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Please immediatelY comPlete the entire form
and return it to the U.S. Equal Employrnent Opportunity'
emPloYment discrimination must be filed within
the time limits
Commission ("EEOC") REMEMBER, a charge of Upon receipt, this
imposed by law, generallY within 180 days or
in some places 300 days of the alleged discrimination.
Answer all questions as completely as possible, and attach
form will be revierved to determine EEOC coverage. ansu€r b.v stating "not klown."
complete your response( s). If you do not know the
pages if needed to RfgEgtFEPn,
lf a question is not applicable, write "N/A." (PLEASE PRINT)

1. Personal
FrB 0 7 zctg

Last Name: First Name:

Street or Address

City County

Phone Numbers: Home: (--) Work: ( )

cer: (512 ) Email Address: le, e{,v

Date of Birth Sex: El Male AFemale Do You a Disability? dY.t tr No
Please answer each of the next three questions. i. Are you Hispanic or Latino? E Yes XXo
ii. What is your Race? Please choose all that apply. E American Indian or Alaskan Native E Asian tr White
ffi3lack or African E Native Hawaiian or Other Pacific Islander
iii. Whatis yornNatiCIral CIigin (ccx.nrty of origin trarcsy)?
Please Provide The ofA w Can Contact If We Are Unable To Reach You:
Address City RZipcode: 7f7: {
Home Phone () Other Phone 16l^ i '4 7oJ li 2
2. I believe that I was discriminated against by the following organization(s): (Check those that apply)
ffimployer tr Union tr Employrnent Agency E Other (Please Specify)
Organization Contact Information (If the organization is an employer, provide the address where you actually worked.
If you work from home, check here ... and provide the address of the office to which you reported.) If more than one
employer is involved, sheets.
o Name: L
City: State: zip: Phone z6-bS l)
Type of Business: ob if org.
Human Resources Director or Owner Name:
Number of Employees in the Organization at All Please Check 1r/) One
LessThan 15 tr 15- 100 K 101 -200 tr 201 - 500 tr More 500 E
3. Your
Date Hired:
Data (Complete as many items as you can
Job Title At Hire
#30 ooo
Pay Rate When Hired 00 or Pa v

Job Title at Time of Alleged t-

Name and Title of Immediate Supervisor {-
If Applicant, Date You Applied for Jo Job Title Applied For

4. What is the reason (basis) for your claim of employment discrimination?
rac'e' yott shottltl t:heck the box nert
EXAMPLE, iJ'-yott.feel thut v-ott r\'€r€ trecfied w'orse tltart sotneotle else becattse of
FOR ancl notional origin' )'ou shoultl
yo,''n'n" treatetl tlorse for severcrl re(lsotls' sttclt tts your sex' religiort
to Ruce. 1'ort feel in sonteone' else's cotttplairtt' orfiled ct charge rd'
c:heck all that appl)'' If complairrccl aboiLt discritrtirtcttirtn' ltttrticipatetl
next to Retoliatiott'
tltreaterted or taken' '-ott ihottd chec'k the bor
rliscrimincttion, ctntl cr negatit'e action vlos
tr Pregnancy (typically a
tr Age F-Disability tr National Origin (Colot tr Religion f,Retaliation
fl.Ruc" ['1Sex Information; circle which type(s) of genetic information
is involved:
diftbrence in skin shacle within thc samc race) E Genetic
education or testing)
Genetic scrvices (genetic services mcans counseling'
i. genetic testing ii. Family medical history iii'

genetic information?
If you checked genetic information, how did the employer obtain the

5. What happened to You that you believe was discriminatory?

and s) of the who believe minated St

(Example: 10102106 - Written Warning from Supervisor, Mr. John Soto)

A) Date:- Action:

Name and Title of Person(s) Responsible:

Name and Title of Person(s) Respon

Describe any other actions you believe were discriminatory. Please attach additional pages if need.

6. What reason(s) were giyen to you for the acts you consider discriminatory? By whom? Title?

7. What reason(s) were given to you for the acts you consider discriminatory? By whom? flis or IIer Job Title?

8. Describe who was in the same or similar situation as you and how they were treated. For example, who else applied
for the same job you did, who else had the same attendance record, or who else had the same performance? Provide the
race, sex, age, national origin, religion, or disability of these individuals, if known, and if it relates to your claim of
discrimination. For example, if your complaint alleges race discrimination, provide the race of each person; if it alleges
sex discrimination, provide the sex of each person; and so on. Use additional sheets if needed.

Of the persons in the same or similar situation as you, who was treated better than you?
Full Namc Race, Sex, Aee, h{ational Oriein, Relision or Disabilitv Job Title Description of Treatment


,f€E a/C,ihrul frye{

than You?
you' rvho rvas treated lrorse
in the same or similar situation as pescriPtion ot fre a
-- - )f the Persons Iob Title
Full Nnme

same as you?
situation as )-ou' who w'as treated the
Of the persons in the same or similar
Fuli Name Race. Sex, Age. National origin'
["iigi"' or bisability Job Title Description of Treatment

based on disability' If not' skip to question 13. Please tell

Answer questions 9-L2 only if you are claiming discrimination
,rrif Vor't uve more tt oo" disability' Please add additional pages if

9. Please check all that aPPIY: H Yes, t have an actual disabilitY

tr I have had an actlral disability in the past
tr No disability but the organization treats me as if I am disabled

you? Does this disability

10. What is the disability that you believe is the reason for the adverse action taken against
prevent or limit you from doing anything? (e'g., lifting, sleeping, breathing, walking, caring for yourself' working' etc')'

11. Did you ask your employer for any assistance or change in working condition because of your disability?
p(Yes tr No

If ''Yes," what medication, medical equipment or othcr assistance do you use?

12. Did you ask your employer for any changes or assistance to do your job because of your disability?
frYes tr No
If "Yes," when did you ask'? How did you ask (verbally or in writing)'?
Who did you ask'? (Provide full name and job title of person)

Describe the changes or assistance that yctu asked for:

Holv did your employer rcspond to your request'?

fte d// frawl /a/€{ 1

incidents? If yes' please identify them belolv and indicate
13. Are there any witnesses to the alleged discriminatory
your response'
they lvill say. Add additional pages if needed to complete
Adtlress & Phone Number What cio bclieve this person will tell us?
Full Name Job Title 'v-ou

14. Have you filed a charge previously in this matter with EEOC or another agency?
Yes E No(
15. If you have filed a complaint with another agency' provide name of agency and date of filing:

16. Have you sought help about this situation from a union, an attorney, or any other source? Yes
( No E
Provide name of organization, name of person you spoke rvith and date of contact' Results' if any'i

Please check one of the boxes below to tell us what you would like us to do with the information
you are providing on this
job discrimination, you must do so either within 180 days from the day you
Questionnaire. If you would like to file a charge of
knew about the discrimination, or within 300 days from the day you knew about the discrimination if the employer is located
a place where a state or local government agency enforces laws similar to the EEOC's laws' If you do not file a charge
of discrimination within the time limits, you will lose your rights' If you would like more information before filing a charge
or you have concerns about EEOCts notifying the employer, union, or employment agency about your charge, you may
wish to check Box 1. If you want to file a charge, you should check Box 2'

BOX L E I want to talk to an EEOC employee before deciding whether to file a charge' I understand that by checking this box,
I hur" t ot filed a charge with the EEOC' I also understand that I could lose my rights if I do not file a charge in time.

BOX 2 rvant to charge of di scrimination, and I authorizc the EEOC to look rnto thcr di scrimination I described above
file a
understand that the EEOC must give the employer, uruon, or employment agency that I accuse of discrimination
about the charge, including my name. I also understand that thc EEOC can only accepl charges of job discrimination hased on race.
colclr. religion. sex, national disability, , genetic information, or retaliation tbr discrimination.

PRIVACY ACT STATEMENT: This form is covered by the Privacy Act of 1974: Public Law 93'579, Authority Ior requesting personal data and the uses thereof are:
1) F0RM NUMBEH/IITLHDATE. EEOC lntake Questionnaire (9/20/08).
2) AUTH0RITY,42U.SC S2000e-5(b) 29US.C $211,29U.SC S626 42USC 121171a)

3) PRtNCIPAL PURPOSE. The purpose of this questionnaire is to solicit information about claims of employment discrimination, determine whether the EEOC has
jurisdiction over those claims. and provide charge filing counseling, as appropriate. Consistent with 29 CFR 1601 12(b) and 29 CFF 1626 B(c) this questionnaire
may serve as a charge if it meets the elements of a charge.
4) ROUTINE USES, EEOC may disclose information from this form to other state, local and federal agencies as appropriate or necessary to carry out the
Commission's functions, or if EEOC becomes aware of a civil or criminal law violation. EE0C may also disclose in{ormation to respondents in litigation, to
congressional offices in response to inquiries from parlies to the charge, to disciplinary committees investigating complaints against attorneys representing lhe
parties to the charge, or to federal agencies inquiring about hiring or security clearance mattels,
is voluntary but the failure to do so may hamper the Commission's investigation of a charge. lt is not mandatory that this form be used to provide the requested

Revised = Nov 2009 / Jan 2013 / DeC 2015 1

seo dilhmo/ /4#{

(This form is affected b1' the Privacy Act of 1974. See Privacy- Act Stoternent orl reverse before completing this
NAME: TELEPHONE NUMBER (6w ue+, co4"e)

Ashley L. Beckford HOME: 1 560-6170 woRK:

ADDAE99 (N**Je., tlTe*, d-1, t+i-tu, z;4-)

14745 Merrilltown Drive, Apl. #2621, Austi n,TX78728


ADDRE9S (Ne@b4{, *lrut, c+fu, tla1L, ,trr)






ADDRE99 (Nanbu, ttyuf, cLfu, yltlL, zv")

EEOC Fryw L33 (LL/oq)

HARM: Dischar-se.

I, Ashley Lynn Beckford. applied for and was hired as a "Production Assistant/ On-Air personality', by the Respondent, Free Speech
Systems. LLC. in June 2016. Alrrost immediately upon my hire, I hegan to bc sub;ected to harassment and discrimination, due to my
race, (Black - Afiican-American), my color, I was subjected to diffcrent terms and conditions of employment. in comparison to my non_
Black African-American peers, w,hen it camc to my salary/wages and benefits (travel), and in regards to my dress, includin-s my hair style.
I also was subiected to harassment and racial slurs by Respondent's management and some peer collea-sues. as well as subjected to sexual
harassment and a hostile. sexually offensive rvork environment, while employed with the Respondent. please see attached document.

On April 26. 2017, after abour 10 7z months of employment and atier asking Respondent's managemeni fbr a raise and adequate oftice
li-ehting in March 2017,l was discharged and terminated from my position with the Respondent as a ,,production Assistant/On_Air
To my knowledge, I'm aware that I was the only Black Afiican-American female emplo),ee that ever the Respclndent in the production
Department. Io my knowledge, I ant aware that there were two (2) other Black Afiican-American male employees who worked for the
Respondent's Production Department, who were also subjected to discrimination, and ultimately terminated.

RESPONDENT'S REASON FOR ADVERSE ACTION: I was intbrmed by Lydia Hernandez, Human Resources Direcror (Race
White/Fiispanic). and Rob Dew. News Director (Race
- ..write-ups.,.
- White), rhat I was bein-s terminated due ro ea..rr'u.
DISCRINIINATION STATEN{ENT: I believe that I have been discriminated against. due to my race (Black * African-American). and
color, subjected to dift'erent terms and conditions of employment with re_cards to my salary/wases, and benefits (travel), my dress.
including my hair style. and also subjected to harassment, sexual harassment and a sexually oft'ensive work environment by the
Respondent'smanagementandalsobysomeofmypeercolleagues. IbelievetheRespondent'sactions,behaviorandconductwerein
violation of Title VII of the Civil Rights Act of 1964, as amended, the Equal Pay Act of I 963, as well as The Tsxas Commission on
Human Rrghts Act.

I declttre under the penaln' of perjun' tlrcil the foregoing is trtte and
PA6E I oF2-
Feb 07,2018
PRIVACY ACT by the Law 93-579 and uses of the persoual data ue given be1ow.)
2. AUTHORITY: 42 USC 2000e(9), 29 USC 201. 29 USC 621, 42 U.S.C. 12117. 42U.S.C. 2000ff-6.
3. PRINCIPAL PURPOSES: Provides a standardized formt for obtaining swom statemeats of informtion relevant to a chage
of discrimination.

and (3) in Comission litigation. to impeach or substantiate a witness,s testimony.

Volunrary: Failure ro provide an affidavit
has no effect upon juisdiction of the Comission to process a charge. However, sworn statements submined by the parties ue. of course.
relied upon more heavily than unsworn
staterents in mking a determination as to the existence of unlawful discrimination.


EEOC Form 5 (1 1/09)

C HARG E OF DISCRI I\TI NATION Charge Presented To Agency(ies) Charge No(s)

This fom is affected by the privacy Act
ol 1gt4. See enclosed privacy Act
Statement and other inlormation before completinl
tf.ri. fom
x FEPA 650-1 8-076
x EEOC 36A-2018-00079
Austin Equal EmploymenUFair Housing Office
and EEOC
State or local if
Name (indicate Mr., Ms., blrs.)
Home Phone (lnct. Area Code) Date of Birth
Ms. Ashley L. Beckford
(512) 560-6170
Street Address
City. State and ZtP Code
14745 Merrilltown Drive, Apl. #2621, Austin, TXZgT2g

Nramed is the Em ployer, Labor Organization, Employment Agency

Apprenticeship Committee, or State Local Government Agency That Believe
Discri minated Against Me or oth ers.
ut more than two, list under PARTICULARS below.)
No Employees, l\y'embers Phone No. (lnclude Area Code)
15 - 100 (s12) 291-s750
Street Address
City. State and Ztp Code
3019 Alvin Devane BIvd., Austin, TX7g741

No. Employees, Members Phone No. (lnclude Area Code)

Street Address
City, State and ZtP Code

DISCRIIMINATION BASED ON (Check appropriate box(es).)

x RACE colon [-l ..* HELIGION NAT'ONAL ORIGIN 06-26-2016

OTHER (Specify)

THE PARTICULARS ARE (lf additional paper is needed, attach ertra sheet(s)):

HARM: Discharse
I, Ashley Lynn Beckfbrd. applied fbr and w,as hired as a ,,production Assistant/ On_Air personality,.
by the Respondent, Free
Speech Systems. LLC, in June 2016. Almost immediatelv upon my hire. I began to be subjccted to harassment
ancl discrimination,
due to my race, (Black - Atiican-American). my color, I wai subjected to ditterenr
terms and conditions of employment. in
comparison to my non-Black Atiican-American peers. when it came to my salary/wages
and benefits (travel), and in regards to my
dress, includin-e my hair style. I also was subjected to harassment and racial
slurs by*Respondent,s management and some peer
colleagues, as well as subjected to sexual harassment and a hostile. sexrrally offensive *ork e.,,rironment,
rvhile cmployed with thc
Respondent. +*Please see attached document.*,k
On April26,201'7 , after about 0 r/2 months of employment and atter askin-s Respondent' S management for a ralse
and adequate
of flce in March 20 l I was and terminated tiom with the AS a 'Production

I want this charge filed with both the EEOC and the State or local Agency, if any. NOTARY
will advise the agencies if I change my address or phone number and I will
I - When necessary for State and Local Agency Requirements

cooperate fully with them in the processing of my charge in accordance with their Timothy Jackson
I swear or affirm that I have read the above charge and
I declare under penalty of perjury that the above is true and correct. that it is true to
the best of my knowledge, information and beliefl

KC (month. day,
Pui:iic, S:oie cf
Party Ccm ;r. Ercire s i8-28-2021
EEOC Form 5 (1 1/09)

CHnncE or DlscRtrMtNATtoN Charge Presented To: Agency(ies) Charge No(s)

This form is affected by the Privacy Act of 1974. See enclosed privacy Act
Statement and other information before completing thls form. x FEPA 650-1 8-076
x EEOC 36A-2018-00079
Austin Equal EmploymenUFair Housin g Office and EEOC
Slate or local if any
Assistant/On-Air Personalitl. "
To my knorvled_ee. I'm aware thar I was the only Black African-American lemaie employee that ever the Respondent in the
Production Department. To m1, kno'"vledge, I am awarc that there were two (2) other Black African_American male employees whct
u'orked for the Respondent's Production Department. who ra,ere also subjected to discrimination. and ultimately tenlinited.
RESPONDENT'S REASON FOR ADVERSE ACTION: I w,as infornred by Lydia Hernandez. Human Resources Dircctor (Race
- White/Hispanic). and Rob Dew, News Direcror (Race - White), that I was being terminated rlue ro excessive .,rvrite_ups.',
DISCRIN'IINATION STATEMENT: I helieve rhar I have becn discriminared a_{ainsr. due ro my race (Black _ Atiican-
American). and color. subjected to diltcrent terms and conditions of employment u,ith regards to my salary/wages. and benefits
(travel), my dress, including my hair style. and also subjected to harassment. sexual harassmcnt and a sexually ofttnsive u.ork
environmentbytheRespondent'smanascmentandalsobysomeofmypeercolleagues. IbelievetheRespondent'sactions.
behavior and conduct were in violation of Title VII of the Civil Ri-shts Act of 1964, as amended, the Equal pay Act of 1963. as well
as The Texas Commission on Human Rights Act.

I want this charge tiled with both the EEOC and the State or local Agency, if any. I NOTAHY - When necessary for State and Local Agency Requirements
will advise the agencies if I change my address or phone number and I will
cooperate fully with them in the processing of my charge in accordance with their Timothy Jackson
I swear or affirm that I have read the above charge and it is true to
I declare under penalty of perjury that the above is true and correct. the best of my information and belief.

x 0 v SU

Pafty Signature
City of Austin, Equal EmPloYment/
Fair Housing Office
Mailing: P. 0. Box i088, Austin, Texas 78761
Physical: 1050 East l ith Street, Suite 200, Austin, Texas
Phone: 512-974-3251 (Voice) I 512-914-3278 (Fax)

CHARGE NUMB ERS: 650-18 - r'lr%pppuo :36A-2018 -oo #?



'\/ L-L-.-r

Although your charge was filed under Title VII (EEOC), this is to advise you of your right to
pursue a lawsuit in State Court under the Texas Commission on Human Rights Act' as
amended TTCHRA).

In order for you to protect your right to pursue a larvsuit under the
you must file your
Lawsuit before the two-year Statute of Limitations has run, which is
If you want to secure a State Right to Sue Notice, please, do so in writing' The City of Austin'
Equal Ernployment/Fair Housing Office will administratively close your charge and you must send
your request to the Texas Workforce Commrssion Civil Rights Division.

I acknowledge that I have read the foregoing statement, and understand its contents' I
acknowledge that I have received a copy of this statement and that a copy rvill be retained in
the records of the City of Austin, Equal EmploymentiFair Housing Office.


* --1 ]-
IV .{
,X- /\
vt /
Date .ture

6J2 07 /8
Date Investigator's Si
1 of13

fJ.S. Equal Emp@ment Opportunity Commission

Intake Questionnaire
Additional Pages of Answers

Ashley Lynn Beckford

FebruarY 7 r 2018

Production Assistant
Free Speech Systems, LLC
June 16,2$16 -April 26,2017

4. What is the reason (basis) foryour claim of employnent discrimination?

Race: To my knowledge, I was the only AfricanAmerican wonurn ever to work at Free Speech
Systems, LLC. I was at the forefront of InfoWars news reports as a broadcast news analyst,
during the Trump election season and tansition period. BothAfrican American men ever to work
for the production team were fired within the same monttr, July 2017 (termination due to race/
color). I believe that certain actions, such me, \rrere taken against me because I
am a black indiYidual.

Color: I was repeatedly mocked for my skin tone, and I was denied promotions to match the
salary of other coworkers who did less work in a similarjob.

Equal Pay/Compensation: I was paid less than my colleagues who did similar work, less
difficult work and/or less hours.

Sex: Joseph Jennings, Alex Jones and several other supervisors and colleagues commonly leered
at women inthe office, made sexual geshnes and advances.

Disability: I have myopia and astigmatism, which affects my ability to work. I was not afforded
a normal level of office lighting in which to do my work.

Retaliation: I was fired after requesting a salary increase.

Other reason (basis for discrimination):

Political affiIiation: I wanted to hold President Trump accountable for his actions,like a fair and
balanced news network, but I was reprimanded if I ever questioned his actions, even though I
heavily campaigned on Trump's behalf for InfoWars.

Hostile work environment: I was intimidated by the constant open carry and display of guns by
co-workers in the workplace. My supervisors and peer colleagues often brandished guns to scare
away crared fans (exhemely hostile work environment), which made me feel uncomfortable and
unsafe at work every day.

5. What happened to you that you believe was discriminatory?

Desuibe any other actions you believe were discriminatory.

A. Date: April2612017

Discrimination - Fired from Frce Speech Systems
Action: Racial
Roh Dew' Lydia Hernandez
Name aud Title of Person(s) Responsihle:

B. Date: March 2017

then Received Bogus Write Up
Action: Retaliation: Asked for Salary Increase'

would need to work on weekends' in addition

The staffwas told by management that we
2017 ' Buckley Hamman (Alex's cousin)
to the longer weekday hours during February
was not the only time that we
referred to the produttion staffas "motherfuckers"'which
than voicing our opinions about
were verbally abused, for absolutely no reason other
scheduling. I have audio evidence for this'

we don't work (for no

Rob Dew told production staffthat we "better be dead" if
extra compensation on the weekends). I have audio evidence
of this'

a salary increase to $45,000 to reflect local salary expectations

for my work'
I requested
showing that I was being underpaid compared to my white co-workers'

I was immediately attacked with fabricated write-ups from multiple managers until they
had sufficient evidence to fire me with the appearance of having cause'

I received continuous write-ups for the same behavior that other workers, including
me, had been previously able to do without negative consequences, in order to build
a case against my work ethic. I was threatened into sisning documeutation without any
review on my part or addition of my aocount of the alleged incidents.

Name and Title of Person(s) Responsible: Rob Ilew, News DirectorrAlex Joneso
CEO, Marcos Morales, Nightty News Editor, Buckley Hamman,Ilirector of

C. Date: January 912017

Action: Race/Color Discrimination - Racial slurs

Rob Dew referued to me as a coon, which is a racial slur for a person who is of African
descent. I was walking througb the darkened warehouse/photogaphy space, throwing
away the rernn mts of my dinner and a paper plate into a fiash can. He switched on the
light jumped back away from me, and shouted, "It's a coon!" When I became angry, he
said that he had meant a raccoon, but did not apologize.

Name and Title of Person(s) Responsible: Robert

llew' News Director

D. Date: January 28,2A11- Texas Rally for Life

Action: Equal PaY/ComPensation

the office on a
Alex Jones was meeting with Daria the Russian operative in
four hours reporting on
Saturday. I was prepari"g * leave the offtce, after spending
that day's pro-liie march activities when Alex Jones said:
"I should give you a r&ise"'
for a pay increase'
but I never received a raise. Instead, I was fired after directly asking

Name and Title of Person(s) Responsible: Alex Jones, CEO

E. Date: Ongoing (around December/January 2016 -2017\

Action: Race/Color Discrimination - Racial slurs

Owen kept referring to black people as "colored" on-air (at least 3 separate
occasions) despite my continued assertions that it was not the correct term,
and that I was offended by his usage of the term to refer to people of African descert'

Name and Title of Person(s) Responsible: Owen Shroyer, On Air Personality

F. Date: October 2016

Action: Race Discrimination - I was shown racist white supremacist symbols

Darrin McBreen received two gifts of fihess shoes (sneakers), one of which was laden
with swastikas, from a fan of Info$/ars and Donald Trump, which he proudly displayed to
me (display of racially-offensive symbols - hostile work environment). He wore one of
the pairs (withoutthe swastikas) often, but showed me the swastikas shoes once.

Name and Title of Person(s) Responsible: Darrin McBreen, Video and Graphics

G. Date: September 26,2016

Action: Sexual Ilarassment - Physical Touch

Although I was hired as an underpaid production assistant, InfoW'ars, specifically the so-
calledNews Director Rob Dew, assigned me to interview attendees as a debut reporter at
a Democratic watch party for the first presidential debate at Scholz Garten inAustin, TX.

I was exFemely nervous to attend the even! but I sensed that I was at risk for losing my
job if I didn't comply. (I had good reason to assume that my job would be at risk
I was constantly told to "keep my head down,, after the only other two black people ever
to work onthe production staffat InfoWars - Jakari Jackson and Gabe Goldiamond _
were fired in close proximity for seemingly no causejust weeks before.)

My cameraman, Josh Owens, who had worked at InfoWars for years, compared to my
less than three month tenure, consistently pressured me to engage with the Hillary
Clinton supporters as a black Trunrp promoter. I was subsequently subjectto multiple
people hurling insults and racial slurs at me, including ..Uncle Tom,o, by one of the gay
white male attendees. Alother Clinton supporter, a white lesbian woman, told me tlrat
she knewmore about black issues than I did because she is married to a black woman,
who was also present. (This was all captured on video, and I suggested that night that
the footage should not be uploaded to the youtube channel because the interactions
weren't newsworthy and had no political value. Rob Dew insisted on uploading it to
exploit the racial attack on me for InfoWars to profit. Now, the existence of these clips is
still hurting my professional reputation as ajournalist.)

I went back to the InfoWars' office in tems, incredulous at how I was being racially
attacked because ofmy support for apolitical candidate, andAlex Jones, taking
advantage of my fragility at that mometrt, forced me to share what had happened to me
on the air for YouTube and other social media that same oight" feigning his own tears of

After the broadcast, I was withAlex Jones, Rob Dew and several otlrer staffmembers in
Rob Dew's office (which also seats several other desks for staffers). I was talking about
how I didn't agree with the white woman who had said that she knows about the black
community better than I do because she has a black wife. Alex Jones was still pretending
to feel sympathy for my plight as a black female Trump supporter, and he put his arm
around my shoulder to initiate a u'side hug." After he pulled me into his side, instead of
removing his amn from my shoulder, he allowed his arm to slide down my back and he
grabbed my butt with his right hand. SimultaneouslS he was commenting to those in the
room, "Who wouldn't want to have a black wife?" to response to my somment.

I felt embarrassed and nervous, but I knew that he had specifically touched my behind at
that moment as a sly come-on that other people may aot notice. It was exbemely ironic
because it was the lesbian white worvrn with the black wife who had mentioned earlier
that night, on camera, howAlex Jones is a womanizer who loves Grey Goose. I didn't
know then that later on that same night" he would be drunk enough to feel confident
about fondling his female staffers. (Most of the staf[was drinking alcohol that night in
the office, as was the usual on late aightr. Alex Jones was in possession of his fiademark
mugs and paper cups, which his staffers often alleged contained alcohol-infused

The aforementioned videos from 9126116 showthe events inrmediately before the sexual
harassment/molestation thatAlex Jones perpetrated against me. Alex Jones himself
wanted my camera maq Josh Owens, to uptoad the rmedited videos to the Alex Jones
channel on YouTube (very rare for this to happen' but I had no say in the matter), despite
my objections.

Even so, the very next morningAJ asked Rob Dew, one of my directmanagers, to delete
the videos from &e AJ YouTube channel because he was afraid that he would be sued (by
the women in the video) as a result of rnaking the videos public. By that time, the videos
had already been downloaded and re-uploaded on multiple YouTube channels, and the
fact that these videos are still there is hurting my professional reputation'

Name and Title of Person(s) Responsible: AIex Jones, CEO

I{. Date: July 14,2016

Action: Staffmembers offended me using racial slurs, by repeatedly using the term
o'Fat blackbitchD

I was offended by continuous attacks against blacks (Africans andAfricanAmericans),

Mexicans and Muslims in the office, on, aad the AJ YouTube channel.

The term "fat black bitch" was repeatedly mentioned and laughed about in the
office because of this article:

The callous, racist attitudes of my coworkers caused me to cry at work that day.

I informed my supervisor Rob Dew (who later called me a coon and referred to Robert
Jacobson as a Resident Jew), but he didn't take any action against the perpetrators.

Lee Ann McAdoo apologized that day for "riggering" me, and I saved the
letter (amounts to offensive jokes, slurs, epithets, ridicule, mockery and name
calling in reference to my race/color).

Name and Title of Person(s) Responsible: LeeAnn McA.doo, Robert Dew, PauI
Joseph'lVatson, Owen Shroyer

I. Date: June 2016 and Ongoing

Action: Sexual Harassment - Grooming


Alex Jones came to my desk on one occasion to find out.lrhat I like

to do for fun.
outside of work, and it's my opinion thatitwas his intention to see ifhe
could groom me
for sexual exploitation because he also mentioned that I had a..good body thatiooked
like I worked out a lot.'I was concemed that these unwanted sexual advances
eventually result in a request for sexual favors in exchange for promotions.
In the office,
it was rumored that he may have had inappropriate relationships with other female
production staffemployees. In addition, Alex Jones himself has alluded to
the fact that he
loves to grab woman's backsides in videos that he has made and uploaded
to youTube.

Alex often spent his time shirtless, and endlessly leering, with or without a shirt, at
female guests and employees while creating a disgusting, hostile environment
that openly
encourages his staff(roughly 90% men) to stare at and make inappropriate comments
toward women.

Name and Title of Person(s) Responsible: Alex Jones, CEO

J. Date: Ongoing

Action: Race/Color Discrimination: Never given press credentials despite beirrg

repeat On Air Personality

I was never given a budget to travel despite promises at hiring. I was doing more
reporting work outside the office than my other coworkers. I had to do rnany of same
broadcast analyst duties (working repeatedly as an oo air news presenter) as my white
European coworkers hired at the same time. In addition, I had production assistant tasks
to complete as well.

Name and Title of Peroon(s) Responsible: Robert Dew, News Director

IC Date: Ongoing from llire Date

Action: Sexual flarassmen* words, gestures, offensive pictures

Joseph Jennings would look at pornography at work, which was easily viewable to
others. He and other coworkers told me that he was the human resources director, when I
first began working ttrere, which was a lie. I was coofirsed about how to report his
behavior. His inappropriate way of dressing at the office (never used belts despite his
obese body) meant that he constantty showed his butt crack, which was another form of
sexual harassment, because he didn't change it despite it's offensiveness being brought to
his attention by female and male coworkers alike.

Name and Title of Person(s) Responsible: Joseph Jennings, Studio Manager


L. Date:Ongoing

Action: Race/Color - Bigoted Skin and Hair Comments

(and other
I was continuously criticized for how my dark skin, naturally kinky hairstyles
and affect the
hair textures that i experimented with) would project on the screen
He said' "you're not black'
audience. Joseph Jennings would tell me that I wasn't black'
you're Ashley" on several occasions, as if being called black is a slur and being
American is a determent in and of itself'

Name and Title of Person(s) Responsible: Joseph Jennings, Studio Manager

M. Date: June 16, 2016' Ongoing

Action: Unequal PaY/ComPensation

I was hired at an initial compensation rate of $25,000 per year as production assistant'
with no openness to negotiate, which was less than 50% of the pay to my white co-
workers who did less work. I was immediately expected to complete the duties of
assistant producer, rryorter, video editor and broadcast news analyst (on air mdio
broadcast and YouTube personality) with at least 50 hours per week and on-call. I had
experience at two major media companiss, The Associated Press and the Voice of
America before working at InfoWars.

Name and Title of Person(s) Responsihle: Robert Dew, News DireetorrAlex Jones,

6. What reason(s) were given to your for the acts you consider discriminatory? By whom?

Unequal PaylCompensation

I was told by Lydia Hernandez, Human Resources Director, that I was being paid the typical rate
for my job title. However, I was working more hours and completing more tasks, essentially
doing much more work, than my job title specified. I explained all of that in a porffolio when I
requested my salary increase.


I complained to Marcos Morales, InfoWars Nightly News Video Editor, about Owen referring to
people ofAfrican descent as colored. He told me that Owen isn't racist, and that no one at
InfoWars is a white supremacist.

discriminatory? By whom?
7. \ilhat reason(s) were given to your for the acts you

His or Her Job Title?

Sexual Harassment
Video Editor' excused Joseph Jennings'
Marcos Morales, lnfoWars Nightly News
by saying that his actions were part of the company
Manager) daily sexual harassment behavior to have
and Rob Dew' News Directoq that I needed
culture. I was told by Morales, Jennings
tough skin and ignore the harassment'

Hostile work environment

was to carry firearms' I was told to "keep my

Rob Dew told me that the company culture
me uncomfortable'
down" and not complain aboufthings that made

as you' who was treated better than

8. Of there persons in the same or similar situation

Full Name: Owen ShroYer

Race: White
Sex: Male
National Origin: USA
Religion: Christian
Disability: Unknown
Job Title: On Air PersonalitY
(salary)' although we
Description of Treatment: He had a higher rate of financial compensation
were hired at the same time. He was given camera crews and travel budgets
for news events'

Full Name: LeeAnn McAdoo

Race: White
Sex: Female
National Origin: USA
Religion: Unknown
Disability: Unknown
Job Title: On Air PersonalitY
(salary)' even though I
Description of Treatment: She had a higher rate of financial compensation
workload' She was
put in more work hours and completed additional tasks compared to her
given camera crews and travel budgets for news events'

FullName: Julian
Race: White
10 of 13

Sex: Male
Age: 20
National Origin: USA
Religion: Christian
Disability: Unknown
Job Title: Assistant Producer
rate of financial compensation (salary)'
Description of Treatment: He was hired at a higher
He had less experience than me' and he was
although he was hired six months later than me'
more pay'
given L" ,*" job as me, with less responsibilities and

who was treated worse than you?

Of the persons in the same or similar situation as you'

Full Name: Robert Jacobson

Race: White
Sex: Male
Age 42
National Origin: USA
Religion: Judaism
Disability: Chron's disease
Job Title: Video Editor
Description of Treatment:

Date: Ongoing

Action: Race/Religion - Affected by Abuse Toward My Colleague

I was offended by several co-workers ridiculing and mocking Robert Jacobson for his
religion (multiple instances of hateful rhetoric, insults, put-downs and so-called jokes,
including the creation of a meme to denigrate Jewish people)' This personally affected me
because my own family includes several Jewish people. These racist attacks were predominately
perpetrated by Michael Zimmerman and Joseph Jennings, who would actually show offthe racist
memes, but it was encouraged by the entire operation.

Alex Jones allegedly uses the term "globalists" as a dog whistle for white supremacists to
refer to Jewish people with a negative connotation. Rob Dew and Owen Shroyer infamously
called Robert Jacobson their'oresident Jew" on ait via YouTube' Rob Dew had earlier called me a
o'colored," so it reasons that they were likely calling
coon and Owen referred to black people as
me a "token black" or "house n-word" when I wasn't in their presence' I have evidence of that
"Jewish individual" meme that Zimmerrnann created as well as the YouTube video of the
"Resident Jew" commentary from Dew and Shroyer.
11 of 13

Rob Dew' News Ilirectori Owen Shroyer' OnAir

Name and Title of Person(s) Responsible:
News Personality, Michael Zimmermann,
ProductionAssistant' Joseph Jennings' Studio

Full Name: Jakari Jackson

Race: Black
Sex: Male
Age: 30
National Origin: USA
Religion: Christian
Disability: Unknown
Job Title: OnAir Personality - InfoWars Nightly News
(July 2017) when he
Description of Treatment: He was fired during the same month as Gabe
refused to support the candidacy of Donald Trump'

Full Name: Gabe Goldiamond

Race: Black
Sex: Male
National Origin: USA
Religion: Unknown
Disability: Unknown
Job Title: Video Editor and ProductionAssistant
Descripion of Treatment: He was fired after one month on the job. He was not given adequate
training or pay.

Full Name: Margaret Howell

Race: White
Sex: Female
National Origin: USA
Religion: Christian
Disability: Unknown
Job Title: OnAir Personality
Description of Treatment: She was forced to resign because of continuous sexual harassment and
a hostile work environment.

Of the persons in the same or similar situation as you, who was treated the same as you?

No one was treated the same as me. I was the only dark-skinned African American woman at

9. Yesr I have an actual disability

12 of 13

10. What is the disability that you believe is the reason for the adverse action taken against
you? Iloes this disability prevent or limit you from doing anything?

I have two visual conditions, myopia and astigmatism. This limits my ability to have clear vision
without assistance. I can't see under low light conditions, and working under low lighting causes
further damage to my eyesight.

11. Did you askyour employer for any assistance in changing working condition because of
your disability?

The overhead fluorescent light bulbs installed in the ceiling above my desk in my office space
had been unscrewed before I started working there. I asked my employer (Rob DeW News
Director and Buckley Hamman, Director of Operations) to allowthe maintenance crewto screw
the light bulbs back into the fixture so that I could have a nomral level of lighting in my
workspace. The room whsre I was working had very littte light from the or*doors, and I only had
small desk lamp.

What medication, medical equipment or other assistance do you use?

I use corrective lenses, including prescription eyeglasses and contact lenses.

12. Did you askyour employer for any changes or assistance to do youriob because of your

When did vou ask?

After having an eye exam in January 2017,I asked to change the lighting in February 2017

How did you ask (verbally or in writing)?

I asked verbally.

\ilho did you ask?

I asked two maintenance workers, then I asked my supervisors, Rob Dew, News Director and
Buckley Hamman, Director of Operations.

Describe the changes or assistance that you asked fur:

I asked for the overhead light bulbs to be screwed back into the fixture. so that I could turn the
lights on and off above my desk.
13 of 13

to your request?
How did you employer respond
request for typical office
specifically Buckley Hamman' would not honor my
My employer, my eye sight in a
fo,'"a to continue *'fi'g in dim lighting' which affected
lighting. l was
negative waY.

to the alleged discriminatory incidents?

13. Are there any witnesses

Full Name: Robert Jacobson

Job Title: Video Editor
will tell vou about the hostile work
iffiilH:fiiiiil?'Jl"' wili ten us? Robert racobson
inclu-ded racism' sexual harassment
and implied physical threats'
environment, which
any other source?
you sought help about this situation from a union' attorney or
16. Have

I have corresponded via email with:'

Ben Meiselas, Esq.
Geragos & Geragos Law Firm
Telephone: (213) 625-3900
Facsimile: (213) 625-1600

of 02/07118 at12:J0 PM CST'

No response. This is not my attorney as

2 7
Dallas District 30? s. HouiionrsirTif,lstiil
Toll Frcc: (866) 103-8075
TTY (S00) 669-6820
(2 I {) 253-2720
"' 't"t.*t-iotit'n F'rx
l'l) 153-2899
Fax (2
l-lr P-::'YY-E$!:a!' gq!

Dallos District Oflice

San Antonio Field Oflicc
El Paso Area Ollice

R ZO l|,-t)aYq
DATE: &' b I8
that your charge is eligible for
Equal Employment Opportunity Commission (EEOC) has determined Try
The ut You Neecl To Know Arul lWry You Should
mediation. Please review the attached pt'"fiil';.-iV;')iiion- ^
for you to try and benefit from mediation!
It", utdread how rn"Oiuiion can work io' Vo''- Wt would like
to the address above or the
to ouTMEDIATION STAFF within 15 tlavs
fax number below


you agree to mediate, please return rftis form and also forms 2&3)


Please comolete the box resardless of the option selected:


Address CitylState/Zip:

Phone: Fax Number:

Email: Fax Number:

If you have representation, please provide thefollowing information:

Representative' s Name: Phone

Representative' s Address

Representative' s City I Statel Zip Fax

Representative' s Email :

. Please ensure the attomey representing you faxes a letter of representation to us.

FAX TO i 214-253-2899
Form #2


a mediation in the above referenced charge'

This is an agreement by the parties to participate in
may be terminated at any time'
parties understand that mediation is a voluntary process' which

The parties and, if they desire, their representatives and/or

attorneys' are invited to attend a
of the mediator(s)'
mediation session. No one else may attend without the consent

The mediator(s) will not function as the representative of either

party' However' the mediator(s) may
assist the parties in crafting a settlement agreement' Each
party acknowledges being advised of their
option to seek independent legal review prior to signing any settlement agreement'
The parties acknowledge that the mediator(s) possesses the discretion to terminate the mediation
any time if any impasse occurs or either party or the mediator deems the case inappropriate for

The parties recognize the mediation is a confidential process and agree to abide bythe terms of the
attached Confidentiality Agreement.

The parties acknowledge that if a settlement is reached as a result of the mediation, the assigned
mediator(s) is required to report to EEOC any benefits received. This information is reported only for
purposes of providing aggregate data to the EEOC for Mediation program evaluation purposes, and the
individualterms of the agreement will not be disclosed to the public.





Form #3


in an effort to resolve the charge(s) filed with the
1. The parties agree to participate voluntarily in mediation

mediation are confidential' unless otherwise discoverable

2. The parties agree that all matters discussed during the
proceeding' Confidentiality'however'
of actual violence that occur during the
will not extend to threats of imminent physical harm or incidents

Any communications between the ADR coordinator and the mediator(s)

and/or the parties are considered dispute
resolution communications with a neutral and will be kept confidential'

produce any documents provided

4. The parties agree not to subpoena the mediator(s) or compel the mediator(s) to
by a party in any pending or future administrative of judicial proceeding' The
mediator(s) will not voluntarily
testifyonbehaliofrprrtyinanypendingorfutureadministrativeorjudicialproceeding' Thepartiesfurtheragree
that the mediator(s) will be held harmless for any claim arising from the mediation process'

5. Mediation sessions will not be tape-recorded or transcribed by the EEOC, the mediator or any of the participants'
All information or materials provided or created by the mediator including all notes, records, or documents
generated during the course of the mediation shall be destroyed by the mediator after conclusion of the
mediation. Parties or their representatives are not prohibited from retaining their own notes' However, the EEOC
will not maintain any such notes or records as part of its record keeping procedures.

6 lf a settlement is reached by all the parties, the agreement shall be reduced to writing and when signed shall be
binding upon all parties to the agreement. lf the charge(s) is not resolved through mediation, it is understood by
the parties that the charge(s) will be transferred to the investigative unit for further processing.

Charging Party Date Respondent Date

Charging Party Date Respondent Date

Representative Representative

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