10 civ 69 sucsom UDG 3E SAND wi cover sucer 50 ev. 1/2008 5 2010 PANTS ‘DEFENDANTS H. CRISTINA CHEN-OSTER; LISA PARISI; and GOLDMAN, SACHS & CO. and THE GOLDMAN SHANNA ORLICH SACHS GROUP, INC., “ATTORNEYS [FIRM NAVE, AOORESS, AND TELEARONE NUMBER) ATTORNEYS (F RNOWN) GUITEN @ GALEN Tit Park vende F126, NV 0016 (212) 2461000, Atonton: Azam Tin LEFF CABRASER HEIMANN & BERNSTEIN, LLP, 275 Baty Stes F129, Trance CA St (115) 280-100 Atealon Kely M Benoa ‘GAUSE OF ACTION (cre Tie Us. cvs svATUTE UnoER Which YOU ane Fao ANU WHITE A PREF STATEWENT OF CAUSE Title VI of the Givil Rights Act of 1964, 42 U.S.C. §§ 20006 et seq: discrimination and retaliation as this or sila case been grevious fled in SDNY at ary no? Nov] Yes?) swage Previously Assigned tyes, wes this case WoiL] invol C) dismissed. NoC] Yes O_ttyes. give date. A Case No. (PLACE AN f ONE Box one NATURE OF SUIT Hyg mewawcr yy mnaag (it sewn ty fo somata (ves se Ho GRRE 1485 SAAS monucr (TR Sema [1 sou Site EMomauer TH HaEREee U8 Germann | Meant en Shen tn Rye ROD Reis came dhe ume 1 FER SSNY Goes Emimeareo SEER 118 RE ie tae amas, Ear COST, (08S Seu iB see Seat a OER Carew BEE anorarvons {is Se Sa ae i ronsoncemorenry — {JR SSSSASE co corvts Sees time sede {SE HER cer HHS Sane, {1s see as toes HE say oneneue (IE Sess, IEE ee ap BSRhcrenene SRS (use wens [IT SURE ng (IMP Seer, e Sieaee, Beeiriows (Se igrenimses 1RN GRR RA Shan (iB Seer 1 Te ae DO TAMERY ay eer Sana seem eecrmry es Seiten Ue So Ben USE soe tha sae, seme nae {ime GtRetir amp 11s Gustowen tire pigugoe [JE Bhesimegn., 0 Saree ty Bote HEL 1B Bene cae tim Bigs ture Beatie” IESE" we dt tro Sones 11720 LAaORINAS MT |[ [801 AGRICULTURAL ACTS ORES acvensonerstnues Sea, mmr EE ancy ee pig HAs yue waesas anne (yo SO 12186 FRANCHIEE: ‘com eG “PRISONER PETTHONS 11790 OTHER LABOR 1109 ea ATTERS | C19 wonenera tim BORN: OUTER MEIarY Um BEES (1s BES amma tom eee fee ute (ig Seas Snr tig feeeenies {iE SERRE Phen cre wevpzaron St HS raters HE SESE new ug See ee SERS, ‘Goch donandedn coma hE This ACLASS ACTION 30 YOU CLAIM THIS CASE 1S RELATED TO ACL CASE NOW PENDING INSONY.? a Gnoen enc? 28 eos DEMAND & omer suoge DOGKET NUMBER Check YES ony demanded in complaint JURY DEMAND: YES ONO NOTE: lease submit atthe time of hing an explanation cf why cases are deemed eso(PIRCE AI ONE BOK ONLY ORIGIN fom [13 neareecton (14 ne Dabremovestan (PLACE AN WORE BOK ONLY BASIS OF JURISDICTION TF DIVERSITY, INDICATE C1 us ptanTiF [12.Us.DEFENDANT [29 FEDERAL GUESTION — (J4 DIVERSITY CITIZENSHIP BELOW. (US.HOTAPARTY) (28. USC 1322, 1441) CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY) (Places (in one box or Phan and ene bos or Deter cmemorrussrare {14 {Tt enaenonsuasser ora TTS TTS— mcowworatenggenciat nace 178 15 PLAINTIFF (8) ADDRESS(ES) AND COUNTY(IES) H. CRISTINA CHEN-OSTER is a resident of Redbank, New Jersey LISA PARISI is a resident of Allanta, Georgia, SHANNA ORLIGH is a resident of Weehawken, New Jersey, DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES) GOLDMAN, SACHS & CO. 200 West Street New York, New York 10282 THE GOLDMAN SACHS GROUP, INC. 200 West Street New York, New York 10282 DEFENDANT(S) ADDRESS UNKNOWN REPRESENTATION iS HERESY MADE THAT, AT THIS TIME, | HAVE BEEN UNABLE, WITH! REASONABLE DILIGENCE, TO ASCERTAIN THE RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS: Ccheck one, THIS ACTION SHOULD BE ASSIGNED To: [] WHITE PLAINS — {Z] MANHATTAN. (00 NOT chook oir box this 3 PRISONER PETITION ) ont “SIGNATURE OF ATTORVEV OF RECORD ‘ADMITTED TO PRAGTICE W TMS OISTRICT No. 7 BYES (DATE aomirreD mo, 24 ye, 1891 recatrre Z Ilorey Ba Goo DES Magistrate Judge is to be designated by the Clerk of the Court Magistrate Judge J. Michael Metahon, Clark of Court by Deputy Clerk, DATED UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)OUTTEN & GOLDEN LLP LIEFF, CABRASER, HEIMANN & Adam T. Klein BERNSTEIN, LLP Cara E, Greene Kelly M. Dermody (pro hae vice forthcoming) Jennifer L. Liu Anne B, Shaver (pro hac vice forthcoming) 3 Park Avenue, 29th Floor Heather H. Wong (pro hae vice forthcoming) New York, New York 10016 275 Battery Street, 29th Floor Telephone: (212) 245-1000 San Francisco, CA 94111-3339 Facsimile: (212) 977-4005 ‘Telephone: (415) 956-1000 Facsimile: (415) 956-1008 IN THE UNITED STATES DISTRICT COURT. FOR THE SOUTHERN DISTRICT OF NEW YORK H. CRISTINA CHEN-OSTER; LISA PARISI; and SHANNA ORLICH, Plaintiffs, CLASS ACTION aA\ GOLDMAN, SACHS & CC SACHS GROUP, INC, and THE GOLDMAN Defendants. Otlich (collectively “Plaintifis"), on behalf of themselves and all others similarly situated, allege, upon personal knowledge as to themselves and upon information and belief as to other matters, as follows: NATURE OF THE CLAIM 1. This is a class action brought by female professionals of Defendant Goldman, Sachs & Co. (“GS”) and Defendant The Goldman Sachs Group, Inc. (“GS Group”) (collectively, “Goldman Sachs”), alleging violations of Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000 et seq. (* itle VII"); and the New York City Human Rights Law, Administrative Code of the City of New York § 8-107 er seg. (*NYCHRL"),2. Goldman Sachs is a global investment banking, securities and investment management firm, The firm is famously secretive. Until its IPO and conversion to a corporation in 1999, the firm operated as a partnership with relatively little public oversight and regulation. Its culture has been described as insular, and its employees intensely loyal. The firm is also famously profitable. In 2009, Goldman Sachs generated $45 billion in net revenues and $13 billion in net earnings. Goldman Sachs credits its employees as “a major strength and principal reason” for its success on Wall Street. And it pays them accordingly—in 2009, it spent $16 Dillion on employee compensation and benefits alone, 3. Goldman Sachs has distributed the benefits of its enormous success unequally ~ systematically favoring male professionals at the expense of their female counterparts. At nearly all levels of its management ranks, it has paid its female professionals less than similarly situated ‘male professionals, even though they hold equivalent positions and perform the same or substantially similar work with similar or in some cases superior results, 4, Goldman maintains policies and practices for promoting its employees that result in the disproportionate promotion of men over equally or more qualified women. As a result, female professionals have been systematically circumvented and excluded from promotion opportunities that are routinely afforded to their male counterparts. 5. The resulting underrepresentation of women in Goldman Sachs’ management ranks is stark, ‘The number of women in management positions at Goldman Sachs dwindles as the level of management rises—from Associates, to Vice Presidents, to Managing Directors, to Partners, and finally to the firm's management committee and executive officers. According to figures released by Goldman Sachs in 2009, women made up only 29% of the firm’s Vice Presidents and 17% of Managing Directors. According to 2008 figures, women were only 14% ofits Partners, Today, only 4 members of its 30-person management committee (roughly 13%)are women, Of its nine executive officers, only a single one is female; she co-heads the Legal Department with the firm’s other General Counsel, a man, 6. Women at Goldman Sachs have received less compensation and have been promoted tess frequently than their male counterparts as a result of the firm’s discriminatory policies, patterns, and/or practices. The violations of its female employees’ rights are systemic, are based upon company-wide policies and practices, and are the result of unchecked gender bias that pervades Goldman s' corporate culture. They have not been isolated or exceptional incidents, but rather the regular and predictable result of Goldman Sachs’ company-wide policies and practices, 7. Specifically, Goldman Sachs gives its managers, the overwhelming majority of whom are men, unchecked discretion to assign responsibilities, accounts, and projects to their subordinates. The end result is that managers, whether based on conscious or unexamined bias, ‘most often assign the most lucrative and promising opportunities, assignments, and “seats” to men. ‘These more favorable business opportunities allow men at Goldman Sachs to produce better results, which in turn eam them greater compensation and career advancement, 8, Goldman Sachs also grants its managers unbridled discretion to allocate resources among its employees, including but not limited to administrative support, training opportunities, and informal mentoring. Goldman Sachs managers exercise this discretion in an ad hoe and/or subjective manner, without any formal oversight or procedure. In practice, Goldman Sachs managers exercise this discretion in a way that provides disproportionately greater resources to their male subordinates than their female subordinates. These policies, pattems and/or practices have the effect of unfairly benefiting men at Goldman Sachs while depriving their female co- workers of the same resources. Such resource assignments may also fe male employees the impression of higher power and seniority that often becomes a self-fulfilling prophecy. Asa