Wendy Williams

FEPA
Ac! Stalcmontbclorecomploling
Ihis form is affectedbv tha Ptivtcy Act of 1974: SeePrivacy
this brm.
New York State Division
NUMBEB
CHAFGE
AGTNLY
UNAHUEUT UIIiUHIMINAIION
EEOC
of Human RighEs
NAMEllndicataMr., Ms., Mrs'l
SPence
M s . Nic ole
wHO
AGENc/
srATEoRLocALGovERNMENT
CoMMITTEE,
AppBENTtcEsHtP
AGENcy,
€MproyMeNT
,strrE EtrpLtER,rJgos oRoANrzATnN,
AtNsT@
0TSCF|M|NATEO
-*ED
^G
NAME Inner City
C o rP .' W B L S
Bro a dc as Ling
TELEPIfONE
flnclud.At o Cod.l
MEMSERS
IUMEEFOFEMPLOYE€5,
100+
FM
COUNTY
ANDAP COOE
CIW. STATE
STRESIADDRESS
New York
New York, New York
NUMBEFilncludo Ana Codcl
TELEPHONE
NAME
W B L S-F M 1 0 7 .5
c /o
Wendy W illiam s ,
MH Z
CITY,STATEANDAP COO€
STFEEIAODRESS
New York,
New York
TOOKPLACE
TEDISCRIMNATON
BASEDON (Chcckeppropriatabxlasll
CAUSEOFOISCFIMINATION
D( se< [-lneucor
XJruarronelonrcr't
l-Jorsnsruw norHER(spacifv)
l--lnce
l-lnnce f]coton
Flnrr*nrol
CONNNUINGACTION
THEPARTf
CULARSAAEltf tdditiontl papor i, neodcd,.ntch cxtn sht€tltll:
P 1eas e S ee AE Ea e h e d S u PP l e me n t
-. |
llnn
liltlf
A q..i ' . ( ' .
r
/g
Lv.t
t
| -
EEoC-trrY00-cHTtu
want thls chargo filed whh borh the EEOC.nd thr St.to or locafAgenry, il rny.
witl advicethc agenc'nsif I chsng€my address or talcphoncnumberrnd I will
:ooperat.fully with lhrm anth€ processingof my chargain rccordencswith
heirprocedures,
|,qI^ry1$,*:
nscosstryiot Statstnd
chrryooncthrt it is tructo(h0
hovqrsadlhootrove
declcreunder psnrlty of pe.iuryrhar the foregoingis |ru6 lnd correct.
I
l+
.-r
*,,j i'rrfn,l,
EocroAtur
s ihev..sdrr
##f#dk##,MarHrsoArE
monrh,.ntl.f?tv
7oa-L...
H*Jelv
Ptav lSigtututel
n.
'---vinbrrfie-eeFnqe
SUPPLEMENTTO EEOCCHARGEOF DISCRIVIINATION
BY NICOLE SPENCE
Beckground
l. In or aboutAugust 2004,1beganworking for WBLS-FM (*WBLS") as an intern
for the radio program"The Wendy WilliamsExperience."WBLS is a radio
stationthat is ownedby InnerCity BroadcastCorporationHoldings,Inc., ("lnner
City") (WBLS and Inner City are hereinafterreferredto as the "Company").
Wendy Williams is an employeeof the Companyand a well-knownradio
personalityand celebritywhoseprogramairsweekdayson WBLS from 2:00 p.m,
to 7:00p.m,
2. Because0f my exemplarywork pcrformance,in or about May 2006, I was
promotedto the position of Talent Booker/Publicist,also known as Talent
Producer,for "The Wendy Williams Experience."In my role asTalentBooker,I
was primarily responsiblefor bookingandcoordinatingthe gueststhat would
appearon the show and preparingguestsfor their appearance.For example,I
preparedbackgroundinformation and draftedthe on-air questionsfor Ms.
Williams to askthe guests,I alsojoined the guestsin the studiofrequentlyand
spokeon the air duringthe program.
3. During my employmentwith the Company,Iperformedand continueto perform
my job with the highestdegreeof professionalismand competence.I consistently
excellentwork performance
at the Companyand havenever
demonstrated
perfbrmance
receivedany negative
evaluation."The Wendy Williams
Experience"receivesthe top ratingsfor manydemographics
during the afternoon
slot and hcr show is syndicatedto stationsacrossthe United States.Becausethe
guestsof the show and the diaioguebetweenMs. Williams and the guestsare
critical to the program,my work productunequivocallycontributedto this
success.
4, Despitemy exemplarywork perlbrmance,I have beensubjectedto an ongoing
workenvironment
hostile
duetomygender.
Moreover,
whenI complained
about
the hostilework environment,Ms. Williams and the Companyunlawfully
retaliatedagainstme by, amongotheracts,strippingme of my job duties.
The Severeand PeryasiveSexualHarassment
5. Throughoutmy employmentwith the Company,Kevin l{unter, Ms. Williams'
husband
andmanager,
subjected
me[0severe
harassment.
andpervasive
sexual
For example,Mr. Hunterrepeatedlysexuallypropositionedme at work, in the
most crude and vulgar ways, telling me over and over that he wanted to "fuck"
me.
intotheobsessive,
andduringthe
his sexualpropositions
escalaied
6. Recently,
toldmeof his desireto "fuck"
workdayat theCompany's
studio,heconstantly
withme'
sleeping
about
droaming
m0andthathehadbeen
7. Mr. Hunteralsomadedemeaningpersonalcommentsto me, includingthat I
needed"a real man in my life to mold me into the woman that I am supposedto
be," proclaiming, of course,that he was that man.
8. He hasalsorepeatedlydegradedme andotherwomenin the workplaceon the
basisof our genderby, amongotherthings,openlyrefening to us as "bitches."
9. Ms. Williams, for her part,hasaidedand abettedthe harassment
and abusethat I
and otherfemaleemployeesweresubjectedto by her husbandand manager,Mr.
Hunter,and evenofferedto takeme shoppingso I could dress"like a sexy iittle
bitch" as Mr. Hunterdemanded.In fact,Ms. Williams' Iack of respectfor proper
workplaceconductis demonstrated
by her own conductin forcing a subordinate
to havesex with her to keephisjob.
10.WhenI refusedto give in to Mr. Hunter'sconstantsexualdemands,
his conduct
becameincreasingoffensive,hostileandthreatening.
I l. Mr. Hunteraiso openlyinsultedme in the workplace,includingby deridingme
for my Jamaicanbackground. For example,he told me that I was not cute but in
fact was "just Jamaican."
PhysicalThreats and Acts of Violence
12.In addition,Mr, Hunterhassoughtto enlistotheremployees
in his harassment,
includingLeonard"Charlamagne"
McKelvey,who is Ms. Williams' co-hoston
"The Wendy Williams Experience."With respectto me, Mr. Huntertold Mr.
McKelvey
to/'get
ather,"
into
bitch's
head"
to"fuck
he/'inorder
to"get
that
to
"break her down physically and mentally" and to ensurethat she "did not forget
whereshecamefrom," He alsotold Mr. McKelvey to "keep your foot on her
throat."
13.Mr, Huntercoupledthesehorrifyingstatements
with escalatingverbalabuse,
includingfrequentlyreferringto me asa "stupidfucking bitch" in the presenceof
otheremployees,which I found deeplyoffensiveandhumiliating.
14.He also physicallythreatened
me. Specifically,on one occasionafter Ms.
Williams
andherco-hosts
consumed
alcoholic
beverages
duringtheshow,
Mr.
Hunterchargedat me while threateningto inflict physicalharm uponme. I also
fearedMr. Hunterbecausehe repeatedlyphysicallyassaultedMs. Williams at or
nearthe WBLS studio, In one instance,Mr. Hunterstormedinto the studio,
demandedthat the otheremployeesleaveandopenlyphysicallyabusedMs.
Williams, pinning her againstthe wall with his handaroundher neck,chokingher
while repeatedlypoundinghis frst into the wall directlyby her head. In another
incident,Mr. HunterreportedlypunchedMs. Williams in the faceand violently
attackedher in the parkinglot acrossthe streetfrom WBLS, r.vhichis frequently
employgoo,
byCompany
used
did notpreventsimilar
theCompany
actsof violence,
15.Despitetheserepeated
by Mr. Hunter,In fact,the
andoutbursts
futureincidents
of physicalintimidation
notonlyfailed
andunlawfulconduct,
awareof Mr, Hunter'simproper
Company,
to takesufficientstepsto stopit, butgavehim freereignoverthestudioand
to sexuallyharass
meandotherwomen.Indeed,at onepoint,
unfettered
access
inthe
interns
thatfemale
thrsat
oftermination,
under
even
demanded,
Mr.Hunter
office wear bathingsuitsin the workplace.
includinghis repeateddemandsfor sex,occurred
16.Mr. Hunter'ssexualharassment,
in plain view and was witnessedby numerousCompanyemployces,includingtop
management,
admittedthat she
17.By way of exampleonly, CatriceAllen of HumanResources
proposition
personally
mein theworkplace,
and
heardMr. Hunter
sexually
warnedme to watchout for Mr. Hunterbecausehe was boastingthat he wantedto
"fuck" me,
in Mr. Hunter'segregious
18.The Companysimply ignoredand evenacquiesced
conducttowardsme and other femaleemployees,apparentlyto placateMs.
amountof revenuesfor the
Williams, whoseprogramgenerates
a substantial
Company.
My RepeatedComplaints and the Company's Failure to Act
19,I complainedaboutMr. Hunter'ssexualdemands,vulgar commentsand other
improperconductto Vinny Brown, who wasthe ProgramDirectorat WBLS until
lastmonth. However,Mr. Brown failed to takeany remedialactionor do
anything about the matter. Without the Company'sintervention,I, along with the
otherfemaleemployees,continuedto endurean environmentin which we were
subjectedto pervasivesexualharassment,
fearedfor our own physicalsafetyand
sufferedemotionaldistress,
20. On or aboutFebruary19,2008,I complainedaboutMr. Hunterto CynthiaSmith,
the AssistantProgramDirector,afterbecomingincreasinglyafraidof him. Ms.
Smith told me to bring my concernsto DeonLivingston,the Vice Presidentand
for
General
Manager
0fWBLSI advised
Mr,Livingston
thatI was
oonserncd
my safetyduc to Mr. Hunter'sviolent andunlawful behavior. I also told Mr.
Livingstonaboutmy prior complaintto Vinny Brown.
submitted
a
otFebruary
20,2008,1also
to theseverbalcomplaints,
21.In addition
at'theCompany.In my complaint,I
writtencomplaintto l{umanResources
andstatedthatI was"afraidof
againdescribed
Mr. Hunter'ssexualharassment
womanor anabused
child."
him" andfelt like "a battered
whofiledwrittenand/orverbalcomplaints
22.1amnottheonly femaleemployee
Mr.Hunter.
about
23. Only afterhaving receivedrepeatedcomplaints,includingmy written complaint
on February20, did the Companytake any action at all, which proved to be
completelyinadequate.For example,asan ineffectiveresolutionto the threats,
violence,sexualharassmentand verbalabusedescribedabove,Mr. Livingston
temporarilybannedMr. Hunterfrom the officesof WBLS. I continueto feel
vulnerablehowever,as the duration andefficacy of this "ban" is unknown.
24. Moreover, Mr. Hunter was neveremployedby WBLS or officially "authorized"
to accessCompanypropertyin the first place,yet he wasallowedto enterthe
workplace
make
ashepleased
andopenlyutterand/oryellobscenities
andthreats,
vulgarsexualand otherderogatorycommentsand engagein sexualharassment.
In addition, the Companyhasnot communicatedto me how long this ban will be
in effectnor hasit takenstepsto preventme from on-goingharm from others,
includingMs. Williams. In fact, aftermy complaints,I havebeensubjectedto
blatanlactsof unlawful retaliation.asdescribedbelow.
Unlawful Retaliationby the Companyand Ms. Williams
25. Immediatelyafter I sentmy written complaintto Mr. Livingston,the Companyre-
located
mydesk
awayfromthestaffof"TheWendy
Williams
Experience,"
The
move wasa retaliatoryact,punishingme by moving me awayfrom the on-going
contactwith and on-air participationin the show,which underminedmy position
at the Company and as a talent booker in the industry. Moreover, this action by
the Companysignaledto Ms. Williamsthat I was the employeewho complained
about her husband.
26. Consequently,in a further act of retaliation,Ms. Williams now refusesto work
witl, acknowledgeor evenspeakto me andhassummarilyrejectedall guests
bookedby me without explanation. Shehasalso actedtowardsme in a hostile
manner. Theseactionshave severelydamagedmy ability to effectively perform
my duties,as well as my repulationandcareeras a talentbooker.
27. On February27 and28,2008,I againcomplainedto the Company,reportingthat
I booked
toallowtheguests
Ms,Williams
mcbyrefusing
wasretaliating
againol
to comeonto the show.
28. In anotherineffectiveresponseby the Company,Ms. Williams was suspended
for
two days,but upon information and belief, was not formally counseledor even
advisedasto why shewas suspended.As a result,when Ms. Williams returned,
shecontinuedto refuseto dealwith meandstill refusesto placemy guestson the
show.
Ms. Williams
to my reputation,
damage
causesevere
29.lnfact,to intentionally
lessthanone
anynotice,sometimes
withoutpractically
ordersmeto cancelguests
on theair andwhiletheyarewaiting
to appear
hourbeforetheguestis scheduled
to go on hershow. For example,Ms. Williamsrecentlyrejectedonesuchguestat
eventhoughthatguesthadbeenbookedfor
thelastminutewithoutjustification,
to beon hershowandwaswaiting
way
from
Florida
wggk5,travEledall the
inthelobby,
downstairs
shehasthreatenedand
30, Moreover,upon Ms. Williams' returnfrom suspension
me on the air. On March 3, Ms, Williams beganher show to the
embarrassed
soundsof gun shotsstating,in substance,
"You thoughtyou got me but I'm still
standing." This blatantact of intimidationhonified me as I againfearedfor my
job, safetyand further retaliation. I againcomplainedto Mr. Livingston, Human
Resourcesand other Companymanagement,all to no avail.
3 I . In addition,a coupleof daysagowhen I escorteda guestinto the studioduringa
broadcast,Ms, Williams orderedme to leavethe studiowhile on the air. As
listenersand industrycolleaguesarewell aware,I typically stay in the studioor
eventalk when I bring guestsin. Now becauseI complainedabouther husband's
sexualharassment,vulgar commentsand acts of physical intimidation, I was
dismissedand openly embarrassedin front of the entire radio audience. I also
complainedaboutthis conductto Mr. Livingston, who did absolutelynothing
aboutit.
32, In responseto my continuedcomplaints,the Companyhasnot disciplinedMs.
Williams or takenstepsto protectme from furtherretaliation. Instead,the
Mr,
specifically,
More
onlyincrca$ed,
moha$
rstaliation
being
committcd
against
Livingstonrecentlyinstructedme to preparea job descriptionfor my position,a
highly unusual,andobviouslypretextual,stepgiven that I havebeenemployedby
the Companyfor four yearswithout a formaljob description.After I complied
with his request,Mr. Livingstonhassystematically
removedtasks,including
more prestigiouswork, I had previouslyperformed.For example,my booking
dutiesweretakenaway from me and givento an individualwho was not even
employedby or affiliatedwith the Company,which waspurelyretaliatory.
33. Becausemy talent booking taskswere reassignedwithout explanation,I have
receivednumeroustelephonecalls from publicistsand othersin my industry, who
believedthat I was terminatedby the Company. Thus, the stripping away of my
duties
has
further
damaged
mycareer.
34. When I againcomplainedto the Companythat my dutieshavebeenunjustly
takenaway,the Companyhasfailed to takeany remedialaction. In fact, Mr.
Livingstonactuallyconfirmedthat the executiveproducerof Ms. Williams' show
insteadof me,asperMs,
wouldnowhandlethetalentbookingresp-onsibilities
Williams'instructions,
35. It is clear that Ms. Williams, Mr. Livingston and others at WBLS are attempting
to force me out of the Company in retaliation for my complaints.
36.Needless
to say,I amdevastated
by theunlawfulactionstakenagainstme. I have
suffered,andcontinueto suffer,severeemotionaldistressasa resultof the
my
me.Inaddition,
committed
against
abusive
sexual
harassment
andretaliation
successful
careerhasbeenineparablyharmedbecause
of theunlawfulretaliation
by theCompanyandMs.Williams.
37.Therefore,
I file thisChargeon behalfof myself,aswell asanyotherfemale
Companyemployees
whohavebeendiscriminated
andretaliatedagainst,and
requestall availableandappropriate
relief.