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6 7 8 9 ANAHITA SEDAGHATFAR, ESQ. (SBN 217289) BRIAN DUNN, ESQ. (SBN 176502) THE COCHRAN FIRM ~ CALIFORNIA. 4929 Wilshire Boulevard, Suite 1010 Los Angeles, California 90010 Telephone: (323) 435-8205 Facsimile: (323) 282-5280 Attomeys for Plaintiff YOUNGIOO HWANG e FILED Superior Court of California Keounte nt ae Amales SEP 182018 Sherri nu uve yuiceriClerk Ry Huathur FLorte peputy SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES ~ CENTRAL DISTRICT YOUNGJOO HWANG, an individual, Plaintiff, vs. FRED SAVAGE, an individual; TWENTIETH CENTURY FOX FILM CORP, a business entity of unknown form; TWENTIETH CENTURY FOX TELEVISION, a business entity of ‘unknown form; and DOES | through 50, inclusive, Defendants. {0 CASE NO. BC699005 aa [Assigned for all purposes to Hon, Holly J. Fujie] SECOND AMENDED COMPLAINT FOR DAMAGES 1. Violation of Civil Code §52.4, et. seq. 2. Violation Civil Code §52.1, et. Seq. 3. Violation Civil Code §51.7, et. Seq. 4, Failure to Prevent Discrimination and Harassment in Violation of Statute (California Government Code § 12490, et. seq.) 5. Negligent Hiring, Supervision, and Retention 6. Intentional Infliction of Emotional Distress 7. Negligent Infliction of Emotion Distress 8. Civil Conspiracy jolation of Business & Professions Code § 17200, et. seq. DEMAND FOR JURY TRIAL Bt ‘SECOND AMENDED COMPLAINT FOR DAMAGES INTRODUCTORY ALLEGATIONS 1, Atall relevant times mentioned herein, Plaintiff YOUNGJOO HWANG (“Plaintif®”) ‘was a female and an individual residing in the State of California, County of Los Angeles. 2. Plaintiffs informed, believes and thereon alleges that at all relevant times mentioned herein, Defendant FRED SAVAGE (“Savage”) was an individual residing in the State of California, County of Los Angeles, and an employee of TWENTIETH CENTURY FOX FILM CORP and TWENTIETH CENTURY FOX TELEVISION. 3. Defendant Savage is a famous television actor, director and producer, best known for his, role as the leading actor in the television series “The Wonder Years.” 4. Plaintiffs informed, believes and thereon alleges that at all relevant times mentioned herein, Defendant TWENTIETH CENTURY FOX FILM CORP. was a business entity of unknown form doing business in California, located at 10201 West Pico Boulevard, Los Angeles, California 90064, 5. Plaintiff is informed, believes and thereon alleges that at all relevant times mentioned herein, Defendant TWENTIETH CENTURY FOX TELEVISION was a business entity of unknown form doing business in California, located at 10201 West Pico Boulevard, Los Angeles, California 90064, 6. tall relevant times mentioned herein, Plaintiff was employed and continues to be jemployed by Defendants TWENTIETH CENTURY FOX FILM CORP. and TWENTIETH CENTURY FOX TELEVISION (collectively “Defendants FOX”). 7, Plaintiffs ignorant of the true names and capacities of Defendants sued herein as DOES 1 through 50 inclusive, whether individual, corporate or otherwise and therefore sues these Defendant by such fictitious names. Plaintiff will amend this Complaint to allege their true names and capacities, ‘when they have been ascertained. 8. Plaintiff is informed, believes and thereon alleges that each Defendant sued herein, inclusive, was acting as the agent or employee of each of the other Defendants, and in doing the acts, alleged herein, was acting within the course and scope of such agency and/or employment, and/or aided, abetted, cooperated with, and/or conspired with one another to do the acts alleged herein. 2 ‘SECOND AMENDED COMPLAINT FOR DAMAGES x Roos ea ee) 10 i 12 1B 14 15 16 7 18 19 20 a 2 23 24 FACTS COMMON TO ALL CAUSES OF ACTION 9. The allegations set forth in paragraphs 1 through 8 are incorporated herein by reference. 10. Plaintiff has been a loyal and trusted employee of Defendants Fox for approximately six years. Subsequent to the incidents described blow, Plaintiff continued to work on numerous shows at Defendants Fox and continues to work on shows at Defendants Fox to date. 11, Plaintiff was employed by Defendants Fox as a “Costumer” on or about 2015 for the television show “The Grinder.” During this time Plaintiff was responsible for the clothing worn by the cast members of this show, including the star actor, Defendant Savage. Some of Plaintiff's responsibilities included setting up Defendant Savage’s outfits in his dressing room, taking photographs of his outfits for continuity purposes, making sure his outfits were free from lint, wrinkles, ete. 12, Defendant Savage has a well known reputation in the entertainment industry as being a “woman hater” and for having a gender animus. Several women who have worked with Defendant Savage, both on “The Grinder” and on other television shows and movies, and who do not know one another, have described Defendant Savage in strikingly similar terms, including him being a “bully towards women,” “treating women like shit,” “treating women like dirt,” “having a distaste for women,” "harassing women,” “bullying women,” “creating an unnecessarily hostile work environment for women” being “sexist,” and “hating women.” Defendant Savage behaves in this manner because he has an animus towards women, Defendant Savage does not have a reputation for treating men this way, for being a man hater in any way, and to the contrary, Defendant Savage is known to treat men in a nice, friendly way. Defendant Savage does not discriminate against or harass men based upon their gender, Defendant Savage does discriminate against and harass women based upon their gender. 13, Plaintiffs informed, believes and thereon alleges that while working on a show entitled “Friends With Better Lives,” a producer confronted Defendant Savage about complaints he received by female crew members that Defendant Savage was being abusive, degrading and sexist towards them. Plaintiff is informed, believes and thereon alleges that in response, Defendant Savage acknowledged his bad behavior towards female crew members and:said “I am working on that, and trying to be better.” ‘SECOND AMENDED COMPLAINT FOR DAMAGES