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1 John M. Begakis, Esq. (SBN 278681)
Sheena B. Tehrani, Esq. (SBN 326373)
2 ALTVIEW LAW GROUP, LLP
9454 Wilshire Blvd., Suite 825
3 Beverly Hills, California 90212
Tel: (310) 230-5580
4 Fax: (562) 275-8954
5 Attorneys for Plaintiff
ALEX GOODE, an individual
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF LOS ANGELES
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ALEX GOODE, an individual, ) Case No.
11 )
Plaintiff, ) UNLIMITED CIVIL CASE
12 v. ) (DEMAND EXCEEDS $35,000)
)
13 BONGO, LLC, a Delaware limited liability ) COMPLAINT FOR:
company; 3 BALL PRODUCTIONS LLC, a )
14 Delaware limited liability company; )
PARAMOUNT GLOBAL, a Delaware ) 1. SEXUAL HARASSMENT IN VIOLATION
15 corporation; JONATHAN TAFFER, an ) OF CALIFORNIA FAIR EMPLOYMENT
individual; and DOES 1 through 10, ) AND HOUSING ACT – HOSTILE WORK
16 inclusive, ) ENVIRONMENT
) 2. FAILURE TO PREVENT HARASSMENT
17 Defendants. ) IN VIOLATION OF CALIFORNIA FAIR
) EMPLOYMENT HOUSING ACT
18 )
) 3. CONSTRUCTIVE DISCHARGE
19 ) 4. NEGLIGENT SUPERVISION
) 5. INTENTIONAL INFLICTION OF
20 ) EMOTIONAL DISTRESS
) 6. BREACH OF CONTRACT
21 ) 7. UNLAWFUL BUSINESS ACTS &
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) PRACTICES
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)
23 ) [Demand For Jury Trial]
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COMPLAINT
1 COMES NOW, plaintiff ALEX GOODE, an individual, hereby submits the following
2 unverified Complaint (the “Complaint”):
3 THE PARTIES
4 1. Plaintiff ALEX GOODE (“Plaintiff”) is, and at all times herein mentioned was, an
5 individual residing in the County of Los Angeles, State of California.
6 2. Plaintiff is informed and believes and, on the basis of such information and belief,
7 herein alleges that defendant BONGO, LLC (“Bongo”) is, and at all times herein mentioned was,
8 a limited liability company duly organized and existing under and by virtue of the laws of the State
9 of Delaware, with its principal place of business located at 15301 Ventura Blvd., Suite 260,
10 Sherman Oaks, California 91403.
11 3. Plaintiff is informed and believes and, on the basis of such information and belief,
12 herein alleges that defendant 3 BALL PRODUCTIONS LLC (“3 Ball”) is, and at all times herein
13 mentioned was, a limited liability company duly organized and existing under and by virtue of the
14 laws of the State of Delaware, with its principal place of business located at 15301 Ventura Blvd.,
15 Suite 260, Sherman Oaks, California 91403.
16 4. Plaintiff is informed and believes and, on the basis of such information and belief,
17 herein alleges that defendant PARAMOUNT GLOBAL (“Paramount”), is a corporation duly
18 organized and existing under and by virtue of the laws of the State of Delaware, with its principal
19 place of business located at 1515 Broadway, 51st Floor, New York, New York 10036.
20 5. Plaintiff is informed and believes, and on the basis of such information and belief,
21 herein alleges that defendant JONATHAN TAFFER (“Taffer”) is, and at all times herein
22 mentioned was, an individual residing in the County of Los Angeles, State of California.
23 6. The true names and capacities of DOES 1 through 10, inclusive, whether individual,
24 corporate, associate or otherwise, are unknown to Plaintiff at this time, who therefore sues said
25 defendants by such fictitious names, and when the true names and capacities of such defendants
26 are ascertained, Plaintiff will ask leave of Court to amend this Complaint to insert the same.
27 7. Plaintiff is informed and believes and, on the basis of such information and belief,
28 herein alleges that each defendant named in this Complaint was, at all times herein mentioned, and
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COMPLAINT
1 now is, the agent and employee of each of the other defendants herein, and was at all times acting
2 within the course and scope of said agency and employment. When referring to “Defendants”
3 herein, Plaintiff intends to include Bongo, 3 Ball, Paramount, Taffer, and all other defendants.
4 JURISDICTION AND VENUE
5 8. Pursuant to California Code of Civil Procedure (“CCP”) § 410.10, this Court has
6 jurisdiction over Defendants because each Defendant is a person or business entity that is a resident
7 and/or business entity that is established, incorporated, and/or has sufficient minimum contacts
8 with the State of California so far as to render exercise of jurisdiction over Defendants consistent
9 with traditional notions of fair play and substantial justice. Further, damages exceed the
10 jurisdictional minimum of this Court.
11 9. Pursuant to CCP § 395.5, venue is proper in this Court because Defendants’ liabilities
12 and obligations to Plaintiff arose in the County of Los Angeles.
13 FACTS COMMON TO ALL CAUSES OF ACTION
14 10. Plaintiff is an actor, digital media content creator, and professional mixologist, who
15 has appeared as a recurring expert mixologist on multiple seasons of the Television series Bar
16 Rescue (the “Series”).
17 11. On or about April 24, 2022, Plaintiff and Defendant Bongo, a producer of the Series,
18 entered into a “Crew Deal Memo” (the “Agreement”), whereby Plaintiff agreed to appear on the
19 Season 8.5 of the Series pursuant to the terms thereof.
20 12. Section 16 of the Agreement set forth Bongo’s explicit obligation to prohibit
21 “harassment by co-workers, supervisors, managers, and other parties with whom the employee
22 comes into contact.” The Agreement also defined harassing conduct to include “verbal, physical,
23 and visual conduct that creates an intimidating, offensive, or hostile working environment or that
24 interferes with an employee’s work performance.” A true and correct copy of the Agreement is
25 attached hereto as Exhibit “A” and incorporated herein by this reference.
26 13. Despite this obligation, Bongo and all other Defendants failed to prevent Defendant
27 Taffer from engaging in ongoing and pervasive harassing and discriminatory conduct towards
28 Plaintiff and others on set. Specifically, after filming a scene on or about September 14, 2022,
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COMPLAINT
1 Taffer cornered Plaintiff in a physically intimidating manner, and verbally berated him in front of
2 colleagues for wearing his long hair down. Among other despicable actions, Taffer called Plaintiff
3 “disgusting,” engaged in gender stereotyping by attempting to humiliate Plaintiff simply because
4 he believed the length and style of Plaintiff’s hair made him less masculine, and encouraged others
5 to join in verbally attacking Plaintiff.
6 14. Following the incident, Plaintiff struggled to complete his scene work with Taffer.
7 Accordingly, on or about September 20, 2022, Plaintiff submitted a detailed complaint outlining
8 the incident and his concerns to Defendant 3 Ball. After 3 Ball interviewed Plaintiff, Defendant
9 Paramount took over responsibility and began an investigation on or about September 26, 2022.
10 15. Despite conducting multiple interviews with other witnesses, and despite
11 Paramount’s admission that Taffer’s behavior violated Company policy, Paramount sent a
12 lukewarm closure letter to Plaintiff on or about November 3, 2022, summarily declaring that
13 “appropriate action” had been taken. Paramount provided no assurances that Taffer’s harassing
14 behavior would cease, and offered no details about what corrective action had or would be taken
15 to ensure a workplace free of harassing conduct. Paramount offered only a personal apology from
16 Taffer, which Plaintiff made clear did not, without more, relieve him of the discomfort and anxiety
17 he experienced from his work with Taffer on the Series.
18 16. As a result of Taffer’s conduct, and the culture of fear Defendants have perpetuated
19 through the creation of a hostile work environment on the Series, Plaintiff is unable to return to
20 work on the Series, and has suffered significant emotional distress.
21 17. On or about September 8, 2023, Plaintiff obtained a Right to Sue letter from the
22 Department of Fair Employment and Housing. Plaintiff has therefore exhausted his administrative
23 remedies to pursue claims under the Fair Employment and Housing Act (“FEHA”). A true and
24 correct copy of Plaintiff’s Right to Sue letter is attached hereto as Exhibit “B” and incorporated
25 herein by this reference.
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COMPLAINT
1 FIRST CAUSE OF ACTION
2 Harassment In Violation of FEHA, Cal. Gov. Code § 12940, et seq.
3 Hostile Work Environment
4 (By Plaintiff Against All Defendants)
5 18. Plaintiff repeats, realleges, and incorporates herein by this reference each and every
6 allegation contained in ¶¶ 1 through 17, inclusive, as though set forth in full herein.
7 19. As alleged herein, Plaintiff was subject to unwanted, harassing conduct from Taffer
8 that, for Plaintiff as well as any reasonable person in Plaintiff’s circumstances, was so severe and/or
9 pervasive as to alter the terms and conditions of his employment with Defendants, making the
10 conditions of such employment intolerable, in direct contravention of Government Code § 12940,
11 et seq. (i.e., “FEHA”).
12 20. Following the incident, on or about September 20, 2022, Plaintiff submitted a
13 detailed complaint outlining the incident and his concerns to 3 Ball. However, Plaintiff was never
14 apprised of any immediate corrective measures taken by Defendants to prevent such sexual
15 harassment. As a result of such failure, which Plaintiff is informed and believes and, on the basis
16 of such information and belief, alleges was a substantial factor in causing Plaintiff’s harm, Plaintiff
17 was left with no recourse to relieve him of the discomfort and anxiety he experienced from his
18 work with Taffer on the Series.
19 21. Defendants are liable for Taffer’s conduct in furtherance of creating a hostile work
20 environment, which conduct occurred during the Series and therefore in a work-related context,
21 because Defendants knew or should have known of such conduct and failed to take immediate and
22 appropriate corrective action.
23 22. As a direct and proximate result of Defendants’ willful, knowing, and intentional
24 wrongdoing, Plaintiff has sustained and continues to sustain damages, including the loss of
25 earnings and benefits, in an amount to be determined according to proof at trial, but exceeding the
26 jurisdictional minimum of this Court.
27 23. As a direct and proximate result of Defendants’ willful, knowing, and intentional
28 wrongdoing, Plaintiff has further suffered and continues to suffer humiliation, emotional distress,
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COMPLAINT
1 and mental and physical anguish, all to his damage, in an amount to be determined according to
2 proof at trial, but exceeding the jurisdictional minimum of this Court.
3 24. Defendants’ wrongdoing was intentional, malicious, fraudulent, oppressive, and in
4 conscious disregard for Plaintiff’s rights, entitling Plaintiff to punitive and/or exemplary damages,
5 in an amount to be determined according to proof at trial, but exceeding the jurisdictional minimum
6 of this Court.
7 25. Additionally, Plaintiff has incurred and will continue to incur as yet unascertained
8 attorneys’ fees and costs. Plaintiff will therefore amend this Complaint to state the full amount of
9 those fees and costs when such amounts have been ascertained.
10 SECOND CAUSE OF ACTION
11 Failure to Prevent Harassment In Violation of FEHA, Cal. Gov. Code § 12940, et seq.
12 (By Plaintiff Against Defendants Bongo, 3 Ball, Paramount, and DOES 1-10)
13 26. Plaintiff repeats, realleges, and incorporates herein by this reference each and every
14 allegation contained in ¶¶ 1 through 25, inclusive, as though set forth in full herein.
15 27. Under FEHA, an employer is strictly liable for the harassing conduct of its agents
16 and supervisors. FEHA also requires employers to take all reasonable steps necessary to prevent
17 discrimination and harassing conduct from occurring.
18 28. As alleged herein, during the course of Plaintiff’s employment, Defendants Bongo,
19 3 Ball, and Paramount failed to prevent Taffer, who was an agent of such Defendants by virtue of
20 his role in the Series, from engaging in intentional acts that resulted in Plaintiff being treated less
21 favorably because of Plaintiff’s protected status (i.e., Plaintiff’s sex and/or gender).
22 29. Furthermore, and as alleged herein, Defendants 3 Ball and Paramount did not keep
23 Plaintiff apprised of, nor did they take, any immediate and/or sufficiently appropriate corrective
24 steps to remedy Taffer’s harassment of Plaintiff after Plaintiff notified 3 Ball and Paramount.
25 30. As a direct and proximate result of Bongo, 3 Ball, and Paramount’s willful, knowing,
26 and intentional wrongdoing, Plaintiff has sustained and continues to sustain damages, including,
27 without limitation, loss of earnings and benefits, in an amount to be determined according to proof
28 at trial, but exceeding the jurisdictional minimum of this Court.
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COMPLAINT
1 31. As a direct and proximate result of Bongo, 3 Ball, and Paramount’s willful, knowing,
2 and intentional wrongdoing, Plaintiff has suffered and continues to suffer humiliation, emotional
3 distress, and mental and physical anguish, all to his damage, in an amount to be determined
4 according to proof at trial, but exceeding the jurisdictional minimum of this Court.
5 32. Bongo, 3 Ball, and Paramount’s conduct was intentional, malicious, fraudulent,
6 oppressive, and in conscious disregard of Plaintiff’s rights, entitling Plaintiff to punitive and/or
7 exemplary damages in an amount to be determined according to proof at trial, but exceeding the
8 jurisdictional minimum of this Court.
9 33. Additionally, Plaintiff has incurred and will continue to incur as yet unascertained
10 attorneys’ fees and costs. Plaintiff will amend this Complaint to state the full amount of those fees
11 and costs when such amounts have been ascertained.
12 THIRD CAUSE OF ACTION
13 Constructive Discharge
14 (By Plaintiff Against Defendants Bongo, 3 Ball, Paramount, and DOES 1-10)
15 34. Plaintiff repeats, realleges, and incorporates herein by this reference each and every
16 allegation contained in ¶¶ 1 through 33, as though set forth in full herein.
17 35. During his employment, Plaintiff was subjected to harassment by Taffer.
18 36. As alleged herein, after filming a scene on or about September 14, 2022, Taffer
19 cornered Plaintiff in a physically intimidating manner, and verbally berated him in front of
20 colleagues for wearing his hair down. Among other actions, Taffer called Plaintiff “disgusting,”
21 engaged in gender stereotyping by attempting to humiliate Plaintiff simply because he believed the
22 length and style of Plaintiff’s hair made him less masculine, and encouraged others to join in
23 verbally attacking Plaintiff.
24 37. Following the incident, Plaintiff struggled to complete his scene work with Taffer,
25 and is unable to return to work on the Series as a result.
26 38. Accordingly, Bongo, 3 Ball, and Paramount’s conduct created intolerable working
27 conditions that led to the constructive termination of Plaintiff, in violation of FEHA.
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7
COMPLAINT
1 39. As a direct and proximate result of Bongo, 3 Ball, and Paramount’s willful, knowing,
2 and intentional wrongdoing, Plaintiff has sustained and continues to sustain damages, including
3 losses of earnings and benefits, in an amount to be determined according to proof at trial, but
4 exceeding the jurisdictional minimum of this Court.
5 40. As a direct and proximate result of Bongo, 3 Ball, and Paramount’s willful, knowing,
6 and intentional wrongdoing, Plaintiff has suffered and continues to suffer humiliation, emotional
7 distress, and mental and physical anguish, all to his damage in an amount to be determined
8 according to proof at trial, but exceeding the jurisdictional minimum of this Court.
9 41. Bongo, 3 Ball, and Paramount’s conduct was intentional, malicious, fraudulent,
10 oppressive, and in conscious disregard of Plaintiff’s rights, entitling Plaintiff to punitive damages,
11 in an amount to be determined according to proof at trial, but exceeding the jurisdictional minimum
12 of this Court.
13 42. Additionally, Plaintiff has incurred and will continue to incur as yet unascertained
14 attorneys’ fees and costs. Plaintiff will amend this Complaint to state the full amount of those fees
15 and costs when such amounts have been ascertained.
16 FOURTH CAUSE OF ACTION
17 Negligent Supervision
18 (By Plaintiff Against Defendants Bongo, 3 Ball, Paramount, and DOES 1-10)
19 43. Plaintiff repeats, realleges, and incorporates herein by this reference each and every
20 allegation contained in ¶¶ 1 through 42, as though set forth in full herein.
21 44. Plaintiff is informed and believes and, on the basis of such information and belief,
22 herein alleges that, at all relevant times, Taffer was employed by Bongo, 3 Ball, and Paramount.
23 Taffer nevertheless was, or became, unfit to perform services on the Series, as evidenced by his
24 conduct towards Plaintiff as set forth herein.
25 45. Bongo, 3 Ball, and Paramount knew or should have known that Taffer was unfit to
26 perform services on the Series, and that such unfitness created a particular risk to other cast
27 members, and possibly others.
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8
COMPLAINT
1 46. Taffer’s unfitness to perform services on the Series, as evidenced by his conduct
2 towards Plaintiff alleged herein, severely harmed Plaintiff, including, without limitation, by
3 causing Plaintiff to struggle to complete his scene work with Taffer.
4 47. Bongo, 3 Ball, and Paramount negligence in hiring and/or supervising Taffer was a
5 substantial factor in causing Plaintiff’s harm.
6 FIFTH CAUSE OF ACTION
7 Intentional Infliction of Emotional Distress
8 (By Plaintiff Against All Defendants)
9 48. Plaintiff repeats, realleges, and incorporates herein by this reference each and every
10 allegation contained in ¶¶ 1 through 47, as though set forth in full herein.
11 49. As alleged herein, Defendants engaged in extreme and outrageous conduct,
12 including, without limitation, by: (a) intentionally and/or recklessly harassing Plaintiff and/or
13 allowing such conduct to occur; (b) conducting a flawed and inadequate investigation into
14 Plaintiff’s claims of harassment (if any investigation was conducted at all); (c) failing to provide
15 harassment training for employees, which could have mitigated or even prevented the alleged
16 wrongdoing; and (d) creating, allowing for, and/or perpetuating a hostile work environment in
17 which Plaintiff did not feel safe.
18 50. As a direct and proximate result of Defendants’ willful, wanton, intentional,
19 outrageous, and malicious conduct, Plaintiff suffered severe and extreme mental and emotional
20 distress. Plaintiff does not at this time know the exact duration or permanence of said injuries but
21 is informed and believes and, on such basis, herein alleges that some of the injuries are reasonably
22 certain to be permanent in character.
23 51. As a direct and proximate result of Defendants’ conduct, and the conduct of each of
24 them, as alleged herein, Plaintiff has suffered damages in an amount to be determined according
25 to proof at trial, but exceeding the jurisdictional minimum of this Court.
26 52. Defendants’ actions were willful, intentional, malicious, oppressive, and despicable,
27 and Defendants acted with willful and conscious disregard for Plaintiff’s rights. Accordingly,
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COMPLAINT
1 Plaintiff is also entitled to punitive and/or exemplary damages in an amount to be determined
2 according to proof at trial, but exceeding the jurisdictional minimum of this Court.
3 SIXTH CAUSE OF ACTION
4 Breach of Contract
5 (By Plaintiff Against All Defendants)
6 53. Plaintiff repeats, realleges, and incorporates herein by this reference each and every
7 allegation contained in ¶¶ 1 through 52, as though set forth in full herein.
8 54. Commencing on or about April 24, 2022, Plaintiff and Bongo entered into a “Crew
9 Deal Memo” (the “Agreement”), whereby Plaintiff agreed to appear and render services on the
10 Series, pursuant to the terms thereof. Section 16 of the Agreement set forth Bongo’s explicit
11 obligation to prohibit “harassment by co-workers, supervisors, managers, and other parties with
12 whom the employee comes into contact.” The Agreement also defined harassing conduct to include
13 “verbal, physical, and visual conduct that creates an intimidating, offensive, or hostile working
14 environment or that interferes with an employee’s work performance.”
15 55. Plaintiff has performed all terms, conditions, and covenants of the Agreement.
16 Notwithstanding the terms thereof, Bongo, as well as 3 Ball and Paramount as successors and/or
17 assignees of Bongo’s rights under the Agreement, materially breached the Agreement in that they
18 have failed and refused, and continue to fail and refuse, to prevent Taffer from engaging in ongoing
19 and pervasive harassing and discriminatory conduct towards Plaintiff and others on set. As a result
20 of Defendants’ material breach, there is now due, owing, and unpaid from Defendants to Plaintiff
21 an amount to be determined at trial but exceeding the jurisdictional minimum of this Court, together
22 with interest thereon at the maximum legal rate.
23 56. As a direct and proximate result of Defendants’ material breach of the Agreement,
24 Plaintiff has suffered damages in an amount to be determined at trial but exceeding the
25 jurisdictional minimum of this Court, together with interest thereon at the maximum rate allowed
26 by law. When the true amount of such damages is ascertained, Plaintiff will seek leave to amend
27 this Complaint to allege the same.
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COMPLAINT
1 SEVENTH CAUSE OF ACTION
2 Unlawful Business Acts & Practices in Violation of
3 Cal. Bus. and Prof. Code §§ 17200, et seq.
4 (By Plaintiff Against All Defendants)
5 57. Plaintiff repeats, realleges, and incorporates herein by this reference each and every
6 allegation contained in ¶¶ 1 through 56, as though set forth in full herein.
7 58. The wrongdoing of Defendants, as alleged herein, has been and continues to be
8 unlawful and harmful to Plaintiff and the general public.
9 59. A violation of Cal. Bus. and Prof. Code §§ 17200, et seq. may be predicated on the
10 violation of any state or federal law. In the instant case, the actions of Defendants violated
11 California employment law.
12 60. Plaintiff has been personally aggrieved by Defendants’ unlawful business acts and
13 practices, as alleged herein, including, but not limited to, the loss of money and/or property.
14 61. Pursuant to Cal. Bus. and Prof. Code §§ 17200, et seq., CCP § 1021.5, and other
15 applicable laws, Plaintiff is therefore entitled to an award of attorneys’ fees and costs against
16 Defendants. Plaintiff will amend this Complaint to state the full amount of those fees and costs
17 when such amounts have been ascertained.
18 WHEREFORE, Plaintiff prays for judgment against Defendants, and each of them, jointly
19 and severally, as follows:
20 1. For the Court to declare, adjudge, and decree that Defendants violated Cal. Bus. and Prof.
21 Code §§ 17200, et seq.;
22 2. For general and special damages in an amount to be determined at trial but exceeding the
23 jurisdictional minimum of this Court;
24 3. For punitive and exemplary damages in an amount to be determined at trial but exceeding
25 the jurisdictional minimum of this Court;
26 4. For reasonable attorneys’ fees and costs in an amount to be determined at trial;
27 5. For pre- and post-judgment interest at the maximum rate allowed by law; and
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COMPLAINT
1 6. For such other and further relief as the Court may deem just and proper.
2 Dated: April 12, 2024 ALTVIEW LAW GROUP, LLP
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4 By: ____________________________________
JOHN M. BEGAKIS
5 SHEENA B. TEHRANI
Attorneys for Plaintiff
6 ALEX GOODE, an individual
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COMPLAINT
1 DEMAND FOR JURY TRIAL
2 Plaintiff hereby demands a trial by jury of all issues triable by a jury.
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Dated: April 12, 2024 ALTVIEW LAW GROUP, LLP
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By: ____________________________________
6 JOHN M. BEGAKIS
SHEENA B. TEHRANI
7 Attorneys for Plaintiff
ALEX GOODE, an individual
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COMPLAINT
EXHIBIT “A”
CREW DEAL MEMO
PRODUCTION: Bar Rescue 8.5 PRODUCER: Bongo, LLC
EMPLOYEE: Alexander P. Goode DATE: 04/24/2022
ADDRESS: PHONE:
SOC. SEC #:
POSITION/DEPT: Expert - Mixologist APPR. 04/24/2022
START:
EMERGENCY Casey Goode PHONE:
CONTACT:
BOX RENTAL:
ADDITIONAL TERMS/PROVISIONS:
HOURLY RATE: WEEKLY RATE:
Based on 0.00 per day
CONDITIONS PRECEDENT: This Agreement is an offer of employment expressly conditioned on (i) Employee’s execution of this
Agreement, (ii) in accordance with the Immigration Reform and Control Act of 1986, completion of a Form I-9 (Employment Eligibility
Verification Form) and submission of original documents proving Employee’s employment eligibility, (iii) Employee submitting to a
post-conditional offer, pre-hire detailed background check; and (iv) Producer’s approval of Employee’s background check results.
Employee’s services shall be rendered on an exclusive basis for such period of time as may be required unless otherwise specified in this
Agreement.
RATE: If a daily rate is indicated, services are for the period of hours indicated above. The daily rate, weekly rate, or hourly rate
(whichever is applicable) is paid according to hours worked per day, subject to applicable law. Weekly rates shall be prorated for any
partial weeks worked. Nothing contained herein shall be construed as a guarantee of continued employment. Time cards must be turned
in at the end of the last day of the production week. Holidays, weekends, and night work shall be paid at the same rate as regular
workdays. Start times will be determined by department head. Compensation shall be inclusive of Employee’s services in connection
with any pre-production, production, and post-production services required on the Production and Employee shall not receive any
additional compensation for any repeat broadcasts or any other exploitation of the Production. All overtime must be pre-approved by
Producer. If Employee is required to render services at a distant location, Employee shall receive coach class air travel, accommodations
(room and room tax only) and a per diem. It is specifically agreed that this is not a “pay or play” deal or run of show contract. The
Producer reserves the right to terminate Employee at any time subject only to the obligation to pay the balance of any compensation
earned by Employee but unpaid by Producer at the date of termination.
PURCHASES / RENTALS / EXPENSES: All purchases and rentals must be accompanied by Producer’s purchase order or check
request. Producer will reimburse only those petty cash expenses accompanied by original receipts. Employee acknowledges Employee
has been furnished with, understands and will comply with the petty cash procedures. Petty cash should never be used for personal
expenses. Producer is not responsible for incidental expenses incurred by Employee, including, without limitation, cellular phone charges
or parking tickets. Box or other authorized rental payments (including for the use of Employee’s personal computer, if any, as set forth
below) will be prorated for any partial week worked. A complete list of items included in rental shall be attached as an addendum to this
Agreement. If deemed necessary by Producer, Employee shall be provided with the use of a computer for Employee’s business-related
use during the period Employee is rendering services hereunder. Employee shall retain sole supervision and control of any personal items
Employee carries with him/her or rents to Producer, and Employee hereby acknowledges that Producer is not responsible for any loss
and/or damage to any such personal property. Employee is responsible for all recoverable items (e.g. expendables, equipment, etc.)
purchased, and these must be reconciled with the Accounting Department during wrap. All recoverable items will be collected at wrap.
Producer credit cards or P cards shall be issued by Producer to Employee in Producer’s sole discretion. Such credit card or P cards may
only be used to incur expenses in connection with the discharge of the cardholding Employee’s duties as an employee of Producer. Under
no circumstances may any personal expenditure be charged to such card(s). Any expenditure charged to the card should be authorized
in advance by Employee’s Line Producer in connection with the above-noted Production. Following receipt of the credit card statement,
Employee is required to provide fully itemized receipts for all items on the statement and a completed expense claim form, as acceptable
1
to Producer, giving a full description of each item of expenditure. The expense form, and the statement, should be signed off by the Line
Producer in connection with the above-noted Production. The card shall remain the property of Producer at all times. Employee must
agree to cease using the card and return it immediately to Producer upon termination of employment with Producer for any reason
whatsoever, including Employee being notified in writing that Employee has failed to comply with any of the terms and conditions set
forth herein this Agreement. On cessation of employment, Employee agrees that any amounts due that have not been accounted for shall
fall due and paid by Employee to Producer immediately.
EMPLOYER OF RECORD: Employee acknowledges and agrees that the “Employer of Record” for the Production may be a payroll
service. Notwithstanding that such Employer of Record may be a payroll service or that Employee’s services may be furnished by a
lender (“Lender”), for the purposes of any and all applicable Workers’ Compensation statutes, an employment relationship exists
between Employee and Producer, such that Producer is Employee’s special employer and Lender is Employee’s general employer (as
the terms “special employer” and “general employer” are understood for purposes of Workers’ Compensation statutes).
OWNERSHIP: All results and proceeds of Employee’s services pursuant to this Agreement shall be deemed a “work for hire” and
Producer shall own all rights thereto, including, without limitation, the right to make any changes. If such results and proceeds are deemed
not a “work for hire”, Employee hereby assigns all rights therein, including copyrights, in perpetuity and throughout the universe, without
further compensation therein to Employee and Producer shall have the sole and exclusive right to exploit such results and proceed in any
and all media, now known or hereafter devised, throughout the universe in perpetuity, without further compensation. Employee
exclusively grants and assigns to Producer in perpetuity throughout the universe all so-called rental or lending rights, however
denominated, now known or later devised. Employee waives any moral rights, droit moral and similar rights which Employee may have
with respect to the Production.
PUBLICITY / CONFIDENTIALITY: No personal photography is permitted on or around the set. Employee agrees not to disclose any
creative and/or material information whatsoever about the Production without Producer’s prior written approval in each instance.
Employee agrees not to take any photographs or copy any material for any use whatsoever. Employee agrees not to give any interviews
or authorize any publicity relating to the Production or Employee’s services thereon without Producer’s prior written permission.
Employee hereby grants Producer the perpetual right to use Employee’s name, likeness, voice and biography in and in connection with
any and all exploitation of the Production, including, without limitation, in merchandising and commercial tie-ins, as well as in publicity
related photographs, “behind the scenes” films, “electronic press kit” video releases, and in advertising or promoting the Production, in
any and all media now known or hereafter devised.
SCREEN CREDIT: Producer shall be under no obligation to accord Employee credit on screen or otherwise. In the event Producer
desires to accord Employee credit on screen, Producer shall in its sole discretion determine such credit, including, without limitation, the
size, style and placement of such credit. No casual or inadvertent failure of Producer, nor any failure of any third party, to comply with
the provisions of this paragraph shall constitute a breach of this Agreement, nor give rise to any form of equitable relief, whatsoever.
DEFAULT / FORCE MAJEURE: If Employee shall commit a felony or fail, refuse, neglect, or threaten to refuse to render services or
to fulfill Employee’s obligations hereunder for any reason whatsoever, including without limitation, default or death of Employee,
Producer shall have the right to suspend this Agreement while such event continues and/or to terminate this Agreement. If production of
the Production is materially hampered, interrupted, or prevented due to inclement weather, an act of God, pandemic, epidemic, infectious
disease, war, riot, civil commotion, fire, casualty, strike, labor dispute, act of any federal, state, or local authority, death, disability, or
default of any member of the cast or any principal member of the crew, or for any other reason beyond Producer’s reasonable control
(including, without limitation, cancellation of the Production by the network), Producer shall have the right to suspend this Agreement
while such event continues and/or to terminate this Agreement. Producer’s election to suspend this Agreement shall not affect Producer’s
right thereafter to terminate this Agreement. If Producer suspends this Agreement, Employee’s services and the accrual of compensation
hereunder shall likewise be suspended. Use of alcohol or drugs during hours of employment is grounds for immediate termination of
this Agreement.
PRODUCT PLACEMENT: Employee shall not engage in any product placement or promotional activity whatsoever.
COLLECTIVE BARGAINING AGREEMENT: This Agreement is not subject to any collective bargaining agreement.
NON-FRATERNIZATION POLICY: Although Producer strongly discourages such relationships, Producer recognizes that consenting
romantic or sexual relationships may develop between a supervisor and a subordinate (whether such supervision is direct or indirect),
between an employee of Producer and on-camera performer, between co-workers, and/or others in the workplace. These relationships
frequently lead to complications and significant difficulties for such employees and Producer. If a consenting romantic or sexual
relationship between any of the above should develop, Producer requires such individual to disclose this information to Producer's
Human Resources department to ensure that there are no issues of actual or apparent favoritism, conflict of interest, sexual harassment
or any other negative impact on others in the work environment. Upon being informed or learning of the existence of such a relationship,
Producer will take steps that it deems appropriate to protect the workplace environment.
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COMPUTER USAGE POLICY: If deemed necessary by Producer, Employee shall be provided with the use of a Producer computer
for Employee’s business-related use during the period Employee is rendering services hereunder. Employee may voluntarily elect to use
his or her personal computer in connection with the services hereunder. Employee understands and agrees that if he or she utilizes her
personal computer for Producer business, the following terms and conditions shall apply:
(i) Employee agrees that a Producer-issued email address may be installed on the personal computer during the period of
employment and uninstalled at the end of the employment relationship. In addition, Employee may be required to have the
emails sent or received from the Producer-issued email address backed up on the Producer's server prior to the end of the
employment relationship. This may involve temporarily relinquishing the physical computer to the Producer's IT Department.
(ii) Employee acknowledges that the unlicensed duplication or use of any software program is illegal and can create civil and
criminal liability under copyright law. Employee agrees that the personal computer must contain only legally-obtained
software and have the most up-to-date, anti-virus program.
(iii) All Producer-related business must be deleted from the personal computer at the end of the employment relationship.
Employee agrees to make his or her personal computer available to the Producer's IT Department to wipe the computer of
Producer-related business. In very limited circumstances, and with the Producer’s approval, Employee may download all
Producer-related files to a jump dive, return the drive to the Producer and delete all Producer-related business from the
computer after turning in the jump drive.
(iv) Producer shall pay Employee a box rental for the use of Employee's personal computer at the rate set forth hereinabove.
PRODUCER’S RIGHT OF INSPECTION OF TECHNOLOGY RESOURCES: The Producer utilizes various forms of technology
resources in conducting its business. “Technology resources” refers to all electronic devices and systems, software, and means of
electronic communications including, but not limited to, the following: personal computers and workstations; laptop computers; mini
and mainframe computers; exchange server; computer hardware such as disk drives; peripheral equipment such as printers, modems,
scanners, fax machines, and copiers; computer software applications and associated files and data, including software that grants access
to external services, such as the Internet; telephones; voicemail systems; electronic-mail systems; portable computer devices; cellular
telephones; pagers; personal digital assistant devices (sometimes referred to as pda’s); personal organizers and other electronic wireless
communication devices; digital cameras; and video recorders. The Producer specifically reserves the right to access, monitor and inspect
the contents of, and data stored in, all of its technology resources at any time for any reason, in its sole discretion. Employees must
understand that they have no right of privacy with respect to any messages or information created, maintained, received or stored on the
Producer’s technology resources, even if those devices require a personal password to use or access or if the information has been deleted.
All email, text and voicemail messages sent and received, including personal messages, all Internet sites visited, and all data and
information stored on the Producer's technology resources may be accessed, monitored and inspected by the Producer and are the
Producer's property, regardless of content. Any Employee who chooses to use Producer’s technology resources for personal use does so
with the express notice that the Producer has the right to access, monitor and inspect all information on the device, including but not
limited to reviewing any personal voicemails, email messages, text messages, images, video or other personal information stored on the
device. In addition, the Producer specifically reserves the right to inspect and review any emails sent from a Producer-issued email
address at any time for any reason, regardless of whether a Producer-issued, personal or third-party computer, or mobile technology
device, is used to draft or view the email message and regardless of whether the email message contains personal information. Employees
should understand that they have no right of privacy with respect to any messages sent or received from a Producer-issued email address.
The Producer may conduct an inspection by reviewing the contents of the technology resources or by obtaining and reviewing records
maintained by a third-party that supplies services to the Producer pertaining to the technology resources or to the Producer-issued email
address. In addition, Employee is responsible for password protecting, and keeping all systems passwords confidential, for any Producer-
issued computer or a personal computer that is being used for Producer-related purposes.
PRODUCER’S RIGHT OF INSPECTION OF PROPERTY: All Producer business machines, equipment and furnishings, including but
not limited to desks, cabinets, and files, are the company’s property. In order to assure that the Producer has access at all times to its
property, equipment, information, records, documents and files, the Producer maintains the right to conduct an inspection or search for
the Producer’s property at any time on the Producer’s premises. Such searches and inspections may include the employee’s office, desk,
file cabinet, closet, computer and similar places where employees may store the Producer’s property or Producer-related information,
whether or not the places are locked or protected by passwords. The Producer reserves the right to have inspections and searches
conducted by an independent security service or law enforcement. Therefore employees should have no anticipation of privacy with
respect to any information or materials stored in company-owned equipment or furnishings.
EQUAL EMPLOYMENT OPPORTUNITY: In order to ensure equal employment opportunity for every employee, all decisions
relating to the employment and personnel will be made without regard to race, color, ancestry, religion/creed (including religious dress
and grooming practices), sex (including pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender
identity or expression, age, national origin, veteran status, family care or medical leave status (including requesting or approved for leave
under the Family and Medical Leave Act or the California Family Rights Act), marital status, genetic information, mental or physical
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disability (including HIV/AIDS), medical condition (including cancer-related and related genetic characteristics), domestic violence
victim status or any other protected category pursuant to applicable federal, state and local law. This applies whether the individual has
or is perceived to have any of the characteristics protected by law or is associated with a person who has or is perceived to have any of
the characteristics protected by law. Producer is firmly committed to a policy and practice of non-discrimination in all areas of
employment, and will comply with all applicable federal, state and local statutes pertaining to employment.
POLICY AGAINST HARASSMENT: The Producer is committed to providing a workplace free of harassment based on race, color,
gender (including pregnancy, childbirth, breastfeeding or related medical conditions), gender identity or expression, religious creed
(including religious dress and grooming practices), marital status, age, national origin, ancestry, physical or mental disability (including
HIV/AIDS), genetic information, medical condition (including cancer-related and related genetic characteristics), veteran status, sexual
orientation, family care or medical leave status (including requesting or approved for leave under the Family and Medical Leave Act or
the California Family Rights Act), domestic violence victim status or any other basis protected by law. This applies whether the individual
has or is perceived to have any of the characteristics protected by law or is associated with a person who has or is perceived to have any
of the characteristics protected by law. The Producer prohibits harassment by co-workers, supervisors, managers, and third parties with
whom the employee comes into contact. Harassing conduct includes verbal, physical, and visual conduct that creates an intimidating,
offensive, or hostile working environment or that interferes with an employee’s work performance. Such conduct constitutes harassing
conduct wh
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1 John M. Begakis, Esq. (SBN 278681) Sheena B. Tehrani, Esq. (SBN 326373) 2 ALTVIEW LAW GROUP, LLP 9454 Wilshire Blvd., Suite 825 3 Beverly Hills, California 90212 Tel: (310) 230-5580 4 Fax: (562) 275-8954 5 Attorneys for Plaintiff ALEX GOODE, an individual 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 FOR THE COUNTY OF LOS ANGELES 9 10 ALEX GOODE, an individual, ) Case No. 11 ) Plaintiff, ) UNLIMITED CIVIL CASE 12 v. ) (DEMAND EXCEEDS $35,000) ) 13 BONGO, LLC, a Delaware limited liability ) COMPLAINT FOR: company; 3 BALL PRODUCTIONS LLC, a ) 14 Delaware limited liability company; ) PARAMOUNT GLOBAL, a Delaware ) 1. SEXUAL HARASSMENT IN VIOLATION 15 corporation; JONATHAN TAFFER, an ) OF CALIFORNIA FAIR EMPLOYMENT individual; and DOES 1 through 10, ) AND HOUSING ACT – HOSTILE WORK 16 inclusive, ) ENVIRONMENT ) 2. FAILURE TO PREVENT HARASSMENT 17 Defendants. ) IN VIOLATION OF CALIFORNIA FAIR ) EMPLOYMENT HOUSING ACT 18 ) ) 3. CONSTRUCTIVE DISCHARGE 19 ) 4. NEGLIGENT SUPERVISION ) 5. INTENTIONAL INFLICTION OF 20 ) EMOTIONAL DISTRESS ) 6. BREACH OF CONTRACT 21 ) 7. UNLAWFUL BUSINESS ACTS & ) ) PRACTICES 22 ) 23 ) [Demand For Jury Trial] 24 25 26 27 28 COMPLAINT 1 COMES NOW, plaintiff ALEX GOODE, an individual, hereby submits the following 2 unverified Complaint (the “Complaint”): 3 THE PARTIES 4 1. Plaintiff ALEX GOODE (“Plaintiff”) is, and at all times herein mentioned was, an 5 individual residing in the County of Los Angeles, State of California. 6 2. Plaintiff is informed and believes and, on the basis of such information and belief, 7 herein alleges that defendant BONGO, LLC (“Bongo”) is, and at all times herein mentioned was, 8 a limited liability company duly organized and existing under and by virtue of the laws of the State 9 of Delaware, with its principal place of business located at 15301 Ventura Blvd., Suite 260, 10 Sherman Oaks, California 91403. 11 3. Plaintiff is informed and believes and, on the basis of such information and belief, 12 herein alleges that defendant 3 BALL PRODUCTIONS LLC (“3 Ball”) is, and at all times herein 13 mentioned was, a limited liability company duly organized and existing under and by virtue of the 14 laws of the State of Delaware, with its principal place of business located at 15301 Ventura Blvd., 15 Suite 260, Sherman Oaks, California 91403. 16 4. Plaintiff is informed and believes and, on the basis of such information and belief, 17 herein alleges that defendant PARAMOUNT GLOBAL (“Paramount”), is a corporation duly 18 organized and existing under and by virtue of the laws of the State of Delaware, with its principal 19 place of business located at 1515 Broadway, 51st Floor, New York, New York 10036. 20 5. Plaintiff is informed and believes, and on the basis of such information and belief, 21 herein alleges that defendant JONATHAN TAFFER (“Taffer”) is, and at all times herein 22 mentioned was, an individual residing in the County of Los Angeles, State of California. 23 6. The true names and capacities of DOES 1 through 10, inclusive, whether individual, 24 corporate, associate or otherwise, are unknown to Plaintiff at this time, who therefore sues said 25 defendants by such fictitious names, and when the true names and capacities of such defendants 26 are ascertained, Plaintiff will ask leave of Court to amend this Complaint to insert the same. 27 7. Plaintiff is informed and believes and, on the basis of such information and belief, 28 herein alleges that each defendant named in this Complaint was, at all times herein mentioned, and 2 COMPLAINT 1 now is, the agent and employee of each of the other defendants herein, and was at all times acting 2 within the course and scope of said agency and employment. When referring to “Defendants” 3 herein, Plaintiff intends to include Bongo, 3 Ball, Paramount, Taffer, and all other defendants. 4 JURISDICTION AND VENUE 5 8. Pursuant to California Code of Civil Procedure (“CCP”) § 410.10, this Court has 6 jurisdiction over Defendants because each Defendant is a person or business entity that is a resident 7 and/or business entity that is established, incorporated, and/or has sufficient minimum contacts 8 with the State of California so far as to render exercise of jurisdiction over Defendants consistent 9 with traditional notions of fair play and substantial justice. Further, damages exceed the 10 jurisdictional minimum of this Court. 11 9. Pursuant to CCP § 395.5, venue is proper in this Court because Defendants’ liabilities 12 and obligations to Plaintiff arose in the County of Los Angeles. 13 FACTS COMMON TO ALL CAUSES OF ACTION 14 10. Plaintiff is an actor, digital media content creator, and professional mixologist, who 15 has appeared as a recurring expert mixologist on multiple seasons of the Television series Bar 16 Rescue (the “Series”). 17 11. On or about April 24, 2022, Plaintiff and Defendant Bongo, a producer of the Series, 18 entered into a “Crew Deal Memo” (the “Agreement”), whereby Plaintiff agreed to appear on the 19 Season 8.5 of the Series pursuant to the terms thereof. 20 12. Section 16 of the Agreement set forth Bongo’s explicit obligation to prohibit 21 “harassment by co-workers, supervisors, managers, and other parties with whom the employee 22 comes into contact.” The Agreement also defined harassing conduct to include “verbal, physical, 23 and visual conduct that creates an intimidating, offensive, or hostile working environment or that 24 interferes with an employee’s work performance.” A true and correct copy of the Agreement is 25 attached hereto as Exhibit “A” and incorporated herein by this reference. 26 13. Despite this obligation, Bongo and all other Defendants failed to prevent Defendant 27 Taffer from engaging in ongoing and pervasive harassing and discriminatory conduct towards 28 Plaintiff and others on set. Specifically, after filming a scene on or about September 14, 2022, 3 COMPLAINT 1 Taffer cornered Plaintiff in a physically intimidating manner, and verbally berated him in front of 2 colleagues for wearing his long hair down. Among other despicable actions, Taffer called Plaintiff 3 “disgusting,” engaged in gender stereotyping by attempting to humiliate Plaintiff simply because 4 he believed the length and style of Plaintiff’s hair made him less masculine, and encouraged others 5 to join in verbally attacking Plaintiff. 6 14. Following the incident, Plaintiff struggled to complete his scene work with Taffer. 7 Accordingly, on or about September 20, 2022, Plaintiff submitted a detailed complaint outlining 8 the incident and his concerns to Defendant 3 Ball. After 3 Ball interviewed Plaintiff, Defendant 9 Paramount took over responsibility and began an investigation on or about September 26, 2022. 10 15. Despite conducting multiple interviews with other witnesses, and despite 11 Paramount’s admission that Taffer’s behavior violated Company policy, Paramount sent a 12 lukewarm closure letter to Plaintiff on or about November 3, 2022, summarily declaring that 13 “appropriate action” had been taken. Paramount provided no assurances that Taffer’s harassing 14 behavior would cease, and offered no details about what corrective action had or would be taken 15 to ensure a workplace free of harassing conduct. Paramount offered only a personal apology from 16 Taffer, which Plaintiff made clear did not, without more, relieve him of the discomfort and anxiety 17 he experienced from his work with Taffer on the Series. 18 16. As a result of Taffer’s conduct, and the culture of fear Defendants have perpetuated 19 through the creation of a hostile work environment on the Series, Plaintiff is unable to return to 20 work on the Series, and has suffered significant emotional distress. 21 17. On or about September 8, 2023, Plaintiff obtained a Right to Sue letter from the 22 Department of Fair Employment and Housing. Plaintiff has therefore exhausted his administrative 23 remedies to pursue claims under the Fair Employment and Housing Act (“FEHA”). A true and 24 correct copy of Plaintiff’s Right to Sue letter is attached hereto as Exhibit “B” and incorporated 25 herein by this reference. 26 /// 27 /// 28 /// 4 COMPLAINT 1 FIRST CAUSE OF ACTION 2 Harassment In Violation of FEHA, Cal. Gov. Code § 12940, et seq. 3 Hostile Work Environment 4 (By Plaintiff Against All Defendants) 5 18. Plaintiff repeats, realleges, and incorporates herein by this reference each and every 6 allegation contained in ¶¶ 1 through 17, inclusive, as though set forth in full herein. 7 19. As alleged herein, Plaintiff was subject to unwanted, harassing conduct from Taffer 8 that, for Plaintiff as well as any reasonable person in Plaintiff’s circumstances, was so severe and/or 9 pervasive as to alter the terms and conditions of his employment with Defendants, making the 10 conditions of such employment intolerable, in direct contravention of Government Code § 12940, 11 et seq. (i.e., “FEHA”). 12 20. Following the incident, on or about September 20, 2022, Plaintiff submitted a 13 detailed complaint outlining the incident and his concerns to 3 Ball. However, Plaintiff was never 14 apprised of any immediate corrective measures taken by Defendants to prevent such sexual 15 harassment. As a result of such failure, which Plaintiff is informed and believes and, on the basis 16 of such information and belief, alleges was a substantial factor in causing Plaintiff’s harm, Plaintiff 17 was left with no recourse to relieve him of the discomfort and anxiety he experienced from his 18 work with Taffer on the Series. 19 21. Defendants are liable for Taffer’s conduct in furtherance of creating a hostile work 20 environment, which conduct occurred during the Series and therefore in a work-related context, 21 because Defendants knew or should have known of such conduct and failed to take immediate and 22 appropriate corrective action. 23 22. As a direct and proximate result of Defendants’ willful, knowing, and intentional 24 wrongdoing, Plaintiff has sustained and continues to sustain damages, including the loss of 25 earnings and benefits, in an amount to be determined according to proof at trial, but exceeding the 26 jurisdictional minimum of this Court. 27 23. As a direct and proximate result of Defendants’ willful, knowing, and intentional 28 wrongdoing, Plaintiff has further suffered and continues to suffer humiliation, emotional distress, 5 COMPLAINT 1 and mental and physical anguish, all to his damage, in an amount to be determined according to 2 proof at trial, but exceeding the jurisdictional minimum of this Court. 3 24. Defendants’ wrongdoing was intentional, malicious, fraudulent, oppressive, and in 4 conscious disregard for Plaintiff’s rights, entitling Plaintiff to punitive and/or exemplary damages, 5 in an amount to be determined according to proof at trial, but exceeding the jurisdictional minimum 6 of this Court. 7 25. Additionally, Plaintiff has incurred and will continue to incur as yet unascertained 8 attorneys’ fees and costs. Plaintiff will therefore amend this Complaint to state the full amount of 9 those fees and costs when such amounts have been ascertained. 10 SECOND CAUSE OF ACTION 11 Failure to Prevent Harassment In Violation of FEHA, Cal. Gov. Code § 12940, et seq. 12 (By Plaintiff Against Defendants Bongo, 3 Ball, Paramount, and DOES 1-10) 13 26. Plaintiff repeats, realleges, and incorporates herein by this reference each and every 14 allegation contained in ¶¶ 1 through 25, inclusive, as though set forth in full herein. 15 27. Under FEHA, an employer is strictly liable for the harassing conduct of its agents 16 and supervisors. FEHA also requires employers to take all reasonable steps necessary to prevent 17 discrimination and harassing conduct from occurring. 18 28. As alleged herein, during the course of Plaintiff’s employment, Defendants Bongo, 19 3 Ball, and Paramount failed to prevent Taffer, who was an agent of such Defendants by virtue of 20 his role in the Series, from engaging in intentional acts that resulted in Plaintiff being treated less 21 favorably because of Plaintiff’s protected status (i.e., Plaintiff’s sex and/or gender). 22 29. Furthermore, and as alleged herein, Defendants 3 Ball and Paramount did not keep 23 Plaintiff apprised of, nor did they take, any immediate and/or sufficiently appropriate corrective 24 steps to remedy Taffer’s harassment of Plaintiff after Plaintiff notified 3 Ball and Paramount. 25 30. As a direct and proximate result of Bongo, 3 Ball, and Paramount’s willful, knowing, 26 and intentional wrongdoing, Plaintiff has sustained and continues to sustain damages, including, 27 without limitation, loss of earnings and benefits, in an amount to be determined according to proof 28 at trial, but exceeding the jurisdictional minimum of this Court. 6 COMPLAINT 1 31. As a direct and proximate result of Bongo, 3 Ball, and Paramount’s willful, knowing, 2 and intentional wrongdoing, Plaintiff has suffered and continues to suffer humiliation, emotional 3 distress, and mental and physical anguish, all to his damage, in an amount to be determined 4 according to proof at trial, but exceeding the jurisdictional minimum of this Court. 5 32. Bongo, 3 Ball, and Paramount’s conduct was intentional, malicious, fraudulent, 6 oppressive, and in conscious disregard of Plaintiff’s rights, entitling Plaintiff to punitive and/or 7 exemplary damages in an amount to be determined according to proof at trial, but exceeding the 8 jurisdictional minimum of this Court. 9 33. Additionally, Plaintiff has incurred and will continue to incur as yet unascertained 10 attorneys’ fees and costs. Plaintiff will amend this Complaint to state the full amount of those fees 11 and costs when such amounts have been ascertained. 12 THIRD CAUSE OF ACTION 13 Constructive Discharge 14 (By Plaintiff Against Defendants Bongo, 3 Ball, Paramount, and DOES 1-10) 15 34. Plaintiff repeats, realleges, and incorporates herein by this reference each and every 16 allegation contained in ¶¶ 1 through 33, as though set forth in full herein. 17 35. During his employment, Plaintiff was subjected to harassment by Taffer. 18 36. As alleged herein, after filming a scene on or about September 14, 2022, Taffer 19 cornered Plaintiff in a physically intimidating manner, and verbally berated him in front of 20 colleagues for wearing his hair down. Among other actions, Taffer called Plaintiff “disgusting,” 21 engaged in gender stereotyping by attempting to humiliate Plaintiff simply because he believed the 22 length and style of Plaintiff’s hair made him less masculine, and encouraged others to join in 23 verbally attacking Plaintiff. 24 37. Following the incident, Plaintiff struggled to complete his scene work with Taffer, 25 and is unable to return to work on the Series as a result. 26 38. Accordingly, Bongo, 3 Ball, and Paramount’s conduct created intolerable working 27 conditions that led to the constructive termination of Plaintiff, in violation of FEHA. 28 /// 7 COMPLAINT 1 39. As a direct and proximate result of Bongo, 3 Ball, and Paramount’s willful, knowing, 2 and intentional wrongdoing, Plaintiff has sustained and continues to sustain damages, including 3 losses of earnings and benefits, in an amount to be determined according to proof at trial, but 4 exceeding the jurisdictional minimum of this Court. 5 40. As a direct and proximate result of Bongo, 3 Ball, and Paramount’s willful, knowing, 6 and intentional wrongdoing, Plaintiff has suffered and continues to suffer humiliation, emotional 7 distress, and mental and physical anguish, all to his damage in an amount to be determined 8 according to proof at trial, but exceeding the jurisdictional minimum of this Court. 9 41. Bongo, 3 Ball, and Paramount’s conduct was intentional, malicious, fraudulent, 10 oppressive, and in conscious disregard of Plaintiff’s rights, entitling Plaintiff to punitive damages, 11 in an amount to be determined according to proof at trial, but exceeding the jurisdictional minimum 12 of this Court. 13 42. Additionally, Plaintiff has incurred and will continue to incur as yet unascertained 14 attorneys’ fees and costs. Plaintiff will amend this Complaint to state the full amount of those fees 15 and costs when such amounts have been ascertained. 16 FOURTH CAUSE OF ACTION 17 Negligent Supervision 18 (By Plaintiff Against Defendants Bongo, 3 Ball, Paramount, and DOES 1-10) 19 43. Plaintiff repeats, realleges, and incorporates herein by this reference each and every 20 allegation contained in ¶¶ 1 through 42, as though set forth in full herein. 21 44. Plaintiff is informed and believes and, on the basis of such information and belief, 22 herein alleges that, at all relevant times, Taffer was employed by Bongo, 3 Ball, and Paramount. 23 Taffer nevertheless was, or became, unfit to perform services on the Series, as evidenced by his 24 conduct towards Plaintiff as set forth herein. 25 45. Bongo, 3 Ball, and Paramount knew or should have known that Taffer was unfit to 26 perform services on the Series, and that such unfitness created a particular risk to other cast 27 members, and possibly others. 28 /// 8 COMPLAINT 1 46. Taffer’s unfitness to perform services on the Series, as evidenced by his conduct 2 towards Plaintiff alleged herein, severely harmed Plaintiff, including, without limitation, by 3 causing Plaintiff to struggle to complete his scene work with Taffer. 4 47. Bongo, 3 Ball, and Paramount negligence in hiring and/or supervising Taffer was a 5 substantial factor in causing Plaintiff’s harm. 6 FIFTH CAUSE OF ACTION 7 Intentional Infliction of Emotional Distress 8 (By Plaintiff Against All Defendants) 9 48. Plaintiff repeats, realleges, and incorporates herein by this reference each and every 10 allegation contained in ¶¶ 1 through 47, as though set forth in full herein. 11 49. As alleged herein, Defendants engaged in extreme and outrageous conduct, 12 including, without limitation, by: (a) intentionally and/or recklessly harassing Plaintiff and/or 13 allowing such conduct to occur; (b) conducting a flawed and inadequate investigation into 14 Plaintiff’s claims of harassment (if any investigation was conducted at all); (c) failing to provide 15 harassment training for employees, which could have mitigated or even prevented the alleged 16 wrongdoing; and (d) creating, allowing for, and/or perpetuating a hostile work environment in 17 which Plaintiff did not feel safe. 18 50. As a direct and proximate result of Defendants’ willful, wanton, intentional, 19 outrageous, and malicious conduct, Plaintiff suffered severe and extreme mental and emotional 20 distress. Plaintiff does not at this time know the exact duration or permanence of said injuries but 21 is informed and believes and, on such basis, herein alleges that some of the injuries are reasonably 22 certain to be permanent in character. 23 51. As a direct and proximate result of Defendants’ conduct, and the conduct of each of 24 them, as alleged herein, Plaintiff has suffered damages in an amount to be determined according 25 to proof at trial, but exceeding the jurisdictional minimum of this Court. 26 52. Defendants’ actions were willful, intentional, malicious, oppressive, and despicable, 27 and Defendants acted with willful and conscious disregard for Plaintiff’s rights. Accordingly, 28 9 COMPLAINT 1 Plaintiff is also entitled to punitive and/or exemplary damages in an amount to be determined 2 according to proof at trial, but exceeding the jurisdictional minimum of this Court. 3 SIXTH CAUSE OF ACTION 4 Breach of Contract 5 (By Plaintiff Against All Defendants) 6 53. Plaintiff repeats, realleges, and incorporates herein by this reference each and every 7 allegation contained in ¶¶ 1 through 52, as though set forth in full herein. 8 54. Commencing on or about April 24, 2022, Plaintiff and Bongo entered into a “Crew 9 Deal Memo” (the “Agreement”), whereby Plaintiff agreed to appear and render services on the 10 Series, pursuant to the terms thereof. Section 16 of the Agreement set forth Bongo’s explicit 11 obligation to prohibit “harassment by co-workers, supervisors, managers, and other parties with 12 whom the employee comes into contact.” The Agreement also defined harassing conduct to include 13 “verbal, physical, and visual conduct that creates an intimidating, offensive, or hostile working 14 environment or that interferes with an employee’s work performance.” 15 55. Plaintiff has performed all terms, conditions, and covenants of the Agreement. 16 Notwithstanding the terms thereof, Bongo, as well as 3 Ball and Paramount as successors and/or 17 assignees of Bongo’s rights under the Agreement, materially breached the Agreement in that they 18 have failed and refused, and continue to fail and refuse, to prevent Taffer from engaging in ongoing 19 and pervasive harassing and discriminatory conduct towards Plaintiff and others on set. As a result 20 of Defendants’ material breach, there is now due, owing, and unpaid from Defendants to Plaintiff 21 an amount to be determined at trial but exceeding the jurisdictional minimum of this Court, together 22 with interest thereon at the maximum legal rate. 23 56. As a direct and proximate result of Defendants’ material breach of the Agreement, 24 Plaintiff has suffered damages in an amount to be determined at trial but exceeding the 25 jurisdictional minimum of this Court, together with interest thereon at the maximum rate allowed 26 by law. When the true amount of such damages is ascertained, Plaintiff will seek leave to amend 27 this Complaint to allege the same. 28 /// 10 COMPLAINT 1 SEVENTH CAUSE OF ACTION 2 Unlawful Business Acts & Practices in Violation of 3 Cal. Bus. and Prof. Code §§ 17200, et seq. 4 (By Plaintiff Against All Defendants) 5 57. Plaintiff repeats, realleges, and incorporates herein by this reference each and every 6 allegation contained in ¶¶ 1 through 56, as though set forth in full herein. 7 58. The wrongdoing of Defendants, as alleged herein, has been and continues to be 8 unlawful and harmful to Plaintiff and the general public. 9 59. A violation of Cal. Bus. and Prof. Code §§ 17200, et seq. may be predicated on the 10 violation of any state or federal law. In the instant case, the actions of Defendants violated 11 California employment law. 12 60. Plaintiff has been personally aggrieved by Defendants’ unlawful business acts and 13 practices, as alleged herein, including, but not limited to, the loss of money and/or property. 14 61. Pursuant to Cal. Bus. and Prof. Code §§ 17200, et seq., CCP § 1021.5, and other 15 applicable laws, Plaintiff is therefore entitled to an award of attorneys’ fees and costs against 16 Defendants. Plaintiff will amend this Complaint to state the full amount of those fees and costs 17 when such amounts have been ascertained. 18 WHEREFORE, Plaintiff prays for judgment against Defendants, and each of them, jointly 19 and severally, as follows: 20 1. For the Court to declare, adjudge, and decree that Defendants violated Cal. Bus. and Prof. 21 Code §§ 17200, et seq.; 22 2. For general and special damages in an amount to be determined at trial but exceeding the 23 jurisdictional minimum of this Court; 24 3. For punitive and exemplary damages in an amount to be determined at trial but exceeding 25 the jurisdictional minimum of this Court; 26 4. For reasonable attorneys’ fees and costs in an amount to be determined at trial; 27 5. For pre- and post-judgment interest at the maximum rate allowed by law; and 28 /// 11 COMPLAINT 1 6. For such other and further relief as the Court may deem just and proper. 2 Dated: April 12, 2024 ALTVIEW LAW GROUP, LLP 3 4 By: ____________________________________ JOHN M. BEGAKIS 5 SHEENA B. TEHRANI Attorneys for Plaintiff 6 ALEX GOODE, an individual 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 12 COMPLAINT 1 DEMAND FOR JURY TRIAL 2 Plaintiff hereby demands a trial by jury of all issues triable by a jury. 3 Dated: April 12, 2024 ALTVIEW LAW GROUP, LLP 4 5 By: ____________________________________ 6 JOHN M. BEGAKIS SHEENA B. TEHRANI 7 Attorneys for Plaintiff ALEX GOODE, an individual 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 13 COMPLAINT EXHIBIT “A” CREW DEAL MEMO PRODUCTION: Bar Rescue 8.5 PRODUCER: Bongo, LLC EMPLOYEE: Alexander P. Goode DATE: 04/24/2022 ADDRESS: PHONE: SOC. SEC #: POSITION/DEPT: Expert - Mixologist APPR. 04/24/2022 START: EMERGENCY Casey Goode PHONE: CONTACT: BOX RENTAL: ADDITIONAL TERMS/PROVISIONS: HOURLY RATE: WEEKLY RATE: Based on 0.00 per day CONDITIONS PRECEDENT: This Agreement is an offer of employment expressly conditioned on (i) Employee’s execution of this Agreement, (ii) in accordance with the Immigration Reform and Control Act of 1986, completion of a Form I-9 (Employment Eligibility Verification Form) and submission of original documents proving Employee’s employment eligibility, (iii) Employee submitting to a post-conditional offer, pre-hire detailed background check; and (iv) Producer’s approval of Employee’s background check results. Employee’s services shall be rendered on an exclusive basis for such period of time as may be required unless otherwise specified in this Agreement. RATE: If a daily rate is indicated, services are for the period of hours indicated above. The daily rate, weekly rate, or hourly rate (whichever is applicable) is paid according to hours worked per day, subject to applicable law. Weekly rates shall be prorated for any partial weeks worked. Nothing contained herein shall be construed as a guarantee of continued employment. Time cards must be turned in at the end of the last day of the production week. Holidays, weekends, and night work shall be paid at the same rate as regular workdays. Start times will be determined by department head. Compensation shall be inclusive of Employee’s services in connection with any pre-production, production, and post-production services required on the Production and Employee shall not receive any additional compensation for any repeat broadcasts or any other exploitation of the Production. All overtime must be pre-approved by Producer. If Employee is required to render services at a distant location, Employee shall receive coach class air travel, accommodations (room and room tax only) and a per diem. It is specifically agreed that this is not a “pay or play” deal or run of show contract. The Producer reserves the right to terminate Employee at any time subject only to the obligation to pay the balance of any compensation earned by Employee but unpaid by Producer at the date of termination. PURCHASES / RENTALS / EXPENSES: All purchases and rentals must be accompanied by Producer’s purchase order or check request. Producer will reimburse only those petty cash expenses accompanied by original receipts. Employee acknowledges Employee has been furnished with, understands and will comply with the petty cash procedures. Petty cash should never be used for personal expenses. Producer is not responsible for incidental expenses incurred by Employee, including, without limitation, cellular phone charges or parking tickets. Box or other authorized rental payments (including for the use of Employee’s personal computer, if any, as set forth below) will be prorated for any partial week worked. A complete list of items included in rental shall be attached as an addendum to this Agreement. If deemed necessary by Producer, Employee shall be provided with the use of a computer for Employee’s business-related use during the period Employee is rendering services hereunder. Employee shall retain sole supervision and control of any personal items Employee carries with him/her or rents to Producer, and Employee hereby acknowledges that Producer is not responsible for any loss and/or damage to any such personal property. Employee is responsible for all recoverable items (e.g. expendables, equipment, etc.) purchased, and these must be reconciled with the Accounting Department during wrap. All recoverable items will be collected at wrap. Producer credit cards or P cards shall be issued by Producer to Employee in Producer’s sole discretion. Such credit card or P cards may only be used to incur expenses in connection with the discharge of the cardholding Employee’s duties as an employee of Producer. Under no circumstances may any personal expenditure be charged to such card(s). Any expenditure charged to the card should be authorized in advance by Employee’s Line Producer in connection with the above-noted Production. Following receipt of the credit card statement, Employee is required to provide fully itemized receipts for all items on the statement and a completed expense claim form, as acceptable 1 to Producer, giving a full description of each item of expenditure. The expense form, and the statement, should be signed off by the Line Producer in connection with the above-noted Production. The card shall remain the property of Producer at all times. Employee must agree to cease using the card and return it immediately to Producer upon termination of employment with Producer for any reason whatsoever, including Employee being notified in writing that Employee has failed to comply with any of the terms and conditions set forth herein this Agreement. On cessation of employment, Employee agrees that any amounts due that have not been accounted for shall fall due and paid by Employee to Producer immediately. EMPLOYER OF RECORD: Employee acknowledges and agrees that the “Employer of Record” for the Production may be a payroll service. Notwithstanding that such Employer of Record may be a payroll service or that Employee’s services may be furnished by a lender (“Lender”), for the purposes of any and all applicable Workers’ Compensation statutes, an employment relationship exists between Employee and Producer, such that Producer is Employee’s special employer and Lender is Employee’s general employer (as the terms “special employer” and “general employer” are understood for purposes of Workers’ Compensation statutes). OWNERSHIP: All results and proceeds of Employee’s services pursuant to this Agreement shall be deemed a “work for hire” and Producer shall own all rights thereto, including, without limitation, the right to make any changes. If such results and proceeds are deemed not a “work for hire”, Employee hereby assigns all rights therein, including copyrights, in perpetuity and throughout the universe, without further compensation therein to Employee and Producer shall have the sole and exclusive right to exploit such results and proceed in any and all media, now known or hereafter devised, throughout the universe in perpetuity, without further compensation. Employee exclusively grants and assigns to Producer in perpetuity throughout the universe all so-called rental or lending rights, however denominated, now known or later devised. Employee waives any moral rights, droit moral and similar rights which Employee may have with respect to the Production. PUBLICITY / CONFIDENTIALITY: No personal photography is permitted on or around the set. Employee agrees not to disclose any creative and/or material information whatsoever about the Production without Producer’s prior written approval in each instance. Employee agrees not to take any photographs or copy any material for any use whatsoever. Employee agrees not to give any interviews or authorize any publicity relating to the Production or Employee’s services thereon without Producer’s prior written permission. Employee hereby grants Producer the perpetual right to use Employee’s name, likeness, voice and biography in and in connection with any and all exploitation of the Production, including, without limitation, in merchandising and commercial tie-ins, as well as in publicity related photographs, “behind the scenes” films, “electronic press kit” video releases, and in advertising or promoting the Production, in any and all media now known or hereafter devised. SCREEN CREDIT: Producer shall be under no obligation to accord Employee credit on screen or otherwise. In the event Producer desires to accord Employee credit on screen, Producer shall in its sole discretion determine such credit, including, without limitation, the size, style and placement of such credit. No casual or inadvertent failure of Producer, nor any failure of any third party, to comply with the provisions of this paragraph shall constitute a breach of this Agreement, nor give rise to any form of equitable relief, whatsoever. DEFAULT / FORCE MAJEURE: If Employee shall commit a felony or fail, refuse, neglect, or threaten to refuse to render services or to fulfill Employee’s obligations hereunder for any reason whatsoever, including without limitation, default or death of Employee, Producer shall have the right to suspend this Agreement while such event continues and/or to terminate this Agreement. If production of the Production is materially hampered, interrupted, or prevented due to inclement weather, an act of God, pandemic, epidemic, infectious disease, war, riot, civil commotion, fire, casualty, strike, labor dispute, act of any federal, state, or local authority, death, disability, or default of any member of the cast or any principal member of the crew, or for any other reason beyond Producer’s reasonable control (including, without limitation, cancellation of the Production by the network), Producer shall have the right to suspend this Agreement while such event continues and/or to terminate this Agreement. Producer’s election to suspend this Agreement shall not affect Producer’s right thereafter to terminate this Agreement. If Producer suspends this Agreement, Employee’s services and the accrual of compensation hereunder shall likewise be suspended. Use of alcohol or drugs during hours of employment is grounds for immediate termination of this Agreement. PRODUCT PLACEMENT: Employee shall not engage in any product placement or promotional activity whatsoever. COLLECTIVE BARGAINING AGREEMENT: This Agreement is not subject to any collective bargaining agreement. NON-FRATERNIZATION POLICY: Although Producer strongly discourages such relationships, Producer recognizes that consenting romantic or sexual relationships may develop between a supervisor and a subordinate (whether such supervision is direct or indirect), between an employee of Producer and on-camera performer, between co-workers, and/or others in the workplace. These relationships frequently lead to complications and significant difficulties for such employees and Producer. If a consenting romantic or sexual relationship between any of the above should develop, Producer requires such individual to disclose this information to Producer's Human Resources department to ensure that there are no issues of actual or apparent favoritism, conflict of interest, sexual harassment or any other negative impact on others in the work environment. Upon being informed or learning of the existence of such a relationship, Producer will take steps that it deems appropriate to protect the workplace environment. 2 COMPUTER USAGE POLICY: If deemed necessary by Producer, Employee shall be provided with the use of a Producer computer for Employee’s business-related use during the period Employee is rendering services hereunder. Employee may voluntarily elect to use his or her personal computer in connection with the services hereunder. Employee understands and agrees that if he or she utilizes her personal computer for Producer business, the following terms and conditions shall apply: (i) Employee agrees that a Producer-issued email address may be installed on the personal computer during the period of employment and uninstalled at the end of the employment relationship. In addition, Employee may be required to have the emails sent or received from the Producer-issued email address backed up on the Producer's server prior to the end of the employment relationship. This may involve temporarily relinquishing the physical computer to the Producer's IT Department. (ii) Employee acknowledges that the unlicensed duplication or use of any software program is illegal and can create civil and criminal liability under copyright law. Employee agrees that the personal computer must contain only legally-obtained software and have the most up-to-date, anti-virus program. (iii) All Producer-related business must be deleted from the personal computer at the end of the employment relationship. Employee agrees to make his or her personal computer available to the Producer's IT Department to wipe the computer of Producer-related business. In very limited circumstances, and with the Producer’s approval, Employee may download all Producer-related files to a jump dive, return the drive to the Producer and delete all Producer-related business from the computer after turning in the jump drive. (iv) Producer shall pay Employee a box rental for the use of Employee's personal computer at the rate set forth hereinabove. PRODUCER’S RIGHT OF INSPECTION OF TECHNOLOGY RESOURCES: The Producer utilizes various forms of technology resources in conducting its business. “Technology resources” refers to all electronic devices and systems, software, and means of electronic communications including, but not limited to, the following: personal computers and workstations; laptop computers; mini and mainframe computers; exchange server; computer hardware such as disk drives; peripheral equipment such as printers, modems, scanners, fax machines, and copiers; computer software applications and associated files and data, including software that grants access to external services, such as the Internet; telephones; voicemail systems; electronic-mail systems; portable computer devices; cellular telephones; pagers; personal digital assistant devices (sometimes referred to as pda’s); personal organizers and other electronic wireless communication devices; digital cameras; and video recorders. The Producer specifically reserves the right to access, monitor and inspect the contents of, and data stored in, all of its technology resources at any time for any reason, in its sole discretion. Employees must understand that they have no right of privacy with respect to any messages or information created, maintained, received or stored on the Producer’s technology resources, even if those devices require a personal password to use or access or if the information has been deleted. All email, text and voicemail messages sent and received, including personal messages, all Internet sites visited, and all data and information stored on the Producer's technology resources may be accessed, monitored and inspected by the Producer and are the Producer's property, regardless of content. Any Employee who chooses to use Producer’s technology resources for personal use does so with the express notice that the Producer has the right to access, monitor and inspect all information on the device, including but not limited to reviewing any personal voicemails, email messages, text messages, images, video or other personal information stored on the device. In addition, the Producer specifically reserves the right to inspect and review any emails sent from a Producer-issued email address at any time for any reason, regardless of whether a Producer-issued, personal or third-party computer, or mobile technology device, is used to draft or view the email message and regardless of whether the email message contains personal information. Employees should understand that they have no right of privacy with respect to any messages sent or received from a Producer-issued email address. The Producer may conduct an inspection by reviewing the contents of the technology resources or by obtaining and reviewing records maintained by a third-party that supplies services to the Producer pertaining to the technology resources or to the Producer-issued email address. In addition, Employee is responsible for password protecting, and keeping all systems passwords confidential, for any Producer- issued computer or a personal computer that is being used for Producer-related purposes. PRODUCER’S RIGHT OF INSPECTION OF PROPERTY: All Producer business machines, equipment and furnishings, including but not limited to desks, cabinets, and files, are the company’s property. In order to assure that the Producer has access at all times to its property, equipment, information, records, documents and files, the Producer maintains the right to conduct an inspection or search for the Producer’s property at any time on the Producer’s premises. Such searches and inspections may include the employee’s office, desk, file cabinet, closet, computer and similar places where employees may store the Producer’s property or Producer-related information, whether or not the places are locked or protected by passwords. The Producer reserves the right to have inspections and searches conducted by an independent security service or law enforcement. Therefore employees should have no anticipation of privacy with respect to any information or materials stored in company-owned equipment or furnishings. EQUAL EMPLOYMENT OPPORTUNITY: In order to ensure equal employment opportunity for every employee, all decisions relating to the employment and personnel will be made without regard to race, color, ancestry, religion/creed (including religious dress and grooming practices), sex (including pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, age, national origin, veteran status, family care or medical leave status (including requesting or approved for leave under the Family and Medical Leave Act or the California Family Rights Act), marital status, genetic information, mental or physical 3 disability (including HIV/AIDS), medical condition (including cancer-related and related genetic characteristics), domestic violence victim status or any other protected category pursuant to applicable federal, state and local law. This applies whether the individual has or is perceived to have any of the characteristics protected by law or is associated with a person who has or is perceived to have any of the characteristics protected by law. Producer is firmly committed to a policy and practice of non-discrimination in all areas of employment, and will comply with all applicable federal, state and local statutes pertaining to employment. POLICY AGAINST HARASSMENT: The Producer is committed to providing a workplace free of harassment based on race, color, gender (including pregnancy, childbirth, breastfeeding or related medical conditions), gender identity or expression, religious creed (including religious dress and grooming practices), marital status, age, national origin, ancestry, physical or mental disability (including HIV/AIDS), genetic information, medical condition (including cancer-related and related genetic characteristics), veteran status, sexual orientation, family care or medical leave status (including requesting or approved for leave under the Family and Medical Leave Act or the California Family Rights Act), domestic violence victim status or any other basis protected by law. This applies whether the individual has or is perceived to have any of the characteristics protected by law or is associated with a person who has or is perceived to have any of the characteristics protected by law. The Producer prohibits harassment by co-workers, supervisors, managers, and third parties with whom the employee comes into contact. Harassing conduct includes verbal, physical, and visual conduct that creates an intimidating, offensive, or hostile working environment or that interferes with an employee’s work performance. Such conduct constitutes harassing conduct wh