Case 1:24-cv-01506 Document 1 Filed 02/28/24 Page 1 of 15
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
------------------------------------------------------------------------X
PATRIA PAULINO, Civil Action No.:
Plaintiff,
v. COMPLAINT
SONY MUSIC ENTERTAINMENT,
COLUMBIA RECORDS, RON PERRY, KIMBERLY Jury Trial Demanded
GREENMAN, JENNY SCHECTER, and
ALEXA ABRAMS,
Defendants.
------------------------------------------------------------------------X
Plaintiff Patria Paulino (“Plaintiff”), by way of Complaint against Sony Music Entertainment,
Columbia Records, Ron Perry, Kimberly Greenman, Jenny Schecter, and Alexa Abrams, hereby
alleges as follows:
NATURE OF THE CASE
1. Plaintiff brings this action against her former employer for violations of the New York State
Human Rights Law (“NYSHRL”) and the New York City Human Rights Law (“NYCHRL”).
Plaintiff was hired as an Executive Assistant for Ron Perry, the Chairman and Chief Executive
Officer of Columbia Records. Although Plaintiff was tasked with screening candidates for
the subordinate Administrative Assistant position, she was explicitly told that she could
only hire Black candidates for the role. Nevertheless, in order to conceal its illegal conduct,
Defendants’ Human Resources department sent Plaintiff a diverse pool of candidates to
interview, including Caucasian candidates. When Plaintiff opposed Defendants’
discriminatory hiring process by recommending qualified non-Black candidates,
Case 1:24-cv-01506 Document 1 Filed 02/28/24 Page 2 of 15
Defendants constructively terminated Plaintiff’s employment. As a Hispanic employee,
Plaintiff, herself, was also subjected to discrimination throughout the course of her employment.
Despite exemplary qualifications, Plaintiff was labeled as a “diversity hire” and was perceived
by Ron Perry as less qualified because of her race and treated less favorably than her Caucasian
counterparts.
JURISDICTION AND VENUE
2. The Court has jurisdiction pursuant to 28 U.S.C. § 1332 in that there is complete diversity of
citizenship and the matter in controversy exceeds, exclusive of interest and costs, the sum of
$75,000.
3. Venue is proper in this district pursuant to 28 U.S.C. § 1391(b) because a substantial part of the
events or omissions giving rise to this action, including the alleged unlawful employment
practices, occurred in this district.
PARTIES
4. Plaintiff Patria Paulino is a former employee of Defendants and a resident of the state of New
Jersey.
5. Plaintiff is Hispanic and of Dominican, Spanish, and Italian national origin.
6. Defendant Sony Music Entertainment is a New York-based recorded music company owned
by the Sony Corporation.
7. Defendant Columbia Records is a New York-based record label owned by Sony Music
Entertainment.
2
Case 1:24-cv-01506 Document 1 Filed 02/28/24 Page 3 of 15
8. Defendant Sony Music Entertainment and Defendant Columbia Records maintain headquarters
located in New York City and are incorporated in the State of Delaware.
9. Defendant Ron Perry (“Perry”) was and is, at all relevant times herein, the Chairman and Chief
Executive Officer of Columbia Records.
10. Defendant Kimberly Greenman (“Greenman”) was and is, at all relevant times herein, the
Human Resources Executive for Sony Music Entertainment.
11. Defendant Jenny Schecter (“Schecter”) was and is, at all relevant times herein, the Human
Resources Director for Sony Music Entertainment.
12. Defendant Alexa Abrams (“Abrams”) was and is, at all relevant times herein, the Senior
Recruiter for Sony Music Entertainment.
13. Upon information and belief, Defendant Perry, Defendant Greenman, Defendant Schecter, and
Defendant Abrams reside outside the state of New Jersey.
14. Defendants Sony Music Entertainment, Columbia Records, Perry, Greenman, Schecter, and
Abrams are also herein collectively referred to as “Defendants.”
FACTUAL ALLEGATIONS
15. On or about November 7, 2022, Plaintiff began working for Defendants Sony Music
Entertainment and Columbia Records as an Executive Assistant for Defendant Perry in New
York City.
16. Plaintiff was highly qualified for the position and went through a rigorous interview process
before she was offered the role. Plaintiff was previously employed at Viacom where she was
quickly promoted and worked across several brands including MTV, BET, and Nickelodeon in
the digital, celebrity talent, and live events sectors. Thereafter, Plaintiff worked for Madison
3
Case 1:24-cv-01506 Document 1 Filed 02/28/24 Page 4 of 15
Square Garden Entertainment in the VIP hospitality department coordinating experiences for
executive leadership and celebrity guests at live music and sporting events.
17. As part of Plaintiff’s application process with Defendants, Plaintiff was required to check a box
identifying her racial identity. Plaintiff checked the box for “Hispanic.”
18. Plaintiff was hired to replace Defendant Perry’s former Executive Assistant, Samantha Sachs,
who was being promoted to the role of Director of Business Development and A&R (Artists
and Repertoire). Ms. Sachs is Caucasian.
19. Prior to Plaintiff’s hire, Ariella Gutsko-Sater was the Administrative Assistant to Defendant
Perry. Ms. Gutsko-Sater applied for a promotion to the Executive Assistant position but was
turned down in favor of Plaintiff.
20. Ms. Gutsko-Sater was subsequently reassigned to another department, leaving a vacancy in the
Administrative Assistant position. She was reassigned because Defendants preferred to hire a
Black Administrative Assistant in the role to create more diversity in Defendant Perry’s office.
Ms. Gutsko-Sater is Caucasian.
21. Approximately one month after Plaintiff’s hire, Ms. Gutsko-Sater told Plaintiff that she
(Plaintiff) was selected for the position because she was a “diversity hire,” irrespective of
Plaintiff’s stellar qualifications. Indeed, Plaintiff was frequently told that Defendant Perry
demonstrated a preference for Caucasian employees but needed to have more “color” in his
office.
22. Defendants preferred to hire a Black Administrative Assistant for Defendant Perry’s office
because he (Defendant Perry) had been the subject of multiple racial discrimination complaints
by former employees. Defendants wanted to evade liability and give the appearance that
Defendant Perry was not engaged in race-based discrimination by hiring more Black
4
Case 1:24-cv-01506 Document 1 Filed 02/28/24 Page 5 of 15
employees, particularly in the lower-level positions of the company. Multiple employees
told Plaintiff that Defendant Perry needed “color in his office,” and that he should hire a Black
Administrative Assistant to mirror the racial composition of the office of the Chief Executive
Officer of Sony Music Entertainment, Rob Stringer.
23. Despite the ongoing complaints of discrimination against him, Defendant Perry would require
Plaintiff to complete compliance training for him, in violation of company policy.
24. Although Plaintiff was hired for the Executive Assistant role, Plaintiff was often treated as less
qualified for the position because of her Hispanic race and national origin. Plaintiff was also
given less independence and decision-making authority than her predecessor - and successor -
because of her race and national origin.
25. Defendant Perry would frequently demean, humiliate and criticize Plaintiff without
justification. For example, Defendant Perry would often criticize Plaintiff for scheduling issues
that were not attributable to her. By way of further example, on one occasion, without any
basis, and in order to humiliate Plaintiff, Defendant Perry text messaged Plaintiff that her
“anxiety is coming across in the work.” On another occasion, in what he described as a
“teaching moment,” Defendant Perry instructed Plaintiff that the only acceptable responses to
him should be: “Yes,” “No,” or “I will find out.” Defendant Perry did not speak to Caucasian
employees in this degrading manner.
26. On or about November 29, 2022, within weeks of Plaintiff’s hire, Plaintiff attended a Teams
videoconference with Defendant Schecter, Defendant Abrams and Ms. Sachs. Plaintiff was
explicitly told that she would be responsible for interviewing applicants for the Administrative
Assistant role and that the right applicant was someone with both music experience and a
“Person of Color (POC).”
5
Case 1:24-cv-01506 Document 1 Filed 02/28/24 Page 6 of 15
27. Despite this directive, in order to conceal its illegal conduct, Defendants’ HR department sent
Plaintiff a diverse pool of candidates to interview, including Caucasian candidates.
28. Although numerous Caucasian candidates were qualified for the position, they were removed
from consideration because of their race.
29. For example, on or about December 12, 2022, Plaintiff interviewed an applicant named Jacob,
who is Caucasian, for the Administrative Assistant position. Jacob was qualified for the
position and had previously interned for the company under Ms. Sach’s leadership. Jacob was
not eligible for the position because of his race.
30. Similarly, on or about December 13, 2022, Plaintiff interview another Caucasian applicant,
Olivia, who was a strong candidate for the position but was not considered because of her race.
In fact, Ms. Sachs personally submitted Olivia’s resume.
31. On or about January 18, 2023, Plaintiff interviewed Erik, another Caucasian candidate. Erik
was among the most qualified applicants for the position, predominately due to his previous
work history, particularly his experience working for the President of another major music label.
When Plaintiff notified Ms. Sachs of Erik’s qualifications, Ms. Sachs immediately asked
Plaintiff via text message, “[I]s he POC” and added that his race was “super important.” See
Exhibit A.
32. On another occasion, Plaintiff was required to list “cons” for a male Caucasian applicant. In
text messages to Ms. Sachs, Plaintiff acknowledged that she “loved him but [was] aware of
the [diversity] situation.” Ms. Sachs instructed Plaintiff to mention the applicant’s lack of
diversity as a negative for hiring. See Exhibit B.
33. On another occasion, Plaintiff sent Ms. Sachs a text message about another person who applied
for the position but conceded that the applicant “doesn’t fit the box.” Ms. Sachs replied,
6
Case 1:24-cv-01506 Document 1 Filed 02/28/24 Page 7 of 15
“white I assume.” Thereafter, Defendant Abrams sent Plaintiff a new candidate that did, in
fact, “fit the box.” In a written exchange, Defendant Abrams asked Plaintiff to vet a pool of
“strong diverse male talent” for the Administrative Assistant position.
34. As part of Plaintiff’s opposition to Defendants’ discriminatory hiring practices, Plaintiff,
herself, submitted a Caucasian and Jewish candidate who was highly recommended by
Plaintiff’s former colleague. However, Plaintiff was not even permitted to interview the
applicant. Plaintiff text messaged Ms. Sachs that she wanted to enter the applicants resume for
consideration even though Plaintiff understood she was not the “target” applicant. In response,
Ms. Sachs text messaged Plaintiff, “We can’t hire another white Jewish girl unfortunately.”
Uncomfortable with Defendants’ hiring practices, Plaintiff attempted to laugh off the blatant
discrimination. See Exhibit C.
35. The above are just some examples of more than a dozen candidates that were not selected for
hire because of their race.
36. Although Plaintiff was initially told that the applicant had to be a POC, Ms. Sachs later qualified
that the search was actually limited to Black employees.
37. Nevertheless, Plaintiff continued to recommend qualified Caucasian applicants in
opposition to Defendants’ discriminatory directive.
38. For example, on or about February 8, 2023, Plaintiff attended a Teams videoconference with
Defendant Abrams, Defendant Schecter, Ms. Sachs and another assistant. During the meeting,
Plaintiff listed a number of applicants that she believed to be qualified, including Black and
Caucasian applicants. However, when Plaintiff named the Caucasian applicants, Ms. Sachs
interrupted Plaintiff and said, “They can’t be hired because they’re not Black.”
7
Case 1:24-cv-01506 Document 1 Filed 02/28/24 Page 8 of 15
Acknowledging that Defendants’ hiring policy was discriminatory, Defendant Schecter replied,
“My HR ears can’t hear this.”
39. Indeed, during multiple conversations where Ms. Sachs discussed hiring a Black employee for
the Administrative Assistant position, Defendant Schecter would say, “I’m not hearing this”
or words to that effect.
40. Over the course of her employment, Plaintiff was forced to interview and review application
submissions for numerous non-Black applicants as part of Defendants’ efforts to conceal their
discriminatory conduct. These sham interviews, which took months, coupled with the fact that
Defendants would not fill the Administrative Assistant vacancy, left Plaintiff working
extremely long hours to fulfill her job responsibilities. Plaintiff was often required to work 80
hours or more per week.
41. In or around early March 2023, after eliminating numerous qualified Caucasian applicants, two
Black candidates were presented to Defendant Perry for consideration.
42. On or about March 21, 2023, Plaintiff attended a meeting with Defendant Greenman.
According to Defendant Greenman, the meeting was to “check in” on Plaintiff as a new
employee. At the onset of the meeting, Plaintiff told Defendant Greenman that Plaintiff’s
position would be more manageable if the company filled the Administrative Assistant vacancy.
Without warning, and in retaliation for Plaintiff’s opposition to Defendants’ discriminatory
hiring practices, Defendant Greenman abruptly responded that Defendant Perry felt that
Plaintiff “was not really working out” and suggested that Plaintiff should resign. Plaintiff
reiterated that she was doing the job alone without an Administrative Assistant and that she was
working long hours to successfully complete her job duties. Defendant Greenman nevertheless
instructed Plaintiff to contact her on the following day to render a decision on her resignation.
8
Case 1:24-cv-01506 Document 1 Filed 02/28/24 Page 9 of 15
43. On or about March 22, 2023, under pressure from Defendant Greenman, Plaintiff complied and
tendered her resignation to Defendant Greenman. In response, Defendant Greenman told
Plaintiff that she should communicate the resignation to Defendant Perry directly. However,
Defendant Greenman explicitly told Plaintiff not to disclose their conversation on the preceding
day to Defendant Perry.
44. That same day, Plaintiff told Defendant Perry that she was resigning from her position. Despite
Defendant Greenman’s directive, Plaintiff disclosed the content of her conversation with
Defendant Greenman; namely, that Defendant Perry was unhappy with Plaintiff’s performance.
Defendant Perry vehemently denied that he had communicated dissatisfaction with Plaintiff’s
performance.
45. Almost immediately, Defendant Perry offered Plaintiff’s position to Ms. Gutsko-Sater, which
she accepted. Unlike Plaintiff, Ms. Gutsko-Sater was granted more independence and decision-
making authority because she was perceived as more capable because of her race and national
origin.
46. Within days of Plaintiff’s departure, a Black applicant was hired to fill the Administrative
Assistant position.
47. During Plaintiff’s exit interview with HR, Plaintiff told Defendant Schecter that her job was
made difficult because she was unable to fill the Administrative Assistant role, despite
proposing highly qualified applicants. Defendant Schecter became visibly uncomfortable and
steered the conversation away from Defendants’ discriminatory hiring practices. Defendant
Schecter then reminded Plaintiff that she had signed an NDA (non-disclosure agreement) to
deter Plaintiff from exposing Defendants’ discriminatory hiring practices.
9
Case 1:24-cv-01506 Document 1 Filed 02/28/24 Page 10 of 15
48. Defendants retaliated against Plaintiff, including constructively terminating her employment,
because she opposed Defendants’ discriminatory hiring practices.
49. Defendants created intolerable working conditions by requiring Plaintiff to participate in the
company’s discriminatory hiring practices and by coercing Plaintiff into submitting her
resignation.
50. Defendants discriminated against Plaintiff because of her race and national origin.
51. As a result of the acts and conduct complained of herein, Plaintiff has suffered and will continue
to suffer the loss of income, the loss of a salary, severance pay, bonuses, benefits and other
compensation which such employment entails, and Plaintiff has also suffered future pecuniary
losses, emotional pain, suffering, inconvenience, loss of enjoyment of life, and other non-
pecuniary losses.
52. As Defendants’ conduct has been malicious, willful, outrageous, and conducted with full
knowledge of the law, Plaintiff demands punitive damages as against the Defendants.
AS A FIRST CAUSE OF ACTION
UNDER THE NYCHRL
DISCRIMINATION
53. Plaintiff repeats and realleges each and every allegation made in the above paragraphs of this
Complaint as if same were set forth herein fully at length.
54. Pursuant to N.Y.C. Admin. Code § 8-107(1), it is an unlawful discriminatory practice for an
employer “to refuse to hire or employ or to bar or to discharge from employment such person
or to discriminate against such person in compensation or in terms, conditions or privileges of
employment” on the basis of race or national origin.
10
Case 1:24-cv-01506 Document 1 Filed 02/28/24 Page 11 of 15
55. Defendants engaged in an unlawful discriminatory practice by discriminating against the
Plaintiff because of her race and national origin.
56. As a direct and proximate result of Defendants’ unlawful conduct, Plaintiff has suffered and
continues to suffer harm for which she is entitled to an award of damages, to the greatest extent
permitted under law, in addition to reasonable attorneys’ fees and expenses.
AS A SECOND CAUSE OF ACTION
UNDER THE NYCHRL
RETALIATION
57. Plaintiff repeats and realleges each and every allegation made in the above paragraphs of this
Complaint as if same were set forth herein fully at length.
58. N.Y.C. Admin. Code § 8-107(7) provides: “It shall be an unlawful discriminatory practice for
any person engaged in any activity to which this chapter applies to retaliate or discriminate in
any manner against any person because such person has…opposed any practice forbidden under
this chapter.”
59. Defendants engaged in unlawful employment practices prohibited by the NYCHRL by
retaliating and otherwise discriminating against the Plaintiff because of her opposition to
Defendants’ unlawful employment practices, including but not limited to, constructively
terminating her employment.
60. As a direct and proximate result of Defendants’ unlawful conduct, Plaintiff has suffered and
continues to suffer harm for which she is entitled to an award of damages, to the greatest extent
permitted under law, in addition to reasonable attorneys’ fees and expenses.
11
Case 1:24-cv-01506 Document 1 Filed 02/28/24 Page 12 of 15
AS A THIRD CAUSE OF ACTION
UNDER THE NYCHRL
AIDING & ABETTING
61. Plaintiff repeats and realleges each and every allegation made in the above paragraphs of this
Complaint as if same were set forth herein fully at length.
62. N.Y.C. Admin. Code §8-107(6) provides that it shall be an unlawful discriminatory practice, “For
any person to aid, abet, incite, compel or coerce the doing of any acts forbidden under this chapter,
or attempt to do so.”
63. Defendants engaged in an unlawful discriminatory practice by aiding, abetting, inciting,
compelling, and coercing the discriminatory conduct.
64. As a direct and proximate result of Defendants’ unlawful conduct, Plaintiff has suffered and
continues to suffer harm for which she is entitled to an award of damages, to the greatest extent
permitted under law, in addition to reasonable attorneys’ fees and expenses.
AS A FOURTH CAUSE OF ACTION
UNDER THE NYSHRL
DISCRIMINATION
65. Plaintiff repeats and realleges each and every allegation made in the above paragraphs of this
Complaint as if same were set forth herein fully at length.
66. Pursuant to N.Y. Exec. Law §296(1)(a), it is an unlawful discriminatory practice for an
employer “to refuse to hire or employ or to bar or to discharge from employment such individual
or to discriminate against such individual in compensation or in terms, conditions or privileges of
employment" on the basis of race or national origin.
67. Defendants engaged in an unlawful discriminatory practice by discriminating against the
Plaintiff because of her race and national origin.
12
Case 1:24-cv-01506 Document 1 Filed 02/28/24 Page 13 of 15
68. As a direct and proximate result of Defendants’ unlawful conduct, Plaintiff has suffered and
continues to suffer harm for which she is entitled to an award of damages, to the greatest extent
permitted under law, in addition to reasonable attorneys’ fees and expenses.
AS A FIFTH CAUSE OF ACTION
UNDER THE NYSHRL
RETALIATION
69. Plaintiff repeats, reiterates and realleges each and every allegation made in the above paragraphs
of this Complaint as if more fully set forth herein at length.
70. N.Y. Exec. Law §296(7) provides that it shall be an unlawful discriminatory practice “[f]or any
person engaged in any activity to which this section applies to retaliate or discriminate against
any person because [s]he has opposed any practices forbidden under this article.”
71. Defendants engaged in unlawful employment practices prohibited by the NYSHRL by
retaliating and otherwise discriminating against the Plaintiff because of her opposition to
Defendants’ unlawful employment practices, including but not limited to, constructively
terminating her employment.
72. As a direct and proximate result of Defendants’ unlawful conduct, Plaintiff has suffered and
continues to suffer harm for which she is entitled to an award of damages, to the greatest extent
permitted under law, in addition to reasonable attorneys’ fees and expenses.
AS A SIXTH CAUSE OF ACTION
UNDER THE NYSHRL
AIDING & ABETTING
73. Plaintiff repeats and realleges each and every allegation made in the above paragraphs of this
Complaint as if same were set forth herein fully at length.
74. N.Y. Exec. Law §296(6) provides: “It shall be an unlawful discriminatory practice for any
13
Case 1:24-cv-01506 Document 1 Filed 02/28/24 Page 14 of 15
person to aid, abet, incite compel or coerce the doing of any acts forbidden under this article,
or attempt to do so.”
75. Defendants engaged in an unlawful discriminatory practice by aiding, abetting, inciting,
compelling, and coercing the discriminatory conduct.
76. As a direct and proximate result of Defendants’ unlawful conduct, Plaintiff has suffered and
continues to suffer harm for which she is entitled to an award of damages, to the greatest extent
permitted under law, in addition to reasonable attorneys’ fees and expenses.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests a judgment against the Defendants:
A. Declaratory judgment that the employment practices of Defendants complained of herein
violate the NYSHRL and the NYCHRL;
B. Awarding damages to the Plaintiff, retroactive to the date of discharge, for all lost wages,
bonuses, and benefits, past and future, back pay and front pay, resulting from Defendants’
unlawful discharge and to otherwise make Plaintiff whole for any losses suffered as a result of
Defendants’ unlawful employment practices;
C. Awarding Plaintiff compensatory damages for mental, emotional and physical injury, distress,
pain and suffering and injury to her reputation;
D. Awarding Plaintiff punitive damages in an amount to be determined at trial;
E. Awarding Plaintiff attorneys’ fees, costs, and expenses incurred in the prosecution of this
action;
F. Awarding prejudgment interest on all amounts due;
14
Case 1:24-cv-01506 Document 1 Filed 02/28/24 Page 15 of 15
G. Awarding Plaintiff such other and further relief as the Court may deem equitable, just and
proper to remedy the Defendants’ unlawful employment practices.
JURY DEMAND
Plaintiff demands a trial by jury on all issues so triable.
Dated: February 28, 2023
SHNAYDER LAW LLC
Attorneys for Plaintiff
By: _/s/ Erica L. Shnayder_________
Erica L. Shnayder, Esq.
89 Headquarters Plaza, Suite 1421
Morristown, NJ 07960
(973) 714-1515
erica@eshnayderlaw.com
15
