APR 7 Z015: Original Iiilj:D

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1 LOUIS R. MILLER (State Bar No. 54141)
smiller@millerbarondess.com
2 AMNON Z. SIEGEL (State Bar No. 234981)
asiegel@ millerbarondess.com
3 LAUREN R. WRIGHT (State Bar No. 280809)
lwright@ millerbarondess.com
4 MILLER BARONDESS, LLP
1999 A venue of the Stars, Suite 1000
5 Los Angeles, California 90067
Telephone:
(31 0) 552-4400
6 Facsimile:
(31 0) 552-8400
County OCI.OSAftt<ln
APR 27 Z015
Sherri A. Carter, Executive Officer/Clerk
By: Kristina Vargas, Deputy
7 Attorneys for Plaintiff Knoyme King
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10
11
CASE NO.
KNOYME KING, anindividual,
COMPLAINT FOR:
Plaintiff,
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(1) UNLAWFUL DISCRIMINATION ON

THE BASIS OF RACE;
v.
13
14 AT&T SERVICES, INC., a Delaware

corporation; AT&T, INC., a Delaware
15 corporation; RANDALL L. S'J;EPHENSON,
an individual; JOYCE ROCHE, an individual;
16 AARON SLATOR, an individual; JOHN
STANKEY, an individual; RYAN SMITH, an
17 individual; JEFF WEBER, an individual;
DANIEL YORK, an individual; and DOES 118 10, inclusive,
Defendants.
19
20
BC5797t:7
(2) UNLAWFUL HARASSMENT ON THE

BASIS OF RACE;
(3) UNLAWFUL DISCRIMINATION ON
THE BASIS OF AGE;
BASIS OF AGE;
BASIS OF SEX;
(6) UNLAWFUL RETALIATION;
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(7) AIDING AND ABETTING FEHA

VIOLATIONS;
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(8) FAILURE TO PREVENT

HARASSMENT, DISCRIMINATION,
AND RETALIATION;
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(9) INTENTIONAL INFLICTION OF

EMOTIONAL DISTRESS; AND
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26
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(10) NEGLIGENT INFLICTION OF

EMOTIONAL DISTRESS
28
DEMAND FOR JURY TRIAL

254439.5
COMPLAINT
Plaintiff Knoyme King ("King") alleges against Defendants AT&T Services, Inc., AT&T,
2 Inc. (together, "AT&T"), Randall L. Stephenson ("Stephenson"), Joyce Roche ("Roche"), Aaron
3 Slator ("Slator"), John Stankey ("Stankey"), Ryan Smith ("Smith"), Jeff Weber ("Weber"), Daniel
4
York ("York"), and Does 1 through 10, inclusive (collectively, "Defendants"), as follows:
INTRODUCTION
5
6
1.
Plaintiff Knoyme King, a 50-year-old African American woman, has worked at
AT&T for over 30 years. King has witnessed-and experienced- race and age discrimination and
harassment by senior AT&T executives (all of whom are White males).
2.
Defendant Aaron Slator is one of King' s bosses. Slator is a racist and is particularly
10 bigoted against African Americans. In furtherance of his racist acts, Slator exposed King and
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another African American subordinate to the racially derogatory and discriminatory images below
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(attached as Exhibits A & B hereto):
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254439.5
1
COMPLAINT
Exhibit A
Slator text messaged this image to a friend, calling it an "oldie but goodie."
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254439.5
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COMPLAINT
Exhibit B
This image was also found on Slator's work phone by an African American colleague.
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2544 39.5
3
COMPLAINT
3.
These images, put out by Slator who is the President of AT&T, are beyond
offensive. When Slator sent the picture of the African child via text message, he referred to it as
an "oldie but goodie." Slator transmitted these images on his work phone, evidencing deep-rooted
racial bigotry in his place of employment.
4.
These messages evoke the type of revolting racism that existed in this country
when slavery was abolished in 1865 . Whites objectified African Americans for ridicule, mockery
and sex; they called them the "N-word"; and viewed them as primitive and subhuman. This high-
ranking AT&T executive-Slator-condones the use of the "N-word." This attitude is consistent
with the demenor Slator portrays at the office and is reflected in his discriminatory employment
10
practices.
11
5.
As AT &T's President of Content and Advertising Sales, Slator has a powetful
12 influence over the television and entertainment industry. He is the head of AT&T's Television
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Division, U-Verse. He reports to Defendant Stephenson, the Chairman and Chief Executive
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Officer of the parent company, AT&T, Inc. He also has a close working relationship with
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Defendant Stankey, AT&T Inc.'s Chief Strategy Officer. Slator manages AT&T's multi-billion
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dollar budget for content acquisition, and he has final decision-making authority over what
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programming AT&T distributes to its 6 million subscribers on its U-Verse television platform. He
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also has the power to hire and fire employees.
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6.
Slator' s discriminatory animus is part of a course of conduct at AT&T that has
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been condoned, encouraged and ratified throughout the years by the highest levels at AT&T.
21
Indeed, AT&T Inc.'s board members and high-level executives-including Defendants
22
Stephenson, Roche, and Stankey-have known about Slator's racism and these appalling
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messages on his work phone for some time, but have done nothing about them. Instead of
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terminating Slator or otherwise properly dealing with his racist conduct, AT&T engaged in an
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illegal coverup. By covering for Slator, AT&T has facilitated and enabled his racism. AT&T
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Inc.'s know ledge, ratification and illegal scheme to cover up Slator' s racist practices ties the
27
parent company-and Defendants Stephenson, Roche and Stankey-into the racial discrimination
28
in this case.
254439.5
4
COMPLAINT
7.
Recently, in October 2014, King applied for a job opening to act as Slator's
2 executive assistant. King had performed the tasks of that role in the past. She was recommended
3 for the position by Slator's previous executive assistant. Nevertheless, Slator hired someone with
4
no experience to fill the role: He hired Susie Bercerra, a younger, non-African American
5 candidate who was having a romantic affair with Slator. The message was clear. Despite her
6 experience and recommendation, King was deemed unqualified for the job because of her race,
7
because of her age and because she was not engaging in a romantic relationship with her boss.
8.
8
9
King has been discriminated against in her compensation at AT&T. During her 30
years at AT&T, King received minimal pay raises. A lesser-experienced, white colleague in a
10 lower-level position than King received higher pay raises each year.
11
9.
No matter how hard she works or how well she performs her job, King was given
12 short shrift due to the color of her skin.

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During her 30 years of employment with AT&T-more than ten of which were
14 served under the individual Defendants named herein (AT&T President Slator and his
predecessors, Defendants Weber and York)- King has repeatedly been passed over for
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smaller raises as compared with non-African American colleagues; and is now being pushed out
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of the company under the guise of taking "early retirement."

11.
19
The hostile workplace under Slator is a continuation of his predecessors '-
20 Defendants Weber's and York's- abusive conduct as Presidents of AT&T. York, Weber and
21
Slator created a work environment in which King could never get ahead. For example,
22 Defendants York and Slator both made discriminatory comments that King could not go any
23
further at AT&T because she was "too old" and that it was "too late" for her. Under Weber,
24
advancement was based on who was engaging in sexual activities with him. Any career
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advancement opportunities were reserved for King's non-African American, younger co-workers,
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who were often engaging in romantic affairs with the boss.

12.
27
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King has complained about the discriminatory treatment she and other similarly-
situated employees faced at AT&T. But rather than address and remedy it, AT&T focused its
254439.5
5
COMPLAINT
1 efforts on an illegal cover-up. For example, when AT&T and its board members were made aware
2 of the racist images on Slator's company cell phone, AT&T's supposedly third party Equal
3 Employment Opportunity Consultant interviewed AT&T employees to determine whether anyone
4
other than Slator' s executive assistant had seen the images. AT&T wanted to ensure that it could
5 keep Slator' s racism under wraps. AT&T has allowed Slator to continue-unabated and
6 unchecked-in his position as President.
13.
King has endured years of discrimination at the hands of Defendants Slator, Weber
8 and York-conduct that was condoned and ratified by AT&T and its board members and high9 level executives, Defendants Stephenson, Roche, and Stankey.
14.
10
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recover damages for the harm and suffering she has incurred.
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King seeks to put an end to Slator' s and AT&T ' s ongoing discrimination, and to
PARTIES
15.
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Plaintiff King is, and at all times relevant to this Complaint was, a resident of the
14 County of Los Angeles in the State of California. King is, and at all times mentioned herein was,
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an employee of Defendant AT&T Services, Inc., located in Los Angeles, California.
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AT&T Services, Inc. and AT&T, Inc. are Delaware corporations with their
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17 principal places of business in Dallas, Texas. AT&T Services, Inc. also has an office and operates
18 in Los Angeles, California, where King is employed. AT&T, Inc. is the parent company of,
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among others, AT&T Services, Inc., which reports directly to AT&T, Inc. AT&T, Inc. is headed
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up by a Board of Directors, which is responsible for establishing and enforcing company-wide
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policies and practices, including with regard to anti-discrimination and other employment policies.
22
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17.
herein Defendant Stephenson is and was a resident of the State of Texas and the County of Dallas.
24
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King is informed and believes, and on that basis alleges, that at all relevant times
18.
herein Defendant Roche is and was a resident of the State of Georgia and the County of Chatham.
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19.
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herein , Defendant Slator is and was a resident of the State of California and the County of Los
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Angeles.
254439.5
6
COMPLAINT
20.
1
2
herein Defendant Stephenson is and was a resident of the State of Texas and the County of Dallas.
21.
herein, Defendant Smith is and was a resident of the State of California and the County of Los
Angeles.
22.
herein, Defendant Weber is and was a resident of the State of California and the County of Los
Angeles.
23.
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herein, Defendant York is and was a resident of the State of California and the County of Los
11
Angeles.
24.
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King is informed and believes, and ori that basis alleges, that at all relevant times
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King is informed and believes, and on that basis alleges, that Defendants Does 1
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through 10, inclusive, are individually and/or jointly liable to King for the wrongs alleged herein .
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The true names and capacities, whether individual, corporate, associate or otherwise, of
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Defendants Does 1 through 10, inclusive, are unknown to King at this time. Accordingly, King
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sues Defendants Does 1 through 10, inclusive, by fictitious names and will amend this Complaint
17
to allege their true names and capacities after they are ascertained.
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25.
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King alleges that each of the Defendants is, and at all times relevant to this
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Complaint was, the employee, agent, employer, partner, joint venturer, alter ego, affiliate,
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principal, and/or co-conspirator of the other Defendants and, in doing the acts alleged herein, was
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acting within the course and scope of such positions at the direction of, and/or with the
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permission, knowledge, consent and/or ratification of, the other Defendants. As such, each
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Defendant, through its acts and omissions, is responsible for the wrongdoing alleged herein and
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for the damages suffered by King.
JURISDICTION AND VENUE
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26.
Pursuant to Article VI, section 10 of the California Constitution, subject matter
27 jurisdiction is proper in the Superior Court of California, County of Los Angeles , State of
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California.
254439.5
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COMPLAINT
27.
Pursuant to the California Code of Civil Procedure, venue is proper in this county
because this is where Defendants are located, do business and/or where the unlawful acts giving
rise to this action occurred. Venue is further proper in this county because it was the county where
King worked and was paid.
FACTUAL ALLEGATIONS
6 A.
King Has Been a Loyal And Dedicated AT&T Employee For Over 30 Years
28.
King was hired by AT&T in 1985, when she was twenty years old. She began as
an operator, and worked her way up to her current position as Content Coordinator in AT&T ' s U-
Verse group. King has been a part of the U-Verse team almost since its inception, joining the
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team in February 2005.

29.
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In her role as Content Coordinator, King is responsible for handling vendor
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payments, organizing executive schedules, and managing executives ' desks. King currently
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reports to Defendants Slator and Smith. Smith is Slator's right-hand man and Vice President of
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Content at AT&T. Before Slator took over the President of Content and Advertising Sales
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position in June 2013, King reported to Defendant Weber; before that, she reported to Defendant
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York.
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30.
In her 30 years at AT&T, King has received consistently positive reviews-
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meeting or exceeding expectations each year. Only recently, when King complained to AT&T
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Human Resources, did King begin to receive negative feedback.
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31.
King is good at her job and has worked hard. Despite this, AT&T and its board
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members have sat by idly while King's superiors have discriminated against and harassed King.
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B.
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AT &T's Top Executives Have a Practice of Discriminating on the Basis of Race

32.
During Defendant York's tenure as AT&T's President of Content and Advertising
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Sales (2005-2012) , King was one of just two African American employees in the office. The other
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African American, Denita Willoughby, was already there when York arrived. York did everything
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in his power to oust Willougby; eventually, forcing her out by hiring a White male to take over her
27 job duties and paying him more money than Willougby.

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254439.5
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COMPLAINT
33.
When York was preparing to depart AT&T, he finally agreed to hire "diverse"
2 employees. At the time, King was the only African American. York wanted to avoid word
3 getting out that the Los Angeles branch of AT&T, which was responsible for choosing the
4 television content distributed to millions of Americans, consisted of a nearly all-white group.
34.
AT&T hired an African American woman as Executive Assistant to the President
6 of Content and Advertising Sales (she is referred to herein as "EA''). EA started after York left,
7
while Defendant Weber was heading the office; she left not long after Slator took over.
35 .
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King witnessed and was aware of the mistreatment and abuse suffered by EA as a
result of her skin color. As soon as Slator assumed the role of President of Content and
10 Advertising Sales, he sought to push EA out and hire Susie Becerra- a younger, non-African
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American female with whom Slator was romantically involved.

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Slator looked for ways to get rid of EA. He encouraged EA to resign . EA told
Slator that she did not want to give up her position at AT&T.
37.
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Unable to convince EA to resign, Slator began complaining about EA ' s work and
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treating her poorly-all with the aim of forcing EA to quit her job so he could hire his younger,
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non-African American mistress, Susie Becerra, in her place.
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1.
EA Sees the Racist Images on Slator's Phone
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38.
As part of her job duties, Slator asked EA to transfer data from his old company
19 cellular telephone to his new one. While completing this task, EA came across the images
20 depicted at Paragraph 2 above (also attached hereto as Exhibits A & B). The text messages found
21
on Slator's company cell phone are attached hereto as Exhibit C. Slator text messaged the image
22
of the African child with the words "It's Friday Niggas" written across the top (Ex. A) to a friend ,
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referring to it as an "oldie but goodie." Ex. C.
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39.
Slator knew that this material was on his company phone, but nevertheless asked
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EA, an African American woman, to perform the data transfer. Slator knew that EA would be
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subjected to these racist words and images.
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40.
The fact that Slator- a high-level AT&T executive with authority over hiring,
firing and promotional decisions-condones the use of racist language (sending an image of a
254439.5
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COMPLAINT
1 Black child with the "N-word" on it) speaks to Slator's state of mind. Slator harbors obvious and
2
deep-seated racial animus toward African Americans. Slator's decisions regarding hiring, firing,
3 promotions and raises are infected by his racism.
41.
EA disclosed the offensive images and messages to AT&T, including to an AT&T
5 board member, Joyce Roche, and to AT&T's Equal Employment Opportunity Consultant ("EEO
6
Consultant"), Stephanie Davis. On information and belief, Ms. Roche shared these images with
AT&T's Chief Executive Officer, Defendant Randall Stephenson. On information and belief,
8 Defendant Stankey, with whom Slator worked closely, also was made aware of the offensive
9
images and messages on Slator's company phone. Nevertheless, AT&T took no action to
10 reprimand Slator, to train or educate him, or to curb his racism. To the contrary, AT&T engaged
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in a deliberate cover-up of Slator' s racism.
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42.
EA voluntarily disclosed the racist images to King. King had witnessed the
discriminatory manner in which Slator treated African American employees, and now her worst
14 fears were confirmed: Slator's discrimination and abuse was based on race.
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Slator Forces Out EA and Refuses to Promote King, Instead Hiring His
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Lesser-Qualified, Younger, Non-African American Mistress
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2014, EA left AT&T.
44.
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EA no longer could endure Slator's discrimination and harassment, and, in January
Unbeknownst to EA, Slator had already planned to get rid of her. In fact, he
offered EA 's job to Susie Becerra in June 2013, before EA notified him of her intent to resign.
21
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When EA informed Slator about her intent to resign, EA recommended King as her
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replacement. EA informed Slator that King was experienced, qualified and hard working. Indeed,
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EA informed Slator that King had filled in for EA when EA was out, so King was familiar with
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and had performed EA' s duties in the past.
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46.
Slator had no intention of considering King's candidacy. He had already promised
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the job to Susie Becerra, even though EA had informed Slator that Becerra lacked the necessary
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expenence.
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254439.5
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COMPLAINT
47.
Astonishingly, despite AT&T and its board members' awareness of Slator's racial
discrimination and role in pushing EA out the door, AT&T allowed Slator to hire her replacement.
3 AT&T knew about the racially offensive messages on Slator's phone; yet it took no steps to
4
ensure the position would be filled on objective, non-discriminatory terms.
3.
After EA Left, Slator Mistreated King
48.
Following EA's departure, Slator turned on King. Slator knew that King and EA
had been friendly, and they were both African Americans. Slator was rude and dismissive to
King. He ignored her when they were in close proximity and was generally dismissive and short
with her. In addition, instead of using King who was in the same office to fulfill EA' s duties,
10 Slator had someone in Dallas, Texas remotely perform these tasks until Susie Becerra arrived.
49.
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On October 20, 2014, Slator brought King into his office to let her know that he
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had given the executive assistant job to Susie Becerra. Slator was rude to King. When King
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asked why Slator had been mistreating her, Slator started yelling at King. King was so frightened
14 that she thought Slator might strike her.
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King was denied the promotion because of her race, because of her age, and
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because she was not in a romantic relationship with Slator. Instead, the job went to Susie Becerra,
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a younger, non-African American female, who was romantically involved with the decision-
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maker: Slator.
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51.
Had King known about the racist culture at AT&T, she would have left years ago
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and obtained a position at another company without the racial bias and discrimination that
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permeates AT&T.
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52.
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AT&T has a pattern and practice of deciding who will fill job openings before the
positions are posted; well-qualified candidates like King do not stand a chance.
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4.
King Receives Smaller Raises Than Her Non-African American Colleagues
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53.
In addition to being denied promotional opportunities, King has been discriminated
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against in terms of her compensation. Given her consistently good job performance, King
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received a pay raise each year she worked at AT&T. But these pay raises were minimal and less
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than her white counterparts.

254439.5
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COMPLAINT
54.
In 2013, King complained to AT&T's EEO Consultant, Stephanie Davis, telling
her that she believed her pay raises were inadequate given her performance, and that they were not
3 commensurate with the raises her non-African American colleagues received.

4
55.
After complaining to Ms. Davis and HR, King received a higher than average raise
(approximately 3.5%) in March 2014. But the following year, King's annual pay raise was
dropped back down to 1.9%-lower than her non-African American colleagues.
5.
AT&T Retaliates Against King And Tries To Force Her Out
56.
When King complained to AT&T' s EEO Consultant, Ms. Davis, she was led to
believe her complaints would be kept confidential unless and until she elected to make a formal
10 complaint and request an investigation. King learned, however, that Ms. Davis had relayed King's
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complaints to others at AT&T.
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57.
In approximately March 2014, King was approached by Bob Reed, an AT&T
human resources representative. King reiterated her concerns, but her conversation with Mr. Reed
14 did not lead anywhere.
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58.
Instead, King began receiving negative feedback and evaluations from her
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superiors in retaliation for King's complaints regarding unequal raises and Slator's rude behavior
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following EA' s departure.
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59.
At King's annual review in March 2015, she was given a poor performance review
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by Defendant Smith, her direct supervisor. Smith lied to King about the reasons for her negative
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review. He claimed that King would be receiving only a small pay raise because one of King's
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superiors, Richard Levine (then-Vice President of Programming at AT&T), supposedly
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complained about King. King was surprised, given that she felt she went above and beyond to
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support Mr. Levine. King told Smith that she planned to approach Mr. Levine to better understand
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what the issues were, but Smith dissuaded her. Smith told King she should not bother speaking to
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Mr. Levine about the negative review because he was leaving the company soon anyway.
60.
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Mr. Levine later learned that Smith had given this false, negative feedback to King.
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He called King into his office and told her that Ryan was a "mother fucker." Mr. Levine was
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upset because Smith had lied to King and made Mr. Levine the fall-guy; Mr. Levine never
254439.5
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COMPLAINT
complained about King. Smith invented reasons to justify King's poor review and minimal pay
2 raise and then attempted to discourage King from discovering the truth.
61.
The negative review by Smith was part and parcel of the retaliation, harassment and
illegal cover-up of discrimination at AT&T. Concerned that King was the closest and potentially
last link toEA, Smith and Slator wanted to force King out of AT&T, just like Slator forced out EA
6 (and York pushed out Willoughby). On information and belief, Smith knew about the offensive
7 images on Slator's phone and actively engaged in the illegal cover-up at AT&T.
62.
In February 2015 , King made another discrimination complaint. This time, King
9 called the AT&T Hotline, which AT&T advises its employees to use to report workplace issues.
10 King submitted a complaint regarding Susie Becerra, reporting that she had been hired with
11
"special privileges," that she rarely comes to work, that work was not being completed, and that
12 she was not knowledgeable of the executive assistant job she had been hired to do . King also
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reported that Becerra brought her son to the office several times per month, and that she kept
14 limited hours-typically, Susie Becerra worked from 9:30a.m. to just 2:00p.m., while the rest of
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the employees in the department work full , 8-hour days.

63.
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In March 2015, Slator approached King about the subject. He brought King into
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his office, shut the door, and spoke in a harsh tone about King's complaints.
64.
18
19
Recently, AT&T has been attempting to push King out the door. For example,
after AT&T and DirecTV announced their plans to merge, AT&T's Vice President of Human
20 Resources, Gary Fraundorfer, reached out to King to discuss "career goals and opportunities,"
21
including the possibility that King would consider accepting an "early retirement" package.
65.
22
23
for her to retire.
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King was surprised by the call. She told him that it was not economically feasible
66.
AT&T is trying to push King out the door-much like Slator pushed another
African American woman, EA, out the door. This is being done in retaliation for King 's
26 complaints and because of her race.

27
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254439.5
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COMPLAINT
c.
AT&T's Nefarious Scheme To Cover Up Clear-Cut Racism

67 .
AT&T has a racism problem. Its top executives push out African American
3 employees; strip African American employees of job duties based on race; reject African
4
American applicants in favor of lesser-qualified, non- African American candidates; and
5 discriminate against African Americans in terms of compensation.

68.
AT&T' s current top programming official, Slator, harbors racial animus toward
7 African Americans. AT&T' s EEO Consultant, HR Department, and its Board member, Roche,
8 were given the racist images and messages on Slater's phone. On information and belief, Roche
9 shared this information with AT&T CEO and Chairman of the Board, Stephenson. On
10 information and belief, Defendant Stankey also saw, or was made aware of, the offensive images
11
and messages on Slater's company phone.

69.
12
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The appropriate reaction-the morally responsible and legally required one-
would have been for AT&T to take steps to remedy this past, and to prevent future, racism by its
14 top television content executive. AT&T did not do this . Instead, AT&T's engaged in an illegal
c:::
15
cover-up, to ensure that its racism remained hidden-even at the expense of long-term, loyal
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16 African American employees such as King and EA.
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70.
17
18
After EA had initiated a complaint with the Equal Employment Opportunity
Commission, AT&T implemented the cover-up. To avoid publicity, on information and belief,
19 AT&T paid EA a substantial sum of money on the condition she keep quiet and not disclose
20 AT&T' s racist practices.
21
71.
Soon thereafter, AT&T's EEO Consultant, Stephanie Davis, began reaching out to
22 AT&T employees, including King, to carry out AT&T's cover-up. AT&T wanted to determine
23
whether other employees had been exposed to the racist images and messages on Slater's cell
24 phone and/or EA 's complaints about Slator.
25
26
72.
ensure that the images on Slater's phone never saw the light of day.
73.
27
28
AT&T was deliberately attempting to conceal Slater's racism. AT&T wanted to
In discussing EA 's departure, AT&T's EEO Consultant asked King whether she
had seen any photographs, referring to the images on Slater's work phone. Concerned about
254439.5
14
COMPLAINT
1 possible retaliation, King said nothing about the images. AT&T thought it had succeeded in its
2 illegal cover-up. King complained to Ms. Davis about EA's mistreatment and abuse by Slator, as
3 she was aware of and had witnessed much of it.
74.
AT&T led King to believe that her conversations with the EEO Consultant would
5 be confidential; in fact, AT&T's EEO Consultant website, to which AT&T employees are directed
6 to submit complaints, indicates that it is intended to be "a confidential and anonymous online
7
process to report suspected or actual violations of AT&T' s Code of Business Conduct, EEO
8 policies and other Company policies."
75.
During King' s conversations with the EEO Consultant, King disclosed that since
10 EA left AT&T, King felt Slator had been retaliating against King because she was the same race
11
as EA. King also mentioned her concerns regarding unequal compensation and pay raises.
12
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13
76.
Despite the assurances of confidentiality, King later discovered that Ms. Davis had
disclosed the substance of their conversation to others at AT&T, including Bob Reed .
77.
14
Shortly after the racist images on Slator' s phone were brought to the attention of
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AT&T's upper echelon, including Roche, AT&T held human resources training for the U-Verse
16 team. The training was part of AT&T' s concealment and cover-up; Slator did not even attend.
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78.
17
After King witnessed how board member Joyce Roche ignored EA ' s cry for help
18 but instead helped to covered up the racism and harassment, King felt she could not trust the board
19
members as well as Jessie Jackson, AI Sharpton, the NAACP, The Urban League and other so-
20 called civil rights organizations. King was very disappointed these so-called civil rights
21
organizations had taken donations from AT&T and had given AT&T sham diversity awards in
22 exchange for those donations. None of those so-called civil rights organizations ever asked any of
23
the African American employees at AT&T if they were happy or felt they were being mistreated.
24 King was completely disgusted by these organizations because they honored AT&T for small
25
donations even though AT&T does not respect or honor Dr. Martin Luther King's birthday as a
26
national holiday. African American AT&T employees have to forfeit one of their own personal
27
vacation days to honor the Dr. Martin Luther King Jr. Holiday. Mrs. King reserves the right to
28
name these organizations as defendants.

254439.5
15
COMPLAINT
1 D.
AT &T's Top Executives Have a Practice of Discriminating on the Basis of Age
79.
AT&T, but she has also been discriminated against on the basis of her age.
4
5
80.
81.
opened up. King approached York to discuss her qualifications for the position. York informed
her that he thought the role would be best suited for someone with a law degree. King told York
that she would be willing to go to law school so that she could apply for the position the next time
it was available.
11
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For example, when King was reporting to Defendant York, a higher-level position
10
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King has always set high goals for herself. Rather than simply "getting by," King
has aimed to excel at and advance in her career.
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Not only has King been subjected to rampant racial discrimination in her time at
82.
Rather than commending King's self-initiative, York discouraged it. He told her:
"It's too late for you." According to York, King was too old to advance at AT&T.
13
83.
York even went so far as to refuse King's request for mentorship for the same
14
reason. King had approached York seeking his advice on steps she could take to improve her
15
skills and knowledge so she would be a stronger candidate for future, higher-level positions within
16
the company. York reiterated that it was "too late" for King.
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84.
In other words, York was willing to provide guidance and mentorship only to
18
younger employees; for employees like King, it was "too late." This age discrimination inhibited
19
King's career trajectory and opportunity to obtain higher-level (and thus higher-paying) positions
20
at AT&T or elsewhere.
21
85.
In 2012, York left AT&T to become DirecTV's Chief Content Officer. In that role,
22
too, York discriminated against older employees. York pushed out a 55-year-old woman so that
23
he could replace her with a younger, white male. York has a pattern of practice of getting rid of
24
employees on the basis of age, race and gender to replace them with younger white male
25
employees (who he awards higher compensation).
26
86.
The age discrimination continued even after York's tenure at AT&T. Defendant
27
Slator, too, made discriminatory comments regarding King's age and discouraged her from taking
28
steps to further her education and career.

254439.5
16
COMPLAINT
87.
1
2
In a meeting with EA, Slator disparaged King, questioning King's skills and ability
based on her age. King had disclosed to Slator that she was working to obtain her Masters in
3 Business Administration ("MBA"). Rather than encouraging King, Slator mocked her. Slator told
4
EA: "What's the point of her [King] getting her MBA? At her age, she isn ' t going anywhere in
this company." Slator also stated: "Diversity candidate or not, she' s too old. She's not going any
6 further; trust me."
88.
7
8
degrees. When EA told Slator that a secretary was putting together an application for an MBA
program, Slator asked: "How old is she?" EA told Slator that the secretary was in her early
10
twenties. Slator nodded and said "good." Slator's employment decisions (e.g. , hiring, firing ,
11
promotions) were infected by this animosity toward older employees.
89.
12
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By comparison, Slator encouraged younger AT&T employees to pursue Masters
13
King was using her free time to take MBA classes at night. Once she learned of
Slator' s discriminatory comments, she was discouraged and dissuaded from continuing her MBA
14 program.
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15 E.
Defendant Weber Subjected King to a Hostile Working Environment
16
90 .
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During Weber's tenure as AT&T ' s top programming official (2012-2013), Weber
17
engaged in at least one illicit relationship with another AT&T employee. Weber favored and
18
treated that employee better than other AT&T employees, including King. And the employee took
19
advantage of her relationship with Weber, treating King and other employees with disrespect and
20
pawning off her work on others-knowing she could get away with her inappropriate behavior
21
because of her romantic involvement with the boss.
22
91.
Under Weber's reign, there was an unspoken office quid pro quo policy: The
23
secret to success was not excelling at work, but rather engaging in a sexual relationship with your
24
superior. King and others who did not participate in such behavior were denied opportunities to
25
succeed and to rise in the ranks at AT&T. On information and belief, King also received lower
26
pay raises than the AT&T employee who was romantically involved with Weber, although King
27
was perfonning her job duties as well as-or better than-this employee.
28
92.
254439.5
Eventually, the relationship between Weber and the AT&T employee deteriorated.
17
COMPLAINT
1 Disgruntled by the termination of their illicit relationship, Weber pushed the AT&T employee out
2
the door. In other words, once the relationship was over, so too was the AT&T employee's job.
This was the environment at AT&T.
93.
AT&T was aware of Weber's relationship with the AT&T employee and the ways
in which the relationship adversely affected the office environment. Nevertheless, AT&T took no
steps to institute or enforce an office policy prohibiting such relationships or to ensure that
employees who refused to engage in such relationships were not mistreated. Indeed, as discu ssed
below , AT&T condoned and ratified romantic relationships between AT&T employees and high-
level executives on future occasions as well.
EXHAUSTION OF ADMINISTRATIVE REMEDIES
10
94.
11
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On April 26, 2015, King filed a timely complaint of discrimination against
12
Defendants with the Department of Fair Employment and Housing ("DFEH") pursuant to the Fair
13
Employment and Housing Act ("FEHA"). King received an immediate right-to-sue letter from
14
DFEH on April 26, 2015. A true and correct copy of the DFEH right-to-sue letter is attached as
15
Exhibit D.
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16
FIRST CAUSE OF ACTION
17
Unlawful Discrimination on the Basis of Race in Violation of FEHA
18
(Against AT&T Services, Inc. and Does 1-10)
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19
20
95.
King hereby repeats, realleges and incorporates each foregoing and subsequent
paragraph of this Complaint as though fully set forth herein. and further alleges as follows:
21
96.
As described hereinabove, the actions of Defendants constitute unlawful
22
discrimination on the basis of race against King. King is informed and believes, and based
23
thereon alleges, that in perpetuating the above-described conduct, Defendants and/or their
24
managers, agents or employees engaged in a pattern and practice of unlawful discrimination on
25
account of race in violation of FEHA, including but not limited to California Government Code
26
section 12940(a).
27
97.
28
During the course of King's employment, Defendants engaged in, condoned, or
ratified severe, pervasive and unlawful race discrimination by stripping King of job duties she had
254439.5
18
COMPLAINT
previously performed; materially changing the conditions of her employment; refusing to promote
2
King to executive assistant and other positions , instead giving these jobs to younger, non-African
American employees who were more junior in education and experience to King; by giving King
unequal pay raises compared to her non-African American colleagues; and by encouraging King
voluntarily to take early retirement, all on the basis of race.

98.
As a proximate result of Defendants ' unlawful conduct, King has suffered and
continues to sustain substantial losses in earning and other employment benefits. King has also
suffered and continues to suffer emotional, physical and mental injuries, and loss of reputation.
King's damages are in excess of $100 million, to be determined according to proof at trial.
99.
10
The aforementioned acts of Defendants were malicious, willful, oppressive,
11
despicable, and in conscious disregard of King's rights and the resulting harm to her. King is
12
therefore entitled to punitive damages in an amount sufficient to punish AT&T-a multi-billion-
13
dollar company-and make an example of it.
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14
SECOND CAUSE OF ACTION
15
Unlawful Harassment on the Basis of Race in Violation of FEHA
16
(Against AT&T Inc., AT&T Services, Inc., Stephenson, Roche, York, Slator, Smith, and
17
Does 1-10)
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19
100.
20
101.
21
harassment on the basis of race against King. This harassment created a hostile, intimidating and
22
oppressive work environment for King, whereby the conditions of her employment were adversely
23
affected. The race-based harassment was pervasive. King was repeatedly subjected to
24
discriminatory conduct on the basis of her race, including, but not limited to, being retaliated
25
against, mistreated and stripped of job duties after EA left AT&T, simply because King was the
26
same race as EA; being denied promotional opportunities that instead went to lesser-qualified,
27
non-African American candidates; and being denied equal pay to her non-African American
28
colleagues. King also witnessed Slator's discriminatory treatment of EA on the basis of race, and
254439.5
19
COMPLAINT
feared for her job because Slator did not like King simply because she was African American.
2 Moreover, Defendants displayed favoritism to employees outside King's protected class and
3 discouraged African Americans from pursuing equal opportunity in the workplace.
102.
As alleged herein, Defendants Stephenson, Roche, York, Slator and Smith each
5 participated in, assisted, or encouraged the harassing conduct described above.

103.
6
7
The harassment by Defendants as described in this Complaint violated FEHA,
including but not limited to Government Code section 12940(j).

104.
King complained about the harassment she suffered to her supervisor, Defendant
9 Smith and to Bob Reed, a member of AT&T's human resources department. King also
10 complained on several occasions about perceived racial discrimination to AT&T's outside EEO
11
Consultant, Davis, who (contrary to AT &T's promises of confidentiality) relayed King's
12 complaints to AT&T. AT&T ratified the acts of Defendants Slator, Weber and York because it
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did nothing to prevent further harassment by the individual Defendants, nor did it prevent their
14 retaliation and interference with King's career advancement.
105.
15
AT&T knew or should have known of the conduct by Defendants Slator, Weber
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16 and York described herein. In fact, AT&T human resource representatives, board members and
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high-level executives (Defendants Roche, Stephenson and Stankey) were made aware of the
18
severe and pervasive racism Slator perpetuated in the office, and yet AT&T took no steps to
19 remedy the harm that had already occurred or to prevent future harm. Instead, AT&T engaged in
20 a nefarious and deliberate cover-up in order to hide the racism that permeated AT&T' s Los
21
Angeles office.
22
106.
As a proximate result of Defendants' unlawful conduct, King has suffered and
23
24
25
26
107.
The aforementioned acts of Defendants were malicious , willful , oppressive,
27
28
therefore entitled to punitive damages in an amount sufficient to punish AT&T-a multi-billion254439.5
20
COMPLAINT
dollar company- and its high-level executives-who make millions per year-and make an
2 example of them.
3
THIRD CAUSE OF ACTION
Unlawful Discrimination on the Basis of Age in Violation of FEHA
108.
7 paragraph of this Complaint as though fully set forth herein. and further alleges as follows:
8
109.
King is fifty years old, and therefore falls within a protected class pursuant to
9 California Government Code sections 12926(b) and 12940(a).

10
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110.
11
discrimination on the basis of age against King. King is informed and believes, and based thereon
12
alleges, that in perpetuating the above-described conduct, Defendants and/or their managers,
13
agents or employees engaged in a pattern and practice of unlawful discrimination on account of
14 age in violation of FEHA, including but not limited to California Government Code section
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15
12940(a).
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111.
During the course of King's employment, Defendants engaged in, condoned, or
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17 ratified severe, pervasive and unlawful age discrimination by stripping King of job duties she had
18 previously performed; by refusing to promote King to executive assistant and other positions,
19 instead giving these jobs to younger, non-African American employees who were more junior in
20 education and experience to King; by discouraging King from advancing her career by, among
21
other things, stating that it was "too late" for her and she was "too old"; and by encouraging King
22
voluntarily to take early retirement, all on the basis of age.
23
112.
As a proximate result of Defendants' unlawful conduct, King has
suffe~ed
and
24 continues to sustain substantial losses in earning and other employment benefits. King has also
25
26
27
28
113.
The aforementioned acts of Defendants were malicious , willful, oppressive,
254439.5
21
COMPLAINT
1 therefore entitled to punitive damages in an amount sufficient to punish AT &T- a multi-billion2 dollar company-and make an example of it.
3
FOURTH CAUSE OF ACTION
Unlawful Harassment on the Basis of Age in Violation ofFEHA
(Against AT&T Services, Inc., York, Slator and Does 1-10)

114.
6
7
115.
9 harassment on the basis of age against King. This harassment created a hostile, intimidating and
10 oppressive work environment for King, whereby the conditions of her employment were adversely
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affected. The harassment was pervasive. King was repeatedly subjected to offensive comments
12
and behavior by Defendants York and Slator regarding her age. Defendant York refused to
13
provide King with mentorship and discouraged her from obtaining her law degree, telling her it
14 was "too late" for her to advance her career at AT&T. Defendant Slator similarly made statements
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that King was "too old" to get her MBA and that she was "too old" to go anywhere within AT&T.
16 Slator also made such statements to or about other older employees. By contrast, Slator
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17 encouraged a younger employee in her twenties to obtain an MBA, even going so far as to agree to
18
write her a letter of recommendation to business school.

116.
19
As alleged herein , Defendants York and Slator both directly participated in the
20 harassing conduct described above.

117.
21
22 including but not limited to Government Code section 12940U).

23
118.
King complained about the harassment she suffered to her supervisor, Ryan Smith,
24 and to Bob Reed, a member of AT&T' s human resources department. King also complained to
25
AT&T's outside EEO Consultant, Stephanie Davis, who (contrary to her promises of
26
confidentiality) relayed King's complaints to AT&T. AT&T ratified the acts of Defendants
27
Slator, Weber and York because it did nothing to prevent further harassment by the individual
28
Defendants, nor did it prevent their retaliation and interference with King's career advancement.
254439.5
22
COMPLAINT
1
2
119.
described herein.
120.
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AT&T knew or should have known of the conduct by Defendants Slator and Y ark
121.
therefore entitled to punitive damages in an amount sufficient to punish AT &T-a multi-billion-
10
dollar company-
11
example of them.
and its high-level executives- who make millions per year- and make an
12
FIFTH CAUSE OF ACTION
13
Unlawful Harassment on the Basis of Sex in Violation of FEHA
14
(Against AT&T Services, Inc., Slator, Weber and Does 1-10)
Cl
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122.
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123.
17
18
harassment on the basis of sex against King. This harassment created a hostile, intimidating and
19
oppressive work environment for King, whereby the conditions of her employment were adversely
20
affected. The sexual harassment and sexual favoritism was widespread, severe and pervasive.
21
King was repeatedly subjected to inappropriate intra-office relationships between AT&T
22
executives and lower-level AT&T employees, which resulted in those employees receiving more
23
favorable treatment than King, including preferential treatment with regard to hiring, promotional
24
and pay-raise decisions. In addition, King was subjected to substandard treatment by the AT&T
25
employees engaged in these illicit affairs, who knew they could get away with such inappropriate
26
behavior because of their romantic involvement with the boss. King was also told about intra-
27
office conversations in which White male executives discussed which woman had the best back-
28
side in the office. Defendants also displayed blatant favoritism to female employees who were
254439.5
23
COMPLAINT
willing to engage in such relationships with their superiors and discouraged King and others in her
2 position from pursuing equal opportunity in the workplace.
3
124.
As alleged herein, Defendants Slator and Weber both participated in the harassing
4 conduct described above.

125.
6 including but not limited to Government Code section 12940U).

7
126.
King complained about the harassment she suffered to her supervisor, Ryan Smith,
8 and to Bob Reed, a member of AT&T' s human resources department. King also complained to
9 AT&T's outside EEO Consultant, Stephanie Davis, who (contrary to her promises of
10 confidentiality) relayed King's complaints to AT&T. AT&T ratified the acts of Defendants Slator
11
and Weber because it did nothing to prevent further harassment by the individual Defendants, nor
12 did it prevent their retaliation and interference with King's career advancement.
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127.
13
AT&T knew or should have known of the conduct by Defendants Slator and Weber
14 and described herein.
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128.
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18
King 's damages are in excess of $100 million, to be determined according to proof at trial.
19
129.
The aforementioned acts of Defendants were malicious, willful , oppressive,
20 despicable, and in conscious disregard of King's rights and the resulting harm to her. King is
21
22
23
example of them.
24
SIXTH CAUSE OF ACTION
25
Unlawful Retaliation in Violation of FEHA
26
27
28
130.
254439.5
24
COMPLAINT
131.
As alleged herein , Defendants, and each of them, and/or their managers, agents and
2 employees knew or reasonably should have known that employees of Defendant AT&T,
3 individually and together in varying combinations, were engaging in the conduct set forth above.
4
132.
FEHA prohibits an employer from retaliating against an employee for engaging in
5 a protected activity. Disclosure of and opposition to an employer's race and age discrimination is
6 a protected activity under FEHA, California Government Code section 12940(a).
133.
King made complaints to AT&T's third-party EEO Consultant, Stephanie Davis,
8 which were disclosed to AT&T, including that King was harassed and discriminated against on the
9 basis of race and age by Defendant Slator and that King received discriminatory pay raises as
10 compared to her non-African American colleagues. King made these same complaints to Ryan
11
Smith and to Bob Reed, AT&T's human resources representative.
12
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13
134.
In violation of FEHA, AT&T retaliated against King for complaining about the
above discrimination and harassment, including by giving her negative performance reviews and
14 lower annual pay raises than her non- African American colleagues. Defendant Slator treated
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King with animosity following her complaint regarding unequal and unfair treatment. Even
16
though King used to perform EA' s duties when she was out, after EA was forced out of AT&T,
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17 Slator refused to deal with King. He ignoring her in the office and used an assistant based in
18 Dallas to cover EA ' s duties, even though Slator and King were in the same office in Los Angeles.
19
135.
21
22
King' s damages are in excess of $100 million , to be determined according to proof at trial.
23
136.
The aforementioned acts of Defendants were malicious, willful , oppressive,
24 despicable, and in conscious disregard of King ' s rights and the resulting harm to her. King is
25
therefore entitled to punitive damages in an amount sufficient to punish AT &T- a multi-billion-
26
dollar company- and make an example of it.
27
28
254439.5
25
COMPLAINT
SEVENTH CAUSE OF ACTION
Aiding and Abetting FEHA Violations
(Against Defendants AT&T Inc., Roche, Stephenson, Stankey, and Does 1-10)
137.
6
7
King hereby repeats , realleges and incorporates each foregoing and subsequent
138.
As alleged herein , Defendant Slator discriminated against and harassed King and
other African American employees on the basis of race, in violation of FEHA, California
8 Government Code sections 12940(a) and 129400).

9
139.
As alleged herein , Defendants AT&T Inc., Roche, Stephenson, and Stankey had
10 knowledge of Slator's discriminatory conduct and harassment and knew that such conduct
11
constituted a breach of the duties owed to AT&T's employees, including King. Defendants
12 AT&T Inc., Roche, Stephenson, Stankey further knew that Slator's conduct constituted a violation
13
ofFEHA.
14
15
140.
Defendants AT&T Inc. , Roche, Stephenson, and Stankey knew that Slator would
continue to discriminate against and harass African American employees, including King.
16 Defendants AT&T Inc., Roche, Stephenson, and Stankey gave substantial assistance and
17 encouragement to Slator to violate King's rights under FEHA. As alleged herein, Defendants
18 AT&T Inc., Roche, Stephenson, and Stankey engaged in a widespread, illegal cover-up to hide
19 Slator' s racist conduct. These defendants used everything at their disposal to carry out this cover20 up, including, among other things: paying off EA for her silence; engaging the EEO Consultant
21
immediately after EA left to interview King and other employees about Slator's racism ; making
22
sure that the racist images would not be revealed to the public; using AT&T's HR department to
23
do sham training and pulling King aside to interview her; and encouraging AT&T to find a way to
24 force King out of the company. By taking affirmative steps to whitewash Slator's discrimination
25
and harassment, Defendants AT&T Inc. , Roche, Stephenson, and Stankey substantially assisted
26
and encouraged Slator to continue such conduct in the future.
27
28
141.
Defendants AT&T Inc. , Roche, Stephenson, and Stankey's aiding and abetting, as
described in this Complaint, violated FEHA, including but not limited to Government Code
254439.5
26
COMPLAINT
1 section 12940(i).
2
142.
King' s damages are in excess of $100 million, to be determined according to proof at trial.
143. The aforementioned acts of Defendants were malicious, willful, oppressive,
despicable, and in conscious disregard of King' s rights and the resulting harm to her. King is
therefore entitled to punitive damages in an amount sufficient to punish AT&T- a multi-billion-
10 example of them.
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EIGHTH CAUSE OF ACTION
12
Failure to Take Reasonable Steps to Prevent Harassment, Discrimination and Retaliation in
13
Violation of FEHA
14
(Against Defendants AT&T Services, Inc. and Does 1-10)
c<:
15
144.
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16
17
18
145.
AT&T knew or had reason to know of the race- and age-based discrimination and
19
harassment, sexual harassment, and retaliation occurring at AT&T. King is informed and
,.,
believes, and thereon alleges, that AT&T failed to take all reasonable steps to prevent such
20
harassment and discrimination in violation of California Government Code section 12940(k).
21
146.
AT&T failed to take appropriate steps to train its employees, supervisors and/or
22
managers regarding race- and age-based harassment and discrimination by failing to enforce a
23
policy against unlawful harassment and discrimination, failing thoroughly to investigate
24 complaints of harassment or discrimination, and failing to take prompt and appropriate

25
disciplinary action against perpetrators of harassment and discrimination.
26
147.
27
28
254439.5
27
COMPLAINT
2
148.
4
5 dollar company-and make an example of it.

6
NINTH CAUSE OF ACTION
Intentional Infliction of Emotional Distress
(Against All Defendants)
149.
10 paragraph of this Complaint as though fully set forth herein. and further alleges as follows:
150.
11
As set forth above, Defendants have subjected King to discriminatory treatment on
12 the basis of her race and age for more than a decade, in violation of FEHA.
"...J
...J
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Vl
13
151.
The actions of Defendants as set forth above were extreme, outrageous, went
14 beyond all possible bounds of decency, and were atrocious and utterly intolerable in a civilized
Cl
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15
society.
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c::::
16
152.
Defendants intended to cause, or acted with reckless disregard for the probability of
...J
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17 causing, distress to King.

18
19
153.
As a direct and proximate result of the aforementioned acts of Defendants, King
has suffered severe grief, anxiety, worry, shock and other distress. After a 30-year career at
20 AT&T, King recently came to the realization that the company is infected with severe and
21
pervasive racism. King spent her career as a loyal, hardworking employee; yet no matter how well
22
she performed, due to the systemic racism she did not have the same opportunities as her younger,
23
non-African American colleagues. AT&T' s racist culture inhibited King's career growth and
24
stifled her earning power. Had King known years (or decades) ago what she knows now, she
25
never would have stayed at AT&T. King has suffered extreme depression and sadness, sometimes
26
resulting in uncontrolled crying episodes. She has been fearful that she could lose her job based
27
not on her performance but on the color of her skin, her age and/or in retaliation for her complaints
28
of discrimination. As a result of such distress, King has been damaged in an amount to be proven
254439.5
28
COMPLAINT
1 at trial, but not less than $100 million.

2
154.
4
therefore entitled to punitive damages in an amount sufficient to punish AT &T-a multi-billion-
5 dollar company- and its high-level executives-who make millions per year-and make an
6 example of them.
7
TENTH CAUSE OF ACTION
Negligent Infliction of Emotional Distress
(Against All Defendants)
10
11
155.
12
13
Vl
Vl
I.U
156.
Defendants had a duty toward King to treat her in a reasonable manner as an
employee and to ensure that she was not subjected to discrimination and harassment in the
14 workplace.
c::::
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~
c::::
15
16
157.
Defendants' actions as described herein breached their duty to King to ensure that
she was not subjected to discrimination and harassment in the workplace. Defendants Slator's,
I.U
.....
.....
17 Weber's and York's conduct as described herein (and as condoned and ratified by the other
18 Defendants named herein) was extreme and outrageous, especially considering Defendants
19 Slator's, Weber's and York's supervisory position of power. At all material times, Defendants
20 acted negligently and carelessly toward King, causing her severe emotional distress.
158.
21
22
Additionally, Defendants knew or should have known that their discrimination and
harassment of King, or ratification of the same, was likely to cause King severe emotional distress.
23
159.
As a direct and proximate result of the aforementioned acts of Defendants, King
24 has suffered severe grief, anxiety, worry, shock and other distress. After a 30-year career at
25
AT&T, King recently came to the realization that the company is infected with severe and
26
pervasive racism. King spent her career as a loyal, hardworking employee; yet no matter how well
27
she performed, due to the systemic racism she was on unequal footing with her younger, non-
28
African American colleagues. AT&T' s racist culture inhibited King's career growth and stifled
254439.5
29
COMPLAINT
her earning power. Had King known years (or decades) ago what she knows now, she never
2
would have stayed at AT&T. King has suffered extreme depression and sadness, sometimes
3 resulting in uncontrolled crying episodes. She has been fearful that she could lose her job based
4
not on her performance but on the color of her skin, her age and/or in retaliation for her complaints
of discrimination. As a result of such distress, King has been damaged in an amount to be proven
at trial, but not less than $100 million.
PRAYER FOR RELIEF
WHEREFORE, King respectfully prays for judgment against Defendants, as follows:
1.
Compensatory damages as permitted by law in excess of $100 million, to be
10 determined according to proof at trial;

11
2.
General damages in an amount according to proof at trial;
12
3.
Punitive and exemplary damages;
13
4.
Attorneys' fees;
U-J
14
5.
Pre- and post-judgment interest;
15
6.
Costs of this suit; and
16
7.
For such other and further relief as the Court may deem just and proper.
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17
18
DATED: April27, 2015
MILLER BARONDESS, LLP
19
20
By:
f_____/ 2 - - -
------~~------------------------------
LOUIS R. MILLER
Attorneys for Plaintiff Knoyme King
21
22
23
24
25
26
27
28
254439.5
30
COMPLAINT
DEMAND FOR JURY TRIAL
Plaintiff Knoyme King hereby demands a jury trial.
DATED: April 27,2015
MILLER BARONDESS, LLP
5
6
By:
-----------------------------------LOUIS R. MILLER
Attorneys for Plaintiff Knoyme King
9
10
11
12
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13
14
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15
16
17
18
19
20
21
22
23
24
25
26
27
28
254439.5
31
COMPLAINT
EXHIBIT A
No
Se rvice~
(Back
2:49PM
2 of 2
--- -- - -
EXHIBIT B
EXHIBITC
No
Service~
2:52PM
( Back (3)
100%
Contact
Read 7/25/13
They say Corp Dev is

AT&Ts brats!
I heard about V quitting
last week- I'm like wow,
oh well better for you!
I won't say anything
Send
No
Service~
2:36PM
Well yay on getting them

here :) I can totally do it
next week?? Let me know
iMessage
Thu, Sep 26, 1:09 PM
I heard Lori Lee give you a

shout out!!
I was thinking of you! Ha, I

came into the office and
was like I wonder how my
Nugget is doing?
Send
No
Service~
2:36PM
o ~
100 %
Contact
( Back (5)
I was thinking of you! Ha, I

came into the office and
was like I wonder how my
Nugg:et is doing?
Sun, Sep 29, 11 :03 AM
Sorry to bother you on the

weekend please apologize
to the girls for me. lts not
working out for me living~
here, I am thinking I may
be moving soon :(
Want to talk in a bit?
I can t :( but maybe
tomorrow?
Send
No
Service~
2:36PM
o ~
( Back (5)
100%
Contact
I can't :( but maybe

tomorrow?
Just dude
Job is good
So, you want to go back to
Dallas?
No just move I'm no quitter
Send
No
Service~
( Back (3)
2:48PM
o 100%
Contact
so I'
calhn
yseJ
e doc or'' no
BVIG
Classic.
Send
No Service
2:51PM
o 100 %
Contact
( Back (3)
Okie see you

Tue, Jun 4, 9:14AM
Congrats!!!!
I'll have my buddy close!!!

And my Sophie
Oh sorry it's Susie got my
number changed
Tue, Jun 4, 6:13 PM
Ugh duh!!!!
Send
No
2:51PM
Service~
( Back (3)
Contact
Tue, Jun 4, 6:13 PM
Ugh duh!l!!
Ok
Wed, Jun 5, 11:31 AM
Let me know when you

land
Wed, Jun 5, 12:44 PM
You have plans tomorrow

Qi_g ht?_Qodg_er__9?Jl1 f}_?
Send
No
Service~
2:52PM
Contact
( Back (3)
Thu, Jul 25, 11 :54 AM
Hi Aaron, just saying hello!

Hope all is well are your
girls here yet?
Read 7/25/13
Send
EXHIBITD
SIAJE.OE..CALIE.OHliiiAJJlusioess. Consumer Ser.vices.andJ:lousina.Aaency
DEPARTMENT OF FAIR EMPLOYMENT
& HOUSING
GD.\lEHliiDB-EDMUliiD_G.JlElOWN,JH.
DIRECTOR KEVIN KISH
2218 Kausen Drive. Suite 100 I Elk Grove I CA I 95758

800-884-1684 I TDD 800-700-2320
www.dfeh.ca.gov I email: contact .center@dfeh.ca. gov
April 26, 20 I 5
Amnon Siegel
1999 A venue Of The Stars
Los Angeles California 90067
RE: Notice to Complainant or Complainant's Attorney

DFEH Matter Number: 540184-156645
Right to Sue: King I ATandT Services Inc.
Dear Complainant or Complainant's Attorney:
Attached is a copy of your complaint of discrimination filed with the Department of Fair
Employment and Housing (DFEH) pursuant to the California Fair Employment and Housing
Act, Government Code section 12900 et seq. Also attached is a copy of your Notice of Case
Closure and Right to Sue. Pursuant to Government Code section 12962, DFEH will not serve
these documents on the employer. You or your attorney must serve the complaint. If you do not
have an attorney, you must serve the complaint yourself. Please refer to the attached Notice of
Case Closure and Right to Sue for information regarding filing a private lawsuit in the State of
California.
Be advised that the DFEH does not review or edit the complaint form to ensure that it meets
procedural or statutory requirements.
Sincerely,
Department of Fair Employment and Housing
& HOUSING
DIRECTOR KEVIN KISH
2218 Kausen Drive, Suite 100 I Elk Grove I CA I 95758

800-884-1684 I TDD 800-700-2320
www.dfeh.ca.gov I email: contact.center@dfeh.ca.gov
April 26, 2015

RE: Notice of Filing of Discrimination Complaint
Right to Sue: King I A TandT Services Inc.
To All Respondent(s):
Enclosed is a copy of a complaint of discrimination that has been filed with the Department of
Fair Employment and Housing (DFEH) in accordance with Government Code section 12960.
This constitutes service of the complaint pursuant to Government Code section 12962. The
complainant has requested an authorization to file a lawsuit. This case is not being investigated
by DFEH and is being closed immediately. A copy of the Notice of Case Closure and Right to
Sue is enclosed for your records.
Please refer to the attached complaint for a list of all respondent(s) and their contact information.
No response to DFEH is requested or required.

Sincerely,
SIAIE.OE CALIEOONIAJJlusiness. Consumer..Sentices_andJ:jousina.Aaency
& HOUSING
GQEilliOREDMUND.G.JlRQIAIN_JR_
DIRECTOR KEVIN KISH
2218 Kausen Drive. Suite 100 I Elk Grove I CA I 95758

800-884-1684 I TDD 800-700-2320
www.dfeh .ca.gov I email : contact.center@dfeh.ca.gov
April 26, 2015

Knoyme King
1817 N. Evergreen St.
Burbank California 91505
RE: Notice of Case Closure and Right to Sue

Right to Sue: King I ATandT Services Inc.
Dear Knoyme King,

This Jetter informs you that the above-referenced complaint was filed with the Department of Fair
Employment and Housing (DFEH) has been closed effective April 26, 2015 because an immediate Right
to Sue notice was requested. DFEH will take no further action on the complaint.
This letter is also your Right to Sue notice. According to Government Code section 12965, subdivi sion
(b), a civil action may be brought under the provisions of the Fair Employment and Housing Act against
the person, employer, labor organization or employment agency named in the above-referenced
complaint. The civil action must be filed within one year from the date of this Jetter.
To obtain a federal Right to Sue notice, you must visit the U.S. Equal Employment Opportunity
Commission (EEOC) to file a complaint within 30 days of receipt of this DFEH Notice of Case Closure
or within 300 days of the alleged discriminatory act, whichever is earlier.
Sincerely,
GQ'LEHNORQMllliQGJlR~JH_

2218 Kausen Drive, Suite 100 I Elk Grove I CA I 95758
800-884-1684 I TOO 800-700-2320
www.dfeh .ca.gov I email : contact.center@dfeh.ca.gov
Enclosures
cc: ATandT Inc.
ATandT Inc. Randall Stephenson
ATandT Inc. Joyce Roche
ATandT Inc. John Stankey
ATandT Services, Inc. Aaron Slator
ATandT Services, Inc. Ryan Smith
Daniel York
Jeff Weber
&
HoUSING
DIR EC TOR KEVIN KISH
COMPLAINT OF EMPLOYMENT DISCRIMINATION
BEFORE THE STATE OF CALIFORNIA
DEPARTMENT OF FAIR EMPLOYMENT AND HOUSING

Under the California Fair Employment and Housing Act
(Gov. Code, 12900 et seq.)
4
5
6
7
8
9
In the Matter of the Complaint of

Knoyme King, Complainant.
1817 N. Evergreen St.
Burbank Californi a 91505
DFEH No. 540184-156645
vs.
10
11
12
ATandT Services Inc. Respondent.

1880 Century Park East
Los Angeles, California 90067
13
14
Complainant all eges:
15
I. Respondent ATandT Services Inc. is a Private Employer subject to suit under the Californi a Fair
Employment and Housing Act (FEHA) (Gov. Code, 12900 et seq.) . Compl ainant believes respondent is
su bject to the FEHA.
16
17
18
19
20
21
2. On or around April17, 2015, complainant alleges that respondent took the following adverse action s against
complainant: Discrimination, Harassment, Retaliation Denied a work environment free of discrimination
and/or retaliation, Denied equal pay, Denied promotion, Other, Stripped of job duties. Complainant
believes respondent committed these actions because of their: Age- 40 and over, Association with a member
of a protected class, Color, Engagement in Protected Activity, Race, Sex- Gender .
3. Complainant Knoyme King resides in the City of Burbank, State of California. If complaint includes corespondents please see below .
22
-5Complaint- DFEH No. 540184-156645
H9021
Date Filed : April 26, 2015
2
3
Co-Respondents:
ATandT Inc.
208 S. Akard St.
Dallas Texas 75202
4
5
7
8
9
10
II
12
ATandT Inc.
Randall Stephenson
208 S. Akard St.
Dallas Texas 75202
ATandT Inc.
Joyce Roche
208 S. Akard St.
Dallas Texas 75202
ATandT Inc.
John Stankey
208 S. Akard
Dall as Texas 75202
ATandT Services, Inc .
Aaron Slator
13
14
15
16
17
ATandT Services, Inc.

Ryan Sm ith
Daniel York
2330 East Imperial Hwy
El Segundo California 90245
18
19
Jeff Weber
9665 Wi lshire Blvd ., 2nd Floor
Beverly Hills California 90212
20
21
22
-6Complaint-DFEH No. 540184-156645
Date Fi led: April 26, 2015
2
3
5
6
7
8
9
10
I1
12
13
14
15
16
17
18
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20
Additional Complaint Details:

While employed by ATandT Services, Inc., Plaintiff Knoyme King was denied a
workplace free from discrimination and harassment, denied equal pay, denied
promotions, and stripped of job duties due to her race, age and sex. King was given
lower raises than similarly situated white employees, was denied promotions that
instead went to lesser-qualified, younger, white employees who were engaged in
romantic relationships with the person making hiring decisions, and was stripped of job
duties because of her race and because of her association with other African American
employees. The statements and conduct of Kings superiors (including Defendants
Slator, Weber and York) constitute direct evidence of discrimination in violation of
FEHA. Among other things, Defendant York told King that it was "too late" for King to
go any further at ATandT, Defendant Weber treated King less favorably than employees
with whom he was engaged in sexual relationships, and Defendant Slator told King she
was "too old" to succeed at ATandT, pushed another African American employee out of
the company, and transmitted racist images from his company-issued cell phone, which
King and other African American employees were given access to , and Defendant
Smith perpetuated Defendant Slators discriminatory attitude and conduct, among other
discriminatory acts. Defendants also retaliated against King when she complained of
perceived FEHA violations, including discrimination and harassment on the basis of
race , age and sex. Defendants ATandT Inc. , Roche, Stephenson and Stankey aided
and abetted Defendant Slators FEHA violations. These Defendants knew that Slator
had engaged in the above-described discriminatory and harassing conduct and had
seen or knew of the racist images on Slators company phone. Defendants ATandT
Inc., Roche, Stephenson and Stankey gave substantial assistance and encouragement
to Slator by engaging in a widespread, illegal cover-up to hide Slators racist conduct.
Defendant ATandT Services, Inc. failed to take reasonable steps to prevent
discrimination, harassment and retaliation in violation of FEHA, including by failing to
take appropriate steps to train its employees and supervisors, by failing to enforce antidiscrimination and harassment policies, failing to investigate complaints of harassment
and discrimination, and failing to take prompt and appropriate disciplinary action,
including against Defendants York, Slator, and Weber.
21
22
-7Complaint- DFEH No. 540184- / 56645
H902 1
Date Fi led : Apri l 26, 20 15
VERIFICATION
2
3
4
I, Amnon Siegel, am the Attorney for Complainant in the above-entitled complaint. I have read the foregoing
complaint and know the contents thereof. The same is true of my own knowledge, except as to those matters
which are therein alleged on information and belief, and as to those matters , I believe it to be true.
On April 26, 2015, I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct.
Los Angeles, CA
Amnon Siegel
7
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12
13
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22
-8Complaint- DFEH No. 540184-156645
H 9021
Date Filed: April 26,2015

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CONFORMED COPY

Supe>for Cdort Ot C:olll~,nl

1 LOUIS R. MILLER (State Bar No. 54141)

7 Attorneys for Plaintiff Knoyme King

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES, CENTRAL DISTRICT

KNOYME KING, anindividual,

(1) UNLAWFUL DISCRIMINATION ON

14 AT&T SERVICES, INC., a Delaware

(2) UNLAWFUL HARASSMENT ON THE

(7) AIDING AND ABETTING FEHA

(8) FAILURE TO PREVENT

(9) INTENTIONAL INFLICTION OF

(10) NEGLIGENT INFLICTION OF

DEMAND FOR JURY TRIAL

Plaintiff Knoyme King, a 50-year-old African American woman, has worked at

harassment by senior AT&T executives (all of whom are White males).

(attached as Exhibits A & B hereto):

racial bigotry in his place of employment.

As AT &T's President of Content and Advertising Sales, Slator has a powetful

also has the power to hire and fire employees.

Slator' s discriminatory animus is part of a course of conduct at AT&T that has

Indeed, AT&T Inc.'s board members and high-level executives-including Defendants

12 short shrift due to the color of her skin.

16 promotions that went to lesser-qualified, younger, non-African American employees; given

of the company under the guise of taking "early retirement."

The hostile workplace under Slator is a continuation of his predecessors '-

who were often engaging in romantic affairs with the boss.

an employee of Defendant AT&T Services, Inc., located in Los Angeles, California.

up by a Board of Directors, which is responsible for establishing and enforcing company-wide

for the damages suffered by King.

JURISDICTION AND VENUE

Pursuant to Article VI, section 10 of the California Constitution, subject matter

King worked and was paid.

team in February 2005.

In her role as Content Coordinator, King is responsible for handling vendor

In her 30 years at AT&T, King has received consistently positive reviews-

Human Resources, did King begin to receive negative feedback.

AT &T's Top Executives Have a Practice of Discriminating on the Basis of Race

During Defendant York's tenure as AT&T's President of Content and Advertising

27 job duties and paying him more money than Willougby.

AT&T hired an African American woman as Executive Assistant to the President

American female with whom Slator was romantically involved.

non-African American mistress, Susie Becerra, in her place.

EA Sees the Racist Images on Slator's Phone

referring to it as an "oldie but goodie." Ex. C.

subjected to these racist words and images.

3 promotions and raises are infected by his racism.

EA disclosed the offensive images and messages to AT&T, including to an AT&T

in a deliberate cover-up of Slator' s racism.

Lesser-Qualified, Younger, Non-African American Mistress

2014, EA left AT&T.

EA no longer could endure Slator's discrimination and harassment, and, in January

and had performed EA' s duties in the past.

Slator had no intention of considering King's candidacy. He had already promised

ensure the position would be filled on objective, non-discriminatory terms.

After EA Left, Slator Mistreated King

14 that she thought Slator might strike her.

King Receives Smaller Raises Than Her Non-African American Colleagues

In addition to being denied promotional opportunities, King has been discriminated

than her white counterparts.

In 2013, King complained to AT&T's EEO Consultant, Stephanie Davis, telling

3 commensurate with the raises her non-African American colleagues received.