SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK

PLAINTIFF: BIANCA NARDI

DEFENDANT: MAURICE RICHARD POVICH aka MAURY POVICH host of THE MAURY POVICH SHOW; DONNA BENNER; PAUL FAULHABER; VINCENT FUSCO; MOPO PRODUCTIONS, INC. NBC UNIVERSAL TELEVISION, INC.

To the above named Defendants:

You are hereby summoned to answer the complaint in this action, and to serve a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of appearance on the Plaintiff’s attorneys within twenty days after the service of this summons, exclusive of the day of service, where service is made by delivery upon you personally within the state, or, within 30 days after completion of service where service is made in any other manner. In case of your failure to appera or answer, judgement will be taken against you by default for the relief demanded in the complaint.

Dated: Brooklyn, New York April 24, 2006

BRUCE BARON, ESQ. BARON ASSOCIATES P.C.

Attorneys for Plaintiff(s) Bianca Nardi, 2509 Avenue U Brooklyn, New York 11229 (718) 934-6501 our File No. 7124

TO: MAURICE RICHARD POVICH, DONNA BENNER, PAUL FAULHABER, VINCENT FUSCO, MOPO PRODUCTIONS, INC.

c/o MOPO Productions, Inc. 15 Penn Plaza/Grand Ballroom New York, NY 10001

NBC UNIVERSAL TELEVISION, INC. 30 Rockefeller Plaza, 10th Floor New York, New York 10112 Att: Stephen J. Malone, Esq.

Plaintiff, BIANCA NARDI, by her attorneys, BARON ASSOCIATES, P.C., complaining of the Defendants, respectfully alleges, upon information and belief, as follows:

INTRODUCTION

1. This is an action, inter alia, to recover damages for hostile work environment sexual harrassment and discriminatory retaliation pursuant to New York State Executive Law article 15 section 296 et seq., and Title 8 of the Administrative Code of the City of New York, and under Title VII of the Civil Rights Act of 1964 (42 U.S.C. 2000 et seq.) The standard for recovery under section 296 of the Executive Law is in accord with the federal standards under Title VII, and the human rights provisions of New York City’s Administrative Code mirror the provisions of the Executive Law

2. The sexually hostile workplace with THE MAURY POVICH SHOW, was permeated with discriminatory intimidation, ridicule, insult and sexual harrassment directed against the Plaintiff, BIANCA NARDI, by the defendants MAURICE RICHARD POVICH, DONNA BENNER INGBER, PAUL FAULHABER, VINCENT FUSCO and others. A “Peyton Place” lifestyle and a poisoned atmosphere existed at THE MAURY POVICH SHOW that featured a long stemmed intimate and sexual relationship between Defendants MAURICE RICHARD POVICH and DONNA BENNER INGBER. The Defendants, encouraged and motivated by Defendant MAURICE RICHARD POVICH’S relationship with Defendant DONNA BENNER INGBER created a hostile workplace that was sexually abusive to woman, and was permeated with the use of alcohol, pornographic videos and parties inviting open and notorious sexual activities. The Defendant PAUL FAULHABER, beginning in 2004 was Executive Producer of THE MAURY POVICH SHOW. Incesed that his counterpart was receiving special treatment, and fearful that any direct objections made by him to Defendant MAURICE RICHARD POVICH or to Defendant DONNA BENNER INGBER would result in termination of his employement, directed his protestations against the Plaintiff BIANCA NARDI. Under threat of loss of employment, he forced Plaintiff to run a gauntlet of sexually abusive and intimidating conduct, including but not limited to: participating in improper undercover operations to illicit sexual acts and comments from prospective guests and celebrities of THE MAURY POVICH SHOW.

A. directing her to pose in sexually explicit positions for the purpose of adding or emphasizing sexually illicit elements to THE MAURY POVICH SHOW

B. directing her to expose her breasts and to have them photographed and shown on THE MAURY POVICH SHOW

C. direcing her to tape the chests of female guests appearing on THE MAURY POVICH SHOW in order to photgraph them with large “boobs”; labeling her as the “Tape Lady” after she complained and refused to do this demeaning task

D. ordering her to watch pornographing videos alone with him, with a (false) excuse that he wanted “to use segments on THE MAURY POVICH SHOW”

E. retaliating against Plaintiff whenever she threatened to complain about the sexual harassment in the workplace, stating that his conduct towards her “is nothing compared to what she can expect if she complained”.

All of the sexually abusive, inimidating and embarrassing instance alleged herein were known and condoned by the Defendant MAURICE RICHARD POVICH and other corporate executives, or with the exercise of reasonable care should have been known by them.

3. The Defendants MOPO PRODUCTIONS, INC. and NBC UNIVERSAL TELEVISION, INC., acquiesced in the discriminatory conduct or subsequently condoned it and otherwise failed to take apporopriate corrective action. The Plaintiff was sexually harassed by NBC’S and MOPO’S highest ranking supervisors, and there was no opportunity for Plaintiff to make a complaint to upper-level management; thus it was unfair and impractical to require the Plaintiff to “go over the head” of an abusive chief executive or upper-level supervisor to notify the corporate directors.

4. Plaintiff was sexually harassed and she was the victim of this harassment because she was a woman, and the harassment complained of affected the terms, conditions or privileges of her employment. Plaintiff was so upset and degraded by the aforesaid conduct and so feared additional occurrences that she has sough and is under medical care and attention as a result of the mental anguish, fear and abuse she has experienced. Instead of acknowledging their failures, and to support the Plaintiff’s attempts to receive medical care and attention, the Defendants have retaliated and have placed a large picture of the Plaintiff at the front lobby entrance to the MOPO studios, warning that she was not permitted in the premises and, if she showed up, to notify the Defendant VINCENT FUSCO.

5. The Plaintiff BIANCA NARDI was, and still is a resident of the State of New Jersey. She is a graduate Syracuse University, a highly driven and successful television producer, whose career included being a celebrity booker at Studios USA Talk Television, and a producer at NBC/Universal’s THE MAURY POVICH SHOW from June 2000 to April 2006. During her career she received excellent reports for interviewing celebrities including but not limited to Stevie Wonder, Vanessa Williams, Donald Trump, Cynthia Nixon, Montel Williams, Kelly Rippa and the Olsen Twins. She was praised throughout her career for her dedication, proficiency, motivation and skill.

6. The Defendant MAURICE RICHARD POVICH, upon information and belief, is a resident of the State of New York and is the NBC and MOPO television talk show host for THE MAURY POVICH SHOW.

7. The Defendant DONNA BENNER INGBER, upon information and belief, is a resident of the State of Pennsylvannia and was and is employed by Defendants NBC and MOPO as Producer(2000-2003) and a Coordinating Producer (2004-Present) of THE MAURY POVICH SHOW.

8. The Defendant PAUL FAULHABER, upon information and belief, is a resident of the State of New York and was and is employed by the Defendants NBC and MOPO as a Supervising Producer (2003) and Executive Producer (2004-Present) of THE MAURY POVICH SHOW.

9. The Defendant VINCENT FUSCO, upon information and belief, is a resident of the State of New York and is employed by the Defendants NBC and MOPO as a Supervising Producer of THE MAURY POVICH SHOW.

10. At all times herein mentioned, the Defendants MAURICE RICHARD POVICH, DONNA BENNER INGBER, PAUL FAULHABER VINCENT FUSCO supervised, managed and controlled the terms and conditions of Plaintiff’s employment.

11. The individual Defendants MAURICE RICHARD POVICH, DONNA BENNER INGBER, PAUL FAULHABER VINCENT FUSCO were and still are officers, directors, supervisors, managers, employees and/or agents of the Defendants NBC UNIVERSAL TELEVISION, INC. and MOPO PRODUCTIONS, INC., and acted within the scope of their duties as officers, directors, supervisors, managers, employees and/or agents for the said Corporate Defendants.

12. The Defendant NBC UNIVERSAL TELEVISION (NBC), formerly Studios USA, and Universal Talk TV, upon information and belief, was and still is a domestic corporation duly organized and exisitng under and by virute of the laws of the State of California and maintains principal places of business at 30 Rockefeller Plaza, New York, New York and 100 Universal City Plaza, Universal City, Ca., and employs the Defendant MAURICE RICHARD POVICH who is the talk show star host of THE MAURY POVICH SHOW.

13. The Defendant NBC, was and still is a foreign corporation duly organized and existing under and by virtue of the laws of the state of California and is authorized to conduct business in the State of New York at 30 Rockefeller Plaza, New York, New York.

14. The Defendant MOPO PRODUCTIONS (MOPO) was and still is a domestic corporation duly organized and existing under and by virtue of the laws of the state of New York and maintains its principal place of business at 15 Penn Plaza/Grand Ballroom, New York, New York 10001. MOPO is the owner/producer of THE MAURY POVICH SHOW.

15. During the relevant times herein, the Defendants NBC and MOPO and their agents, managers, directors, officers, servants and/or employees, had the duty to provide the Plaintiff with a non-hostile work environment, and a work environment free of sexual harassment and sexual hostility.

16. Upon information and belief, beginning January 2000, an at all times hereinafter mentioned, the Defendants NBC and MOPO, their agents, servants and/or employees, were engaged in the television production of a talk show program called THE MAURY POVICH SHOW, with the Defendant MAURICE RICHARD POVICH, the star talk show host.

17. Defendants NBC and MOPO, were the respondeat superior of their agents, servants and/or employees, including but not limited to Defendants MAURICE RICHARD POVICH, DONNA BENNER INGBER, PAUL FAULHABER, VINCENT FUSCO.

18. Defendants NBC and MOPO were vicariously liable for the acts of their agents, servants and/or employees, including but not limited to Defendants MAURICE RICHARD POVICH, DONNA BENNER INGBER, PAUL FAULHABER, VINCENT FUSCO.

19. At all times herin Plaintiff, who is a female, was in the course of her employment with the Defendants NBC and MOPO, and belonged to a group protected against the acts described herein under the relevant New York State Human Rights Law, as well as the applicable Federal and local New York City laws and ordinances.

STATEMENT OF FACTS

20. On or about June, 2000, the Plaintiff BIANCA NARDI was employed by the Defendants NBC and MOPO as a Production Assistant assigned to Gloria Harrison-Hall and Meredith Ullman, on of seven teams involved in producing THE MAURY POVICH SHOW. Each team consisted of three employees and was responsible to produce one show per week for THE MAURY POVICH SHOW.

21. Prior to June 2000, the Defendants MAURICE RICHARD POVICH, PAUL FAULHABER and VINCENT FUSCO, together with Defendants NBC and MOPO, along with their agents, managers, directors, officers, servants and/or employees created and maintained a work environment where hostility, initmiation, humiliation, ridicule, sexual harassment, as well as alcohol use, was explicit, rampant, pervasive and was condoned and acquiesced to by the Defendants.

22. Beginning June 2000, the Defendants MAURICE RICHARD POVICH, PAUL FAULHABER and VINCENT FUSCO were Plaintiff’s top level supervisors.A. It was common knowledge to all NBC and MOPO employees working on THE MAURY POVICH SHOW, and it became apparent to Plaintiff, that Defendants MAURICE RICHARD POVICH, DONNA BENNER INGBER had been engaged in a long time, intimate and sexual relationship and as a result of this relationship “favorite treatment” was given to the Defendant DONNA BENNER INGBER, to the detriment of the members of her team, and to other Producers.

B. The (then) Executive Producer AMY ROSENBLUM, Supervising Producers MARK VICTOR and Defendant PAUL FAULHABER, and Producers TODD KEMMER, MEREDITH ULLMAN and MIRIAM CELEDONIA, as well as the members of her team, were openly resentful and hostile towards Defendant DONNA BENNER INGBER.

23. This animostiy was expressed by the Defendant PAUL FAULHABER, in part, by harassing intimidating and mistreating the Plaintiff, and, in part, by harassing, intimidating and mistreating other female employees.A. Beginning on or about June 2000 and continuing throughout Plaintiff’s employment, Defendant PAUL FAULHABER ordered Plaintiff:

to wear short skirts, low cut blouses

to wear hidden television cameras/microphones and to do undercover television assignments

to “go back stage” and take off her shirt and have the television crew “photograph” her

to wear a concealed video and sound recording equipment

to engage in sexually explicit “undercover” activities such as going bars to secretly videotap married me agreeing to have sex with her.

B. All of the above assignments were beyond the scope of Plaintiff’s employment, and, under threat of loss of employment, Plaintiff was forced to comply. When Plaintiff complained, the Defendant PAUL FAULHABER retaliated by ordering Plaintiff to do other similar activities beyond teh scope of the terms and conditions of her employment.

C. On numerous occasions, beginning June 2000 and continuing throughout her employment, without Plaintiff’s knowledge or consent, Defendant PAUL FAULHABER showed and circulated video and audio tapes as well as pictures of the Plaintiff’s breasts and body parts. He used these videos, tapes and pictures and showed them in a NYC bar on a big screen television, and they appeared on the E-Television network “Talk Soup” program, all without Plaintiff’s knowledge and consent, causing her to sustain public ridicule, embarrassment and humiliation.

D. On numerous occasions, beginning June 2000 and continuing throughout her employment, Defendant PAUL FAULHABER, further and continuously sexually harassed teh Plaintiff by making offensive remarks about her body, breasts and voice. On numerous occasions Plaintiff BIANCA NARDI was ordered by Defendant PAUL FAULHABER to put on a “sexy voice” recording and to talk “dirty” for segments of THE MAURY POVICH SHOW. During those occasions Defendant PAUL FAULHABER attended the recordings and was “coaching” the Plaintiff and directing her “sex it up”. He repeatedly ordered Plaintiff on a push up bra, to emphasize her “big breasts”, so that the television crew could film her breasts and cleavage, for use on THE MAURY POVICH SHOW.

E. In and about 2001 the Defendant DONNA BENNER INGBER, in the presence of Executive Producer AMY ROSENBLUM inappropriately approached Plaintiff and demanded (in a loud, boisterous voice) to know if Plaintiff was catholic because she needed a “non-Jew” to work on a show she was producing. Ms. Rosenblum responded: “Donna, don’t speak to her like that. Get in your office with me right now!” Afterwards, Amry apologized for what was said. Defendant DONNA BENNER INGBER refused to apologize, saying: “I don’t apologize to anyone in this place. I only hire and fire!”

F. On or about September 2001, during a live shooting of THE MAURY POVICH SHOW featuring girls dressing like boys, without cause or justification, and in the presence of the television guests, the Defendant PAUL FAULHABER screamed at Plaintiff, cursing her and blaming her for “errors” than in fact were caused by said Defendant. Plaintiff was embarrassed and humiliated and told(then) Executive Producer AMY ROSENBLUM that she could no longer stand the abouse and she was quitting. Instead of correcting the harm, Ms. Rosenblum stated “you are not quitting, we love you and you are amazing at what you do!” She then “promoted” Plaintiff to Associate Producer, assigned her to work with Producer Mariam Celedonia, and promised to promote her to Producer in the near future.

G. This promise (to be promoted to Producer) was in fact a retaliatory act against the Plaintiff, to attempt to keep her working and to continue and increase the sexual harassment, intimidation and abuse.

24. Beginning September 2001, while Plaintiff was assigned to work with producer Mariam Celedonia, the Defendant PAUL FAULHABER continued harassing, intimidating and mistreating the Plaintiff, and, in part, continued harassing, intimidating and mistreating other female employees. In addition to the facts set forth above, the Defendant PAUL FAULHABER did the following:

A. Ordered close up video shot’s of Plaintiff’s breasts and cleavage, which were shown to Defendant NBC’s and MOPO’s employees and television guests, for the purpose of eliciting sexual excitement from “guests” of the show. In at least one instance, close-up footage of Plaintiff’s cleavage ended up on another television show “Talk Soup” (on the E! television channel), without Plaintiff’s prior knowledge or permission.

B. Frequently directed Plaintiff to put on lip liner and lipstick and “to look sexy while kissing into the camera”, stating that he needed the footage for THE MAURY POVICH SHOW.

C. Ordered Plaintiff to wear hidden television cameras/microphones and to do undercover television assignments such as traveling to Florida bars to secretly videotape married men agreeing to have sex with her. On some occasions when the Plaintiff said she would not participate in these activities, the Defendant PAUL FAULHABER directed her to get men to act and make sexually explicit offers even if they did not mean it.

D. Ordered Plaintiff to interview young people who claimed they were addicted to sex and to get them to make false statements about their sexual ability or prowess for the purpose of adding excitement to THE MAURY POVICH SHOW.

E. Ordered Plaintiff to go back sage and take off her shirt and have the television crew “tape” her, in order to have footage for use on THE MAURY POVICH SHOW.

F. Assigned Plaintiff the task of taping the chests of female guests to give them an appearance of having large breasts. When Plaintiff complained about having to perform this embarrassing, demeaning task, Defendant PAUL FAULHABER retaliated by labeling the Plaintiff as the “tape lady” and soon many NBC and MOPO high level employees referred to her as the “tape lady”.

25. During the time she was assigned to work with Producer Mariam Celedonia, after the incident involving teen age sex addicts (23[d]), Plaintiff warned the Defendant PAUL FAULHABER she was going to file a sexual harassment complaint with Defendants MAURICE RICHARD POVICH and the NBC human relations department. Defendant PAUL FAULHABER retaliated and threatened that she better not complain to anyone and that things will only get worse for you and you will eventually be fired! out of fear of loss employment, Plaintiff did not complain, yet the sexual harassment, intimidation and abuse continued and increased.

26. As part of the pattern of retaliation, instead of correcting the hostile environment and ceasing the sexually abusive and intimidating conduct, the Defendant PAUL FAULHABER had Producer Mariam Celedonia assign extra work assignments to the Plaintiff who found she working in excess of eighty hours per week.

27. In January 2002, after complaining to Executive Supervisor AMY ROSENBLUM, instead of correcting or at least investigating Plaintiff’s complaints, she was transferred to the Defendant DONNA BENNER INGBER’S production team. Historically, most, if not all members of this team were fired or obtained different jobs within six months of assignment. Shortly thereafter, Defendant PAUL FAULHABER sent Plaintiff on assignment with cameraman Christopher Voos to Los Angeles, California to film a segment about “A Day In The Life Of A Porn Star”. Upon returning, Plaintiff learned that the film was not going to be shown on air and that Defendant PAUL FAULHABER really wanted this shoot for his own private collectin. The cameraman quit and when Plaintiff threatened to quit or get assigned to another team, Defendant DONNA BENNER INGBER warned Plaintiff that she could never leave her team: “If you complain, I’ll hear about it and make things ten times worse for you around here!”

28. After assignment to Defendant DONNA BENNER INGBER, the sexually hostile work environment and the poisoned atmosphere (within the workplace) became exacerbated and worsened by the acts and conduct of the Defendants MAURICE RICHARD POVICH, DONNA BENNER INGBER, PAUL FAULHABER, VINCENT FUSCO, in that:

A. Defendant DONNA BENNER INGBER used her position and relationship with Defendant MAURICE RICHARD POVICH, the “star” of THE MAURY POVICH SHOW, to intimidate and coerce the Plaintiff to perform the majority of Defendant DONNA BENNER INGBER’S workload, under threat of immediate termination of employment if she complained to anyone.

B. Defendant DONNA BENNER INGBER, many times in an intoxicated condition, telephoned Plaintiff’s residence at all hours of the late evening to discuss her personal relations with Defendant MAURICE RICHARD POVICH, {and other men whom she was secretly seeing,} and to question Plaintiff about statements made to her by fellow employees concerning her relationship with the Defendant MAURICE RICHARD POVICH.

C. At the same time, the Defendants PAUL FAULHABER, VINCENT FUSCO, together with Executive Producer AMY ROSENBLUM, Supervising Producers MARC VICTOR, STEPHANIE POSNER and JOHN PASCARELLA constantly harassed Plaintiff with office meetings to discuss any information she may have learned about the relationship between Defendants MAURICE RICHARD POVICH and DONNA BENNER INGBER, and to attempt to determine why Defendant DONNA BENNER INGBER wasn’t doing her job and why Plaintiff was taking on her responsibilities without complaining to Defandents MAURICE RICHARD POVICH and VINCENT FUSCO.

29. At the same time, the Defendant PAUL FAULHABER continued harassing, intimidating and mistreating the Plaintiff, and, in part, continued harassing, intimidating and mistreating other female employees. In addition to the facts set forth above, the Defendant PAUL FAULHABER did the following:

A. At a social dinner for Producers of THE MAURY POVICH SHOW to celebrate a successful interview with celebrity Michael Jackson, the Defendant DONNA BENNER INGBER walked out of the dinner party shortly after the Defendant MAURICE RICHARD POVICH, prompting the Defendant PAUL FAULHABER to ask Plaintiff, in the presence of other attendees, if she had arranged a hotel room for “Donna to fuck Maury!” Afterwards, almost every Producer asked Plaintiff the same question.

B. In 2004, after participating in an undercover “scam” investigation for a NY American Idol segment on THE MAURY POVICH SHOW, Plaintiff was asked to sit in the audience among the members of the public she had scammed. The Defendant MAURICE RICHARD POVICH asked Plaintiff if it was difficult to scam the public and on live TV Plaintiff stated “it wasn’t hard at all. In less than two hours I made 200 dollars!” Within a short time, the Defendant PAUL FAULHABER created a tape segment of a guest accused of cheating on his wife, who while waiting to come onstage, exposed his penis in front of a female “decoy” waiting with him in the “greenroom”. The tape segment had the plaintiff’s voice saying: “It wasn’t hard at all!” This tape was later shown to all members of the production staff at a “wrap party” just before the 2004 Christmas season.

C. The Defendant PAUL FAULHABER continued to insist that Plaintiff participate in and do the sexy voice over for the “DRAG QUEEN” segments on THE MAURY POVICH SHOW, each time accompanying Plaintiff into the sound studio and insisting she be sexier and sexier, saying Plaintiff “was blessed with a sexy porn voice.”

D. Almost form the beginning of her assignment to the Defendant DONNA BENNER INGBER’S, the Defendant PAUL FAULHABER required Plaintiff to watch pornographic videos in a private room with him. He claimed he needed her input to see if clips from these porno movies could be used on THE MAURY POVICH SHOW. Despite Plaintiff’s complaints that this was abusive and sexual harassment, he insisted that this was “our job” and “we need to do this and you have to do it with me!”

E. In 2003 and continuing to the present, the Defendants PAUL FAULHABER and DONNA BENNER INGBER, publicly rebuked Plaintiff for getting fat and for having a fat ass, and insisting that she come to work in loose clothing to hide her fat body. In 2004 and 2005 on several occasions, Defendant DONNA BENNER INGBER, literally ripped food from Plaintiff’s hands and mouth and threw it into a receptacle shouting “How could you eat this shit!” On several occasions she said: “You don’t have a boyfriend because guys don’t like fat girls!”

F. On April 2, 2004, Plaintiff was promoted to Producer and was promised a pay increase that was never implemented despite several requests to do so. At the same time, Defendant DONNA BENNER INGBER was promoted to Supervisory Producer but she remained as head of her team, with Plaintiff having to perfor both Producer’s and Associate Producer’s responsibilities.

G. In 2005 Plaintiff and ANNETTE COLEMAN, a nationally recognized black hairdresser, protested to the Defendant VINCENT FUSCO that the Producers were not giving credits to black hairdressers for the great work they did for guests appearing on THE MAURY POVICH SHOW. Ms. Coleman threatened to file a complaint with the National Association for the Advancement of Colored People, NAACP. Shortly thereafter, Defendant DONNA BENNER INGBER retaliated and rebuked plaintiff for speaking up for the African Americans saying: “you like to hang out with blackies!” and “you have too many black friends!”

H. On September 22, 2005, the Defendant DONNA BENNER INGBER refused to attend an early morning reading of the script she wrote for a segment to be taped for TV. Plaintiff had to attend in her absence and Defendant PAUL FAULHABER directed her to read the script that Defendant DONNA BENNER INGBER had prepared and written for that day’s show. After Plaintiff read the script, Defendant PAUL FAULHABER ordered her to stay in the room while the others left. He then begin to verbally scream at her, abusing, criticizing and rebuking her for writing such a script. He questioned her ability to think normally and said that there must be something wrong with her to write such a script. Plaintiff repeated several times that she did not write the script, that Defendant DONNA BENNER INGBER ABER wrote and produced it, but the Defendent continued ranting and raving.

I. In March 2006, Supervisory Producer STEPHANIE POSNER asked the Defendant DONNA BENNER INGBER to write the script for a “Sexy Wife Makeover” segment for THE MAURY POVICH SHOW to be taped on March 22, 2006. She intentionally stayed away form work for the five days preceding the taping of the show. Not knowing that the date for the show to be aired was changed to the 23rd, Defendant DONNA BENNER INGBER showed up on March 22nd. Plaintiff and Supervising Producer STEPHANIE POSNER asked her to write the script and to help Plaintiff complete the show. Defendant DONNA BENNER INGBER refused to do anything and continued to sit at her desk during the entire day reading magazines and making personal calls. Plaintiff complained to the Defendant PAUL FAULHABER who replied that “because she’s Maury’s girl” he couldn’t say anything to “the Prima Donna”. He further commented that there’s nothing different about her work and there was nothing he could do. He ended the conversation by saying that she should complain to Defendant MAURICE RICHARD POVICH if she disapproved of the special treatment that Defendant DONNA BENNER INGBER was receiving.