EXHIBIT SUPERIOR COURT OF THE DISTRICT OF COLUMBIA U1) CIVIL DIVISION CIVILACTIONS BRANCH KAROLINA WILSON 515 White Oak Drive FEB 09 2018 | Glen Burnie, MD 21060 Su, Tourt of the District of Columbia Plaintiff, Washington. D.C. y, Civil Action No, INGRAHAM MEDIA GROUP, INC. d/b/a LIFEZETTE, 1055 Thomas Jefferson St NW, Ste. 301 Washington, D.C. 20007 JURY TRIAL DEMANDED and LAURA INGRAHAM and, KG AIRCO, INC. 1090 Vermont Avenue NW ‘Washington, D.C. 20005 Defendants, LAINT. (Pregnancy diseri the District of Columbia Protecting Pregnant Workers Fairness Act of 2014; Interference and retaliation in violation of the D.C. Family and Medical Leave Act) COMES NOW Plaintiff Karolina Wilson, through her counsel, Correia & Puth, PLLC, and for her complaint states to this Honorable Court as follows: INTRODUCTION Defendant Ingraham Media Group, Ine. (“Ingraham Media”), d/b/a LifeZette (LifeZette”), and Defendant Laura Ingraham fired Plaintiff Karolina Wilson within one day of13. When working for Defendants, Plaintiff was a highly motivated and responsible employee who conducted herself with great integrity. 14, When working for Defendants, Plaintiff was a loyal and reliable employee who showed proficiency in all her numerous job responsibilities. 15, When working for Defendants, Plaintiff was extremely efficient and showed superb communication skills, as well as composure in stressful situations, 16. At all times relevant hereto, Plaintiff's work performance met the legitimate expectations of her employers, 17, Prior to her pregnaney, Ingraham and Plaintiff were in constant contact. Ingraham demanded a time commitment significantly above standard work hours and Plaintiff met that. While Defendants’ executive assistant immediately before Wilson was only able to hold the job fora few months, Plaintiff worked in this role for over a year before the birth of her child, maternity leave, and subsequent termination. 18. Plaintiff notified Ingraham and Anthony of her pregnancy in March 2017. She also shared the news with Defendants’ other employees, Plaintiff told Defendants that her baby was due in August 2017. 19. When Plaintif announced her pregnancy in March 2017, Ingraham’s attitude toward her noticeably changed, Plaintiff observed Ingraham becoming distant and angry with her work performance, 20. To prepare for the birth of her child, in April 2017, Plaintiff asked Anthony about the company’s matemity leave policy. Plaintiff and Anthony met in his office in the District of Columbia. Anthony told Plaintiff, “no employee here has been pregnant,” Instead of allowing 16 weeks of leave provided to employees under the D.C, Family and Medical Leave Act, Anthonyasked Plaintiff to start working from home immediately or one week after giving birth. Plaintiff said she did not think that was possible given the need to physically recover from child birth and asked for at least three weeks of full matemity leave. 21, Anthony then told Plaintiff that the company had to give her six or eight weeks of ‘maternity leave, Anthony said eight weeks was too long for her to be out of work and stated that “8 weeks of leave should be right as long as you can start working from home two or three weeks. after” giving birth 22, Plaintiff felt pressured to commit to working from home only two or three weeks after the birth of her child. ‘This was her first child and she was not sure when her postpartum Fecovery would permit her to handle substantive work items. Plaintiff conveyed her concerns and ‘Anthony reiterated that “we won't be able to go for eight weeks.” 23. Plaintiff felt that Defendants’ push to limit her maternity leave showed their hostility toward her pregnancy announcement. 24. Due to the pressure, Wilson agreed to work remotely, and Plaintiff and Defendants set a work schedule, Defendants agreed that Plaintiff could take maternity leave for three weeks after giving birth, Affer the three week period, Defindants required Plaintiff to execute her job duties that could be done remotely, such as managing Ingraham’s work and personal schedules, ‘managing houschold employees, and managing Ingraham’s travel. Defendants’ intern, Alexis Papa, would take care of Plaintiff's job duties while she was on maternity leave for three weeks and when Plaintiff returned, Papa would continue to manage Ingraham’s schedule related to her book tour for her new book, Billionaire at the Barricades: The Populist Revolution from Reagan 10 Trump,25, Plaintiff would have taken full advantage of the job-protected leave available to her under the law if Defendants had maintained an effective policy that informed employees of thei rights under the District of Columbia Human Rights Act and the Family and Medical Leave Act, and if Defendants had not interfered with her ability to take more than 8 weeks of leave. 26. After Plaintiff announced her pregnancy, Ingraham began to treat her with new hostility; her demands and Plaintiff's obligations changed. Ingraham was hyper critical of PlaintifYs job performance in a way she was not before she announced her pregnancy, and lashed out at Plaintiffon issues never before raised, 27, For example, in April 2017, Ingraham left Plaintiff a voice message on a Sunday requesting information, Plaintiff promptly responded and provided Ingraham with the information she needed. Ingraham responded by telling Plaintiff “you must always answer my phone calls.” In response to this incident, Plaintiff later heard from Ingraham’s nanny that Ingraham told ‘Anthony “Need to can Karolina... She is a colossal fuck up.” 28. Neither Ingraham nor Anthony told Wilson at that time that Defendants were dissatisfied with her job performance or that her employment may be terminated. 29. Plaintiff raised Ingraham’s hostile response with Anthony that Monday and he told Plaintiff, “I'm sure it was nothing I know you're doing a good job.” 30. Prior to her pregnancy, Plaintiff was available to answer questions and Ingraham was satisfied with an adequate response; she did not take issue with how Plaintiff delivered the information, whether by text, email, or telephone. After Plaintiff announced her pregnancy, even the smallest of incidents (like missing a call), prompted Ingraham to be critical of Plaintiffs performance.31. Inaddition to continuing her job duties, Plaintiff worked with Defendants to prepare for her maternity leave. She compiled a document that contained instructions and information to aid Papa in coordinating Ingraham’ travel. She reviewed applications for an open nanny position at Ingraham’s home, and kept Ingraham and the current nanny updated on the process so they could handle a portion of her job duties while she was on maternity leave 32. Plaintiff gave birth on August 6, 2017, two weeks carlier than her due date. She was working full time up until the birth, working Friday, August 4, going into labor Saturday, August 5, and having the baby on Sunday, August 6, 33. When she began her labor, Plaintiff notified Ingraham’s nanny, Petra Mitchell, that she was going to the hospital and asked her to please share the information with Ingraham. 34. At 8:09 am on August 6, Defendant Ingraham texted Plaintiff to tell her she heard she was in labor and wished her luck. Within a few hours, by 11:30 am, Ingraham began to send. Plaintiffa series of texts about work: “Pls just have someone take over the nanny interviews which are critical... Just make sure Petra has everything or Drew re nannies and anything else on schedule... . need that exercise equip person to come fix ete.” By August 8, Ingraham and Anthony were contacting Plaintiff with work items, and by August 28, PlaintifT was executing her job duties remotely. 35. When Plaintiff began working remotely in August 2017, the hostility continued. Ingraham began to copy Papa on emails related to tasks that were assigned to Plaintiff and contacted Plaintiffless. Prior to her pregnancy, Ingraham did not copy other employees on emails related to tasks that were ssigned to Plaintiff, and given that Plaintiff and Defendants had established a clear plan on her duties, Plaintiff saw this as a sign that Ingraham suddenly did not trust her to execute her work42, Wilson reiterated to Carmichael it was not just his comments that had her concerned about termination, Ingraham was treating Plaintiff with hostility and distance, her insurance was, cut off, and she thought her job was in jeopardy “because I have a baby.” 43, Plaintiff returned to work on October 9, 2017. On October 10, she asked Anthony if he had a moment to discuss her work schedule, Anthony called Plaintiff into his office and before Plaintiff could address her work schedule, Anthony told Plaintiff she was fired. 44, Anthony told Plaintiff, “I don’t want to be firing you today because you just came back, So I will keep you on until the end of the month. But if you just want to say “fuck you all, P'm out,’ T would understand that” Anthony told Plaintiff she could stop working or continue working until October 31 when she had to be out of the office. 45. Anthony told Plaintiff her position was no longer needed with the company and that Papa, the person who filled in for Plaintiff while she was out on maternity leave, was becoming Ingraham’s permanent assistant. Anthony said that the decision was based on Papa’s experience in polities. 46. Plaintiff had been successfully executing the job duties of Ingraham’s assistant for over a year prior to her pregnancy. 47. Plaintiffasked Anthony if there were other roles she could fill in the company and Anthony said no. 48, Defendants terminated Plaintiff's employment one day after her return from maternity leave. 49. Upon return from Plaintiff's matemity leave, Defendants failed to restore Plaintiff to the position of employment she held when her leave commenced.50. Upon return from Plaintiff's matemity leave, Defendants failed to restore Plaintiff to a position of employment equivalent to the position she held when her leave commenced that included equivalent benefits, pay, security, and other terms and conditions of employment. SI. Although Anthony said he would fix what he called “mistake in the system, Defendants never put Plaintiff back on the company’s health insurance plan, As a result, she was without Defendants’ health insurance from September 1, 2017 through the last day of her maternity. leave, October 9, 2017. 52. Upon Wilson’s return to the workplace following maternity leave, Defendants did not restore her health insurance coverage. As a result, Plaintiff was without Defendants’ health insurance coverage through her last day on the job, October 31, 2017, 53. Defendants terminated Plaintiff's health insurance coverage effective August 31, 2017, denying her a benefit at the same level and under the same conditions that coverage would have been provided to her had she continued in employment from the date she commenced her matemity leave. 54. Upon her termination, Defendants never gave Plaintiff information about continued health insurance coverage required by the District of Columbia Health Care Benefits Continuation Law. 55. Asa result, Plaintiff continued without health insurance coverage for a significant period after her termination, 56. Defendants cut off Plaintiff" health insurance coverage one month before they told her of her termination, As a result, Plaintiff incurred signit t personal expenses for postpartum. ‘medical care, Her family has withheld secking planned medical treatment because they were without health insurance or the benefit of continued health coverage. 1057. Resisting Anthony's invitation to quit, Plaintiff worked until October 31, 2017, three weeks after being told of her termination. She knew that if'she quit, she would not be eligible for unemployment benefits and she was concerned about her and her family's financial circumstances. 58. When Plaintiff returned to the workplace in October, she told Ingraham and Anthony that she was breastfeeding. During the three weeks she continued working with Defendants, Plaintiff was in the D.C. of at least six hours a day without her baby and needed a place to pump. The office space has primarily glass walls without much private space. 59. Defendants did not give Plaintiff a breastfeeding accommodation or a place to pump. 60. Without a private, clean place to pump, Plaintiff bought a converter for her car and pumped in her car in the parking garage for three weeks. 61, Throughout the three weeks that Plaintiff worked, Ingraham mainly ignored Plaintiff and told her that she should assist Papa with her job duties. When they did interact, she continued to be more hostile than she was prior to Wilson’s pregnancy, for example criticizing Plaintiff for minor issues like not immediately responding to a message when “I emailed you six minutes ago.” 62, As of February 5, 2018, the copyright information on the Ingraham’s LiteZette website reads: 2018 LifeZette - KG Airco. 63. Upon information and belief, effective on or about October 2, 2017, Delaware corporation KG Airco, Inc. registered to do business in the District of Columbia, 64. Upon information and belief, KG Airco, Inc., acquired all or substantially all of the assets of Ingraham Media Group, Inc. in a recent transaction,65. Upon information and belief, KG Airco, Inc., acquired, of is in the process of transferring, Defendants Ingraham and Ingraham Media Group’s assets including LifeZette website, data, brand, copyright, trademark, licenses, employees, customers, investors, contracts, equipment, and leases. 66. Defendants had notice of Plaintiff's claims as early as November 11, 2017 67. Upon information and belief, since KG Airco's acquisition of Ingraham Media Group’s assets, the same business operations have continuously been in place, with the same workforce, jobs, management, and production, 68. Upon information and belief, prior to the acquisition of Ingraham by KG Airco, Inc., Defendants Ingraham and Ingraham Media Group knew that Plaintiff Wilson recently had been terminated, 69. Upon information and belief, prior to the acquisition of Ingraham by KG Airco, Inc., Defendants Ingraham and Ingraham Media Group had notice of Plaintiff's claims of discrimination, retaliation, and interference related to her pregnancy and family leave, COUNT ONE Pregnancy discrimination in violation of the District of Columbia Human Rights Act D.C. Code §§ 2-1401.05, 2-1402.11 70. Plaintiff incorporates by reference and re-alleges each of the allegations contained in paragraphs 1-69 of this Complaint as if set out here in full, 71. Plaintiff was pregnant and gave birth to a child while employed by Defendants, 72. Defendants discriminated against Plaintiff when they terminated her employment wholly or partially because of her pregnancy or childbirth. 73. Defendants discriminated against Plaintiff when they treated her with hostility in the workplace wholly or partially because of her pregnancy or childbirth. 1274, Defendants discriminated against Plaintiff when they terminated her health insurance coverage benefits while she was out on maternity leave and materially altered her employment benefits wholly or partially because of her pregnancy or childbirth, 78. Defendants’ conduct was malicious, wanton, reckless, and done with willful disregard for Plaintiff's rights. 76. Asa direct and proximate result of Defendants’ unlawful acts, Plaintiff suffered and continues to suffer lost earnings, embarrassment, humiliation, mental anguish, mental distress, indignity, and loss of enjoyment of life. COUNT TWO Breastfeeding discrimination in violation of the District of Columbia Human Rights Act D.C. Code § 2-1402.82 77. Plaintiff incorporates by reference and re-alleges each of the allegations contained in paragraphs 1-69 of this Complaint as if set out here in full 78. Plaintiff was a breastfeeding mother while employed by Defendants. 79. Defendants did not make reasonable efforts to provide a sanitary room or other location in close proximity to the work area, other than a bathroom or toilet stall, for Plaintiff to express her breast milk in privacy and security. 80. Defendants’ conduct was malicious, wanton, reckless, and done with willful disregard for Plaintiff's rights. 81, Asa direct and proximate result of Defendants’ unlawful acts, Plaintiff suffered and continues to suffer embarrassment, humiliation, mental anguish, mental distress, indignity, and loss of enjoyment of lifeCOUNT THRE Interference in violation of the District of Columbia Family and Medical Leave Act D.C. Code §§ 32-502, 32-505, 32-507 82. Plaintiff incorporates by reference and re-alleges each of the allegations contained in paragraphs 1-69 of this Complaint as if set out here in full 83. Plaintiff was pregnant and gave birth to a child while employed by Defendants Ingraham Media and KG Airco. 84. Defendants provided only three workweeks of family leave to Plaintiff despite D.C. law that entitles her to a total of 16 workweeks of family leave for the birth of her child. 85. Defendants told Plaintiff she was only entitled to six or eight weeks of leave under the law. 86. Defendants required Plaintiff to work remotely during her 8-week leave period, 87. Defendants terminated Plaintiff's health insurance coverage while she was on family leave, in violation of her right to coverage for the duration of her leave at the same level and under the same conditions that coverage would have been provided if she had continued in employment from the date she commenced the family leave to the date she returned from her leave. 88, Defendants interfered with, restrained, and denied the exercise of and the attempt to exercise Plaintiff's rights to 16 workweeks of family leave under the law. 89. Defendants’ conduct was malicious, wanton, reckless, and done with willful disregard for PlaintifY's rights. 90. Asa direct and proximate result of Defendants’ unlawful acts, Plaintiff suffered and continues to suffer lost earnings, embarrassment, humiliation, mental anguish, mental distress, indignity, and loss of enjoyment of life 14COUNT FOUR Retaliation in violation ofthe District of Columbia Family and Medical Leave Act D.C. Code §§ 32-502, 32-505, 32-507, 91. PlaintifF incorporates by reference and re-alleges each of the allegations contained in paragraphs 1-69 of this Complaint as if set out here in full 92, Plaintiff was pregnant and gave birth to a child while employed by Defendants Ingraham Media and KG Airco. 93. Plaintiff requested and took family leave, as her right under the law, immediately following the birth of her child. 94. Defendants treated Plaintiff adversely after Plaintiff requested family leave related to her pregnancy and when she took family leave after the birth of her child. 95. Defendants terminated Plaintiff's employment one day after returning from family leave. 96. Defendants retaliated against Plaintiff for exercising her rights under the law by terminating her employment one day after return from maternity leave. 97. Defendants retaliated against Plaintiff for exercising her rights under the law by treating her with hostility when she sought to exercise her rights to job-protected family leave. 98. Defendants retaliated against Plaintiff for exercising her rights under the law by terminating her health insurance coverage while she was on family leave and failing to restore her health insurance coverage when she retumed from family leave. 99. Defendants’ conduct was malicious, wanton, reckless, and done with willful disregard for Plaintiffs rights.100. As a direct and proximate result of Defendants’ untawful acts, Plaintiff suffered ‘and continues to suffer lost earnings, embarrassment, humiliation, mental anguish, mental distress, indignity, and loss of enjoyment of life. COUNT FIVE Discrimination in violation of the D.C. Protecting Pregnant Workers Fairness Act D.C. Code §§ 32-1231.01, 32-1231.03 101. Plaintiff incorporates by reference and re-alleges each of the allegations contained in paragraphs 1-69 of this Complaint as if set out here in full 102. Plaintiff was a breastfeeding mother while employed by Defendants Ingraham Media and KG Airco, 103. Defendants did not provide Plaintiff with a private, non-bathroom space to express breast milk 104, Defendants’ conduct was malicious, wanton, reckless, and done with willful disregard for Plaintif?’s rights. 105, Asa direct and proximate result of Defendants’ unlawful acts, Plaintiff suffered and continues to suffer embarrassment, humiliation, mental anguish, mental distress, indignity, and loss of enjoyment of life. PRAYER FOR RELIEF WHEREFORE, the premises considered, Plaintiff respectfully prays that this Honorable Court 1. Enter judgment in favor of Plaintiff Karolina Wilson on each of her claims; 2. Enter judgment against Defendants Ingraham Media Group, Inc., Laura Ingraham, and KG Airco, Inc., jointly and severally;3. Declare Defendants’ conduct in violation of the District of Columbia Human Rights Act, D.C. Code §§ 2-1401.05, 2-1402.11, and 2-1402.82;, 4, Declare Defendant Ingraham Media’s and KG Airco, Inc.’s conduct in violation of the District of Columbia Protecting Pregnant Workers Faimess, D.C. Code §§ 32-1231.01 and 32- 1231.03; 5. Declare Defendant Ingraham Media’s and KG Airco, Inc.'s conduct in violation of the District of Columbia Family and Medical Leave Act, D.C. Code §§ 32-502, 32-505, and 32- 507; 6. Award Plaintiff economic and compensatory damages and all other damages available to her under the law; 7. Award Plaintiff her court costs and expenses, including reasonable attorneys’ fees; 8. Award Plaintiff pre-judgment interest and post-judgment interest; 9. Award Plaintiff punitive damages: and 10, Grant such other relief as this Court deems just and proper. Date: February 5, 2018 Respectfully submitted, CORREIA & PUTH, PLLC Af Linda M, Correia Linda M. Correia (D.C. Bar No. 435027) Lauren A. Khouri (D.C. Bar No. 10282288) 1775 K Street NW, Suite 600 Washington, DC 20006 Tel: (202) 602-6500 7JURY DEMAND Plaintiff demands a trial by jury on all issues contained herein, Linda M. Correia (D.C. Bar No. 435027) Lauren A. Khouri (D.C. Bar No. 10282288) CORREIA & PUTH, PLLC 1775 K Street NW, Suite 600 Washington, DC 20006 Tel: (202) 602-6500 creie@-correiaputh.com wouriwearlM XERIFICATION 1, Karolina Wilson, declare under penahy of perjury that 1 have reat the foregoing Complaint and that it is tre othe best of my personal knowledge, 2jsp wie UlichrySuperior Court of the District of Columbia CIVIL DIVISION- CIVIL ACTIONS BRANCH INFORMATION SHEET ina Wilson. Case Number February 5, 2018 ¥s Date: Ingraham Media Group, Inc.; Laura Ingraham; KG Airco, Inc. One of the defendants is being sued in ther offical capacity. Name: Please P01) nda M, Correia; Lauren A. Khouri Relationship to Laws 0 Atorey for Plainift Firm Name: Correia & Puth, PLLC CO seit Pro Se) hone No Six digit Unified Bar No 202-602-6500 _ Correia: 435027; Khouri: 10282288 Oo otter: _ TYPE OF CASE: CI Non-Jury Demand: $_ PENDING CASE(S) RELA’ Case No Case No, CO 6 Person Jury Other: TO THE ACTION BEING FILED Judge: Judge: CB 12 Person Jury Calendar Calendar NATURE OF SUIT: (Chev One Box Only) CONTRACTS: Dor Breach of Contract Bor Breach of Warranty (Boe Negorable instrument [07 Persona Property BB 1 Employment Discrimination EIS Special Euston Fees COLLECTION CASES 14 Under $25,000 Pi. Grants Consent 116 Under $2 ts Consent] 18 OVER $25,000 Consent Denied i 1 over 825.000 Pe 27 lasurancesSubrogation (Over $25,000 Pit. Grants Consent or nsurancerSubrogation Under 8 ‘Awad (Colleton Cases Onl 10 Pr. Grants Consent 28 Motion to Confim Arttration 000 Coaseat Denied Ei2s insurance’ Subrogation (Over $25,000 Consent Denied (34 tnsurance’Subrogation Under $25,000 Chasen Denied ) B, PROPERTY TORTS or automorie 02 Conversion (Do? Shopliting, D.C. Code § 27 os Desirstion of Private Property Tos Property Damage 102) Dos trespass C. PERSONAL TORTS, 01 Abuse of Process (0? Alienation of Aifection 105 Assaut and Bartery F 1otmasion of Privacy (B11 Lie and Stander Bi t2 Malicious lnererence (oF Automobile: Personal Injury 2113 Malicious Prosecution 05 Deceit (Mistepresemation) (06 False Accusation 07 False rest, a La Malpracice Legal TIS state sia in Eto nealigence- (Nor Automobile, (17 Pessoal tnjuy- (Not Automobile Not Malpractice) {sWrongfil Death (Not Malpractice) [i9 Wrongfal Eviction B20 Friendly sue dees) EE]21 Asbestos 22 Tories Tons Cox Froud Not Malpractice) [B25 Tobacco p24 Lend PaiInformation Sheet, Continued [26 Peon for Civil Asset Foriure(Vebiele) 27 Pesisin for Civil Asset Forfeiture (Cusreney) 2s eision fo Civil Asset Forfeiture (Other) C. OTHERS ot Accouning 1117 Mert Peron Act(OEA) (02 an. Before Fudgment DC. Code Tite 1, Chapter 6 (0 Fiecnet Pro iaity lo special WeivWarants {OC Code § 11381) ( % Application Coat, Modify, Co Tris Adjudication Vacate Aehitation Awaed (DC Code § 16-4401) Ti We at Replevin 2129 Meri Personne Act (OHR) C2 Enforce Mechanics Lien EI 31 Housing Code Regulations CA toeclawory Suge — EI 2 QuiTam 153 Whisticiower u Ts change of Name Tis Lite of nformation Tat petiion or Subpoena os Focign udgmess:Domestic [2] 19 Fater Administtive Order as [Rae 264) los Foreign dgnecvtnteratonal Judgment D.C. Code § 22 Release Mechanics Lisa TA iscorecionofBiahCenifte —2-180208 (bor 32-181 9(0)) EI 23 Rule2710K1) TA isCorection of Marrioge C1 20 Maser Meter(D C.Code§ (Pepetat Testimony) Cenifete 423301, e593) 1D > pesion for Seared Serlement 25 Petition fr Liquidation REAL PROPERTY (09 Real Propery-Real Estate (Dos Quiet Title [111 Petition for Cis Asset Forkeiure (RP) 22 Specie Performance (hos Liens: Tax Water Consent Grates [or Condemsation meen Dowsisy C130 ens Tax Water Consent Denied (5]10 Morgige Foreclosure Suda Sale C131 Tax Lien Bid OM Cerificate Consem Granted /s/ Lauren Khouri 2105/2018 Attomey’s Signature (C¥.496 Jane 2015 Date‘Superior Court of the District of Columbia CIVIL DIVISION Civil Actions Branch 500 Indiana Avenue, N.W., Suite 5000 Washington, D. “Telephone: (202) 879-1133 Website: www.dccourts.gov Karolina Wilson Praia Ingraham Media Group, Inc. ‘Case Number aan, SUMMONS To the above named Defendant You are hereby summoned and required to serve an Answer to the attached Complaint, either personally or through an attorney, within twenty one (21) days after service of this summons upon you, exclusive of the day of serviee. If you are being sued as an officer or agency of the United States Government or the District of Columbia Government, you have sixty (60) days after service of this summons to serve your Answer. A copy of the Answer must be mailed to the attomiey tor the plaintiff who is suing you. The attorney's name and address appear below. If plaintiff has no attomey, a copy of the Answer must be mailed to the plaintiff at the address stated on this Summons. You are also required to file the original Answer with the Court in Suite $000 at $00 Indiana Avenue, N.wW,, between 8:30 a.m, and 5:00 p.m., Mondays through Fridays ot between 9:00 a.m, and 12:00 noon on Saturdays. You may tile the original Answer with the Court either before you serve & copy of the Answer on the plaintiff or within seven (7) days after you have served the plaintiff. If you fail to file an Answer. judgment by default may be entered against you for the relief demanded in the complaint, Lauren A. Khouri Clerk of the Court ‘Name of Plant's Atomey Correia & Puth, PLLC By aac Depnty Clerk 1775 K Street NW, Suite 600 Washington, D.C. 20006 202-602-6500 Date Telephone SDREATEE (202) 879.4828 Voullz appter au (202) 678.4828 pour une adcton Ec am bi ch hy (202} 679.4828 OH 29 Fe, 202)079.4020 ALLE Amu Hor Aer (202) 679.4828 HON IMPORTANT: IF YOU FAIL TO FILE AN ANSWER WITHIN THE TIME STATED ABOVE, OR IF, AFTER YOU ANSWER. YOU FAIL TO APPEAR AT ANY TIME THE COURT NOTIFIES YOU TO DO SO. A JUDGMENT BY DEFAULT MAY HE ENTERED AGAINST YOU FOR THE MONEY DAMAGES OR OTHER RELIEF DEMANDLD IN THE COMPLAINT. IF THIS OCCURS, YOUR WAGES MAY BE ATPACHED OR WITHHELD OR PERSONAL PROPERTY OR REAL ESTATE YOU OWN MAY BE TAKEN AND SOLD TO PAY THE JUDGMENT. IF YOU INTEND 10 OPPOSE THIS ACTION, DOMOL Hdl 10 ANSWER WIILIN [tle REQUIRED DIME. {you wish to talk 10 a lawyer and feet that you cannot afford to pay a fe toa lawyer. prompiy contact one af the offices af the Legal Aid Society (202-628-1161) oF the Neighborhood Legal Services (202-279-3100) for help oF come to Suite S000 at $00 Indiana Avenue, N.W.. for more information concerning places where you may ask for such help. See reverse side for Spanish teaslation ‘Vea al dorso la traduccisn al espatiol (CV-3110 Rey dune 2017), super. Cr-Civ RASuperior Court of the District of Columbia en CIVIL DIVISION Ge ‘vil Actions Branch 500 Indiana Avenue, N.W., Suite S000 Washington, D.C. 20001 ¥ “Yelephone: (202) 879-1133 Website: swww.dccourts gov a? Karolina Wilson, Pata Laura Ingraham, Case Number : Beteadant SUMMONS To the above named Defendant: You are hereby summoned and required to serve an Answet to the attached Complaint, either petsonally of through an attorney. within twenty one (21) days after service of this summons upon you, exclusive of the day of serviee. If you are being sued as an officer or agency of the United States Government or the District of Columbia Government. you have sixty (60) days after service of this summons to serve your Answer. A copy of the Answer must be mailed to the attomey for the plaintiff who is suing you. The attorney's name and address appear below. If plaintiff has no attomey, a copy of the Answer must be mailed to the plaintiff at the address stated on this Summons, You are also required to file the original Answer with the Court in Suite 5000 at 500 Indiana Avenue, N.W., between 8:30 am, and 5:00 p.m., Mondays through Fridays or between 9:00 a.m. and 12:00 noon on Saturdays. You may file the original Answer with the Court either before you serve a copy of the Answer on the plaintif? or within seven (7) days alter you have served the plaintiff. If you fail to file an Answer, judgment by default may be entered against you for the relief demanded in the complaint, Lauren A. Khouri Clerk of the Court ‘Name of Painui's Anomey Correia & Puth, PLLC by Address Deputy Clare 1775 K Street NW, Suite 600 Washington, D.C. 20006 202-602-6500 Date Telephone TAREE ARTES (202) 879-4828 Vell appter au (202) 878-4828 pour vaducton Deco mt icici wot (202) 670-4828 Sta 2 202) 075.4020R PTAA enon! Yr aewrsh (202) 879.4828 esx IMPORTANT: IF YOU FAIL TO FILE AN ANSWER WITHIN THE TIME STATED ABOVE, OR IR. AFYER YOU ANSWER, YOU FAIL TO APPEAR AT ANY TIME THE COURT NOTIFES YOU TO DO SO. A JUDGMENT BY DEFAULT MAY BE ENTERED AGAINST YOU FOR THE MONEY DAMAGES OR OTHER RELIEF DEMANDED iN THE COMPLAINT, IF THIS OCCURS, YOUR WAGES MAY BE ATFACHED OR WITHHELD OR PERSONAL PROPERTY OR REAL ESTATE YOU OWN MAY BE TAKEN AND SOLD TO PAY THE JUDGMENT. f YOU INTEND TO OPPOSE THIS ACTION. DO NOT 4h 10 ANSWER W/TLUN TIE REQUIRED TLE, [you wish o alk to a fawyer and fee that you cannot afford to pay a fee toa lawyer. promptly contact one ofthe offices of the Legal Aid Society (202-628-1161) of the Neighborhood Legal Services (202-279-5100) for help or come to Suite S000 at 50) Indiana Avenue, N.W., for more information concerning places where you may ask for such help. See reverse side for Spanish translation Vea al dorso ls traduccion al espaitol €¥3U10 Rev. June 2017} Super Ct.Civ. 4Superior Court of the Distriet of Columbia CIVIL DIVISION Civil Actions Branch 500 Indiana Avenue, N.W., Suite 5000 Washington, D.C. 20001 ‘elephone: (202) 879-1133 Website: www.decourts.gov Karolina Wilson Pain KG Airco, Inc, (Case Number = ~Betendant SUMMONS To the above named Defendant: You are hereby summoned and required to serve an Answer to the attached Complaint, cither personally or through an attorney, within twenty one (21) days alter service of this summons upon you, exclusive of the day of serviec. If you are being sued as an officer or agency of the United States Government or the District of Columbia Government, you have sixty (60) days after service of this summons to serve your Answer. A copy of the Answer must be mailed to the attorney tor the plaintiff who is suing you, The attorney's name and address appear below. If plaintiff has no attomey. a copy of the Answer must be mailed to the plaintiff at the address stated on this Summons. You are also required to file the original Answer with the Court in Suite $000 at 500 Indiana Avenue, NW. between 8:30 a.m, and 5:00 p.m., Mondays through Fridays or between 9:00 a.m. and 12:00 noon on Saturdays. You may tile the original Answer with the Court either before you serve a copy of the Answer on the plaintiff or within seven (7) days after you have served the plaintiff. If you fail to file an Answer. judgment by default may be entered against you for the relief demanded in the complaint, Lauren A, Khouri Clerk of the Court ‘Name of Pinas Awomey Correia & Puth, PLLC ay Address 1775 K Street NW, Suite 600 Washington, D.C. 20006 202-602-6500 Date Telephone ‘SOB. WNATIUI (202) 670-1228 ———_Veulex appoer au (202) 87B-4028 pourure vaducon DR ODay yi (202) 879-4828 “9g A AR 202) 979-40208 IIBAME — CT! Hor ger (202) 879-4828 rom Clerk IMPORTANT: IF YOU FAIL TO FILE AN ANSWER WITHIN THE TIME STATED ABOVE, OR IF. AFTER YOU ANSWER, YOU PAIL TO APPEAR AT ANY TIME THE COURT NOTIFIES YOU TO DO SO. A JUDGMENT BY DEFAULT. MAY HE ENTERED AGAINST YOU FOR THE MONEY DAMAGES OR OFHER RELIEF DEMANDED IN THE COMPLAINT. IF THIS OCCURS, YOUR WAGES MAY BE ATTACHED OR WITHHELD OF PERSONAL PROPERTY OR REAL ESTATE YOU OWN MAY BE TAKEN AND SOLD TO PAY THE JUDGMENT. [F YOU INTEND TO OPPOSE THIS ACTION, DO.XOT UL 10 ANSWER WITHIN IIE REQUIRED TIM [you wish io talk to a lawyer and fet that you cannot afford to pay & fee to lawyer prompiy contact one af the offices af the Legal Aid Society (202-628-1161) oF the Neighborhood Legal Services (202-279-3100) for help oF come to Suite 5000 at 300 Indiana Avenue, N.W.. for more information concerning places where you may ask for such help. See reverse side for Spanish trasfation Vea a dorso la traduceiém a espaiol (€V-3110 (Rev. dune 2017] Super C1 Civ.SUPERIOR COURT FOR THE DISTRICT OF COLUMBIA. CIVIL DIVISION KAROLINA WILSON, Plaintiff, v Civil Action No. 2018 CA 000870 B Judge John M. Mott INGRAHAM MEDIA GROUP, INC. d/b/a LIFEZETTE, and LAURA INGRAHAM and KG AIRCO, INC. ___ Defendants [PROPOSED] ORDER GRANTING CONSENT MOTION FOR A PROTECTIVE ORDER This matter is before the court on Defendant Laura Ingraham's Motion for a Protective ‘Order, which Plaintiff has consented to. Upon consideration of the Motion and the accompanying Memorandum, itis this __ day of February, 2018, hereby ORDERED that Defendant's Motion for a Protective Order is GRANTED; and it is further ORDERED that the Clerk of Court immediately substitute Plaintif?’s Complaint with the Complaint attached to Defendant’s Motion as Exhibit 1, which does not make reference to Defendant Laura Ingraham’s personal home address; and it is further ORDERED that no party is permitted to list Defendant Laura Ingraham’s personal home address in any filings made to this Court unless the information is redacted or filed under seal Dated: ‘The Honorable John M. Mott