COMMONWEALTH OF MASSACHUSETTS, MIDDLESEX: ss. SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT Mary Jayne Brackett-Kelly, Plaintiff, Civil Action No.: v, Thomas E. Dillon Jr., In his individual capacity and in his capacity as former Chief Information Officer of Wynn Boston Harbor; Robert J. DeSalvio, COMPLAL: In his capacity as President of Wynn Boston Harbor; Gregory Dauenhauer, PLAINTIFF DEMANDS, In his capacity as Chief Information Officer of ATRIAL BY JURY Encore Boston Harbor; Michael Carazza, Inhis capacity as Director of Corporate Compliance and Investigations for Encore Boston Harbor; Jacqui Krum, In her capacity as Senior Vice President and Corporate Counsel for Encore Boston Harbor; Troy Mitchum, In his capacity as Vice President of Human Resources for Encore Boston Harbor, Wynn MA, LLC, ‘Wynn Resorts, Ltd., ‘Wynn Resorts Development, LLC. Defendants. Now comes the plaintiff, by her attorneys, and files the following complaint: 1, PARTY PLAINTIFF Plaintiff Mary Jayne Brackett-Kelly is a former employee of Encore Boston Harbor, then and for all material times known as Wynn Boston Harbor, and resides at 49 Hall Avenue #2, Watertown, MA 02472,2. PARTY DEFENDANTS 2A. Upon information and belief, Defendant Thomas “Tom” E. Dillon Jr. is a current resident of the State of Tennessee. He is sued here for actions taken in Massachusetts while employed by Defendant Wynn MA, LLC. 2B. Upon information and belief, Defendant Robert “Bob” J. DeSalvio is the President of Encore Boston Harbor, located at 101 Station Landing, Suite 220, Medford, MA 02155. 2C. Upon information and belief, Defendant Gregory “Greg” Dauenhauer is the Chief Information Officer of Encore Boston Harbor, located at 101 Station Landing, Suite 220, Medford, MA 02155. 2D. Upon information and belief, Defendant Michael Carazza is the Director of Corporate Compliance and Investigations for Encore Boston Harbor, located at 101 Station Landing, Suite 220, Medford, MA 02155. 2B. Upon information and belief, Jacqui Krum is a Senior Vice President and Corporate Counsel of Encore Boston Harbor, located at 101 Station Landing, Suite 220, Medford, MA 02155 2F, Defendant Wynn MA, LLC is a Nevada corporation which has registered with the ‘Commonwealth of Massachusetts. Defendant Wynn MA, LLC, on information and belief, owns and operates Encore Boston Harbor, formerly and at all material times known as Wynn Boston Harbor, a luxury resort and casino that is currently under development, located at 1 Horizon Way, Everett, MA 02149. 2G. Defendant Wynn Resorts, Ltd, is a Nevada corporation which, upon information and belief, has an ownership interest in Encore Boston Harbor, located at 1 Horizon Way, 2Everett, MA 02149. 2H. Defendant Wynn Resorts Development, LLC is a Nevada corporation which, upon information and belief, has an ownership interest in Encore Boston Harbor, located at 1 Horizon Way, Everett, MA 02149. 3. In October of 2015, Wynn Boston Harbor hired Mary Jayne Brackett-Kelly to work in Administrative Support, performing administrative tasks for executive staff at Encore Boston Harbor, then and at all materials times known as Wynn Boston Harbor. 4. Ms. Brackett-Kelly’s direct supervisor throughout the duration of her employment at Wynn Boston Harbor was Defendant Bob DeSalvio, President of Wynn Boston Harbor. 5. For the first year, Ms, Brackett-Kelly’s employment with Wynn Boston Harbor was uneventful, but in December of 2016 Wynn brought on Defendant Tom Dillon as a Chief Information Officer, despite already having Defendant Greg Dauenhauer in this role, Defendant Dillon had previously worked for Wynn MA, LLC, Wynn Resorts Ltd., and/or Wynn Resorts Development, LLC (collectively, “the Wynn Defendants”) in their Macau resort location, 6. When Defendant Tom Dillon began work at Wynn Boston Harbor, Ms. Brackett-Kelly was his direct administrative support. She worked with Defendant Tom Dillon in this role until April of 2017, 7. Ms. Brackett-Kelly recalls that right from the beginning, working with Defendant Tom Dillon was uncomfortable, and says that “he was always too friendly” with her, 8. On her first day working with Defendant Tom Dillon, he asked her (o breakfast with him at the AC Hotel, located across the street from their offices. Ms. Brackett-Kelly declined, 3