1 

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:20-CV-22995-KMW

SILVA HARAPETI, 

 Plaintiff, 

v. 

CBS TELEVISION STATIONS, INC., 

a Foreign Profit Corporation, et al.

Defendant. 

 ________________________________________/ 

THIRD AMENDED COMPLAINT

Plaintiff, SILVA HARAPETI (hereinafter “Plaintiff”), by and through the undersigned 

counsel, hereby sues Defendant, CBS TELEVISION STATIONS, INC., CBS BROADCASTING,

INC. and CBS CORPORATION (hereinafter “Defendants”), and in support avers as follows:

GENERAL ALLEGATIONS

1. This is an action by the Plaintiff for damages due to Defendant’s violation of the Equal Pay

Act 1936, 29 U.S.C. § 206, et seq. (“EPA”); for Defendant’s unlawful discrimination and

retaliation predicated on Plaintiff’s sex (gender) and age in violation of Title VII of the

Civil Rights Act of 1964 as amended (“Title VII”) the Age Discrimination in Employment

Act (“ADEA”) the Florida Civil Rights Act of 1992, Florida Statutes, Chapter 760, et seq.

("FCRA") and for intentional and negligent infliction of emotional distress.

2. This court has jurisdiction over Plaintiff’s ADEA, EPA, Title VII and FCRA and infliction

of emotional distress claims.

3. Plaintiff was at all times relevant to this action a resident of Miami Dade County, Florida,

within the jurisdiction of this Honorable Court.

4. Plaintiff is over the age of eighteen years old and otherwise suris juris.

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5. Defendants CBS Broadcasting, Inc., CBS Television Stations, Inc. and CBS Corporation

all conducted business in Miami-Dade County, Florida, where Plaintiff worked for

Defendants, all of whom jointly employed Plaintiff.

6. Defendants CBS Television Stations, Inc. an “employer” pursuant to the ADEA 29 U.S.C.

§§ 630(b) since it employs twenty (20) or more employees for the applicable statutory

period.

7. At all times material hereto, Plaintiff was an “employee” within the meaning of Title VII

and the ADEA, in that she was subjected to negative, disparate treatment and retaliation

by her employer based on her age, and sex (gender) and/or her complaints of

discrimination.

8. Defendant, CBS Television Stations, Inc., is a “person” and/or an “employer” pursuant to

Florida Civil Rights Act of 1992, Fla. Stat. Section 760.01, et seq. since it employs fifteen

or more employees for the applicable statutory period; and it is subject to the employment

discrimination provisions of the applicable statute, the FCRA.

9. At all times material hereto, Plaintiff was an “employee” within the meaning of Florida

Civil Rights Act of 1992, Fla Stat. Section 760, et seq. and it is subject to the employment

discrimination provisions of the applicable statutes.

10. Venue is proper in Miami-Dade County, Florida, because all of the actions that form the

basis of this complaint occurred within Miami-Dade County, Florida.

11. On January 9, 2019 Plaintiff filed a charge of employment discrimination with the Equal

Employment Opportunity Commission (“EEOC”) (EEOC Charge No.:511-2019-02980).

which was dually filed with the Florida Commission on Human Relations.

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12. At the time of the filing of Plaintiff’s Charge of Discrimination, the Equal Employment

Opportunity Commission was subject to the lapse in appropriations that occurred from

December 22, 2018 to January 26, 2019, which required the EEOC to shut down most

operations and services. Because the government shutdown was beyond the Plaintiff’s

control, the EEOC tolled the filing deadline for Plaintiff’s Charge as it did for all Charges

of Discrimination during the government shutdown. For any documentation or responses

due to the EEOC between December 22, 2018 and January 28, 2019, the EEOC extended

the submission deadline to February 12, 2019. This extension applied to both Respondents

and Charging Parties. Ultimately, instead of dismissing the Charge of Discrimination as

untimely, the EEOC equitably tolled the filing deadline by accepting Plaintiff’s Charge of

Discrimination and assigning her Charge to an investigator for processing.

13. The Florida Commission on Human Relations did not issue a finding on Plaintiff’s charge

within 180 days of the filing of said charge.

14. On or about February 25th, 2020, the EEOC issued a Notice of Determination from the

EEOC which was not mailed until February 26, 2020 and Plaintiff timely instituted suit by

filing this action.

15. Declaratory, injunctive, legal and equitable relief sought pursuant to the laws set forth

above together with attorneys’ fees, costs and damages.

16. All conditions precedent for the filing of this action before this Court have been previously

met, including the exhaustion of all pertinent administrative procedures and remedies.

17. Defendant directly or indirectly acted in the interest of an employer towards Plaintiff and

other similarly situated employees at all material times, including without limitation

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directly or indirectly controlling the terms of employment of Plaintiff and other similarly 

situated employees. 

FACTUAL ALLEGATIONS COMMON TO ALL COUNTS

18. Plaintiff began working for Defendant on or about February 21, 2011 as a freelance reporter,

and worked for Defendant on and off, with the same title, until on or about March 18, 2018.

19. Throughout her time working for Defendant as a freelance reporter, Plaintiff was paid on a

per-diem (per day) basis.

20. Plaintiff was hired as a freelance reporter in 2011, 2012, and 2015. Each time Plaintiff was

hired, Defendant assured her that she would be considered for a full-time reporter position

when an opening became available.

21. With this in mind, Plaintiff continued working as a freelance reporter with the hopes that

she would be hired full-time, with a contract, salary, and benefits when an opening became

available.

22. However, throughout her seven years working for Defendant, various opportunities for fulltime positions became available, yet Plaintiff was never offered a position.

23. This is due to Defendant’s systematic practice of giving full-time employment contracts,

top news story assignments, and increased salaries to both males and younger female

employees.

24. Plaintiff’s claims arise out of the investigation of her Charge of Discrimination and the

Defendant’s Position Statement.

25. The storied history of Defendant’s discrimination against Plaintiff provides a convincing

mosaic of a pattern of Defendant’s discrimination and hostility by denying Plaintiff

opportunities for advancement and subjecting Plaintiff to a hostile work environment by

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forcing Plaintiff to work on dangerous assignments where she was assaulted and physically 

impacted by onlookers for her field assignments as a per diem on air news reporter. 

26. On multiple occasions, Plaintiff complained to Defendant that she was being treated

unfairly compared to her other male and younger female colleagues.

27. Throughout Plaintiff’s time working for Defendant, she was continually passed over for

full-time reporter positions.

28. Despite Defendant’s assurances that she would be considered for the position when an

opening became available, when a position did become available, it was continually given

to younger female employees with less experience than Plaintiff.

29. Ms. Harapeti’s history of her employment with Defendant begins on or about April 2011.

After working for Defendant for several months, a full-time reporter position became

available. Plaintiff inquired about the position on multiple occasions, yet the position was

given to a younger, less experienced female, Kara Kostanich.

30. Following this, on or about June 2011, another full-time position became available and

Plaintiff again inquired about the position on multiple occasions. Defendant, yet again,

chose a younger, less experienced female, Maggie Newland.

31. The following year, in April 2012, another full-time position became available and Plaintiff

again inquired about the position on multiple occasions. Once again, Defendant hired a

younger, less experienced female, Summer Knowles.

32. That same year, another full-time position became available and Plaintiff again inquired

about the position on multiple occasions. Defendant chose a younger, less experienced

female, Lauren Pastrana.

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33. Three years later, in 2015, after a month before being told by Vice President of News, Liz

Roldan (“Ms. Roldan”), and Executive Producer, Cari Hernandez (“Ms. Hernandez”) that

no full-time positions were available, Defendant hired Oralia Ortega. Ms. Ortega is a

younger, less experienced female and was hired full-time with a contract and benefits.

34. Additionally, male employees were given more resources and greater choice of story

selection, along with other income opportunities.

35. Plaintiff was continuously denied any other income opportunities by Defendant, despite

being classified as a freelance reporter, which in theory would allow her to maintain her

own personal business while working for Defendant.

36. When Plaintiff was asked to work in the Special Projects Unit, normally a full-time

position, she was told she would still be classified as a freelancer, because the full-time onair position was not available. The position offered to her was significantly lower than the

positions of her male and younger female peers.

37. However, as a freelancer, this would have allowed Plaintiff to continue to run her personal

marketing, education, and production business which was helping her financially due to

her per-diem pay status with Defendant.

38. Another male employee who worked in the Special Projects Unit, Mr. Sutta, who had a

full-time position with Defendant, was allowed to run his own personal photography

company, while simultaneously working for Defendant.

39. In February of 2016, Plaintiff took time off to manage an emergency matter for one of her

education clients. After following company procedures and protocol, upon her return

Plaintiff was told by Ms. Hernandez and Ms. Roldan that she in fact could not have her

own personal business and work for Defendant as a freelancer simultaneously.

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40. Thereafter, Plaintiff, Ms. Hernandez, and Nick Bourne (“Mr. Bourne”) Assistant Vice

President of News, had a meeting in which Ms. Hernandez threatened to fire Plaintiff, and

stated that the company was “questioning her loyalty.”

41. Plaintiff pointed out that she was a freelancer and was entitled to have her own side

business and also pointed out that male employees were never questioned regarding their

own side businesses.

42. Through Defendant’s intimidation and threats of termination, Plaintiff was forced to scale

back her business, significantly reducing the number of her clients.

43. At no point however was Mr. Sutta, Plaintiff’s male colleague who worked in the same

division, questioned or harassed regarding his own personal photography business.

44. After the meeting, Mr. Bourne escalated this issue to Human Resources, as he felt that what

Ms. Hernandez and Ms. Roldan were doing was against company policy. Yet, despite

escalating the issue, no corrective action was ever taken by Defendant.

45. In November of 2016, Defendant hired Tiani Jones (“Ms. Jones”) as a freelance reporter.

Ms. Jones, a younger female, was paid significantly more than Plaintiff was being paid as

a freelance reporter.

46. To make matters worse, when Defendant moved Plaintiff to Ms. Jones position, the primetime evening shift, Ms. Roldan denied Plaintiff’s request to have her pay increased to what

Ms. Jones was making. Ms. Roldan stated, “that money isn’t available to you.”

47. Defendants went so far as to having a meeting with Plaintiff on or about May 2017 just to

tell her not to report issues she was having at work to Human Resources, the General

Manager, or to any of her superiors.

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48. The following month, on or about June 2017, Plaintiff had inquired about a full-time

position and was told by Ms. Roldan that there were none. Plaintiff then told Ms. Roldan

that she was applying for a full-time special projects position in Los Angeles with KNBC.

Ms. Roldan happened to know the manager there, Matt Goldberg (“Mr. Goldberg”), and

was scheduled to have lunch with him that month.

49. After Plaintiff applied for the position at KNBC, and emailed Mr. Goldberg to setup a call,

Plaintiff never heard back from Mr. Goldberg, nor did he respond to any of her follow up

emails. Upon information and belief, Plaintiff was told that Ms. Roldan said Plaintiff was

not going to be qualified for the position for which she was applying.

50. This was just one example of the many ways that Ms. Roldan and Ms. Hernandez

continually intimidated Plaintiff and retaliated against her for voicing complaints to

management, despite Plaintiff being a so-called “per-diem” employee.

51. In fact, when Plaintiff attempted to address issues of discrimination and disparate

treatment, Ms. Hernandez told Plaintiff “not to rock the boat” because Ms. Roldan had

“given her an opportunity to be on the air.”

52. In July of 2017, a month after Plaintiff was told that there was no budget for an increase

in her pay, Defendant hired Rielle Creighton (“Ms. Creighton”) as a freelance reporter.

Ms. Creighton, a younger female, was paid significantly more than Plaintiff was, despite

having the same exact position.

53. The following year, on or about January 2018, Defendant hired Amber Diaz (“Ms. Diaz”)

as a freelance reporter. Ms. Diaz, a younger female, was paid $33,000.00 more than

Plaintiff.

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54. The above facts show a pattern in which Defendant discriminated against Plaintiff based

on her age by continually choosing younger females, with far less experience, for full-time

positions.

55. Further, even when Defendant hired younger female reporters as freelancers, it paid these

younger females considerably more than Plaintiff.

56. Defendant tolerated and cultivated a work environment that discriminated against female

freelance employees.

57. Plaintiff, and other female freelance employees, were subjected to unlawful disparate

treatment, in that female freelance employees got paid at a lower rate than their male

counterparts for equal work.

58. Throughout Plaintiff’s employment, Defendant has consistently hired men at considerably

higher rates than women, such that the salary structure has resulted in a substantial disparity

between male and female employees. Specifically, a disparity exists between female

freelance employees and their equal male counterparts.

59. Male freelance employees in Plaintiff’s team performed the same and/or similar duties as

Plaintiff, including sourcing and gathering information on local and national news

coverage, posting on social media regarding the stories they covered, answering emails and

phone calls, and frequently working in the field reporting stories assigned to them.

60. Male freelance workers performed the same and/or similar work under the same and/or

similar working conditions as female freelance reporters, had the same and/or similar

responsibilities, and used the same and/or similar system and equivalent equipment to

perform their duties.

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61. Throughout Plaintiff’s employment, Defendant paid male freelance employees at a higher

rate than Plaintiff; the increased pay that Plaintiff’s male counterparts received was not

based on superior skills, effort, responsibility, or any other legitimate factor.

62. Plaintiff was compensated at a lower pay rate than her equal male counterparts who

performed the same and/or similar duties under substantially similar conditions.

63. Specifically, Plaintiff was paid at a lower rate than her team members, who were similarly

situated, including but not limited to, Hank Tester (“Mr. Tester”), David Sutta (“Mr.

Sutta”), Ted Scouten “Mr. Scouten”), and Cary Codd (“Mr. Codd”).

64. Another example of the disparate treatment Plaintiff was subjected to was Defendant

paying another male per-diem employee, Mr. Tester, at a higher rate than Plaintiff, despite

both performing substantially similar work that required the same skill, effort, and

responsibility.

65. During Hurricane Irma, Plaintiff was working on Miami Beach covering the storm with

another male per-diem employee, Mr. Mends. Plaintiff later found out through Mr. Mends

that his pay during that time was structured in a way that he received both overtime and

double-time.

66. Plaintiff and Mr. Mends worked the same shifts, the same hours, and delivered the same

news. Yet Plaintiff was paid significantly less because she was a female freelance

employee.

67. Plaintiff also voiced her complaints to management about them continually placing

employees, specifically reporters, in dangerous situations without any care for their safety

nor did they care to listen to employees who had experienced verbal and physical assaults

which physically impacted reporters while working.

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68. On numerous occasions while working in the field, Plaintiff was assaulted, both verbally

and physically, by individuals whom would physically impact her in the area she was

placed to cover.

69. Specifically, on September 9, 2017 while covering Hurricane Irma, Plaintiff was harassed

and groped by an individual. Plaintiff reported the harassment to Ms. Roldan, which

responded by telling Plaintiff to “not put any drunks on television.”

70. Following this incident, on or about November 11, 2017, Plaintiff was sent to cover the

University of Miami v. Notre Dame game at the Hard Rock Stadium where thousands of

fans had been drinking and tailgating for hours. Plaintiff was verbally, physically, and

sexually assaulted by a fan just minutes before her 11:00 p.m. report. Plaintiff’s Assistant

Manager, Abby Lewing (“Ms. Lewing”) had insisted that Plaintiff and her videographer

“report live” despite Plaintiff’s repeated protests about the dangerous conditions in which

they were being placed.

71. Ms. Lewing responded to Plaintiff’s concerns by saying “are you refusing to do your job?”

This left Plaintiff in a position where she feared she would lose her job, and ultimately

Plaintiff’s fears became reality.

72. Just one month later, on or about December 30th, 2017, Ms. Lewing sent Plaintiff to cover

another football game at the Orange Bowl. Plaintiff was scheduled to work in the same

area of the parking lot where she had previously been assaulted and physically impacted.

Plaintiff complained to Assistant Manager, Ms. Lewing that she did not feel safe working

there due to the lack of security and the prior incident which had occurred in the same

location.

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73. In January of 2018, Plaintiff reported to Vice President of News, Ms. Roldan, the two

incidents where she had been assaulted and Ms. Roldan callously responded, “this is not a

whining session.” She added, “The fact is that people are shitty people and we have to deal

with it. We all create our own perception and reality around what happens to us.”

74. Subsequent to this meeting, each time Plaintiff voiced her complaints, she was told that

these things “just happen to her,” insinuating that Plaintiff somehow invites this kind of

flagrant behavior.

75. Defendant failed to take any corrective action to Plaintiff’s complaints about harassment

and discrimination instead condoning and fostering an environment where sexual assault

and abusive behavior was not only acceptable, but it was the norm.

76. Defendant did not take any corrective action and instead chose to retaliate against Plaintiff

by continually passing her over for full-time positions, forcing her to significantly scale

back her business, giving her lesser pay than her peers, and assigning her the least desired

stories.

77. These three separate incidents and Defendants responses to each of them, show

Defendant’s negligent and reckless complacency with sexual harassment being a normal

part of a reporter’s job and also show that speaking up against harassment in the workplace

only causes one to be “blacklisted” and to be threatened.

78. An example of this was right after Plaintiff had addressed concerns of being assaulted at

work, she was placed on a story that had nothing to do with what all the other employees

were working on, the devastating Parkland High School mass shooting.

79. Any time Plaintiff tried to speak out, she was met with opposition, threats, and intimidation.

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80. Defendant’s actions and/or failures to act, began to impact Plaintiff’s mental and physical

health. She no longer could work in a toxic, misogynistic environment, in which no one

addressed her concerns for her safety.

81. As time went on, Defendant’s continued to intimidate and retaliate against Plaintiff for

voicing her complaints by failing to promote Plaintiff, subjecting her to a hostile work

environment through the end of her career with the Defendant.

82. Ultimately, after years of continuously being subjected to a hostile work environment and

continuously being passed over for full-time positions to younger female employees,

having male counterparts continuously given preferential treatment and higher pay, and

continuously enduring verbal and physical assaults while on the job with not a single

corrective action taken, and after Plaintiff continuously complained about all of this, on or

about March 16, 2018, Defendant constructively discharged Plaintiff.

COUNT I

Age Discrimination in Violation of the ADEA

83. Plaintiff re-adopts each and every general and factual allegation as stated in paragraphs 1

through 82 above as if set out in full herein.

84. Plaintiff is a member of a protected class under the ADEA, to wit Plaintiff is over forty

(40) years of age.

85. By the conduct described above, Defendant has engaged in discrimination against Plaintiff

because of Plaintiff’s age and subjected the Plaintiff to age-based animosity.

86. Such discrimination was based upon the Plaintiff’s age in that Plaintiff would not have

been the object of discrimination but for the fact that Plaintiff is over the age of forty (40).

87. Defendant’s conduct complained of herein was willful and in disregard of Plaintiff’s

protected rights. Defendant and its supervisory personnel were aware that discrimination

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on the basis of Plaintiff’s age was unlawful but acted in reckless disregard of the law. 

88. At all times material hereto, the employees exhibiting discriminatory conduct towards

Plaintiff possessed the authority to affect the terms, conditions, and privileges of Plaintiff’s

employment with the Defendant.

89. Defendant retained all employees who exhibited discriminatory conduct toward the

Plaintiff and did so despite the knowledge of said employees engaging in discriminatory

actions.

90. As a result of Defendant’s actions, as alleged herein, Plaintiff has been deprived of rights,

has been exposed to ridicule and embarrassment, and has suffered emotional distress and

damage.

91. The conduct of Defendant, by and through the conduct of its agents, employees, and/or

representatives, and the Defendant’s failure to make prompt remedial action to prevent

continued discrimination against the Plaintiff, deprived the Plaintiff of statutory rights

under federal law.

92. The actions of the Defendant and/or its agents were willful, wanton, and intentional, and

with malice or reckless indifference to the Plaintiff’s statutorily protected rights, thus

entitling Plaintiff to damages in the form of compensatory and punitive damages pursuant

to federal law, to punish the Defendant for its actions and to deter it, and others, from such

action in the future.

93. Plaintiff has suffered and will continue to suffer both irreparable injury and compensable

damages as a result of Defendant’s discriminatory practices unless and until this Honorable

Court grants relief.

WHEREFORE, Plaintiff respectfully prays for the following relief against Defendant: 

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A. Adjudge and decree that Defendant has violated the ADEA, and has done so willfully, 

intentionally, and with reckless disregard for Plaintiff’s rights; 

B. Enter a judgment requiring that Defendant pay Plaintiff appropriate back pay, benefits' 

adjustment, and prejudgment interest at amounts to be proved at trial for the unlawful 

employment practices described herein;

C. Require Defendant to reinstate Plaintiff to the position at the rate of pay and with the 

full benefits Plaintiff would have had Plaintiff not been discriminated against by 

Defendant, or in lieu of reinstatement, award front pay; 

D. Award Plaintiff the costs of this action, together with a reasonable attorneys' fees; and 

Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances.

COUNT II

Sex Discrimination in Violation of the Title VII

95. Plaintiff re-adopts each and every general and factual allegation as stated in paragraphs 1

through 82 above as if set out in full herein.

96. Plaintiff is a female individual and is a member of a protected class under Title VII.

97. By the conduct describe above, Defendant has engaged in discrimination against Plaintiff

because of Plaintiff’s sex/gender and subjected the Plaintiff to sex-based animosity.

98. Such discrimination was based upon the Plaintiff’s sex/gender in that Plaintiff would not

have been the object of discrimination but for the fact that Plaintiff is a female.

99. Defendant’s conduct complained of herein was willful and in disregard of Plaintiff’s

protected rights. Defendant and its supervisory personnel were aware that discrimination

on the basis of sex/gender was unlawful but acted in reckless disregard of the law.

100. At all times material hereto, the employees exhibiting discriminatory conduct towards 

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Plaintiff possessed the authority to affect the terms, conditions, and privileges of Plaintiff’s 

employment with the Defendant. 

101. Defendant retained all employees who exhibited discriminatory conduct toward the 

Plaintiff and did so despite the knowledge of said employees engaging in discriminatory 

actions.

102. As a result of Defendant’s actions, as alleged herein, Plaintiff has been deprived of rights, 

has been exposed to ridicule and embarrassment, and has suffered emotional distress and 

damage. 

103. The conduct of Defendant, by and through the conduct of its agents, employees, and/or 

representatives, and the Defendant’s failure to make prompt remedial action to prevent 

continued discrimination against the Plaintiff, deprived the Plaintiff of statutory rights 

under federal law. 

104. The actions of the Defendant and/or its agents were willful, wanton, and intentional, and 

with malice or reckless indifference to the Plaintiff’s statutorily protected rights, thus 

entitling Plaintiff to damages in the form of compensatory and punitive damages pursuant 

to federal law, to punish the Defendant for its actions and to deter it, and others, from such 

action in the future. 

105. Plaintiff has suffered and will continue to suffer both irreparable injury and compensable 

damages as a result of Defendant’s discriminatory practices unless and until this Honorable 

Court grants relief. 

WHEREFORE, Plaintiffs respectfully prays for the following relief against Defendant: 

A. Adjudge and decree that Defendant has violated Title VII, and has done so willfully, 

intentionally, and with reckless disregard for Plaintiff’s rights;

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B. Enter a judgment requiring that Defendant pay Plaintiff appropriate back pay, benefits' 

adjustment, and prejudgment interest at amounts to be proved at trial for the unlawful 

employment practices described herein;

C. Enter an award against Defendant and award Plaintiff compensatory damages for 

mental anguish, personal suffering, and loss of enjoyment of life; 

D. Require Defendant to reinstate Plaintiff to the position at the rate of pay and with the 

full benefits Plaintiff would have had Plaintiff not been discriminated against by 

Defendant, or in lieu of reinstatement, award front pay; 

E. Award Plaintiff the costs of this action, together with a reasonable attorneys’ fees; and 

F. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances.

G. Award any other compensation allowed by law including punitive damages, attorney’s 

fees and further demands a trial by jury on all issues so triable.

COUNT III

Discrimination in Compensation against CBS Television Stations, Inc.

Equal Pay Act of 1963, 29 U.S.C. §206 et seq. 

106. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1 through 82 

of this complaint as if set out in full herein.

107. This action is brought by Plaintiff and other similarly situated individuals to recover back

pay damages for Defendant’s violation, as well as an additional amount as liquidated 

damages equal to the amount of back pay awarded, costs, and reasonable attorney’s fees 

under the provisions of the EPA. 

108. Plaintiff belongs to a protected class; she is a female. 

109. This Court has jurisdiction over Plaintiff’s EPA claims pursuant to 29 U.S.C. §206 et seq.

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110. Counts for EPA violations may be brought and maintained as an opt-in collective action 

pursuant to 29 U.S.C. § 216(b), for all claims asserted by the EPA similarly situated 

plaintiffs who opt-in to this action because the claims of the Plaintiffs are similar to the 

claims of the EPA opt-in Class. 

111. Plaintiffs and the EPA opt-in Class (a) are similarly situated in that (b) they were subjected 

to Defendant’s common practice of sex-based discrimination in failing to compensate 

female freelance employees on par with their male counterparts. 

112. Plaintiff job function as a freelance per-diem employee were and are the of equal skill, 

effort, and responsibility as the job functions of Defendant’s male freelance per-diem 

employees and they were performed under the same or similar conditions. 

113. During all relevant periods, Plaintiff received wages lower that most if not all, of 

Defendant’s male freelance employees’ wages while performing the same or substantially 

more work than her male coworkers. 

114. Plaintiff was qualified for and entitled to wages equal to or higher than her male coworkers’ 

wages performing the equal and/or same or at times substantially more work than her male 

counterparts. 

115. Defendant violated the EPA in not paying Plaintiff and other similarly situated females on 

par with their male counterparts; Plaintiff is entitled to damages and equitable relief.

WHEREFORE, Plaintiff respectfully prays for the following relief against Defendant: 

A. Adjudge and decree that Defendant has violated the EPA and has done so willfully, 

intentionally, and with reckless disregard for Plaintiff’s rights. 

B. Award Plaintiff actual damages in the amount shown to be due, with interest; and 

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C. Award Plaintiff an equal amount in double damages/ liquidated damages; and 

D. Award Plaintiff the cost of this action, together with reasonable attorney’s fees; and 

E. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances. 

COUNT IV

Discrimination in Compensation against CBS Broadcasting Inc. 

Equal Pay Act of 1963, 29 U.S.C. §206 et seq. 

110. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1 through 82 

of this complaint as if set out in full herein.

111. This action is brought by Plaintiff and other similarly situated individuals to recover back 

pay damages for Defendant’s violation, as well as an additional amount as liquidated 

damages equal to the amount of back pay awarded, costs, and reasonable attorney’s fees 

under the provisions of the EPA. 

112. Plaintiff belongs to a protected class; she is a female. 

113. This Court has jurisdiction over Plaintiff’s EPA claims pursuant to 29 U.S.C. §206 et seq.

116. Counts for EPA violations may be brought and maintained as an opt-in collective action 

pursuant to 29 U.S.C. § 216(b), for all claims asserted by the EPA similarly situated 

plaintiffs who opt-in to this action because the claims of the Plaintiffs are similar to the 

claims of the EPA opt-in Class. 

117. Plaintiffs and the EPA opt-in Class (a) are similarly situated in that (b) they were subjected 

to Defendant’s common practice of sex-based discrimination in failing to compensate 

female freelance employees on par with their male counterparts. 

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118. Plaintiff job function as a freelance per-diem employee were and are the of equal skill, 

effort, and responsibility as the job functions of Defendant’s male freelance per-diem 

employees and they were performed under the same or similar conditions. 

119. During all relevant periods, Plaintiff received wages lower that most if not all, of 

Defendant’s male freelance employees’ wages while performing the same or substantially 

more work than her male coworkers. 

120. Plaintiff was qualified for and entitled to wages equal to or higher than her male coworkers’ 

wages performing the equal and/or same or at times substantially more work than her male 

counterparts. 

121. Defendant violated the EPA in not paying Plaintiff and other similarly situated females on 

par with their male counterparts; Plaintiff is entitled to damages and equitable relief.

WHEREFORE, Plaintiff respectfully prays for the following relief against Defendant: 

A. Adjudge and decree that Defendant has violated the EPA and has done so willfully, 

intentionally, and with reckless disregard for Plaintiff’s rights. 

B. Award Plaintiff actual damages in the amount shown to be due, with interest; and 

C. Award Plaintiff an equal amount in double damages/ liquidated damages; and 

D. Award Plaintiff the cost of this action, together with reasonable attorney’s fees; and

E. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances. 

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COUNT V 

Discrimination in Compensation against CBS Corporation 

Equal Pay Act of 1963, 29 U.S.C. §206 et seq. 

114. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1 through 82 

of this complaint as if set out in full herein.

115. This action is brought by Plaintiff and other similarly situated individuals to recover back 

pay damages for Defendant’s violation, as well as an additional amount as liquidated 

damages equal to the amount of back pay awarded, costs, and reasonable attorney’s fees 

under the provisions of the EPA. 

116. Plaintiff belongs to a protected class; she is a female. 

117. This Court has jurisdiction over Plaintiff’s EPA claims pursuant to 29 U.S.C. §206 et seq.

122. Counts for EPA violations may be brought and maintained as an opt-in collective action 

pursuant to 29 U.S.C. § 216(b), for all claims asserted by the EPA similarly situated 

plaintiffs who opt-in to this action because the claims of the Plaintiffs are similar to the 

claims of the EPA opt-in Class. 

123. Plaintiffs and the EPA opt-in Class (a) are similarly situated in that (b) they were subjected 

to Defendant’s common practice of sex-based discrimination in failing to compensate 

female freelance employees on par with their male counterparts. 

124. Plaintiff job function as a freelance per-diem employee were and are the of equal skill, 

effort, and responsibility as the job functions of Defendant’s male freelance per-diem 

employees and they were performed under the same or similar conditions. 

125. During all relevant periods, Plaintiff received wages lower that most if not all, of 

Defendant’s male freelance employees’ wages while performing the same or substantially 

more work than her male coworkers. 

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126. Plaintiff was qualified for and entitled to wages equal to or higher than her male coworkers’ 

wages performing the equal and/or same or at times substantially more work than her male 

counterparts. 

127. Defendant violated the EPA in not paying Plaintiff and other similarly situated females on 

par with their male counterparts; Plaintiff is entitled to damages and equitable relief.

WHEREFORE, Plaintiff respectfully prays for the following relief against Defendant:

A. Adjudge and decree that Defendant has violated the EPA and has done so willfully, 

intentionally, and with reckless disregard for Plaintiff’s rights. 

B. Award Plaintiff actual damages in the amount shown to be due, with interest; and

C. Award Plaintiff an equal amount in double damages/ liquidated damages; and 

D. Award Plaintiff the cost of this action, together with reasonable attorney’s fees; and 

E. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances. 

COUNT VI 

Retaliation in Violation of Title VII 

128. Plaintiff re-adopts each and every general and factual allegation as stated in 1 through 82 

of this complaint as if set out in full herein.

129. Plaintiff is a member of a protected class under Title VII, to wit she complained of 

discriminatory treatment. 

130. By the conduct describe above, Defendant retaliated against Plaintiff for exercising rights 

protected under the Title VII.

131. Defendant’s conduct complained of herein was willful and in disregard of Plaintiff’s 

protected rights. Defendant and its supervisory personnel were aware that discrimination 

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on the basis of Plaintiff’s sex or age was unlawful but acted in reckless disregard of the 

law. 

132. As a result of Defendant’s actions, as alleged herein, Plaintiff has been deprived of rights, 

has been exposed to ridicule and embarrassment, and has suffered emotional distress and 

damage. 

133. The conduct of Defendant, by and through the conduct of its agents, employees, and/or 

representatives, and the Defendant’s failure to make prompt remedial action to prevent 

continued discrimination against the Plaintiff, deprived the Plaintiff of statutory rights 

under federal law. 

134. The actions of the Defendant and/or its agents were willful, wanton, and intentional, and 

with malice or reckless indifference to the Plaintiff’s statutorily protected rights, thus 

entitling Plaintiff to damages in the form of compensatory and punitive damages pursuant 

to federal law, to punish the Defendant for its actions and to deter it, and others, from such 

action in the future. 

135. Plaintiff has suffered and will continue to suffer both irreparable injury and compensable 

damages as a result of Defendant’s discriminatory practices unless and until this Honorable 

Court grants relief. 

WHEREFORE, Plaintiffs respectfully prays for the following relief against Defendant: 

A. Adjudge and decree that Defendant has violated Title VII, and has done so willfully, 

intentionally, and with reckless disregard for Plaintiff’s rights; 

B. Enter a judgment requiring that Defendant pay Plaintiff appropriate back pay, 

benefits' adjustment, and prejudgment interest at amounts to be proved at trial for 

the unlawful employment practices described herein;

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C. Enter an award against Defendant and award Plaintiff compensatory damages for 

mental anguish, personal suffering, and loss of enjoyment of life; 

D. Require Defendant to reinstate Plaintiff to the position at the rate of pay and with 

the full benefits Plaintiff would have had Plaintiff not been discriminated against 

by Defendant, or in lieu of reinstatement, award front pay; 

E. Award Plaintiff the costs of this action, together with a reasonable attorneys’ fees; 

and

F. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances.

COUNT VII

Age Discrimination in Violation of the FCRA 

136. Plaintiff re-adopts each and every general and factual allegation as stated in paragraphs 1 

through 82 above as if set out in full herein. 

137. Plaintiff is a member of a protected class under the FCRA, to wit Plaintiff if over forty (40) 

years of age. 

138. By the conduct describe above, Defendant has engaged in discrimination against Plaintiff 

because of Plaintiff’s age and subjected the Plaintiff to age-based animosity. 

139. Such discrimination was based upon the Plaintiff’s age in that Plaintiff would not have been 

the object of discrimination but for the fact that Plaintiff is over the age of forty (40). 

140. Defendant’s conduct complained of herein was willful and in disregard of Plaintiff’s protected 

rights. Defendant and its supervisory personnel were aware that discrimination on the basis of 

Plaintiff’s age was unlawful but acted in reckless disregard of the law. 

141. At all times material hereto, the employees exhibiting discriminatory conduct towards Plaintiff 

possessed the authority to affect the terms, conditions, and privileges of Plaintiff’s employment 

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with the Defendant. 

142. Defendant retained all employees who exhibited discriminatory conduct toward the Plaintiff 

and did so despite the knowledge of said employees engaging in discriminatory actions. 

143. As a result of Defendant’s actions, as alleged herein, Plaintiff has been deprived of rights, has 

been exposed to ridicule and embarrassment, and has suffered emotional distress and damage. 

144. Defendant’s bases for the adverse conduct against Plaintiff, if any, are pretextual and 

illegitimate, asserted only to cloak the discriminatory nature of their conduct. 

145. The conduct of Defendant, by and through the conduct of its agents, employees, and/or 

representatives, and the Defendant’s failure to make prompt remedial action to prevent 

continued discrimination against the Plaintiff, deprived the Plaintiff of statutory rights under 

state and federal law. 

146. The actions of the Defendant and/or its agents were willful, wanton, and intentional, and with 

malice or reckless indifference to the Plaintiff’s statutorily protected rights, thus entitling 

Plaintiff to damages in the form of compensatory and punitive damages pursuant to federal 

law, to punish the Defendant for its actions and to deter it, and others, from such action in the 

future. 

147. Plaintiff has suffered and will continue to suffer both irreparable injury and compensable 

damages as a result of Defendant’s discriminatory practices unless and until this Honorable 

Court grants relief. 

WHEREFORE, Plaintiffs respectfully prays for the following relief against Defendant: 

A. Adjudge and decree that Defendant has violated the FCRA, and has done so willfully, 

intentionally, and with reckless disregard for Plaintiff’s rights; 

B. Enter a judgment requiring that Defendant pay Plaintiff appropriate back pay, benefits' 

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adjustment, and prejudgment interest at amounts to be proved at trial for the unlawful 

employment practices described herein;

C. Enter an award against Defendant and award Plaintiff compensatory damages for 

mental anguish, personal suffering, and loss of enjoyment of life; 

D. Require Defendant to reinstate Plaintiff to the position at the rate of pay and with the 

full benefits Plaintiff would have had Plaintiff not been discriminated against by 

Defendant, or in lieu of reinstatement, award front pay; 

E. Award Plaintiff the costs of this action, together with a reasonable attorneys' fees; and

F. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances.

COUNT VIII 

Sex Discrimination in Violation of the FCRA

148. Plaintiff re-adopts each and every general and factual allegation as stated in paragraphs 1 

through 82 above as if set out in full herein. 

149. Plaintiff is a female individual and is a member of a protected class under the FCRA. 

150. By the conduct describe above, Defendant has engaged in discrimination against Plaintiff 

because of Plaintiff’s sex/gender and subjected the Plaintiff to sex-based animosity. 

151. Such discrimination was based upon the Plaintiff’s sex/gender in that Plaintiff would not 

have been the object of discrimination but for the fact that Plaintiff is a female. 

152. Defendant’s conduct complained of herein was willful and in disregard of Plaintiff’s 

protected rights. Defendant and its supervisory personnel were aware that discrimination 

on the basis of sex/gender was unlawful but acted in reckless disregard of the law. 

153. At all times material hereto, the employees exhibiting discriminatory conduct towards 

Plaintiff possessed the authority to affect the terms, conditions, and privileges of Plaintiff’s 

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employment with the Defendant. 

154. Defendant retained all employees who exhibited discriminatory conduct toward the 

Plaintiff and did so despite the knowledge of said employees engaging in discriminatory 

actions.

155. As a result of Defendant’s actions, as alleged herein, Plaintiff has been deprived of rights, 

has been exposed to ridicule and embarrassment, and has suffered emotional distress and 

damage. 

156. The conduct of Defendant, by and through the conduct of its agents, employees, and/or 

representatives, and the Defendant’s failure to make prompt remedial action to prevent 

continued discrimination against the Plaintiff, deprived the Plaintiff of statutory rights 

under federal law. 

157. The actions of the Defendant and/or its agents were willful, wanton, and intentional, and 

with malice or reckless indifference to the Plaintiff’s statutorily protected rights, thus 

entitling Plaintiff to damages in the form of compensatory and punitive damages pursuant 

to federal law, to punish the Defendant for its actions and to deter it, and others, from such 

action in the future. 

158. Plaintiff has suffered and will continue to suffer both irreparable injury and compensable 

damages as a result of Defendant’s discriminatory practices unless and until this Honorable 

Court grants relief. 

WHEREFORE, Plaintiffs respectfully prays for the following relief against Defendant: 

A. Adjudge and decree that Defendant has violated the FCRA, and has done so willfully, 

intentionally, and with reckless disregard for Plaintiff’s rights; 

B. Enter a judgment requiring that Defendant pay Plaintiff appropriate back pay, benefits' 

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adjustment, and prejudgment interest at amounts to be proved at trial for the unlawful 

employment practices described herein;

C. Enter an award against Defendant and award Plaintiff compensatory damages for mental 

anguish, personal suffering, and loss of enjoyment of life; 

D. Require Defendant to reinstate Plaintiff to the position at the rate of pay and with the full 

benefits Plaintiff would have had Plaintiff not been discriminated against by Defendant, or 

in lieu of reinstatement, award front pay; 

E. Award Plaintiff the costs of this action, together with a reasonable attorneys’ fees; and 

F. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances.

COUNT IX

Retaliation in Violation of the FCRA 

159. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1 through 82 

of this complaint as if set out in full herein.

160. Plaintiff is a member of a protected class under the FCRA. 

161. By the conduct describe above, Defendant retaliated against Plaintiff for exercising rights 

protected under the FCRA. 

162. Defendant’s conduct complained of herein was willful and in disregard of Plaintiff’s 

protected rights. Defendant and its supervisory personnel were aware that discrimination 

on the basis of Plaintiff’s sex or age was unlawful but acted in reckless disregard of the 

law. 

163. As a result of Defendant’s actions, as alleged herein, Plaintiff has been deprived of rights, 

has been exposed to ridicule and embarrassment, and has suffered emotional distress and 

damage. 

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164. The conduct of Defendant, by and through the conduct of its agents, employees, and/or 

representatives, and the Defendant’s failure to make prompt remedial action to prevent 

continued discrimination against the Plaintiff, deprived the Plaintiff of statutory rights 

under federal law. 

165. The actions of the Defendant and/or its agents were willful, wanton, and intentional, and 

with malice or reckless indifference to the Plaintiff’s statutorily protected rights, thus 

entitling Plaintiff to damages in the form of compensatory and punitive damages pursuant 

to federal law, to punish the Defendant for its actions and to deter it, and others, from such 

action in the future. 

166. Plaintiff has suffered and will continue to suffer both irreparable injury and compensable 

damages as a result of Defendant’s discriminatory practices unless and until this Honorable 

Court grants relief. 

WHEREFORE, Plaintiffs respectfully prays for the following relief against Defendant: 

A. Adjudge and decree that Defendant has violated the FCRA, and has done so willfully, 

intentionally, and with reckless disregard for Plaintiff’s rights; 

B. Enter a judgment requiring that Defendant pay Plaintiff appropriate back pay, benefits' 

adjustment, and prejudgment interest at amounts to be proved at trial for the unlawful 

employment practices described herein;

C. Enter an award against Defendant and award Plaintiff compensatory damages for mental 

anguish, personal suffering, and loss of enjoyment of life;

D. Require Defendant to reinstate Plaintiff to the position at the rate of pay and with the full 

benefits Plaintiff would have had Plaintiff not been discriminated against by Defendant, or 

in lieu of reinstatement, award front pay; 

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E. Award Plaintiff the costs of this action, together with a reasonable attorneys' fees; and

F. Grant Plaintiff such additional relief as the Court deems just and proper under the 

circumstances.

COUNT X

Intentional Infliction of Emotional Distress 

167. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1 through 82 

of this complaint as if set out in full herein.

168. During the time frame enumerated, Defendant deliberately and recklessly inflicted mental 

suffering on Plaintiff by and through intentional verbal and physical harassment and 

humiliation by forcing Plaintiff to report in unsafe areas where it was reasonably

foreseeable that Plaintiff would be physically assaulted. 

169. Defendant adopted a cavalier “suck it up, buttercup” attitude in the face of Plaintiff’s 

complaints about unsafe working conditions and insinuated Plaintiff was inviting physical 

attacks from onlookers. 

170. Defendant’s conduct is so outrageous in character, and so extreme in degree, that it is 

considered atrocious and utterly intolerable in a civilized society. 

171. Defendant’s conduct caused Plaintiff severe emotional distress.

172. As a direct and proximate result of Defendant’s conduct described above, Plaintiff suffered 

mental anguish, loss of capacity for the enjoyment of life, medical care and treatment, loss 

of earnings, loss of ability to earn money, and/or the aggravation of a previously existing 

condition. The losses are either permanent or continuing, and Plaintiff will suffer the losses 

in the future. 

WHEREFORE, the Plaintiff demands judgment for damages against Defendant and such other 

relief as this Court deems appropriate and just. 

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COUNT XI 

Negligent Infliction of Emotional Distress

173. Plaintiff re-adopts each and every factual allegation as stated in paragraphs 1 through 82 

of this complaint as if set out in full herein.

174. At all relevant times, Defendant owed Plaintiff a duty to act with reasonable care, and/or 

the injury to the Plaintiff was reasonably foreseeable.

175. At all relevant times, Defendant had the power, ability, authority and duty to stop the 

conduct described herein and to intervene to prevent or prohibit such conduct. 

176. At all relevant times, defendant knew or reasonably should have known, that the conduct 

described herein would and did proximately result in Plaintiff’s physical and emotional 

distress.

177. Despite said knowledge, power, and duty, Defendant negligently failed to stop the conduct 

described herein or to prevent or to prohibit such conduct or otherwise to protect Plaintiff, 

thereby breaching its duty to her. To the extent that said negligent conduct was perpetrated 

by third parties not under Defendant’s control, the Defendant confirmed and ratified said 

conduct with the knowledge that Plaintiff’s emotional and physical distress would thereby 

increase and with wanton and reckless disregard for the deleterious consequences to 

Plaintiff.

178. As a direct and legal result of Defendant’s wrongful act, Plaintiff has endured emotional

distress, increased anxiety in public places and depression associated with her condition. 

179. As a direct and legal result of Defendant’s wrongful acts, Plaintiff has suffered and will 

continue to suffer significant physical injury, pain, and suffering, and extreme and severe 

mental anguish and emotional distress. 

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180. Defendant’s conduct constitutes the negligent infliction of emotional distress and is 

actionable under the laws of the State of Florida. 

WHEREFORE, the Plaintiff demands judgment for damages against Defendant and such other 

relief as this Court deems appropriate and just. 

JURY DEMAND

Plaintiff demands trial by jury of all issues triable as of right by 

jury. Dated: October 20, 2020 

Respectfully submitted,

/s/ Peter M. Hoogerwoerd 

Peter M. Hoogerwoerd, Esq.

Fla. Bar No.: 0188239 

pmh@rgpattorneys.com 

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on October 20, 2020, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF. I also certify that the foregoing 

document is being served this day on all counsel of record either via transmission of Notices 

of Electronic Filing generated by CM/ECF or in some other authorized manner for those 

counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. 

/s/ Peter M. Hoogerwoerd 

Peter M Hoogerwoerd, Esq. 

Florida Bar No.: 0188239 

pmh@rgpattorneys.com

REMER & GEORGES-PIERRE, PLLC 

44 West Flagler Street, Suite 2200 

Miami, FL 33130 

Telephone: (305) 416-5000 

Facsimile: (305) 416-5005 

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