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Case
1:09-cv-00094-SJD
Document
1
Filed 02/06/2009 Page
1
of 9
UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF OHIOWESTERN DIVISION
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COMPLAINT WITH JURY DEMANDENDORSED HEREON
LAURE QUINLIVAN3624 Kroger AvenueCincinnati, Ohio 45226
Plaintiff,
v.
WCPO-TV/E.W. SCRIPPS COMPANY312 Walnut Street2800 Scripps CenterCincinnati, Ohio 45202Defendant.
PARTIES
1.
Plaintiff Laure Quinlivan is a citizen and resident of the State of Ohio.
2.
Defendant WCPO-TV/E.W. Scripps Company is an Ohio corporation. Defendantis an employer within the meaning of state and federal law.
NATURE OF ACTION
3.
This action is filed by Plaintiff Laure Quinlivan ("Plaintiff), who worked forDefendant WCPO-TV/E.W. Scripps Company ("Defendant") as an InvestigativeReporter/Producer from May, 1995 until her termination effective December
31,
2007. Pursuantto an Agreement between Defendant and its Reporters, Plaintiff was due approximately 26 weeksof severance pay Defendant refused to make this severance pay to
Plaintiff.
At the time of hertermination, Plaintiff was 48 years old and had recently returned from maternity leave. Plaintiffbrings this action alleging breach of contract, discrimination on the basis of her gender and recentpregnancy, age, and retaliation for consulting with an attorney.
4.
Throughout her employment, Plaintiff was a loyal and dedicated employee andwas well-regarded by her colleagues and viewers. By all accounts Plaintiff excelled in her role asan Investigative Reporter/Producer and was recognized nationally for her coverage of stories of
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Case
1:09-cv-00094-SJD
Document
1
Filed 02/06/2009 Page 2 of 9
significant relevance to the local community. Plaintiff won two George Foster Peabody Awards.The George Foster Peabody Award is television's highest honor and Plaintiff is the only reporterfor Defendant to ever win two of these prestigious awards. Plaintiff was the recipient ofnumerous other national awards, including three SPJ Sigma Delta Chi Awards, the ScrippsHoward Award, the duPont Columbia Award, the IRE Award, the Walter Cronkite Award, andeighteen regional Emmy Awards. Plaintiff has also been named Best Reporter in Ohio.
5.
Plaintiff was the Lead I-Team reporter during her employment with Defendantand is well-known for many of her stories. Plaintiff exposed the mismanagement of public fundsused for construction of Paul Brown Stadium between 1999 and
2001.
Plaintiffs "Visions ofVine Street" first aired in December, 2001. This was the first one-hour commercial-freedocumentary Defendant had ever aired. This documentary won the Peabody and numerousnational awards, and was picked up by various public broadcasting stations and aired manytimes. Plaintiffs work resulted in government and community action leading to more than 50million dollars of investment into revitalization of the neighborhood. Over the next five years,Plaintiff continued to report on the progress of Vine Street. Her work garnered the respect of thecommunity and brought positive attention to Defendant. Plaintiff simply was the mostaccomplished Reporter/Producer that Defendant ever employed.6. Plaintiff became pregnant in 2006. In December, 2006, Plaintiff contacted herdirect supervisor to discuss her upcoming maternity leave. Plaintiff and Defendant were unableto come to agreement on Plaintiffs maternity leave and Plaintiff consulted an attorney to assisther in negotiating her leave of absence. With the assistance of her attorney, Plaintiff was able toget her leave of absence request granted.7. Upon returning from maternity leave, Plaintiff
s
job duties were different. HerAnchor/Reporter Employment Agreement with Defendant stated that to ensure a quality product,
2
 
Case
1:09-cv-00094-SJD
Document
1
Filed 02/06/2009 Page 3 of 9
she would not be required to do more than twelve investigations a year. However, she was nowrequired to complete one story per week.8. Plaintiff tried to explore the possibility of working a part-time schedule or a moreflexible full-time schedule. Defendant refused to consider options presented by
Plaintiff.
Otheremployees had been permitted to work reduced or part-time schedules upon request.9. Defendant terminated Plaintiff effective December
31,
2007. Pursuant to theAgreement between WCPO-TV and Reporters Plaintiff was due approximately 26 weeks ofseverance pay. Defendant refused to make this severance pay to Plaintiff Other individuals whowere separated from Defendant received large severance packages. Defendant replaced Plaintiffwith a significantly younger male.
JURISDICTION AND
VENUE
10.
This Court has personal jurisdiction over Defendant because it conducts businesswithin this district and division,
11.
This Court has federal question jurisdiction to hear this case pursuant to 28 U.S.C.§1331 as it arises under the laws of the United States. Plaintiffs Count II arises under thePregnancy Discrimination Act of 1978 ("PDA"), 42 U.S.C. §2000e(k), Plaintiffs Count IVarises under Title VH of the Civil Rights Act of 1964 as amended
("Title
VH"), and PlaintiffsCount VI arises under the Age Discrimination in Employment Act ("ADEA"), 29 U.S.C. §621 etseq.
12.
This Court also has supplemental jurisdiction over the state law claims in CountsI, IE, V, VH and VIE pursuant to 28 U.S.C. §1367 on the grounds that these Counts are so relatedto the federal claims included in Counts II,
TV
and VI over which this Court has originaljurisdiction, that they form part of the same case or controversy.
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