #193315. WILED 501 N Canon Deve a 20 s ‘Supevtav Court of Callfornia 301 N. Canon Drive, Suite Gs Beverly Hills, CA 90210 “County of Les Angeles naan FEB 05 2018 ‘Attomeys for Plaintiff Sherr R, OftieriClerk SHONITRIA ANTHONY By, it Ae oS Deputy 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES caseno: BO695883 5. DEFAMATION sURY TRIAL DEMANDED ) SHONITRIA ANTHONY, ) } COMPLAINT FOR DAMAGES: nor } } RACE DISCRIMINATION IN : VIOLATION OF FEHA ) 2, RETALIATION'IN VIOLATION ) OF FEHA ATTN: INC,, a Delaware Corporation; ) KATHERINE STARROS, an ) 3, FAILURE TO PREVENT individual; MIKE VANISI, an ) HARASSMENT, individual; JARRETT MORENO, an) DISCRIMINATION AND individual; and DOES | through $0, ) RETALIATION IN VIOLATION inclusive, 3 OF FEHA 4. WRONGFUL TERMINATION IN Defendants. ; VIOLATION OF PUBLIC POLICY ) ) ) ) ) PRELIMINARY STATEMENT Plaintiff Shonitria Anthony relocated to California from New York pursuant to an offer of ‘employment from ATTN: INC. After leaving a promising career at another well respected. Internet news provider, ATTN terminated Ms. Anthony’s employment approximately ten months rh, 4 ‘COMPLAINT FOR DAMAGES Dect 1 Paget 1 - Doe ID = 1729664786 - Doo Type = OnEER(age 3 of 3) 1] after her hire date, 2 Prior to her termination, Ms. Anthony organized her African American co-workers after 3 | an ATTN investor and frequent collaborator used a racial slur against African Americans during an on-air broadcast on HBO. Ms. Anthony led the charge in holding ATTN accountable for its failure to respond and delayed reaction over the use ofa derogatory and racial slur by one ofits investors. Ms. Anthony was then terminated because of her race and in retaliation for asserting race based complaints and seeking diversity initiatives at the workplace to improve the working ‘environment of persons of color at ATTN. Plaintiff Shonitria Anthony alleges: 10 GENERAL ALLEGATIONS u 1. Defendant ATTN: INC. (hereinafter “ATTN” i and a all relevant times a ee a awe 12 } corporation organized and existing under the Jaws of the State of Delaware, with its principal sorporat 14 | California 90046. ATTN employed more than 50 persons and was an employer as defined in the 15 | California Fair Employment and Housing Act (FEHA) and the California Family Rights Act 16] (CFRA). "7 2, Defendant Katherine Starros (hereinafter “Starros”) is the Head of People Ip ae S13 | ptace of business in Los Angeles County, California, at 7251 Melrose Avenue, Los Angeles, ne Hl iaa's 18 | Operations for ATTN. By knowledge and belief Defendant Starros is an individual d 19 | the County of Los Angeles, State of California. 20 3. Defendant Mike Vanisi (hereinafter “Vanisi”) is the Head of Editorial for ATTN. 21 | By knowledge and belief Defendant Vanisi is an individual domiciled in the County of Los 22.| Angeles, State of Calif SB 4, Defendant Jarrett Moreno (hereinafter “Moreno”) is the Head of Editorial for & = 24 | ATTN. By knowledge and belief Defendant Moreno is an individual domiciled in the County of % 25 | Los Angeles, State of California. 26 5. Plaintiff Shonitria Anthony is a former employee of ATTN and is an individual 27 | domiciled in the Courity of Los Angeles, State of Califori 28|° —6._Plaintiff sues fictitious Defendants DOES 1 through 50, inclusive, pursuant to 2 ‘COMPLAINT FOR DAMAGES Doct 1 Page# 3 - Dos XD = 1729664786 ~ Doo Type = OnE(rage & of 37) 1 | California Code of Civil Procedure § 474 because Plaintiff does not know their true names and/or capacities, and upon ascertainment, will amend this Complaint with their true names and capacities. Plaintiff is informed and believes and on that basi alleges that each of said fictitiously named Defendants is responsible in some manner for the occurrences herein alleged, and that Plaintiff's damages were proximately caused by their conduct. 7. Plaintiffs informed and betieves and on that basis alleges that at all times mentioned herein, each of the individual Defendants was in part acting within the course and scope of his or her employment and was, atleast in part, serving a purpose of his or her own in carrying out the above conduct against the Plaintiff and in so doing was motivated by malice and 10 | itl will toward Plaintiff, n 8. Plaintiff has exhausted her administrative remedies by timely filing charges of i 12] harassment, é iscrimination, and retaliation with the Department of Fair Employment and 13 | Housing. The Department of Fair Employment and Housing issued to Plaintiff right to sue 14 | letters permitting her to file a civil lawsuit against Defendants j | 15 FACTS Hy 16 9. Prior to working for ATTN, Plaintiff Shonitria Anthony (hereinafter “Plaintiff” or 17] sAntnony”) was based in New York working as a News Bitor for one ofthe most recognizable 18 | news sources on the world wide web. 19 10, Inor around October 2016, Anthony applied forthe postion of Editor at ATTN. 20 || Katherine Starros, ATTN’s Head of People Operations, asked Anthony if she was willing to 21 || relocate and Anthony was flown to Los Angeles for an in-person interview. Upon her return to ge 22 | New York a formal offer of employment from ATTN was waiting for her. 3 2B 11. Along with the Editor position, ATTN promised Anthony amore active role, a fe 24 || stable environment, higher pay, and a sign-on bonus for relocating to California. Relying on £25 | armysotterand promises, Anthony accepted the poston and relocated her family to 26 | catifomia a 12, OnJune 2, 2017, Bill Maher, an investor and frequent collaborator of ATTN, 28 | called himself a “house-ni**er” on-air on his cablé talk show, Real Time with Bill Maher. CONFLAINT FOR TANACES oot 1 Pagel 4 - Doe ID = 172966476 ~ Doo Type = OmIERrage Sof 37) 1 13, Asan African American, Anthony was understandably upset by the racial shar uttered by someone publicly connected to the company who, at the time of the incident, had ‘multiple videos and other materials posted on ATTN’s website. 14, Aside from the incident itself, Anthony, along with other African American employees of ATIN, were upset and frustrated by the lack of response by ATTN to the inappropriate and racist comment made by Maher. 15. Inthe moming of June 5, 2017, Anthony led a meeting attended by other African American employees of ATTN. All who were present at the meeting expressed their disappointment and frustration at ATTN’ lack of response and silence over the racially charged 10} incident. The group reached a consensus to request a me 1g with ATTN upper management to 11 ] express their concern about the incident, including the company’s lack of response. The meeting, 12 | with upper management was scheduled on the same day later that afternoon. 13 16, Present at this meeting was Anthony, all of ATTN’s Affican American 14 | employees, Starros, Mike Vanisi (Head of Editorial), and Jarrett Moreno (ATTN Co-Founder). 15 | During the meeting, ATTN management apologized for failing to respond to and condemn the 17 attendance at the meeting, believed that ATTN must do more than their belated apology to 18 | address the issue. Anthony on behalf of herself and her African American colleagues requested 19] that management send out a public email to ATTN employees for a company meeting to discuss 16'| racial incident in atimely manner. Nevertheless, Anthony, along with other persons of color in a 20 | the racist and discriminatory comments made by Maher. In addition, Anthony expressed the 21 | concem of the African American employees regarding ATTN’s continued partnership with 22 | Maher. Furthermore, Anthony and her African American colleagues pointed out that there were ° 23 | no persons of color in upper management and requested that perhaps someone of color move into Se ——————C S25 | could provide ATTN with valuable insight on issues involving the compeny and persons of colo, 26 | such as what happened in the June 2" incident, 7 17. Despite the positive and respectful approach by Anthony and ATTN's African * 28 || American employees in asserting their race-based complaints and request for representation of | ~ CORPLATNT FOR DANCES Dect 1 Paget 5 - Doo XD = 1729664786 ~ Doo Type = OTHERGeage 6 of 3) 1 | persons of color in upper management, Anthony and her African American colleagues felt that ATTN’s management only met with them in an effort to conduct damage control over the ‘company’s lack of response to the racial incident, ‘They observed that while Mareno seemed ‘open to their complaints, issues and suggestions, Vanisi and Starros were openly hostile during the meeting, Rather than direct his attention to formulating a solution, Vanisi asserted excuses attempting to deflect from ATTN’s deficient response to Plaintiff and her colleagues race discrimination complaints, Vanisi claimed that ATTN was a start-up without previous ‘experience in handling and that the timing of Maher’s racist comment affected their ability to provide @ response. Contrary to her position as Head of People Operations, Starros minimally 10 | participated in the meeting and remained mostly silent clearly indicating her lack of support 11 } regarding the claims asserted by Anthony and other persons of color employed by ATTN. 2 18 On June 7, 2017, days after Anthony and ATTN’s African American employees 13 ]| met with the company’s management, Starros sent out a company-wide email scheduling a vague 14 | “optional” meeting for June 8, 2017. The meeting was scheduled pursuant to Anthony and other 15 | African American employees’ request to schedule one to discuss the discriminatory and racially \ ‘ i 16 || derogatory comment by one of the company's investors and frequent collaborator. But, Starros’ 17 ] email did not indicate the purpose of the meeting and since attendance was optional, Anthony y 18 ] was worried that employees with concems over the June 2™ incident would not know to attend 19 | the meeting. Starros later re-sent another fotice to all ATTN employees this time witha ttle for 20 | the meeting identifying its purpose. Starros identified the purpose of the meeting only after 21 | Anthony specifically requested for Starros to make such change. Had it not been for Anthony's, 22 | vigilance and attention to detail, ATTN’s employees would not have known the importance of 23 || the meeting and may have opted not to attend. m4 19, On June 8,2017, ATTN’s upper management met with each of the company's 25 | teams to discuss the June 2 incident, Many of ATTN's Aftican American employees, including QIBZs Re CB 26 | Anthony, believed that the meeting conducted by management like its apology was nothing more 27 | than damage control o present an appearance of concern and sensitivity towards the issues raised 28 | by persons of color. It was observed that upper management’s responses and actions during the 5 ‘COMPLAINT FOR DAMAGES Deck 1 Page# 6 ~ Dos 1D = 1729664786 ~ Doo Type = OTHER(rage 7 of 3 1 || meeting were mechanical and lacking sincerity. 20. After the June 8 meeting, Anthony sent an email to upper management attaching a document created by ATTN’s African American employees highlighting the importance of diversity at the workplace and how it could benefit a media publishing company like ATTN. 21. Because of her role in leading ATTN’s African American employees ini 2 3 4 5 6 || complaining about the June 2” incident, requesting a meeting to address the issue, requesting 7'|| that ATTTN sever ties with the investor, including the requests for diversity initiatives, such as the 8 | hiring of persons of color into upper management, ATTN began to treat Anthony differently. 9 22. Upper management began to avoid interaction with Anthony. Prior to her 0 || complaints regarding June 2 incident, Anthony regularly received feedback and direction from 11 | upper management, After the June 2 incident this was no longer true. Nevertheless, Anthony | 12 12:] continued to work as she had prior to the incident despite upper management's cold-shoulder | 13 } treatment, Aside from ceasing to provide Anthony with feedback and direction on her work, 3 14 | staros, at the lst minute, cancelled her attendance for the lunch lotto meeting with Anthony and 15 | other ATTN employees. Moreover, Starros failed to show for another meeting scheduled with 16 | Anthony regarding the National Association of Black Journalist convention, which Anthony was 17] scheduled to attend as ATTN's representative 18 23, Further, ATTN criticized Plaintiff's communication with her co-workers 19 | specifically relying on an incident involving a mis-communication created by ATTN’s 20 | management and not by Plainlff, ATTN also cancelled the podcast discussing diversity and 21 | issues affecting persons of color that Anthony was working on. One episode in the podcast ay 22 | iseussed the use ofthe N-word by Maher, ATIN's investor and frequent collaborator. 5 OB 24, Inthe morning of August 3, 2017, ATTN terminated Anthony's employment o 24 || claiming lay-off and that the company was moving in a different direction. ie 8 ts FIRS! OF 26| (RACE DISCRIMINATION AGAINST DEFENDANT ATTN: INC. AND DOES 1-50) 2 25. Plaintiff repleads, realleges and incorporates by reference each and every 28 || allegation set forth in this Complaint. = 6 COMPLAINT FOR DAMAGES oot 1 paged 7 = Dos 1D = 1729664786 - Doc Type = omaerage 8 of 37) 1 26. —Atall times herein mentioned, Goverment Code sections 12940 ef seg. and the California Constitution were in full force and effect and were binding on Defendants, These sections require Defendants to refrain from discriminating against any employee on the basis of race. 27. Defendants respond and treat of racial issues affeoting African American and persons of color differently than it does with other social issues unrelated to race. Moreover, isoues raised by non Aftican American employees to upper management are immediately addressed, whereas issues raised by African American employees are not. fe el ont ee) 28. Plaintiff's race was a motivating factor in the adverse employment actions taken 10 || against her, which includes but is not limited to PlaintifP’s termination, and Plaintiff's race was a 11 J substantial factor in causing harm to Plaintiff, 2 29. Such discrimination is in violation of the public policy of the State of California 13 J as reflected in Government Code sections 12940 ef seq., and the California Constitution and has 14 ] resulted in damages and injury to Plaintiff as alleged herein. 1s 30. Asa proximate result of Defendant's willful, knowing and intentional ‘Borety Hilla, CA 90210 ‘Yel: 3102083000 Fax: 9102082002 16 | discrimination against Plaintiff, she has sustained and continues to sustain substantial losses in. {Lae Offices of Lanren Abrams ‘A Brofentonal Law Cargerstion ‘901 N. Cone Drive Site 220 17 || earnings and other employment benefits in an amount according to proof. 18 31. Defendant acted for the purpose of causing Plaintiff to suffer financial loss and 19 | severe emotional distress and physical distress and is guilty of oppression and malice, justifying 20 | an award of exemplary and punitive damages. 2 32. Plaintiffhas incurred and continues to incur legal expenses and attorneys” fees. cq 72 | Plaintiffs presently unaware ofthe precise amount ofthese expenses and fes and prays leave of i 23 }| court to amend this complaint when the amounts are more fully known eo 33, Plaintiff requests that injunctive relief be issued requiring Defendant Employer to z 25 || cease and desist from any discriminatory practices and to take action, including but not limited to 26 | hiring, reinstatement or upgrading of employees to effectuate the purposes of Government Code 27 | 12940, et sea. 28 e a ‘COMPLAINT FOR DAMAGES Dect 1 Paget 6 - Doo ID = 1729664786 - Doo Type = OTHERage 9 of 37) 1 SECOND CAUSE OF ACTION (RETALIATION FOR PROTECTED ACTIVITY AGAINST DEFENDANT ATTN: INC. AND DOES 1-50) 34, Plaintiff repleads, realleges and incorporates by reference each and every allegation set forth in this Complaint. 2 3 4 s 6 35, Atall times herein mentioned, Government Code sections 12940 et seq. and the 7| California Constitution were in full force and effect and were binding on Defendant. These 8 | sections require Defendant to refrain from retaliating against any employee for raising race-based 9} complaints and requesting diversity initiatives for persons of color employed by ATTN. 0 36. The adverse actions and termination of Plaintiff's employment was motivated by 1 | Plaintiff's race, for raising race-based complaints and requesting diversity initiatives for persons of color employed by ATTN. After her rasing her complaint, Plaintiff was immediately terminated in retaliation for complaining of discrimination pursuant to the California Fair He ti manta Me 37. Such retaliation is in violation of the public policy of the State of California 1s reflected in Goverment Code sections 12940 et seq, and the California Constitution and has +7 | resulted in damages and injury to Plaintiffs alleged herein. 18 38 Asa proximate result of Defendants’ wilful, knowing and intentional retaliation 19 | against Plaintiff, she has sustained and continues to sustain substantial Losses in earnings and 20 | other employment benefits in an amount according to proof. a 39° Defendant acted for the purpose of causing Plaintiff to suffer financial loss and 22 | severe emotional distress and physical distress and is guilty of oppression and malice, justifying [23 | snawardof exemplary and punitive damages. = 40. Plaintiff has incurred and continues to incur legal expenses and attorneys” fees. 25 Plaimiftis presently unaware ofthe precise amount ofthese expenses and fees and prays leave of 26 | court to amend this complaint when the amounts are more fully known, 2 41, Plaintiff requests that injunctive relief be issued requiring Defendant Employer to 28 || cease and desist from any retaliatory behavior and to take action, including but not limited to COWPEAIRT FOR DAGES ‘oot 1 Pages 9 Doo ID = 1729664786 ~ Doc type = oTrage 10 of 3) 1 | hiring, reinstatement or upgrading of employees to effectuate the purposes of Goversment Code 12940, et seq. ‘HU Us (FAILURE TO PREVENT HARASSMENT, DISCRIMINATION, AND/OR RETALIATION AGAINST DEFENDANT ATTN: INC, AND DOES 1-50) 42, Plaintiff repleads, realleges and incorporates by reference each and every allegation set forth in this Complaint. 43, tall times herein mentioned, Government Code sections 12940 et seq. and the eer anne un California Constitution were in full force and effect and were binding on Defendant. These 10 | sections require Defendants to take all reasonable steps necessary to prevent discrimination and 11 } retaliation form occurring in its workplace, among other things. 12 44, Defendants discriminated against Plaintiff on the basis of Plaintiff's race, 13 | including retaliating against Plaintiff for complaining of discrimination under FEHA. 14 45. Defendants were aware of the discrimination and retaliation to which Plaintiff was Lae Office of Laren Atoms ADrofentenal Law Gerporston ‘SOL. Canon Drive Saise 320 ‘Beverly Hilla CA 90210 ‘Tek 3103082000 Fans 310052022 15 || subjected and failed to take all reasonable steps necessary to prevent such discrimination and/or 16 | retaliation from occurring, . 7 46, Such failure to prevent harassment, discrimination and/or retaliation was in 18 | violation of Government Code sections 12940 et seq. and the public policy embodied th 19 | and have resulted in damage to the Plaintiff as alleged in herein, 20 47. Asa proximate result of Defendants' willful, knowing and intentional failure to 21 | prevent harassment, discrimination, and/or retaliation of Plaintiff, she has suffered and continues 22 | to suffer humiliation, emotional distress, mental and physical pain and anguish, all to her damage Paes in a sum according to proof. ne 48 Plaintiff has incurred and continues to incur legal expenses and attorneys’ fees. © 25) taints presently unaware ofthe presse amount ofthese expenses and fees and prays eave of © 26 | oon to encod eis complaint wha te amount re moe filly im 0 49. Plaintiff requests that injunctive relief be issued requiring Defendant Employer to ~ 28 | cease and desist from any discriminatory practices and to take action, including but not limited to ~ FLATT FOR DAMAGES Doo 1 Pagal 10 ~ Doc 1D = 17256656786 - Dee Type = omwage 1 of 37) 1 | hiting, reinstatement or upgtading of employees to effectuate the purposes of Government Code 12940, et seq. FOURTH CAUSE OF ACTION (WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY AGAINST DEFENDANT ATTN: INC. AND DOES 1-50) 50. Plaintffrepleads, realleges and incorporates by reference each and every allegation set forth in this Complaint, 51, Under Califomnia law, no employee, whether an at-will employee or employee ee a aw eo under a written or other employment contract, can be terminated for a reason that isin violation 10 } of a fundamental public policy. ‘California courts have interpreted a fundamental public policy to 11 | be any particular constitutional ot statutory provision, or regulation that is concemed with a 12 | matter affecting society at large rather than a purely personal or proprietary interest of the 13 employee or employer. Moreover, said public policy is fundamental, substantial, and well Ihe i i 14 | established at the time of Plaintiff's discharge. J d Is ‘52. It was and is the public policy of the State of California, as set forth in the Fair i! i 16 | Employment and Housing Act that it is unlawful for any employer, labor organization, is 2-17] employment agency, or person to discharge, expel, or otherwise discriminate against any 18 |] employee because that employee's race and for complaining of discrimination. 19 53, It was and is the public policy of the State of California, as set forth in the 20 | California Fair Employment and Housing Act that an employer may not discriminate based on 21 || race. It was and is the public policy of the State of California, as set forth in the California Fair 22 | Employment and Housing Act that ari employer may not retaliate against an employee for 23 || asserting discrimination based on race. 24 54. The policies set forth in the Fair Employment and Housing Act and the California 25 || Family Rights Act are designed to protect the fundamental public interest of protecting QlOZs Testa 26 | employees from harassment, discrimination, retaliation and for allowing individuals protected 27} medical leave time to his/her own serious condition. 28 55. The termination of Plaintiff's employment was motivated by Plaintiff's race and 10 ‘COMPLAINT FOR DAMAGES ool 1 Pagel it - boo 20 = 1729664786 - Doo Type = om(age 12 of 37) 1 | for asserting complaints of discrimination based on race pursuant to the California Fair Employment and Housing Act. 36. As adirect and proximate result of the actions of Defendants, including the termination of Plaintiff's employment in violation of public policy of the State of California, Plaintiff has suffered and will continue to suffer lost wages and other employment benefits, whereby Plaintiff is entitled to general compensatory damages in amounts to be proven at trial, in addition to any other remedies and damages allowed by law. 57. The conduct of Defendants described herein above was outrageous and executed wea aw with malice and fraud, and with conscious disregard for Plaintiff's rights and further, with the af 10 | intent, design and purpose of injuring Plaintiff S85 58. Defendants authorized, condoned andlor ratified the unlawful conduct described pi 12] herein above, By reason thereof, Plaintiff is entitled to an award of punitive damages in an if 13 | amount to be proven at trial. Additionally, and as a proximate result of the actions described 3 LB 14 | above, Plaintiff is entitled to recover nominal, actual, compensatory, punitive and exemplary 15 || damages in amounts to be proven at trial, in addition to any othet remedies and damages 16 | allowable by law. 7 FIRTH CAUSE OF ACTION 18 (DEFAMATION AGAINST ALL DEFENDANTS) 19 59. Plaintiff repleads, ealleges, and incorporates by reference each and every 20 | allegation set forth in this Complaint. a 60, Defendants made defamatory statements about Ms. Anthony to her colleagues that 22 | significantly misrepresented the truth of Ms. Anthony’s efforts, ability, and performance. ex 61, Defendants and each of them published or caused to be published such false = aa statements to punish Ms. Anthony for leading the complaint by persons of color employed by S25] Arn segating the ciscriminatory comment based on race by an investor and fequent = 26 |} collaborator of the company. In making these statements, Defendants were motivated by 27 | discriminatory and retaliatory animus and malice and ill will toward Ms. Anthony. 2B 62. Defendants acted for the purpose of causing Ms. Anthony to suffe? financial loss i ‘COMPLAINT FOR DAMAGES ooh 1 Pageb 12 ~ Boo 2D = 2729661786 - Doc type = om(age 15 of 37) 1 | and severe emotional and physical distress. Defendants are guilty of oppression and malice, 2 | justifying an award of exemplary and punitive damages. 3 63. The statements, as alleged above, were false as they pertain to Ms. Anthony. 4 64. These statements were made by management level employees of Defendant s| arm. 65. These statements were slanderous per se in that they accuse Ms. Anthony of incompetence in her profession and harm her reputation causing her shame, mortification, and hurt feelings. 66. Asa proximate result of the above described publications, Mr. Anthony has i 10 | suffered loss of reputation, embarrassment, distress and hurt feelings, all to his general damage in 22 |e mente be proven atti of i a 12 WHEREFORE, Plaintiff prays for judgment as follows: pry 3 1. Forcompensatory damages, including lost wages and employment benefits 3 4 according to proof; 1S 2. For mental and emotional distress damages; 16 3. For punitive damages in an amount appropriate to punish Defendants for their 17| wrongful conduct and set an example for others. 18 4. Forinterest on the sum of damages awarded, calculated from the date said 19 } discrimination began to the date of Judgment; 20 5. Forreasonable attomeys” fees pursuant to Government Code section 12965(b), 21 | Labot Code § 1194 and any ather applicable attomeys' fee provision; 2 6. Forcosts of suit herein incurred; Bees 8 “24 Bie 26 |r ay it 28 | 1 12 ‘COMPLAINT FOR DAMAGES ooh 4 Pages 13 = Doo TD = 3729664786 ~ Doo Type = OERrage 14 of 37) 2 2 Row 10 ul 12 13 4 15 16 7 18 19 2 2B 25 26 a 28 7. For equitable remedies; and 8. Forsuch other and further relief as the Court deems proper. Plaintiff requests a trial by jury on all issues so triable, LAW OFFICES OF LAUREN ABRAMS _ Fora Phang Tauren Abrams Attomey for Plaintiff Shonitria Anthony DATED: February 27, 2018 By: 13, ‘COMPLAINT FOR DAMAGES Doct 1 Faget 14 - Boo 1D = 1729664766 - Doo aype = one