Lauren Johnson V Hearst Communications Inc. Summons Complaint

FILED: NEW YORK COUNTY CLERK 09/23/2020 01:04 PM INDEX NO.
157789/2020
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/23/2020
SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK
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LAUREN JOHNSON, Index. No.
Plaintiff,
SUMMONS
-against-
HEARST COMMUNICATIONS, INC.,
Defendant.
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TO THE ABOVE NAMED DEFENDANT:
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
demanded in the complaint.
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
giving rise to this action occurred in New York County.
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FILED: NEW YORK COUNTY CLERK 09/23/2020 01:04 PM INDEX NO. 157789/2020
Dated: New York, New York

September 23, 2020
VLADECK, RASKIN & CLARK, P.C.
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:
Hearst Communications, Inc.

300 West 57th Street
New York, NY 10019
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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -x
LAUREN JOHNSON, Index. No.
Plaintiff,
COMPLAINT
-against-
HEARST COMMUNICATIONS, INC.,
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”
or “Defendant”), alleges as follows:
NATURE OF CLAIMS
1. Johnson is a 52-year-old, female sales and advertising professional. Johnson
spent most of her professional career at Hearst, a well-known media conglomerate that owns
numerous respected and widely circulated publications.
2. Following a brief stint working for a competitor, in December 2016,
Johnson—in response to Hearst’s entreaties—accepted a role at Hearst for Esquire, a prominent
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.
4. Although Hearst professes to value diversity and maintains policies purporting
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.
5. Given Hearst’s response to Johnson’s concerns, it comes as no surprise that
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,
oversaw a toxic environment, and covered up and ignored a discriminatory culture.
6. Johnson now brings this action to help remedy this biased and unlawful
conduct.
7. Specifically, Johnson asserts claims for age discrimination, sex
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”),
Admin. Code of the City of New York § 8-107 et seq.
JURISDICTION AND VENUE
8. This Court has jurisdiction pursuant to N.Y. Const. art. VI, § 7(a) and N.Y.
Jud. Law § 140-b.
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9. Venue in the Court is proper pursuant to CPLR § 503(a), as defendant
resides within New York County and a substantial part of the events giving rise to Plaintiff’s claims
arose in New York County, where Plaintiff was employed.
10. Pursuant to Section 8-502(c) of the NYCHRL, plaintiff has caused to be
served within ten days a copy of the Complaint on the City of New York Commission on Human
Rights and the Corporation Counsel of the City of New York.
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
decades. Johnson is a citizen of and resides in New York.
12. Hearst is a multinational media and business information (meaning that
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
enterprises, including Fitch Group.
13. Hearst is a corporation organized and incorporated under Delaware law that
has a principal place of business in New York, New York.
14. At all times relevant to this action, Hearst was Johnson’s employer within the
meaning of the NYSHRL and the NYCHRL.
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FACTUAL ALLEGATIONS
Johnson’s Background and Her Return to Hearst
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
respected sales and advertising professional.
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
American monthly fashion and entertainment magazine for women.
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
Hearst-affiliated publications for more than two decades.
19. As reflected by her extended tenure at Hearst, Johnson regularly received
positive performance reviews, consistent salary increases, and promotions to positions of
increasing responsibility.
20. After Johnson left Hearst to work as Advertising Director at The New Yorker,
Hearst made significant efforts to persuade her to rejoin the company.
21. Those efforts ultimately succeeded. In or about December 2016, Johnson
accepted the position of Integrated Advertising Director at Esquire, a well-known and long-running
men’s magazine that Hearst publishes.
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Essig’s Biased Comments
22. Johnson worked as Esquire’s Integrated Advertising Director from on or
about December 12, 2016 to in or about November 2018.
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
advertising, sales, and marketing of Hearst’s portfolio of male-oriented publications, including
Esquire, Men's Health, Popular Mechanics, Runner’s World, and Bicycling.
24. Essig is a man in his mid-to-late 40s.
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”
and should “hang it up.”
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
complained about Essig’s discriminatory and abusive conduct.
Essig’s Disparate Treatment
31. Beyond Essig’s apparent comfort in frequently making biased comments,
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
spoke to Johnson more dismissively than her male colleagues.
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.
35. In addition to openly disparaging Johnson in a biased manner, Essig made it
difficult for Johnson to do her job.
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
important information concerning Johnson’s work.
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.
39. In Johnson’s observations and on information and belief, Essig invited
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
his planned absences.
40. Essig—as he had done to several other older female employees—also
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.
41. Essig’s biased treatment of Johnson was not surprising. Indeed, on
information and belief, Johnson’s predecessor, also a woman in her 50s, encountered a similar pattern
of biased treatment before Essig ultimately fired her.
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
male or younger employees.
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.
44. In contrast, in Johnson’s observations and on information and belief, Essig
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
toward younger and male employees.
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
opportunities at Hearst outside of Essig’s supervision available to her.
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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
Essig was pushing her out of the company.
47. Johnson’s complaints, however, proved to be her downfall.
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,
however, were subterfuge.
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
but to move to the lower paying, diminished role.
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52. After coercing Johnson into the new diminished role, Hearst gave a younger
man Johnson’s previous position at Esquire.
53. Johnson spoke to Janine Miceli (“Miceli”), Hearst’s Vice President of
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,
Essig’s second in command for the Hearst Men’s Group.
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
with other guests.
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
before the year even started.
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.
58. Accordingly, in or about September 2019, Johnson submitted a formal written
complaint to Hearst about Essig’s conduct, ignoring earlier admonitions from Hearst Human
Resources not to do so.
59. After Johnson lodged her written complaint, Hearst informed Johnson that it
would conduct an internal investigation.
60. Troy Young (“Young”), Hearst’s then-President of Magazines, who recently
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.
61. Consistent with Hearst’s earlier practices concerning Johnson’s complaints,
however, Hearst’s investigation proved to be window-dressing. On information and belief, Hearst
conducted a cursory investigation and did not review all relevant documents and other information
concerning Essig’s treatment of Johnson and other employees.
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
retaliated against her.
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
Resources and senior executives.
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
January 10, 2020.
FIRST CAUSE OF ACTION

(Discrimination Based on Age under the NYSHRL)
67. Plaintiff repeats and realleges each and every allegation contained in
paragraphs 1 through 66 of this Complaint as if set forth herein.
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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.
69. Defendant’s discriminatory conduct showed reckless disregard for
Plaintiff’s statutorily protected rights under 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
until this Court grants relief.
SECOND CAUSE OF ACTION

(Discrimination and Hostile Work Environment Based on Age under the NYCHRL)
terms and conditions of her employment and subjected Plaintiff to a hostile work environment on the
basis of her age in violation of the NYCHRL.
73. Defendant’s discriminatory conduct showed willful and/or wanton
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
for Plaintiff’s statutorily protected rights.
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THIRD CAUSE OF ACTION

(Discrimination Based on Sex under the NYSHRL)
terms and conditions of her employment based on her sex in violation of the NYSHRL.
77. Defendant’s discriminatory conduct showed reckless disregard for
Plaintiff’s statutorily protected rights under the NYSHRL.
FOURTH CAUSE OF ACTION

(Discrimination and Hostile Work Environment Based on Age under the NYCHRL)
terms and conditions of her employment and subjected Plaintiff to a hostile work environment on the
basis of her sex in violation of the NYCHRL.
81. Defendant’s discriminatory conduct showed willful and/or wanton
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
for Plaintiff’s statutorily protected rights.
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FIFTH CAUSE OF ACTION

(Retaliation under the NYSHRL)
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.
85. Defendant’s retaliatory conduct showed reckless disregard for Plaintiff’s
statutorily protected rights under the NYSHRL.
86. As a result of Defendant’s retaliatory acts, Plaintiff has suffered and will
SIXTH CAUSE OF ACTION

(Retaliation under the NYCHRL)
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.
89. Defendant’s retaliatory conduct showed reckless disregard for Plaintiff’s
statutorily protected rights under the NYCHRL.
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90. As a result of Defendant’s retaliatory acts, Plaintiff has suffered and will
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that this Court enter a Judgment:
(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;
(b) awarding Plaintiff compensatory damages, including damages for emotional
distress, humiliation, pain and suffering, and injury to professional standing and reputation;
(c) awarding Plaintiff punitive damages;
(d) awarding Plaintiff such interest as is allowed by law, and damages for any
adverse tax consequences stemming from an award;
(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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Dated: New York, New York

September 23, 2020
VLADECK, RASKIN & CLARK, P.C.
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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Lauren Johnson V Hearst Communications Inc. Summons Complaint

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Lauren Johnson V Hearst Communications Inc. Summons Complaint

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FILED: NEW YORK COUNTY CLERK 09/23/2020 01:04 PM INDEX NO.

SUPREME COURT OF THE STATE OF NEW YORK

LAUREN JOHNSON, Index. No.

HEARST COMMUNICATIONS, INC.,

TO THE ABOVE NAMED DEFENDANT:

demanded in the complaint.

giving rise to this action occurred in New York County.

Dated: New York, New York

VLADECK, RASKIN & CLARK, P.C.

Hearst Communications, Inc.

SUPREME COURT OF THE STATE OF NEW YORK

LAUREN JOHNSON, Index. No.

HEARST COMMUNICATIONS, INC.,

or “Defendant”), alleges as follows:

1. Johnson is a 52-year-old, female sales and advertising professional. Johnson

numerous respected and widely circulated publications.

2. Following a brief stint working for a competitor, in December 2016,

Johnson—in response to Hearst’s entreaties—accepted a role at Hearst for Esquire, a prominent

4. Although Hearst professes to value diversity and maintains policies purporting

5. Given Hearst’s response to Johnson’s concerns, it comes as no surprise that

oversaw a toxic environment, and covered up and ignored a discriminatory culture.

7. Specifically, Johnson asserts claims for age discrimination, sex

Admin. Code of the City of New York § 8-107 et seq.

JURISDICTION AND VENUE

Jud. Law § 140-b.

9. Venue in the Court is proper pursuant to CPLR § 503(a), as defendant

arose in New York County, where Plaintiff was employed.

10. Pursuant to Section 8-502(c) of the NYCHRL, plaintiff has caused to be

Rights and the Corporation Counsel of the City of New York.

decades. Johnson is a citizen of and resides in New York.

12. Hearst is a multinational media and business information (meaning that

enterprises, including Fitch Group.

has a principal place of business in New York, New York.

meaning of the NYSHRL and the NYCHRL.

Johnson’s Background and Her Return to Hearst

respected sales and advertising professional.

American monthly fashion and entertainment magazine for women.

Hearst-affiliated publications for more than two decades.

19. As reflected by her extended tenure at Hearst, Johnson regularly received

positive performance reviews, consistent salary increases, and promotions to positions of

Hearst made significant efforts to persuade her to rejoin the company.

21. Those efforts ultimately succeeded. In or about December 2016, Johnson

men’s magazine that Hearst publishes.

Essig’s Biased Comments

22. Johnson worked as Esquire’s Integrated Advertising Director from on or

about December 12, 2016 to in or about November 2018.

advertising, sales, and marketing of Hearst’s portfolio of male-oriented publications, including

Esquire, Men's Health, Popular Mechanics, Runner’s World, and Bicycling.

24. Essig is a man in his mid-to-late 40s.

and should “hang it up.”

complained about Essig’s discriminatory and abusive conduct.

Essig’s Disparate Treatment

31. Beyond Essig’s apparent comfort in frequently making biased comments,

spoke to Johnson more dismissively than her male colleagues.

35. In addition to openly disparaging Johnson in a biased manner, Essig made it

difficult for Johnson to do her job.

important information concerning Johnson’s work.

39. In Johnson’s observations and on information and belief, Essig invited

his planned absences.

40. Essig—as he had done to several other older female employees—also

41. Essig’s biased treatment of Johnson was not surprising. Indeed, on

of biased treatment before Essig ultimately fired her.