deepundercover
09-28-2004, 11:08 PM
www.lukeisback.com
Case No. BC318102
Attorney K. Arianne Jordan
First Amended Complaint For Damages
1. Sexual harassment
2. Retaliation
This is a classic case of quid pro quo sexual harassment in which Scott Taylor, the President of several adult entertainment companies, pursued and became obsessed with a salacious sexual relationship with his 18 year old employee, Deena DeRosa. Despite the fact that Ms. DeRosa was him employee and more than 20 years his junior, Mr. Taylor used his power and position as President of the Defendant Companies to entice her into a lurid sexual relationship in which Mr. Taylor demanded that Ms. DeRosa make herself available for sexual trysts at all times convenient for him, notwithstanding the effect that this would have on Ms. DeRosa's ability to perform her job duties. When the sexual relationship between Ms. DeRosa and Mr. Taylor ended, the Defendants retaliated against her by demoting her from Vice President of Sales to data processing assistant, a position that paid substantially less, with the goal of forcing her to resign from the Defendant's employ. In addition to this treatment, Ms. DeRosa was forced to work in an environment pervaded by sexual hostility towards women including...offensive behavior and comments. The unfair and illegal treatment that Ms. DeRosa was subjected to by the Defendants has caused her substantial psychological and economic damages.
[Deena DeRosa] began her employment on September 25, 2000.
11. Ms. DeRosa was initially employed as an assistant to Leilani Whitney, the managing director of the companies. Thereafter, due to her exemplary performance, she was promoted to Vice President of Sales in or about March 2001.
12. Beginning in or about January 2001, Defendant Taylor initiated and pursued an obsessive intimate relationship with Ms. DeRosa. The relationship lasted approximately two years. Defendant Taylor's affair with Ms. DeRosa included unannounced visits to her apartment very late at night during the work week. Defendant Taylor initited sexual liasons in his office before work, during work hours, and on weekends. Defendant Taylor took Ms. DeRosa to numerous locations to have sex including, but not limited to, a Hyatt hotel at a "Park-n-Ride" location in Porter Ranch and in a parking lot at Chatsworth Park. Defendant Taylor bought Ms. DeRosa expensive jewelry and other gifts and contributed monthly payments for her apartment. Defendant Taylor communicated with Ms. DeRosa during the work day by instant messaging her and by calling her into his office whenever he desired. These communications and visits to Defendant Taylor's office decreased Ms. DeRosa's ability to generate telephone sales, which was her primary function as Vice President of Sales.
13. Defendant Taylor spied on Ms. DeRosa in order to know what she was doing at all times when he was not with her. He demanded that employees of Defendant Companies report to him regarding their knowledge of Ms. DeRosa's personal life. As a result of Defendant Taylor's actions, Ms. DeRosa was worried and concerned that if she did not participate in the relationship, that her job as well as that of her mother (who also worked for the Defendant), would be placed jeopardy.
14. The intimate relationship between Defendant Taylor and Ms. DeRosa ended in or about March or April 2003. Defendant Taylor's wife discovered their relationship and demnaded that Defendant Taylor end it. Defendant Taylor's wife also demanded that he fire Ms. DeRosa as soon as possible.
Case No. BC318102
Attorney K. Arianne Jordan
First Amended Complaint For Damages
1. Sexual harassment
2. Retaliation
This is a classic case of quid pro quo sexual harassment in which Scott Taylor, the President of several adult entertainment companies, pursued and became obsessed with a salacious sexual relationship with his 18 year old employee, Deena DeRosa. Despite the fact that Ms. DeRosa was him employee and more than 20 years his junior, Mr. Taylor used his power and position as President of the Defendant Companies to entice her into a lurid sexual relationship in which Mr. Taylor demanded that Ms. DeRosa make herself available for sexual trysts at all times convenient for him, notwithstanding the effect that this would have on Ms. DeRosa's ability to perform her job duties. When the sexual relationship between Ms. DeRosa and Mr. Taylor ended, the Defendants retaliated against her by demoting her from Vice President of Sales to data processing assistant, a position that paid substantially less, with the goal of forcing her to resign from the Defendant's employ. In addition to this treatment, Ms. DeRosa was forced to work in an environment pervaded by sexual hostility towards women including...offensive behavior and comments. The unfair and illegal treatment that Ms. DeRosa was subjected to by the Defendants has caused her substantial psychological and economic damages.
[Deena DeRosa] began her employment on September 25, 2000.
11. Ms. DeRosa was initially employed as an assistant to Leilani Whitney, the managing director of the companies. Thereafter, due to her exemplary performance, she was promoted to Vice President of Sales in or about March 2001.
12. Beginning in or about January 2001, Defendant Taylor initiated and pursued an obsessive intimate relationship with Ms. DeRosa. The relationship lasted approximately two years. Defendant Taylor's affair with Ms. DeRosa included unannounced visits to her apartment very late at night during the work week. Defendant Taylor initited sexual liasons in his office before work, during work hours, and on weekends. Defendant Taylor took Ms. DeRosa to numerous locations to have sex including, but not limited to, a Hyatt hotel at a "Park-n-Ride" location in Porter Ranch and in a parking lot at Chatsworth Park. Defendant Taylor bought Ms. DeRosa expensive jewelry and other gifts and contributed monthly payments for her apartment. Defendant Taylor communicated with Ms. DeRosa during the work day by instant messaging her and by calling her into his office whenever he desired. These communications and visits to Defendant Taylor's office decreased Ms. DeRosa's ability to generate telephone sales, which was her primary function as Vice President of Sales.
13. Defendant Taylor spied on Ms. DeRosa in order to know what she was doing at all times when he was not with her. He demanded that employees of Defendant Companies report to him regarding their knowledge of Ms. DeRosa's personal life. As a result of Defendant Taylor's actions, Ms. DeRosa was worried and concerned that if she did not participate in the relationship, that her job as well as that of her mother (who also worked for the Defendant), would be placed jeopardy.
14. The intimate relationship between Defendant Taylor and Ms. DeRosa ended in or about March or April 2003. Defendant Taylor's wife discovered their relationship and demnaded that Defendant Taylor end it. Defendant Taylor's wife also demanded that he fire Ms. DeRosa as soon as possible.