1 BRYAN J. FREEDMAN (SBN 151990) Email:
[email protected] 2 BENJAMIN A. MARSH (SBN 247913) Email:
[email protected] 3 FREEDMAN + TAITELMAN, LLP 1901 Avenue of the Stars, Suite 500 4 Los Angeles, California 90067 Telephone: 310-201-0005 5 Facsimile: 310-201-0045 6 Attorneys for Claimant Gabrielle Union 7 CALIFORNIA DEPARTMENT OF FAIR EMPLOYMENT AND HOUSING 8 9 GABRIELLE UNION, an individual; 10 Claimant, COMPLAINT 11 vs. 12 UNIVERSAL TELEVISION, LLC, a New 13 York limited liability company; FREMANTLE PRODUCTIONS NORTH 14 AMERICA, INC., a Delaware corporation; SYCO ENTERTAINMENT INC.; a Delaware 15 corporation; SIMON COWELL, an individual; and DOES 1 through 10, inclusive, 16 Respondents. 17 18 19 20 Deadline 21 22 23 24 25 26 27 28 COMPLAINT 1 Claimant Gabrielle Union (“Union” or “Claimant”) alleges causes of action against 2 Respondents Universal Television, LLC (“NBC”)1, Fremantle Productions North America, Inc., 3 (“Fremantle”), Syco Entertainment, Inc. (“Syco”), Simon Cowell (“Cowell”), and DOES 1 through 10 4 (hereinafter collectively referred to as “Respondents”) as follows: 5 INTRODUCTION 6 1. Union, an African American woman, was a judge on America’s Got Talent (“AGT”), 7 but, in what has become a widely publicized matter, was terminated from the Cowell-created show after 8 just one season. Sadly, what led to Union’s termination was her refusal to remain silent in the face of a 9 toxic culture at AGT that included racist jokes, racist performances, sexual orientation discrimination, 10 and excessive focus on female judges’ appearances, including race-related comments. Union raised 11 numerous complaints while working on AGT, including: 12 Cowell’s Smoking: On Union’s first day on AGT, she was forced to request that Cowell 13 smoke cigarettes outside in accordance with California law.