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