Lauren Johnson V Hearst Communications Inc. Summons Complaint
Lauren Johnson V Hearst Communications Inc. Summons Complaint
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Plaintiff,
SUMMONS
-against-
Defendant.
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You are hereby summoned and required to serve upon the plaintiff’s attorney an answer to
the complaint in this action within twenty (20) days after the service of this summons and
complaint, exclusive of the day of service, or within thirty (30) days after service is complete if this
summons and complaint are not personally delivered to you within the State of New York.
In case of your failure to answer, judgment will be taken against you by default for the relief
Venue is proper pursuant to CPLR § 503 in that New York County is the principal place of
business of defendant and the county in which defendant resides. In addition, many of the events
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By:
Jeremiah Iadevaia
Yannick A. Grant
Vladeck, Raskin & Clark P.C.
Attorneys for Plaintiff
565 Fifth Avenue, 9th Floor
New York, New York 10017
(212) 403-7300
To the defendant:
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Plaintiff,
COMPLAINT
-against-
Defendant.
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Plaintiff, Lauren Johnson (“Johnson” or “Plaintiff”), by her attorneys, Vladeck, Raskin &
Clark, P.C., complaining of Defendant, Hearst Communications, Inc. (“Hearst” or the “company”
NATURE OF CLAIMS
spent most of her professional career at Hearst, a well-known media conglomerate that owns
men’s magazine.
3. Johnson was excited to return to Hearst, a company where she had a long track
record of success. Johnson, however, found herself under the supervision of Jack Essig (“Essig”).
Essig did not hide his disdain for older workers and female employees and he regularly mocked them
openly. For instance, Essig ridiculed a Hearst employee for being “tired” and “old” and stressed that
the employee needed to “hang it up.” Essig similarly mocked the appearance of a female Hearst
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employee in her 60s whom Essig said was trying unsuccessfully “to look young” and should be
“mortified” given her age. Essig’s biased insults were part of his pattern of mistreatment of older
workers and female employees compared to their younger and male peers.
to protect employees who raise concerns about discriminatory conduct from retaliation, these
promises prove to be illusory in practice. After Johnson began raising concerns about Essig’s conduct,
Hearst gave her an ultimatum: accept a new position with a reduced salary and less-prestigious duties
or leave the company. Not wanting to lose her job, Johnson moved to the lower paying job.
Essig’s conduct is not out of the ordinary at the company. Indeed, recent stories in the New York
Times and other publications catalog allegations that several Hearst senior executives mistreated staff,
6. Johnson now brings this action to help remedy this biased and unlawful
conduct.
discrimination, and retaliation under the New York State Human Rights Law (the “NYSHRL”),
N.Y. Exec. Law § 290 et seq.; and the New York City Human Rights Law (the “NYCHRL”),
8. This Court has jurisdiction pursuant to N.Y. Const. art. VI, § 7(a) and N.Y.
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resides within New York County and a substantial part of the events giving rise to Plaintiff’s claims
served within ten days a copy of the Complaint on the City of New York Commission on Human
PARTIES
11. Johnson is a 52-year-old, female sales and advertising professional who has
worked in the industry—including extended stints at several Hearst publications—for nearly three
Hearst provides business information it can use to guide its planning, operations, and the
evaluation of its activities) company that has ownership interests in more than 300 businesses.
Hearst owns many well-known magazines, including ELLE, Esquire, Harper’s Bazaar, Marie
Claire, Men’s Health, O, The Oprah Magazine, and Seventeen, as well as other well-respected
periodicals, including the San Francisco Chronicle. In addition, Hearst has ownership interests in
several cable television networks, including A+E, Lifetime, and ESPN, and several non-media
13. Hearst is a corporation organized and incorporated under Delaware law that
14. At all times relevant to this action, Hearst was Johnson’s employer within the
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FACTUAL ALLEGATIONS
15. Johnson, who holds a Bachelor of Arts degree from the University of
California, Berkeley and a Master of Arts degree from the University of Southern California, is a
16. Johnson has devoted most of her professional career to Hearst. Before
returning to Hearst in or about December 2016 after a stint at The New Yorker, a Condé Nast
publication, Johnson held several senior positions within Hearst, including one at Cosmopolitan, an
17. Johnson also held senior corporate positions at Hearst, including serving as
Group Advertising Director of Hearst Integrated Media from February 2006 to August 2014 and
Group Advertising Director for Hearst Integrated and Digital Media from September 2015 to January
2016.
18. Over the course of her professional career, Johnson has worked for Hearst or
increasing responsibility.
20. After Johnson left Hearst to work as Advertising Director at The New Yorker,
accepted the position of Integrated Advertising Director at Esquire, a well-known and long-running
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23. In this role, Johnson reported to Essig, Senior Vice President, Publishing
Director, and Chief Revenue Officer of Hearst Men’s Group. The Men’s group oversaw the
25. Throughout Johnson’s time at Esquire, Essig made repeated biased and
inappropriate comments to Johnson about women and older Hearst employees, which demoralized
Johnson and conveyed to her that her age and gender were unacceptable to Essig.
26. For instance, Essig said of Johnson’s mentor who worked at Hearst at the
time, a man who was then in his late 50s or early 60s, that he looked “tired” and that he was “old”
27. Essig made similar comments about a female Hearst employee in her 60s.
Hearst announced that the female employee would be assuming advisory responsibilities in
addition to her duties at Good Housekeeping. In response to this announcement Essig said, in sum
and substance, that she was too old to keep working much less take on new responsibilities.
28. Essig said of another female Hearst employee in her late 60s that you cannot
“teach an old dog new tricks.” He mocked her for wearing a “faux ponytail” because he thought
she was trying, unsuccessfully in his assessment, to “look young[er].” Essig said that the female
Hearst employee should be “mortified” and that, in sum in substance, someone “her age” should
know better.
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29. Essig also frequently made biased and derisive comments about a male Hearst
employee’s older husband. Essig said of the Hearst employee’s husband, who was in late 50s and
approximately 20 years older than the Hearst employee, that although he worked out to stay in shape,
his physical appearance would ultimately deteriorate because of his age. Essig said that the Hearst
employee would be unhappy in his marriage when his husband showed his age and, therefore, the
employee should start dating other people or else end up stuck with an aging husband.
30. On information and belief, Essig made similar discriminatory comments about
Johnson to other Hearst employees. Also, on information and belief, other Hearst employees have
Essig treated Johnson and other female employees over 40 years old worse than their younger male
peers.
32. Essig humiliated Johnson in front of her coworkers on multiple occasions and
33. For instance, during a meeting on or about September 28, 2018, Essig
described Johnson’s team as “really fucking lazy” in front of Johnson’s younger male colleague, who
then headed Digital Marketing for Hearst Men’s Group. When Johnson challenged Essig’s
erroneous characterization, Essig was condescending and insulting. Despite treating Johnson
contemptuously, Essig was friendly towards, and joked with, Johnson’s younger male colleague.
34. In Johnson’s observations and on information and belief, Essig did not
similarly humiliate Johnson’s male colleagues by disparaging them directly and in the presence of
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others. Nor did Essig speak contemptuously to younger male colleagues who questioned him
during meetings.
36. Essig regularly excluded Johnson from meetings to which Johnson, based on
her senior role, would normally be invited to and during which Essig and other managers discussed
37. For example, in or around August 2018, shortly before the company forced
Johnson into a lesser position, Essig did not inform Johnson about a series of team meetings he
intentionally scheduled during Johnson’s absence. During those meetings, Essig and other employees
discussed information relevant to Johnson’s job. Neither Essig nor other senior employees advised
Johnson about what was discussed during those meetings after she returned from her absence.
38. Essig also regularly failed to tell Johnson when he would be away from the
office even though Essig’s absence required Johnson to assume some of his duties while he was out
of the office. Because Essig failed to inform Johnson of his absences, Johnson was not given an
opportunity to prepare in advance and, as a result, she encountered workflow issues and unexpected
managerial problems that Essig left for her to address without guidance.
younger and male colleagues to meetings during which Essig and other team members discussed
information pertinent and critical to their jobs. He also informed younger and male colleagues about
routinely ignored Johnson and failed to get back to her about time-sensitive issues, which further
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hampered Johnson’s ability to perform her job effectively. In Johnson’s observation and on
information and belief, Essig did not similarly ignore Johnson’s younger, male peers.
information and belief, Johnson’s predecessor, also a woman in her 50s, encountered a similar pattern
42. Also, on several occasions, Essig openly berated other women over 40. For
instance, between June and August 2018, Essig subjected two women in their 50s to verbal attacks
on separate occasions. In Johnson’s observations, Essig did not unleash similar outbursts toward
43. In addition, in his role, Essig was responsible for, inter alia, helping sales
employees to secure business for Hearst. Essig frequently ignored two female salespeople who
requested his assistance in obtaining business by, inter alia, cancelling meetings with them and
ignoring their emails. Whenever Essig did meet with them, he was, based on Johnson’s observations
and on information and belief, impatient, harsh, and unwilling to provide them with help.
regularly assisted younger and male employees who asked for Essig’s support in securing business,
was responsive to younger and male employees’ requests for help, and not dismissive or hostile
Johnson Complains About Essig and the Company Forces Her into a Diminished Role
45. Frustrated with Essig’s disparaging, humiliating, and biased treatment of her
and others, Johnson complained about Essig’s conduct, which was well known within the
organization. In addition, in or around November 2018, Johnson asked whether there were other
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46. Given the parallels between Essig’s treatment of her and her predecessor and
Essig’s treatment and comments about older employees and female employees, Johnson feared that
48. In 2017 and 2018, Johnson complained about Essig’s behavior to several
Hearst officials. Those executives told Johnson, in sum and substance, that she should not be
concerned because Essig could be on his way out in light of his reputation at Hearst. These assurances,
49. During a discussion between Johnson and Jeff Hamill (“Hamill”), Hearst’s
Executive Vice President and Chief Media Officer for Hearst Magazines, on or about November 2,
2018, Johnson began raising concerns about Essig’s biased and offensive behavior. Hamill, however,
cut off Johnson and made it clear he did not wish to hear her protected complaints.
50. Following the discussion with Hamill, in or around early November 2018,
Hearst informed Johnson that the company was offering her a position at Hearst Health, a division at
Hearst focused on sales, advertising, and marketing in the healthcare space. The position came with
a significant pay cut and narrower, less-important responsibilities than those Johnson had in her role
at Esquire.
51. When Johnson went to Todd Haskell (“Haskell”), Senior Vice President and
Chief Marketing Officer for Hearst Magazines, to raise concerns about the position the company
offered her, Haskell told Johnson bluntly, “If you don’t take this, you can’t stay.” Although the
company offered the job to Johnson in retribution for complaining about Essig, Johnson had no choice
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52. After coercing Johnson into the new diminished role, Hearst gave a younger
Human Resources, about the demotion. Miceli asked why Johnson opted to accept a job that paid
less and had narrower responsibilities. Johnson responded that she felt under duress. Miceli
stressed that Johnson needed to elaborate and tell Miceli the reasons for her decision. Fearful of
further retaliation, Johnson told Miceli that she was not comfortable sharing details then but that
she would do so in writing later when she was ready. Miceli was resistant and told Johnson that
she should not put her complaint in writing because, in sum and substance, Johnson should “avoid
hurting someone” at the company. Throughout the remainder of the conversation, Miceli stressed
on several occasions that Johnson should not reduce her complaints to writing. When Johnson
asked about certain bonuses due to her, Johnson was told that the decision was left to Sam Irwin,
54. Essig insisted that Johnson participate in several social events to save face and
counteract any negative perceptions in the company arising from her forced demotion. During two of
these events, both holiday parties in late 2018, Essig was physically aggressive toward Johnson.
During both parties, Essig cornered Johnson and made it difficult for her to move around and interact
Johnson Excels in Her New Role and Hearst Conducts a Farce Investigation
55. Even though the company had relegated Johnson to an inferior role and
provided her with little support, Johnson nevertheless excelled in her new position. Under Johnson’s
stewardship and consistent with Johnson’s prior strong performance at Hearst, Hearst Health sales
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and revenues grew substantially and eclipsed the company’s performance expectations for the
division.
56. Indeed, in late 2019, Johnson received significant praise within the company
for securing deals for calendar year 2020 that were set to exceed her 2020 performance benchmarks
57. Despite the success she was having in her diminished role, Johnson continued
to find her treatment and Essig’s continued leadership within the organization objectionable.
complaint to Hearst about Essig’s conduct, ignoring earlier admonitions from Hearst Human
59. After Johnson lodged her written complaint, Hearst informed Johnson that it
resigned from Hearst in the wake of multiple reports of misconduct, called Johnson to his office and
told Johnson that he would take care of her complaint and stated that others had complained about
Essig.
conducted a cursory investigation and did not review all relevant documents and other information
62. Not long after Johnson submitted her complaint, Hearst told Johnson that the
company had concluded that Essig had not engaged in discriminatory actions and gave Essig little
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more than a slap on the wrist. This outcome was not surprising given Hearst’s ongoing discrimination
and retaliation against Johnson and its efforts to cover up other biased conduct.
63. Curiously, despite purportedly finding that it was not unlawful activity,
Hearst, on information and belief, informally reprimanded Essig for his conduct. Essig, however,
remains in his senior role at Hearst and continues to supervise other Hearst employees.
64. Johnson tried to fix the discrimination she faced internally. Despite having
spent more than 20 years at Hearst, however, the company made clear repeatedly that it did not take
her concerns seriously and it would continue to protect the perpetrator of the discrimination.
Moreover, Johnson was worried about her future at the company given that she had complained that
senior executives and Human Resources employees had ignored her discrimination complaints and
65. This was not the first time Hearst had failed to address discrimination and
covered up the unlawful conduct of senior executives. As set forth in articles by the New York Times
and other publications, Hearst promoted Young to Magazines President in 2018 after at least four
employees had complained about Young’s harassment and inappropriate conduct to Human
66. Under the circumstances, after the company had ignored Johnson and
punished her for complaining, Johnson believed she had choice but to leave Hearst. Johnson
announced that she was leaving on January 6, 2020 and her last day of work at the company was
67. Plaintiff repeats and realleges each and every allegation contained in
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68. By the acts described above, Defendant discriminated against Plaintiff in the
terms and conditions of her employment based on her age in violation of the NYSHRL.
70. As a result of Defendant’s discriminatory acts, Plaintiff has suffered and will
continue to suffer irreparable injury, emotional distress, and other compensable damage unless and
71. Plaintiff repeats and realleges each and every allegation contained in
72. By the acts described above, Defendant discriminated against Plaintiff in the
terms and conditions of her employment and subjected Plaintiff to a hostile work environment on the
negligence, recklessness, and conscious disregard for Plaintiff’s statutorily protected rights under
the NYCHRL. Defendant’s conduct was reckless to the degree it demonstrated conscious disregard
74. As a result of Defendant’s discriminatory acts, Plaintiff has suffered and will
continue to suffer irreparable injury, emotional distress, and other compensable damage unless and
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75. Plaintiff repeats and realleges each and every allegation contained in
76. By the acts described above, Defendant discriminated against Plaintiff in the
terms and conditions of her employment based on her sex in violation of the NYSHRL.
78. As a result of Defendant’s discriminatory acts, Plaintiff has suffered and will
continue to suffer irreparable injury, emotional distress, and other compensable damage unless and
79. Plaintiff repeats and realleges each and every allegation contained in
80. By the acts described above, Defendant discriminated against Plaintiff in the
terms and conditions of her employment and subjected Plaintiff to a hostile work environment on the
negligence, recklessness, and conscious disregard for Plaintiff’s statutorily protected rights under
the NYCHRL. Defendant’s conduct was reckless to the degree it demonstrated conscious disregard
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82. As a result of Defendant’s discriminatory acts, Plaintiff has suffered and will
continue to suffer irreparable injury, emotional distress, and other compensable damage unless and
83. Plaintiff repeats and realleges each and every allegation contained in
84. By the acts described above, Defendant retaliated against Plaintiff for her
complaints about conduct that she reasonably believed was in violation of the NYSHRL.
86. As a result of Defendant’s retaliatory acts, Plaintiff has suffered and will
continue to suffer irreparable injury, emotional distress, and other compensable damage unless and
87. Plaintiff repeats and realleges each and every allegation contained in
88. By the acts described above, Defendant retaliated against Plaintiff for her
complaints about conduct that she reasonably believed was in violation of the NYCHRL.
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90. As a result of Defendant’s retaliatory acts, Plaintiff has suffered and will
continue to suffer irreparable injury, emotional distress, and other compensable damage unless and
(a) awarding Plaintiff damages to make her whole for all earnings and other
benefits she would have received but for Defendant’s discriminatory and retaliatory treatment,
including but not limited to wages, including back pay and front pay, bonuses, and other lost benefits;
distress, humiliation, pain and suffering, and injury to professional standing and reputation;
(d) awarding Plaintiff such interest as is allowed by law, and damages for any
(e) awarding Plaintiff the costs of this action, together with reasonable attorneys’
fees; and
(f) awarding such other and further relief as this Court deems necessary and
proper.
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By: _____________________________
Jeremiah Iadevaia
Yannick A. Grant
Vladeck, Raskin & Clark P.C.
Attorneys for Plaintiff
565 Fifth Avenue, 9th Floor
New York, New York 10017
(212) 403-7300
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