Christensen v. Howard & Howard

Case: 1:20-cv-05051 Document #: 1 Filed: 08/27/20 Page 1 of 19 PageID #:1
IN THE UNITED STATES DISTRICT

COURT FOR THE NORTHERN
DISTRICT OF ILLINOIS EASTERN
DIVISION
)
JENNIE CHRISTENSEN )
)
) Case No.: 20CV05051
Plaintiff )
)
v. )
)
HOWARD & HOWARD ATTORNEYS, )
PLLC )
)
)
Defendant. )
PLAINTIFF'S COMPLAINT AND JURY DEMAND
NOW COMES the Plaintiff, JENNIE CHRISTENSEN, by and through her
attorneys, PATRICOSKI LAW OFFICES and for her COMPLAINT AND JURY
DEMAND, alleges as follows:
I. INTRODUCTION
1. While working as a Summer Associate with Howard & Howard in the
summer of 2019, Plaintiff Jennie Christensen was subjected to sexual harassment
and gender discrimination. Plaintiff Christensen was then terminated from her
Summer Associate position and denied a full-time position in violation of Title VII
of the Civil Rights Act of 1964, as amended.
II. PARTIES
2. Plaintiff Christensen was a resident of the State of Illinois at the time
her claims arose. Howard and Howard employed ms. Christensen as a Summer
Associate at the time of her termination and simultaneous wrongful denial of
employment on 8/5/2019.
3. Defendant Howard & Howard Attorneys, PLLC is a Professional
Limited Liability Company, with its principal place of business located in the State
of Michigan and is registered in the State of Illinois with an office located in
Chicago, Illinois.
III. JURISDICTION AND VENUE
4. Jurisdiction is proper in this judicial district because Plaintiff
Christensen is alleging violations of her rights under Title VII of the Civil Rights
Act of 1964, as amended, 42 U.S.C. § 2000(e).
5. Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391(b).
A substantial part of the events or omissions giving rise to Plaintiff Christensen’s
claims occurred within the jurisdiction of The United States District Court For The
Northern District Of Illinois Eastern Division.
6. The United States Equal Employment Opportunity Commission has
issued a Notice of Right to Sue, which was received by the Plaintiff on June 9th,
2020, a copy of which is attached to this complaint.
7. Plaintiff Jennie Christensen has complied with all administrative,
jurisdictional, and legal prerequisites to the filing of this action.

8. GENERAL ALLEGATIONS
A. Background
9. Plaintiff Jennie Christensen is a 24-year-old female who recently
graduated from Notre Dame Law School.
10. On or about 7/24/2016, prior to committing to attend law school, Ms.
Christensen contacted Scott Levin of Howard & Howard Attorneys, PLLC
("Howard & Howard"), to express her desire to meet and discuss a possible future
career as an attorney. Shortly thereafter, Mr. Levin gave Ms. Christensen a tour of
Howard & Howard's Chicago offices. Upon reviewing Ms. Christensen's pre-law
school resume, Mr. Levin noted to colleague Phillip Crivellone, "[t]his is the
resume for the remarkable young woman I mentioned to you. If we have any work
opportunities that do not require law school training, I think she would be very
worth considering."
11. During her first year of law school, Ms. Christensen sought and was
granted an On-Campus Interview ("O.C.I.") with Howard & Howard.
12. Howard & Howard use the O.C.I.s as tools to identify and select
Summer Associates for the following summer. Howard & Howard treated the
Summer Associate position as a working job interview, and the position typically
ends with an End of Summer Review where it decides whether to offer the
Summer Associate a position as an Associate Attorney following the completion of
their final year of law school and subsequent bar exam passage.
13. On 8/10/2018, Ms. Christensen had an O.C.I. with Jane Hahn and
David Van Dyke from Howard & Howard and was subsequently invited for a
call-back interview on 8/27/2018.
14. Throughout the O.C.I. and her call-back interview, Ms. Christensen
stated that her professional interests included data and intellectual privacy law.
15. On 9/12/2018, Ms. Christensen was offered and accepted a Summer
Associate position at Howard & Howard's Chicago office, which was scheduled to
begin on 5/20/2019.
16. Ms. Christensen was one of three Summer Associates in the Chicago
office during the summer of 2019. The other two Summer Associates were both
males.
17. On reason and belief, Ms. Christensen was the only female Summer
Associate to be employed by Defendant Howard & Howard for a period of at least
eight (8) years.
B. Ms. Christensen Was Subjected To Gender Discrimination
18. Upon beginning her Summer Associate position with Howard &
Howard, Ms. Christensen was immediately subjected to a culture of gender
discrimination and bizarre bullying tactics by the firm. Specifically, on 5/22/2019,
during Ms. Christensen's first week of employment, Ms. Hahn informed Ms.
Christensen that she "liked [her] now much better than [she] did during the
interview process" and that she had initially shown a preference for another Notre

Dame candidate who was a male because "[She] was worried [Ms. Christensen]
would be ‘too competitive.'"
19. In addition to this gender-stereotypical comment, in the first week of
her employment, Ms. Christensen noticed the scarcity of female attorneys at the
firm. At the time she worked for Howard & Howard, Ms. Christensen observed
that, although there were six female attorneys in total at the Chicago office, all but
one (Ariane Janz) were partners and that, on any given day, only 2-3 other females
were present in the office, compared to over 30 male attorneys.
20. On or about 6/12/2019, less than a month into her employment,
Howard & Howard's attorney Jude Sullivan told Ms. Christensen that she was a
good fit at Howard & Howard because she was "like a dude in heels." On at least
three occasions during her employment, different Howard & Howard attorneys
told Ms. Christensen to avoid Mr. Sullivan because he is "our H.R. liability."
21. On 8/2/2019, the culture of gender-discrimination continued when
Sr. Partner Robert Ambrose asked Ms. Christensen to lunch. While at lunch Mr.
Ambrose indicated that he was avoiding being present at the office because his
secretary was about to be fired and then directed Ms. Christensen to go onto the
street and "take photos of the girls going to Lollapalooza" (a concert event that
typically attracts many young females) so he could send those photos to a friend of
his.
22. In addition to these overt acts, Ms. Christensen was treated hostilely
throughout her internship by Miram Burkland. Ms. Burkland, Firm Counsel and a

leading partner at Howard & Howard, was assigned to be Ms. Christensen's mentor.
Howard & Howard's website description for the Summer Associate position stated
that Summer Associates are matched with a mentor/supervising Attorney who
"provides constructive feedback to help improve their skills." However, in stark
contrast to the website, Ms. Burkland never once sought out Ms. Christensen to
check in, offer counsel, advise, or even initiate a casual conversation. Throughout
the summer, Ms. Burkalnd never provided meaningful feedback. Instead, she
chose to repeatedly provide bitter, negative, and underserved comments, paired
with suggestions that Ms. Christensen might not be competent enough to complete
the work at hand. Moreover, Ms. Burkland often refused to acknowledge Ms.
Christensen's presence or return a hallway greeting.
23. For example, on 7/15/2019, after receiving a stack of papers on her
desk with a note that simply read "come see me - MLB," (i.e., Miriam Burkland) Ms.
Christensen approached Ms. Burkland's office hoping to receive assignment
details. After inquiring if Ms. Burkland had time, Ms. Burkland responded, "No,"
and continued typing on her computer.
24. Additionally, on repeated occasions, Ms. Christensen arrived at her
office to find a stack of papers on her desk, with a stick note which merely said
“MLB” and with no instruction as to what her assignment was.
25. On another occasion during her internship, Ms. Burkland instructed
Ms. Christensen to "review" thousands of printed pages of documents, with no
other instructions. Shortly thereafter, Ms. Burkland "expressed disappointment" at
a typo on a single document and pointed at one of the hundreds of dates on
another page, a page which Ms. Burkland had instructed Ms. Christensen to ignore,
and stated "I looked up the date (e.g., Tuesday, March 15, 1982), it was a Monday,
not a Tuesday. I was expecting you to pick up on this stuff. That is the entire
reason I gave you this assignment to begin with."
26. Much like her dismissive behavior in person, Ms. Burkland also
disregarded and did not respond to countless emails sent by Ms. Christensen.
C. Ms. Christensen Had Nowhere To Turn
27. Ms. Christensen had no place to voice her complaints of
discrimination and hostility. Howard & Howard's employee website stated that
"any employee with concerns about discrimination in the workplace is encouraged
to bring these issues to the attention of the Firm's Director of Human Resources,
Firm Counsel, or C.E.O."
28. However, Howard & Howard does not have a "Director of Human
Resources" or any single individual with this role. Office Manager Phillip
Crivellone explicitly articulated to Ms. Christensen early on in the summer that he
did not handle conflicts on the legal side of the office.
29. Further, Mary Dirkes, perhaps the closest example of a human
resource person for the Summer Associates, stated in one of her earliest emails to
Ms. Christensen that Ms. Burkland was a "close friend" and would "be a fantastic
mentor." As such, Ms. Dirkes obviously could not help Ms. Christensen navigate
Ms. Burkland's hostilities in an unbiased fashion.

30. Finally, there can be little expectation of a Summer Associate
approaching Howard & Howard's C.E.O., Mark Davis, whom she had only met
once briefly and who worked in an office in a different state.
D. Ms. Christensen Performed Admirably
31. Despite being treated with hostility and despite having no functional
H.R. structure in place to voice her complaints, Ms. Christensen performed highly
during her employment. Ms. Christensen forged solid relationships with many
Attorneys, produced high caliber work that was relied upon and published by the
firm, and was assured by many that she was creating a work-product worthy of an
offer for a full-time position at the end of the summer. In fact, toward the end of
her employment, Mr. Levin expressed that he had “only heard good things around
the office” about Ms. Christensen.
32. Numerous attorneys expressed thanks to Ms. Christensen during her
employment for help on projects including Justin Gingerich, Jeff Barclay, Chase
Hundman, Michael Lied, and Leo Aubel. In fact, at an office meeting, in front of a
group of over a dozen Attorneys, Mr. Aubel told the group a story about how he
had recently gone to Court with an excel chart Ms. Christensen created for him
and, upon noticing her chart, the Court Clerk remarked about how good it was and
asked for a copy. Mr. Aubel expressed gratitude for such a helpful and
color-organized sheet and requested an additional print-out since the Clerk had
taken his only copy.
33. Additionally, Howard & Howard posted an article that Ms.
Christensen authored on the office web-page/blog and shared it multiple times on

LinkedIn (credit for the article was given to one of the firm's Partners, Mr. Michael
Lied who received the article from Ms. Christensen and did not change anything
whatsoever prior to the article's publication).
E. Howard & Howard Terminates Ms. Christensen And Denys Her

Future Employment For Pretextual Reasons
34. On 8/5/2019, at her End of Summer Review conducted by Ms.
Burkland, Ms. Christensen was informed that she was terminated from her
Summer Associate position (three days before it was scheduled to end) and that she
would not be receiving an offer for full-time employment as an Associate.
35. Howard & Howard's reasons for these two decisions were: poor work
quality, incomplete projects, and because the firm had no interest in going into
data privacy.
36. All three of these reasons are pretextual.
i. Pretextual Reason 1: Poor Work Quality
37. Ms. Burkland is the only Howard & Howard employee who rated Ms.
Christensen's work quality as poor. To that end, Ms. Burkland's examples of this
poor performance are limited to a single typo and an incorrect date that was not
caught on a document that Ms. Christensen was instructed to ignore. Significantly,
other than these two minor critiques, Ms. Christensen received no written
admonishment regarding her work or other behavior throughout the entire
internship.
38. On the contrary, Ms. Christensen's work product was praised
explicitly by other attorneys in the firm, and an article she drafted was published
to the firm's website.
ii. Pretextual Reason 2: Incomplete Projects
39. To support her allegation of incomplete projects, in the termination
meeting, Ms. Burkland offered only that the unfinished work product referred to a
single project due to Mary Corrigan, "which was never received." However, Ms.
Corrigan was clear in writing that Ms. Christensen had until her last day to
complete the project. Ms. Christensen had corresponded with Ms. Corrigan at least
twice during the summer to assure her that the project was in progress and that it
would be completed by her last day. Ms. Corrigan confirmed the same was
acceptable. The project was in progress, and its due date had not passed at the time
Ms. Burkland asserted that Ms. Christensen had not completed the work.
iii. Pretextual Reason 3: Howard & Howard’s Practice of Data Privacy
Law
40. Howard & Howard’s assertion that it had no interest in Data Privacy
Law is also pretextual.
41. Ms. Christensen expressed interest in pursuing data law to Howard &
Howard, including on her resume submitted for O.C.I. (including mention of
interest in GDPR and biometric scanning) and during her call-back interview
where, in multiple rounds of interviews, she outlined the GDPR and data privacy
work that she had completed during her 1L Summer Associate position at JetBlue
Airways.
42. Because the intention of hiring a Summer Associate is to determine
whether to offer that person an Associate Attorney position, if Howard & Howard
had not been interested in practicing Data Privacy Law, it defies logic that it would
hire Ms. Christensen as a Summer Associate.
43. Additionally, at the time it terminated Ms. Christensen, Howard &
Howard's website expressly indicated that it practiced Data Privacy Law.
Specifically, its website, which was updated approximately one month before Ms.
Christensen's termination, added an entirely new practice area titled "Data Privacy
& Cybersecurity." Within this new practice area section, Howard & Howard states
that the firm has "built a team of attorneys with training and experience in data
privacy in the United States and abroad, who can help businesses stay compliant
with the rapidly changing legal environment."
44. The newly created page also adds that Howard & Howard represents
"the industries that find themselves on the front lines of cyber threats and data
theft risks" and that the [Howard & Howard] works to "anticipate, address, avoid,
and mitigate risk" through services including data breach crisis management,
transnational transfers of data, and drafting of internal privacy policies. Finally, the
page notes that, through "forming a comprehensive team," Howard & Howard is
"able to provide guidance with laws both at home and abroad." The page concludes
with a sentence reading, "Privacy compliance is no longer a luxury, it is a legal
necessity. Clients depend on data privacy and cyber-security attorneys at Howard
& Howard to help navigate today's complex compliance landscape."
45. At the same time, it updated its website to include "Data Privacy &
Cybersecurity," Howard & Howard also changed its "General IP" section to include
the fact that it included a group of lawyers counseling and providing
representation on topics including "privacy and publicity rights."
46. At the same time it updated its website to include “Data Privacy &
Cybersecurity,” Howard & Howard also changed its website to add a Financial
Institutions Section indicating Howard & Howard's "dynamic, cross-functional
team of business and corporate […] data privacy […] and tax attorneys [...who] not
only ensure that transactions adhere to the letter and spirit of the law, but also
bring creative solutions to the table."
47. At the same time it updated its website to include “Data Privacy &
Cybersecurity,” Howard & Howard also changed its website to add a Media Section
featuring Howard & Howard attorneys commenting on and contributing to a wide
range of privacy-related news articles including topics such as privacy regulations,
the impact of cell phone selfies on privacy concerns, the Employee Credit Privacy
Act, privacy law court rulings, and annual privacy notice changes.
F. Howard and Howard Changed its Justification for

Terminating/Denying Employment to Ms. Christensen in its Position Statement
48. The reasons cited by Howard and Howard for the termination and
denial of employment to Ms. Christensen are demonstrably false.

49. In its position statement to the U.S. Equal Employment Opportunity
Commission, Defendant Howard and Howard presented an entirely different set
of justifications for why it terminated and denied employment to Ms. Christensen,
including altogether new references to:
a. Ms. Christensen "not being committed to building her career with
Howard and Howard."
b. Ms. Christensen "unprofessional behavior at a firm event."
c. Ms. Christensen expected too much from her mentor.
d. Ms. Christensen "improper alteration of treatise citation style."
e. Ms. Christensen "failed to meet reasonable expectations or engage in
the type of professional behavior expected of a summer associate."
f. Ms. Christensen was "not proactive with respect to actual work
assignments and soliciting feedback."
50. These new justifications offered subsequently and in contrast to the
initially provided justifications at the time of Ms. Christensen's wrongful
termination and denial of employment are all false and, therefore, pretextual.
G. Similarly Situated Male Interns Were Treated Differently
51. Unlike Ms. Christensen, the two male Summer Associates were
offered full-time employment.

52. The two male Summer Associates were offered full-time employment
notwithstanding the fact that, during their summer experiences, both of these male
employees had received written and verbal admonishments for a range of
problems, including unacceptable work and failure to integrate socially.
53. Specifically, one male Summer Associate received an admonishment
in writing that his work product was "completely unacceptable." On another
occasion, he had been sternly admonished at a firm social outing for making no
effort to engage socially. Additionally, he did not pass the Illinois bar on first
attempt, but was kept on for a year as intern until he finally passed.
54. This male was treated in stark contract with Ms. Christensen.
H. Howard & Howard’s Behavior Cause Harm To Ms. Christensen
55. Failing to secure an offer of future employment for a Summer
Associate is exceptionally harmful.
Associate is a rare event at Howard & Howard. Ms. Hahn told Ms. Christensen that
she can recall only two Summer Associates not receiving an offer during her
tenure. In those instances, it was clear very early on that the Summer Associate was
not a good fit.
Associate at Howard & Howard is a fact that becomes known generally in the legal
community.
58. The shame and reputational black eye associated with failing to secure
an offer of future employment for a Summer Associate at Howard & Howard
resulted in considerable reputational damage in Chicago and Notre Dame's
tight-knight legal communities.
59. To this end, Defendant Howard & Howard Partner Scott Levin has
recently suggested that Ms. Christensen pursue other career paths rather than
applying to law firms in Chicago.
CLAIMS FOR RELIEF
FIRST CLAIM FOR RELIEF

Sexual Harassment in Violation of Title VII

60. Plaintiff hereby incorporates Paragraphs 1 through 59 as though fully
alleged herein.
61. Ms. Christensen was subjected to inappropriate sexual behavior at
Defendant Howard and Howard’s Chicago Office.
62. The inappropriate sexual behavior was unwelcome and offensive.
63. The inappropriate sexual behavior was directed at Ms. Christensen
because of her gender.
64. The inappropriate sexual behavior was sufficiently severe and
pervasive to alter the conditions of Ms. Christensen’s employment by creating a
hostile work environment.

65. Defendant Howard and Howard and its agents knew or should have
known of the inappropriate sexual behavior and failed to take prompt and
corrective remedial action.
66. Defendant’s actions were willful and wanton and done with reckless
disregard for Ms. Christensen’s protected rights.
67. As a result of Defendant’s behavior, Ms. Christensen has suffered
damages.
SECOND CLAIM FOR RELIEF

Sex Discrimination in Violation of Title VII

alleged herein.
69. As a woman, Ms. Christensen is a member of a protected class.
70. During her employment, Ms. Christensen was subjected to gender
discrimination, including being subjected to a hostile work environment and
adverse actions, including but not limited to, harassment, humiliation, and
meaningless tasks and being terminated.
71. Ms. Christensen was treated less favorably than her male counterparts.
72. The hostile work environment and adverse actions taken against Ms.
Christensen were motivated by her gender.

73. Defendant's actions, as described herein, were willful and wanton and
done with reckless disregard for Ms. Christensen's protected rights.
74. As a result of Defendant's discriminatory conduct, Ms. Christensen
has suffered damages.
FOURTH CLAIM FOR RELIEF

Denial of Employment in Violation of Title VII

alleged herein.
76. As a woman, Ms. Christensen is a member of a protected class.
77. During her employment, Ms. Christensen was subjected to gender
discrimination, including being subjected to a hostile work environment and
adverse actions, including but not limited to, harassment, humiliation, and
meaningless tasks and being terminated.
78. Ms. Christensen was treated less favorably than her male counterparts.
79. The hostile work environment and adverse actions taken against Ms.
Christensen were motivated by her gender.
80. Ms. Christensen was denied employment as a result of her gender.
81. Defendant's actions, as described herein, were willful and wanton and
done with reckless disregard for Ms. Christensen's protected rights.

82. As a result of Defendant's discriminatory conduct, Ms. Christensen
has suffered damages.
WHEREFORE Plaintiff Christensen respectfully requests that this Court
enter judgment in her favor and against the Defendants an award
1. injunctive and declaratory relief;
2. damages in such an amount as shall be proven at trial for back-pay
and damages including lost benefits, wages, promotions, tenure,
seniority, other employment opportunities, and contract damages;
3. an order for the Defendant to reinstate Ms. Corio or in the alternative
to pay front-pay and benefits, including lost benefits in an
appropriate amount;
4. compensatory damages, including emotional distress as allowed by
law;
5. punitive damages under Title VII;
6. attorney’s fees and costs as provided for by law;
7. pre- and post-judgment interest, costs, expert witness fees; and
8. such other relief as the Court deems just and proper.
PLAINTIFF REQUESTS A TRIAL BY JURY ON ALL ISSUES.
Respectfully Submitted:
Patricoski Law Offices
_______________________
Mark G. Patricoski
one of plaintiff’s attorneys
Patricoski Law Office

Mark G. Patricoski
Gregory A. Patricoski
1755 S. Naperville Rd. #206
Wheaton, Illinois 60189
Office (630)-933-8000
Fax: (630) 933-8000
mark@markpatlaw.com

Case: 1:20-cv-05051 Document #: 1-1 Filed: 08/27/20 Page 1 of 1 PageID #:20
ILND 44 (Rev. 09/07/18) CIVIL COVER SHEET
The ILND 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose
of initiating the civil docket sheet. (See instructions on next page of this form.)
I. (a) PLAINTIFFS DEFENDANTS
JENNIE CHRISTENSEN HOWARD & HOWARD ATTORNEYS,PLLC
(b) County of Residence of First Listed Plaintiff Cook County, IL County of Residence of First Listed Defendant
(Except in U.S. plaintiff cases) (In U.S. plaintiff cases only)
Note: In land condemnation cases, use the location of the tract of land involved.
(c) Attorneys (firm name, address, and telephone number) Attorneys (if known)
Mark G. Patricoski
1755 S. Naperville Rd. Suite 206, Wheaton IL 60189
II. BASIS OF JURISDICTION (Check one box, only.) III. CITIZENSHIP OF PRINCIPAL PARTIES (For Diversity Cases Only.)
(Check one box, only for plaintiff and one box for defendant.)
1 U.S. Government ■ 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government not a party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business in This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate citizenship of parties in Item III.) of Business in Another State
Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
IV. NATURE OF SUIT (Check one box, only.)
CONTRACT TORTS PRISONER PETITIONS LABOR OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 510 Motions to Vacate Sentence 710 Fair Labor Standards Act 375 False Claims Act
120 Marine 310 Airplane 530 General 530 General 720 Labor/Management Relations 376 Qui Tam (31 USC 3729 (a))
130 Miller Act 315 Airplane Product 367 Health Care/ 535 Death Penalty 740 Railway Labor Act 400 State Reapportionment
140 Negotiable Instrument Liability Pharmaceutical 751 Family and Medical 410 Antitrust
150 Recovery of Overpayment 320 Assault, Libel & Slander Personal Injury 540 Mandamus & Other Leave Act 430 Banks and Banking
& Enforcement of Judgment 330 Federal Employers’ Product Liability 550 Civil Rights 790 Other Labor Litigation 450 Commerce
151 Medicare Act Liability 368 Asbestos Personal Injury 555 Prison Condition 791 Employee Retirement 460 Deportation
152 Recovery of Defaulted Student 340 Marine Product Liability 560 Civil Detainee – Conditions Income Security Act 470 Racketeer Influenced and
Loans (Excludes Veterans) 345 Marine Product Liability of Confinement Corrupt Organizations
153 Recovery of Veteran’s Benefits 350 Motor Vehicle 480 Consumer Credit
160 Stockholders’ Suits 355 Motor Vehicle PERSONAL PROPERTY PROPERTY RIGHTS 485 Telephone Consumer
190 Other Contract Product Liability 370 Other Fraud 820 Copyrights Protection Act (TCPA)
195 Contract Product Liability 360 Other Personal Injury 371 Truth in Lending 830 Patent 490 Cable/Sat TV
196 Franchise 362 Personal Injury - 380 Other Personal 835 Patent – Abbreviated 850 Securities/Commodities/
Medical Malpractice Property Damage New Drug Application Exchange
385 Property Damage 840 Trademark 890 Other Statutory Actions
Product Liability 891 Agricultural Acts
893 Environmental Matters
REAL PROPERTY CIVIL RIGHTS BANKRUPTCY FORFEITURE/PENALTY SOCIAL SECURITY 895 Freedom of Information Act
210 Land Condemnation 440 Other Civil Rights 422 Appeal 28 USC 158 625 Drug Related Seizure 861 HIA (1395ff) 896 Arbitration
220 Foreclosure 441 Voting 423 Withdrawal 28 USC 157 of Property 21 USC 881 862 Black Lung (923) 899 Administrative Procedure
230 Rent Lease & Ejectment ■ 442 Employment 690 Other 863 DIWC/DIWW (405(g)) Act/Review or Appeal of
240 Torts to Land 443 Housing/ 864 SSID Title XVI Agency Decision
245 Tort Product Liability Accommodations IMMIGRATION 865 RSI (405(g)) 950 Constitutionality of
290 All Other Real Property 445 Amer. w/Disabilities - 462 Naturalization State Statutes
Employment Application
446 Amer. w/Disabilities - 463 Habeas Corpus - Alien FEDERAL TAXES
Other Detainee (Prisoner Petition) 870 Taxes (U.S. Plaintiff
448 Education 465 Other Immigration or Defendant)
Actions 871 IRS—Third Party
26 USC 7609
V. ORIGIN (Check one box, only.)

1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation Litigation
(specify) Direct File
VI. CAUSE OF ACTION (Enter U.S. Civil Statute under which you are filing and VII. PREVIOUS BANKRUPTCY MATTERS (For nature of suit 422 and 423, enter the
write a brief statement of cause.) case number and judge for any associated bankruptcy matter previously adjudicated by a judge of this Court.
Use a separate attachment if necessary.)
Title VII of the Civil Rights Act of 1964
VIII. REQUESTED IN Check if this is a class action Under rule 23, Demand $ Check Yes only if demanded in complaint.
COMPLAINT: F.R.CV.P. Jury Demand: Yes No
IX. RELATED CASE(S) (See instructions)
IF ANY Judge Case Number
X. Is this a previously dismissed or remanded case? Yes No If yes, Case # Name of Judge
Date Signature of attorney of record
Case: 1:20-cv-05051 Document #: 1-2 Filed: 08/27/20 Page 1 of 1 PageID #:21
EEOC Form 161-B (11/16) U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
NOTICE OF RIGHT TO SUE (ISSUED ON REQUEST)

To: Jennie Christensen From: Chicago District Office
c/o Gregory A. Patricoski 230 S. Dearborn
Patricoski Law Offices Suite 1866
1755 S. Naperville Rd., Suite 206 Chicago, IL 60604
Wheaton, IL 60189
On behalf of person(s) aggrieved whose identity is

CONFIDENTIAL (29 CFR §1601.7(a))
EEOC Charge No. EEOC Representative Telephone No.
Marina Ravelo,
440-2019-07593 Investigator (312) 872-9746
(See also the additional information enclosed with this form.)
NOTICE TO THE PERSON AGGRIEVED:
Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act (ADA), or the Genetic Information Nondiscrimination
Act (GINA): This is your Notice of Right to Sue, issued under Title VII, the ADA or GINA based on the above-numbered charge. It has
been issued at your request. Your lawsuit under Title VII, the ADA or GINA must be filed in a federal or state court WITHIN 90 DAYS
of your receipt of this notice; or your right to sue based on this charge will be lost. (The time limit for filing suit based on a claim under
state law may be different.)
More than 180 days have passed since the filing of this charge.
X Less than 180 days have passed since the filing of this charge, but I have determined that it is unlikely that the EEOC will
be able to complete its administrative processing within 180 days from the filing of this charge.
X The EEOC is terminating its processing of this charge.
The EEOC will continue to process this charge.
Age Discrimination in Employment Act (ADEA): You may sue under the ADEA at any time from 60 days after the charge was filed until
90 days after you receive notice that we have completed action on the charge. In this regard, the paragraph marked below applies to
your case:
The EEOC is closing your case. Therefore, your lawsuit under the ADEA must be filed in federal or state court WITHIN
90 DAYS of your receipt of this Notice. Otherwise, your right to sue based on the above-numbered charge will be lost.
The EEOC is continuing its handling of your ADEA case. However, if 60 days have passed since the filing of the charge,
you may file suit in federal or state court under the ADEA at this time.
Equal Pay Act (EPA): You already have the right to sue under the EPA (filing an EEOC charge is not required.) EPA suits must be brought
in federal or state court within 2 years (3 years for willful violations) of the alleged EPA underpayment. This means that backpay due for
any violations that occurred more than 2 years (3 years) before you file suit may not be collectible.
If you file suit, based on this charge, please send a copy of your court complaint to this office.
On behalf of the Commission
Nanisa Pereles
Digitally signed by Nanisa Pereles
DN: cn=Nanisa Pereles, o=EEOC, ou,
email=nanisa.pereles@eeoc.gov, c=US
Date: 2020.06.09 07:01:05 -05'00' For 06/09/2020
Enclosures(s) Julianne Bowman, (Date Mailed)
District Director
cc: HOWARD & HOWARD ATTORNEYS PLLC

c/o Mark Davis
450 W. 4th St.
Royal Oak, MI 48067

Christensen v. Howard &amp; Howard

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Christensen v. Howard &amp; Howard

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Case: 1:20-cv-05051 Document #: 1 Filed: 08/27/20 Page 1 of 19 PageID #:1

IN THE UNITED STATES DISTRICT

PLAINTIFF'S COMPLAINT AND JURY DEMAND

DEMAND,​ alleges as follows:

1. While working as a Summer Associate with Howard & Howard in the

Summer Associate position and denied a full-time position in violation of Title VII

of the Civil Rights Act of 1964, as amended.

3. Defendant Howard & Howard Attorneys, PLLC is a Professional

Limited Liability Company, with its principal place of business located in the State

III. JURISDICTION AND VENUE

4. Jurisdiction is proper in this judicial district because Plaintiff

Act of 1964, as amended, 42 U.S.C. § 2000(e).

5. Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391(b).

claims occurred within the jurisdiction of The United States District Court For The

Northern District Of Illinois Eastern Division.

6. The United States Equal Employment Opportunity Commission has

2020, a copy of which is attached to this complaint.

7. Plaintiff Jennie Christensen has complied with all administrative,

jurisdictional, and legal prerequisites to the filing of this action.

9. Plaintiff Jennie Christensen is a 24-year-old female who recently

graduated from Notre Dame Law School.

granted an On-Campus Interview ("O.C.I.") with Howard & Howard.

Summer Associate a position as an Associate Attorney following the completion of

call-back interview on 8/27/2018.

eight (8) years.

B. Ms. Christensen Was Subjected To Gender Discrimination

interview process" and that she had initially shown a preference for another Notre

would be ‘too competitive.'"

one (Ariane Janz) were partners and that, on any given day, only 2-3 other females

were present in the office, compared to over 30 male attorneys.

21. On 8/2/2019, the culture of gender-discrimination continued when

typically attracts many young females) so he could send those photos to a friend of

throughout her internship by Miram Burkland. Ms. Burkland, Firm Counsel and a

that Summer Associates are matched with a mentor/supervising Attorney who

Christensen's presence or return a hallway greeting.

Christensen approached Ms. Burkland's office hoping to receive assignment

and continued typing on her computer.

“MLB” and with no instruction as to what her assignment was.

other instructions. Shortly thereafter, Ms. Burkland "expressed disappointment" at

another page, a page which Ms. Burkland had instructed Ms. Christensen to ignore,

reason I gave you this assignment to begin with."

C. Ms. Christensen Had Nowhere To Turn

"any employee with concerns about discrimination in the workplace is encouraged

Firm Counsel, or C.E.O."

Crivellone explicitly articulated to Ms. Christensen early on in the summer that he

did not handle conflicts on the legal side of the office.

Ms. Burkland's hostilities in an unbiased fashion.

once briefly and who worked in an office in a different state.

D. Ms. Christensen Performed Admirably

her employment, Mr. Levin expressed that he had “only heard good things around

the office” about Ms. Christensen.

and, upon noticing her chart, the Court Clerk remarked about how good it was and

taken his only copy.

Christensen authored on the office web-page/blog and shared it multiple times on

LinkedIn (credit for the article was given to one of the firm's Partners, Mr. Michael

whatsoever prior to the article's publication).

E. Howard & Howard Terminates Ms. Christensen And Denys Her

would not be receiving an offer for full-time employment as an Associate.

36. All three of these reasons are pretextual.

i. Pretextual Reason 1: Poor Work Quality

caught on a document that Ms. Christensen was instructed to ignore. Significantly,

to the firm's website.

ii. Pretextual Reason 2: Incomplete Projects

meeting, Ms. Burkland offered only that the unfinished work product referred to a

Christensen v. Howard & Howard

Christensen v. Howard & Howard

DEMAND, alleges as follows: