Sydney Watson Blaze Complaint

Case 3:23-cv-00279-B Document 1 Filed 02/08/23 Page 1 of 17 PageID 1
IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
SYDNEY WATSON, §
§
Plaintiff, §
§ Case No. _____________________
v. §
§
BLAZE MEDIA LLC, §
§
Defendant. §
COMPLAINT
Plaintiff Sydney Watson files this Complaint against Defendant Blaze Media LLC (“The
Blaze” or “Defendant”), and would respectfully show the Court as follows:
SUMMARY OF ACTION
1. Ms. Watson has suffered injuries and the derailment of her multi-million-dollar career
in conservative commentary as a result of her former employer, Defendant The Blaze, creating and
tolerating a hostile work environment and allowing sexual harassment, retaliation, and
discriminating against her on the basis of her sex and religion. The Blaze’s conduct was continuing,
pervasive, and appalling, particularly in light of The Blaze’s representation to its audience of largely
conservative Americans that it stood for solid traditional values. The Blaze, founded and run by
famous conservative commentator Glenn Beck, told its audience that it protected traditional values
and practiced integrity, and this was part of the reason Ms. Watson trusted her career to it. But the
Blaze instead opted to cater to the demands, tantrums, and misbehavior of another young rising star,
a male one who – long after Ms. Watson had been terminated for complaining and demanding justice
– was finally fired based on allegations that he physically assaulted and manhandled at least one
other female The Blaze employee. Much of the abuse was perpetrated by this individual, Elijah
Schaffer, but Ms. Watson’s claim also implicates officers of The Blaze not interceding to correct the
COMPLAINT PAGE 1
manifest problems that they created, that occurred in front of them, or that were brought directly to
their attention and to which they failed to act promptly, reasonably, and as required by law. Ms.
Watson complained of the misconduct continually from December 2021 to August 2022 to various
personnel at The Blaze, including but not limited to The Blaze CEO Tyler Cardon. Mr. Cardon and
The Blaze did nothing to address the grievous misconduct, totally abdicating both their legal
responsibilities to Ms. Watson and their moral responsibilities to Ms. Watson and as well as The
Blaze’s own loyal audience to the point that CEO Tyler Cardon, who should have protected Ms.
Watson’s rights and the integrity of the program, asked Ms. Watson to “get Mr. Schaffer to stop
talking about dicks so much” on the show. The conduct set forth below was based upon Ms.
Watson’s gender and her religious beliefs and violated both the law, the company’s purported
procedures and policies, as well as the principles The Blaze and Mr. Beck represented to their
audience.
PARTIES
2. Plaintiff Sydney Watson is an individual residing in Denton County, Texas. The last
three digits of her social security number are 623, and the last three digits of her driver’s license
number are 357.
3. Defendant Blaze Media LLC is a Texas corporation doing business in Irving, Texas
and may be served through its registered agent, CT Corporation System, 1999 Bryan St., Ste 900,
Dallas, TX 75201.
VENUE
4. Venue is proper in the Norther District of Texas in accordance with 28 U.S.C. §1391
(b)(2) because Dallas County, which falls in the Dallas Division of the Northern District, is the
county in which all or a substantial part of the events or omissions giving rise to the claim occurred.
COMPLAINT PAGE 2
JURISDICTION
5. The Court has jurisdiction over this matter in accordance with 28 U.S.C. §1331
because claims herein arise under federal law.
SUMMARY OF FACTS
6. Plaintiff Sydney Watson (“Ms. Watson” or “Plaintiff”) is a promising young voice in
the conservative commentary space with – prior to this – no limits to her potential for advancement.
7. After she gained prominence as a YouTuber, The Blaze saw her talent and
demonstrated her worth by offering her a multi-year agreement that would pay Ms. Watson
significant amounts. The maximum value of the agreement is approximately $1,275,000, most of
which Ms. Watson will not be paid because of the Blaze’s misconduct.
8. But the pay was only one factor in Ms. Watson choosing The Blaze over other
opportunities.
9. The Blaze represented itself as an incubator of talent that helped accelerate the
careers of such conservative commentary superstars as Dana Loesch and Tomi Lahren.
10. Further, The Blaze represented itself as living the moral values that its talent,
including Glenn Beck, preached to its audience.
11. Based upon its representations, Ms. Watson expected to be part of an environment
that would allow her to grow and develop but that would also treat her (and others) with respect and
dignity. Sadly, that did not happen.
12. Ms. Watson was to co-host a show with Elijah Schaffer.
13. Ms. Watson and Mr. Schaffer began production of You Are Here (“YAH”) on
September 9, 2021.
COMPLAINT PAGE 3
14. YAH was an internet-based interview show centering on politics and culture that
streamed on The Blaze and that was supported by subscriptions. It was not to be a sexually explicit
show, nor was it intended to be actively misogynistic.
15. Ms. Watson is informed and believed, and on that basis alleges, that both she and Mr.
Schaffer were subject to the same general employment terms, though not necessarily pay and
benefits.
16. The Agreement between The Blaze and Ms. Watson provided that The Blaze would
be deeply involved in every aspect of the show and approved its content:
2. Programs. The “Programs” shall refer to the following, including each

episode thereof:
(a) an episodic audio-video series consisting of daily news and commentary
with Talent as co-host. The title and format of the Programs and underlying
concepts related to each Program are subject to Company approval, in its
sole discretion. Each episode of the Programs shall be at least forty-four
(44) minutes in length, excluding commercial breaks and depending on the
Network clock requirements, as determined by Company in its sole
discretion, exclusively for BlazeTV subscribers and podcast listeners, or as
otherwise determined by Company in its sole discretion.
(b) The Program shall consist of at least five (5) episodes per week for a
minimum of forty-eight (48) weeks per contract year, for a minimum of two
hundred forty (240) episodes per contract year.
(c) Each episode of the Programs shall be written collectively by Talent and
the designated co-host. Other persons, such as guests (as reasonably
approved by Company, and subject to securing applicable clearances), may
appear on any episodes of the Programs. Company shall have the
reasonable right to approve or reject each episode and the final content
included in each episode of the Programs and any related materials (such
as promotional clips).
3. Production of Programs. Company shall produce (including via any
third-party production company) the Programs at Company’s sole cost and
expense, and agrees to use reasonable efforts to expediently designate a
producer for the Programs to be approved by Talent, such approval not to
be unreasonably withheld, (though Talent and Company agree that said
producer may also work on Company projects or initiatives other than the
Programs, so long as said work does not materially interfere with
producer’s ability to effectively produce Talent’s Programs). The Programs
are expected to be filmed in the greater Dallas, Texas, metropolitan area;
COMPLAINT PAGE 4
however, some episodes of the Programs may be filmed in other locations

as and when mutually agreed by Talent and Company. Talent will be
reimbursed for any preapproved travel expenses incurred by Talent at the
request of Company for such productions outside of Dallas.
17. YAH was taped on-set at The Blaze’s studios in Irving, Texas under the direct
supervision of The Blaze management and employees.
18. Paragraph 1 of the general terms of the Agreement between The Blaze and Ms.
Watson requires that the talent comply with direction and The Blaze’s rules:
Services. Talent will render the Services in connection with this

engagement to the best of Talent’s ability, and subject to Company’s
direction and control. Talent shall abide by all reasonable, rules,
regulations and requests of Company in the performance of the Services
hereunder.
19. The show was initially successful and was growing its audience as hoped. However,
Mr. Schaffer’s persona on the show became increasingly aggressive and soon began to veer into
outright misogyny. He appeared to enjoy the intimidation factor that his physical size gave him with
respect to Ms. Watson. The choice of guests compounded Ms. Watson’s growing discomfort with
the anti-female tone of the show and the off-air interactions with her co-host.
20. On December 3, 2021, notorious bigot Nick Fuentes appeared on YAH. He was
grossly misogynistic, and most troubling was how this appeared to be condoned by Mr. Schaffer.
It was at about this time that the environment on the production began to become notably more
hostile not merely to Ms. Watson but to many of the women at The Blaze.
21. On December 17, 2021, Jack Murphy appeared on YAH. Ms. Watson found Murphy
grossly misogynistic and he shouted at Ms. Watson when she read a YouTube livestream superchat
question from a viewer regarding his controversial past (Ms. Watson had no prior knowledge of this
past when she innocently read the viewer’s question).
COMPLAINT PAGE 5
22. After Murphy swore at Ms. Watson and stormed out of the studio, Mr. Schaffer went
out for dinner and drinks with Murphy to “smooth” it over. Ms. Watson and members of the
audience were upset at Mr. Schaffer’s reaction and his tolerance of Murphy’s abuse.
23. Mr. Schaffer told Ms. Watson that he refused to control Murphy because Ms. Watson
was a woman and stated that if he demanded his guest stop his abuse, Ms. Watson would have
looked “weaker.” Ironically, Ms. Watson, reluctantly, defended Mr. Schaffer later over the blow-
back. Mr. Schaffer later tweeted about the incident, embarrassing Ms. Watson.
24. When YAH returned from its break in early January 2022, Mr. Schaffer unilaterally
booked several additional guests with particularly contemptible and sexist opinions towards women,
typically without consulting Ms. Watson or letting her know the extent of these opinions.
25. It became clear to Ms. Watson that on each of these episodes she was to be the
designated punching bag for the sexist guests and for Mr. Schaffer himself. Ms. Watson is a serious
journalist, and she did not agree to assume that demeaning role nor was she warned about it in
advance.
26. The idea behind YAH was never that it was to be a forum for the humiliation and
abuse of the female co-host as the male host smirked and egged on this appalling behavior.
27. It should be noted that a significant part of Mr. Schaffer’s audience calls itself
“traditional,” but actual traditional values have nothing to do with the abuse of and contempt for
women.
28. This portion of Mr. Schaffer’s audience, which he cultivates, simply uses the idea of
“tradition” as a cover for its extreme misogyny. Such viewers often flooded YAH’s discussions with
superchats and grossly sexist comments (as well as anti-Jewish commentary) that made Ms. Watson
extremely uncomfortable and prevented her from performing her duties as she wished.
COMPLAINT PAGE 6
29. No matter how many times she asked Mr. Schaffer to address the issue and to end the
hostile atmosphere of harassment, which she did repeatedly, he would not.
30. It became a running gag for Mr. Schaffer and his audience that some of Mr.
Schaffer’s fans would leave superchat comments with coded dog whistles that referenced grossly
misogynistic and/or anti-Semitic comments for Ms. Watson to read with her not knowing what they
meant.
31. Mr. Schaffer encouraged this humiliation of Ms. Watson even though he was aware
of how much she hated it and protested it. She complained to the management of The Blaze about it
to no avail.
32. Mr. Schaffer would also consistently make disrespectful comments about the fact that
Ms. Watson is an atheist. This also encouraged the audience to attack her, something she must still
put up with today and that did not happen before Mr. Schaffer made it an issue.
33. Much of the conduct that created the hostile work environment was of an explicitly
sexual nature.
34. Mr. Schaffer would endlessly reference sex, often specifically gay sex, and discuss
penises, among other sexual matter (often graphically), in front of the guests and Ms. Watson.
35. CEO Tyler Cardon even asked Ms. Watson to “get Mr. Schaffer to stop talking about
dicks so much.” She told Mr. Cardon that if he wanted it to stop, he must talk to Mr. Schaffer
himself, as Mr. Schaffer refused to listen to women – something Mr. Schaffer proudly admits.
Working with a man who would not ever listen to her solely because she is female was insulting and
damaged her ability to perform her duties.
36. It did not help that Mr. Schaffer would get drunk on set, and get guests drunk as well.
He would do shots of hard liquor before many of the shows. It was impossible to work
professionally in an environment where her co-host was drunk and impaired.
COMPLAINT PAGE 7
37. The hostile work environment created by Mr. Schaffer was taking a toll on Ms.
Watson. She was so disturbed and stressed by Mr. Schaffer’s conduct that she experienced
significant vertigo. She had to sit out of a number of shows because of it.
38. On March 4, 2022, the YAH team had a group planning session to address these
matters. It was a two-hour meeting with Ms. Watson, Mr. Schaffer, and other The Blaze employees,
including Rikki Ratliff, and The Blaze President Gaston Mooney. Ms. Watson expressed how much
Mr. Schaffer’s constant sexism and hostile, unprofessional behavior on the show distracted and
humiliated her, making it impossible for her to do her job. She detailed the same regarding his
constant offensive comments about women and pointed out how this was also encouraging some
individuals in the audience to reflect this attitude. These audience members, encouraged by Mr.
Schaffer’s conduct, attacked Ms. Watson so often and so intensely that other guests noted it and
were put off. As this meeting, Mr. Schaffer asked Ms. Watson point blank if the hostile sexism
bothered her. She said “Yes.” He also asked if it made her want to quit. She again said “Yes.”
39. The Blaze management knew about this and agreed that this conduct was
inappropriate, promising Ms. Watson that management would address the issues. But the
management failed to do so despite knowing of the hostile work environment and harassment.
40. After a tantrum in which Mr. Schaffer refused to participate in production meetings
until his demands were met, Mr. Schaffer told Ms. Watson that he would not be helping select guests
any longer because Ms. Watson “shot down his suggestions.” In reality, Ms. Watson had merely
asked him – again – to stop unilaterally booking misogynistic and abusive people without discussing
it with her.
41. At this point, Mr. Schaffer refused to participate in daily show planning and refused
to book guests. This increased the burden on Ms. Watson. Ms. Watson informed The Blaze
management, which did nothing.
COMPLAINT PAGE 8
42. Ms. Watson was subjected to public disparagement by Mr. Schaffer of a grossly
sexual nature. Because this was an Internet-based show, social media interaction by Mr. Schaffer
was a component of his participation in the show. He used social media, in the context of the show,
to harass Ms. Watson.
43. For example, on April 7, 2022, Mr. Schaffer tweeted in response to a tweet by
conservative media personality and former government official Dr. Seb Gorka that he “hopes” Ms.
Watson saw what Dr. Gorka had tweeted and “sleeps with” him. This disgraceful comment in the
context of a well-known and respected member of the conservative community – and one who
himself is happily married to an accomplished woman – was devastating to Ms. Watson.
44. Dr. Gorka’s tweet was referring to the situation where Mr. Schaffer sat silently and
said nothing while Jack Murphy shouted abuse at her during the show. This was too much.
45. Unable to perform her duties within this hostile work environment any longer, Ms.
Watson immediately texted The Blaze CEO Tyler Cardon and President Gaston Mooney and
informed them that she could not continue this way.
46. Mr. Schaffer texted Ms. Watson an apology some days later but did not delete his
appalling tweet. The offending tweets were still accessible as of the time of Ms. Watson’s
administrative complaint.
47. The Blaze management was fully aware that they had a problem with Mr. Schaffer,
but he was their “star.” He was abusive and sexist to other women at The Blaze as well. Ms. Watson
is informed and believes that other women also complained to management about him to no avail.
48. Ms. Watson tried to find a solution to the deteriorating situation.
49. She had been having weekly interactions with The Blaze officers since January 2022
alerting them to Mr. Schaffer’s behavior, the things he did and said that created the hostile
COMPLAINT PAGE 9
environment, the continuing sexism he expressed, and how hostile he made the working
environment.
50. Ms. Watson was prepared to fix the show, but it became clear management
considered Mr. Schaffer its primary “asset” and that it had no interest in protecting her from the
unlawful, discriminatory behavior of its star. Management repeatedly promised that corrective
actions would be taken, but none ever were.
51. Left with no other options, Ms. Watson was forced stop participating in the show
until the situation resolved.
52. Tyler Cardon called her and indicated that he had told Mr. Schaffer that she had left
and that the show was over. Ms. Watson told him that she was extremely upset.
53. Through this period of time Ms. Watson informed management that Mr. Schaffer had
publicly disparaged her and continued to do things that have hurt her reputation. During this period,
Mr. Schaffer was still with The Blaze.
54. A few weeks later, Ms. Watson asked management if she could address what was
going on with the audience. Many members of the audience were loyal and decent, and Ms. Watson
felt an obligation to them, especially since they had paid money to subscribe to The Blaze in order to
watch YAH. Mr. Cardon reminded her that she was contractually obligated to ask permission before
making a public statement. The Blaze asked that she email its management before she went public
with the workshopped version of the announcement, and Ms. Watson did that. She cooperated in
coordinating the message.
55. In May 2022, The Blaze finally made a community post on YAH’s YouTube channel
telling people that the show was on hiatus. The Blaze had not once said a single thing about this
show, about what happened, or addressed what would happen going forward.
COMPLAINT PAGE 10
56. What Ms. Watson ultimately posted was on Twitter and was posted on May 15, 2022.
Mr. Schaffer responded to this saying that this was the first he was hearing that the show was over.
57. Mr. Schaffer also posted this to his Telegram, where he said he was not a liar and
“don’t believe the hype.” This was not true, which he admitted to on a livestream with another very
prominent YouTuber, Nick Rekieta. This publicly disparaged Ms. Watson as a liar.
58. Mr. Schaffer also then went to his Twitter and posted a series of bizarre tweets about
the situation, such as “I haven’t played a single card,” “I just got professionally dumped by text lol,”
and so forth.
59. There was more disparagement by Mr. Schaffer while he was still with The Blaze. On
a Nick Rekieta livestream in May 2022, Mr. Schaffer made comments about how he helped a female
friend make a lot of money, who then stabbed him in the back. People immediately understood that
he meant Ms. Watson and were quick to send the clips to her. This is obviously also untrue but
damaged Ms. Watson’s reputation in the industry.
60. On another stream, Mr. Schaffer contended that he had nothing to do with an incident
(that he caused) where a guest thought Ms. Watson was trying to blindside him. The insinuation was
that Ms. Watson was the one who arranged the conflict.
61. At a movie premiere at the end of July 2022, again while still affiliated with The
Blaze, Mr. Schaffer told Harrison Smith of InfoWars and Scooter Downey (an influential Fox news
employee) and Scooter’s wife that Ms. Watson tried to get his wife to divorce him and he had to
“sue her to keep her quiet.” He told others that Ms. Watson called him and threatened to go public
with information about personal indiscretions. This was all completely false.
62. Mr. Schaffer has also told several people that Ms. Watson had made “passes” at him
and tried to hit on him on more than one occasion. This was also false.
COMPLAINT PAGE 11
63. The Blaze constructively terminated Ms. Watson in the Spring of 2022, or
alternatively actively terminated her in or about July 2022 after she complained, through counsel,
about Mr. Schaffer’s conduct.
64. On or about September 24, 2022, The Blaze announced on Twitter that Schaffer had
been “terminated for violating company policies and standards” after an “investigation regarding a
personal matter.” Ms. Watson is informed and believes that the alleged wrongdoing was Mr.
Schaffer physically harassing one or more female The Blaze employees.
65. Ms. Watson asserts that The Blaze failed to properly investigate her complaints
regarding Mr. Schaffer, that it failed to take reasonable and necessary corrective action when it
became aware of the misconduct, and that it failed to discipline Mr. Schaffer in any way for his
misconduct as to Ms. Watson.
66. This misconduct has been devastating to Ms. Watson’s future and has derailed a very
promising career.
67. But for the discriminatory and retaliatory actions by The Blaze based on Ms.
Watson’s sex and religion, Ms. Watson would have continued to thrive and develop her career.
68. Worse yet, when Ms. Watson raised these issues to The Blaze, it failed to conduct a
proper investigation and either wrongfully constructively terminated her or terminated her as a result
of her complaint. The Blaze’s actions and termination of Ms. Watson represents a continuing pattern
of discrimination and retaliation against her in violation of the law, the Agreement, and The Blaze’s
own policies and procedures.
EXHAUSTION OF ADMINISTRATIVE REMEDIES
69. Ms. Watson has met all prerequisites for bringing this action against The Blaze for
violations of Title VII and the TCHRA. 42 U.S.C. §2000e; Tex. Labor Code § 21.051. Ms. Watson
timely filed a complaint with the Texas Workforce Commission Civil Rights Division (“TWCCRD”)
COMPLAINT PAGE 12
within 300 days of the adverse action asserted herein and that complaint sufficed as a complaint
under the federal EEOC. Ms. Watson received a Notice of Right to File a Civil Action from the
TWCCRD on December 20, 2022, and a Notice of Right to Sue from the EEOC on January 23,
2023. This suit was filed within 90 days of Ms. Watson’s receipt of the Notices. As such, all
conditions precedent to the institution of this lawsuit have been fulfilled.
CAUSES OF ACTION
70. All factual allegations above are incorporated by reference into each of the causes of
action below.
COUNT 1: SEX AND RELIGIOUS DISCRIMINATION

IN VIOLATION OF TITLE VII
71. Pursuant to federal law, Plaintiff pleads a cause of action against Defendant of
intentional and malicious sex discrimination and discrimination based on Plaintiff’s religion.
72. During the course of Ms. Watson’s employment, The Blaze, acting through its
employees, agents, and representatives, discriminated against Ms. Watson in the terms, conditions,
and privileges of her employment due to her sex.
and privileges of her employment due to her religion.
74. This discrimination was knowing, intentional, and occurred with malice or with
reckless indifference to the rights of Plaintiff.
75. As a proximate result of Defendant’s conduct, Ms. Watson is entitled to all remedies
under 42 U.S.C. §2000e, including without limitation, compensatory damages, exemplary damages,
costs, and attorneys’ fees for all of which she hereby sues.
COMPLAINT PAGE 13
COUNT 2: SEX AND RELIGIOUS DISCRIMINATION

IN VIOLATION OF THE TEXAS COMMISSION ON HUMAN RIGHTS ACT
76. Pursuant to Texas State law, Plaintiff pleads a cause of action against Defendant for
sexual discrimination in violation of the Texas Commission on Human Rights Act (TCHRA). Tex.
Labor Code § 21.051.
and privileges of her employment due to her sex.
and privileges of her employment due to her religion.
under Chapter 21 of the Texas Labor Code, including without limitation, compensatory damages,
exemplary damages, costs, and attorneys’ fees for all of which she hereby sues.
COUNT 3: WRONGFUL CONSTRUCTIVE TERMINATION

wrongful termination in violation of the TCHRA. Tex. Labor Code § 21.051
81. Upon information and belief, at all times material to this action, The Blaze employed
more than 200 employees and is an “employer” within the meaning of the TCHRA.
82. The Blaze, acting through its employees, agents, and representatives, wrongfully
constructively terminated Ms. Watson in the Spring of 2022, by knowingly creating and tolerating a
hostile work environment that made it impossible for Ms. Watson to perform her duties.
COMPLAINT PAGE 14
83. The Blaze, acting through its employees, agents, and representatives, thereby
terminated Ms. Watson in the terms, conditions, and privileges of her employment due to her gender
and religion.
84. Alternatively, The Blaze, acting through its employees, agents, and representatives,
wrongfully terminated Ms. Watson in or about July 2022 for making a complaint to The Blaze
through counsel regarding the conduct set forth herein.
85. The Blaze, acting through its employees, agents, and representatives, thereby
terminated Ms. Watson in the terms, conditions, and privileges of her employment due to her
complaints regarding sexual harassment and/or a hostile work environment, and discrimination
based on religion.
exemplary damages, costs, and attorneys’ fees for all of which she hereby sues.
COUNT 4: RETALIATION
retaliation in violation of § 21.055 of the TCHRA.
88. The Blaze violated the TCHRA by terminating Ms. Watson’s employment in
retaliation for her opposition to conduct prohibited by TCHRA, and for her participation in conduct
protected under the TCHRA.
exemplary damages, costs and attorneys’ fees for all of which she hereby sues.
COMPLAINT PAGE 15
ATTORNEYS’ FEES
90. Ms. Watson seeks recovery of all attorneys’ fees and costs from The Blaze pursuant
to 42 U.S.C. §2000e-5(k) and (TEX. CIV. PRAC. & REM. CODE § 38.001, the TCHRA, and under any
other applicable provision at law or equity, for which she hereby sues.
EXEMPLARY DAMAGES
91. Defendant’s actions were intentional, with malice or with reckless disregard to Ms.
Watson’s statutory-protected rights. Accordingly, Ms. Watson asks that punitive damages be
awarded against Defendant in the highest amount under law for all of which she hereby sues.
JURY DEMAND
92. Pursuant to Federal Rules of Civil Procedure 38 and 39, Plaintiff hereby demands a
trial by jury.
PRAYER
For the reasons stated, Plaintiff prays that Defendant be cited to appear and answer herein,
and that on final hearing, Plaintiff Sydney Watson have judgment against Defendant Blaze Media
LLC, for the following:
A. Declaratory judgment, declaring Defendant’s past practices herein complained of to

be unlawful under Title VII and the TCHRA.
B. Plaintiff’s actual damages, including mental anguish, pain and suffering, lost wages
and benefits (both back pay and front pay);
C. Exemplary damages for the maximum amount allowed by law;
D. Pre-judgment and post-judgment interest at the maximum rate allowed by law;
E. Costs of suit, including attorney’s fees;
F. The award of such other and further relief, both at law and in equity, to which
Plaintiff may be justly entitled.
COMPLAINT PAGE 16
Respectfully submitted,
SCHLICHTER, SHONACK
& KEETON, LLP
By: /s/ Kurt A. Schlichter

Kurt A. Schlichter
State Bar No. 24104610
kas@sandsattorneys.com
2381 Rosecrans Ave., Ste. 326
El Segundo, California 90245
Phone: (310) 643-0111
Fax: (310) 643-1638
Respectfully submitted,
SCHEEF & STONE, LLP
James A. Pikl
State Bar No. 16008850
jim.pikl@solidcounsel.com
2600 Network Blvd., Ste. 400
Frisco, Texas 75034
Phone: (214) 472-2100
Fax: (214) 472-2150
ATTORNEYS FOR PLAINTIFF

SYDNEY WATSON
COMPLAINT PAGE 17

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Case 3:23-cv-00279-B Document 1 Filed 02/08/23 Page 1 of 17 PageID 1

IN THE UNITED STATES DISTRICT COURT

Blaze” or “Defendant”), and would respectfully show the Court as follows:

number are 357.

because claims herein arise under federal law.

6. Plaintiff Sydney Watson (“Ms. Watson” or “Plaintiff”) is a promising young voice in

including Glenn Beck, preached to its audience.

dignity. Sadly, that did not happen.

12. Ms. Watson was to co-host a show with Elijah Schaffer.

show, nor was it intended to be actively misogynistic.

2. Programs. The “Programs” shall refer to the following, including each

however, some episodes of the Programs may be filmed in other locations

supervision of The Blaze management and employees.

Services. Talent will render the Services in connection with this

past when she innocently read the viewer’s question).

hostile atmosphere of harassment, which she did repeatedly, he would not.

damaged her ability to perform her duties.

professionally in an environment where her co-host was drunk and impaired.

management, which did nothing.

to harass Ms. Watson.

himself is happily married to an accomplished woman – was devastating to Ms. Watson.

informed them that she could not continue this way.

48. Ms. Watson tried to find a solution to the deteriorating situation.

actions would be taken, but none ever were.

until the situation resolved.

Mr. Schaffer was still with The Blaze.

coordinating the message.

damaged Ms. Watson’s reputation in the industry.

about Mr. Schaffer’s conduct.

Schaffer physically harassing one or more female The Blaze employees.

misconduct as to Ms. Watson.

own policies and procedures.

EXHAUSTION OF ADMINISTRATIVE REMEDIES

conditions precedent to the institution of this lawsuit have been fulfilled.

COUNT 1: SEX AND RELIGIOUS DISCRIMINATION

and privileges of her employment due to her sex.

and privileges of her employment due to her religion.

reckless indifference to the rights of Plaintiff.

COUNT 2: SEX AND RELIGIOUS DISCRIMINATION

Labor Code § 21.051.

and privileges of her employment due to her sex.

and privileges of her employment due to her religion.

COUNT 3: WRONGFUL CONSTRUCTIVE TERMINATION

wrongful termination in violation of the TCHRA. Tex. Labor Code § 21.051

through counsel regarding the conduct set forth herein.

retaliation in violation of § 21.055 of the TCHRA.

protected under the TCHRA.

LLC, for the following:

A. Declaratory judgment, declaring Defendant’s past practices herein complained of to

C. Exemplary damages for the maximum amount allowed by law;

D. Pre-judgment and post-judgment interest at the maximum rate allowed by law;

E. Costs of suit, including attorney’s fees;

By: /s/ Kurt A. Schlichter

SCHEEF & STONE, LLP

ATTORNEYS FOR PLAINTIFF

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