Professional Documents
Culture Documents
Justin Q101
Justin Q101
Justin Q101
Law Division Motion Section Initial Case Management Dates for CALENDARS Jury will be heard In Person.
All other Law Division Initial Case Management Dates will be heard via Zoom
For more information and Zoom Meeting IDs go to https.//www.cookcountycourt,org/HOME?Zoom-Links?Agg4906_SelectTab/12
Court Date: 2/15/2024 9:30 AM FILED
12/12/2023 5:56 PM
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS IRIS Y. MARTINEZ
CIVIL DEPARTMENT, LAW DIVISION CIRCUIT CLERK
COOK COUNTY, IL
FILED DATE: 12/12/2023 5:56 PM 2023L012576
2023L012576
JUSTIN NETTLEBECK ) Calendar, S
) 25571738
)
) Case No.
Plaintiff, )
)
v. )
)
)
CUMULUS MEDIA, INC. ) JURY TRIAL DEMANDED
)
)
Defendant. )
__________________________________________)
COMPLAINT
“Nettlebeck”), by and through his attorneys, LÁZARO LAW GROUP, LLC., and for his
NATURE OF ACTION
This action challenges pervasive sexual harassment and retaliatory practices at Cumulus.
While employed by Defendant, Plaintiff was subjected to harassment and discriminatory treatment
on the basis of his gender, including sexual harassment, as well as retaliation based on his
opposition to the harassment and discrimination he suffered. After Plaintiff complained and/or
employment.
3. This Court has jurisdiction pursuant to 735 ILCS 5/2-209 in that all of the events
FILED DATE: 12/12/2023 5:56 PM 2023L012576
which form the underlying basis for this complaint took place in Cook County, Illinois.
4. Venue is proper in Cook County because all of the events which form the
underlying basis for this complaint took place in Cook County, Illinois, and Defendant resides and/
5. Plaintiff timely filed charges with the Equal Employment Opportunity Commission
6. On or about September 14, 2023, the IDHR sent Plaintiff notice of his Right to Sue.
7. As Plaintiff received notice from the IDHR, he has fully complied with the
PARTIES
8. Plaintiff most recently held the title of Host/Executive Producer at Cumulus before
Plaintiff was featured, at an office at 455 N. Cityfront Plaza Dr. #600, Chicago, IL 60611.
FACTUAL ALLEGATIONS
10. Nettlebeck worked for the Defendant from approximately November of 2018 until
approximately April 2023 as an Executive Producer and performed his job in a reasonable and
11. Throughout his employment Defendant subjected Plaintiff to severe and pervasive
harassment and retaliation on the basis of his gender, including but not limited to, inappropriate,
unwanted, and sexually based comments, providing less access to resources such as ad revenue
2
and support from the production team that negatively impacted Plaintiff’s ability to perform his
duties, subjecting Plaintiff to employment decisions that negatively affected his pay and/or his
FILED DATE: 12/12/2023 5:56 PM 2023L012576
ability to earn his ratings bonus, and intimidating Plaintiff with remarks and gestures intended to
cause fear of physical harm. Defendant did not treat female employees in a similar manner.
12. During his employment with Defendant, Nettlebeck reported directly to the Vice
13. Almost immediately upon beginning to work with Hanson, Nettlebeck observed
that Hanson was openly abusive and discriminatory, and that Defendant did nothing to discourage
or inhibit his behavior—in fact, he was allowed to retaliate against any employee that opposed his
a. Hanson made graphic, sexual remarks regarding female employees and Hanson’s
including but not limited to, “have you guys noticed that my voice is shot today?
It’s from eating so much pussy this weekend,” and stating that he needed to go
home to “clean up all the blood” after “having sex with a girl on her period last
b. Hanson referred to Nettlebeck with offensive, sex-based insults, including the word
“faggot.”
c. Hanson showed sexually explicit materials to Nettlebeck against his will while he
was on air, attending work functions, or otherwise unable to leave the situation;
3
15. Hanson’s behaviors towards Nettlebeck were unwanted and Nettlebeck protested
them on multiple occasions. Specifically, Nettlebeck reported Hanson’s behavior to Marv Nyren
FILED DATE: 12/12/2023 5:56 PM 2023L012576
(“Nyren”), Vice President and Market Manager of Cumulus Media Chicago Operations on at least
six (6) occasions, in or about March 2020, November 2020, July 2021, August 2021, March 2022,
16. Following Nettlebeck’s various complaints, Nyren, and Cumulus generally, failed
to take any action whatsoever to stop Hanson’s behavior. In fact, Hanson’s behavior only escalated
as he was allowed to retaliate against Nettlebeck for complaining about his behavior. On various
a. threatened to kill himself if Nettlebeck reported him to human resources for his
behavior;
b. withholding funding and resources from Nettlebeck and his show such that his
impacted;
and therefore Nettlebeck’s complaints would never put a stop to his behavior;
proximity with a closed fist, suggesting that he might punch or hit Nettlebeck if he
e. harassing Nettlebeck about his work and/or performance, including during live
4
17. Hanson’s discriminatory and retaliatory behaviors targeting Nettlebeck reached a
breaking point in April of 2023, when Nettlebeck had no choice but to resign his position, as he
FILED DATE: 12/12/2023 5:56 PM 2023L012576
18. The Illinois Human Rights Act, as amended, makes it unlawful to discriminate
against any individual in the terms, conditions, or privileges of employment on the basis of sex.
19. Here, as set forth above, Defendant allowed Plaintiff to be sexually harassed and
discriminated against on the basis of his sex and allowed its employees (including but not limited
to Hanson, the Plaintiff’s supervisor) to create a hostile work environment by subjecting the
20. Additionally, Defendant failed to take adequate action to stop the harassment
21. WHEREFORE, the Plaintiff requests the entry of judgment in his favor and against
the Defendant, in an amount in excess of this Court’s jurisdictional minimum, plus costs and fees.
22. The Illinois Human Rights Act makes it unlawful for an employer to discriminate
and/or harassment.
24. Defendant retaliated against Plaintiff for his complaints in violation of the Illinois
5
WHEREFORE, the Plaintiff requests the entry of judgment in his favor and against the
a. All wages and benefits he would have received but for the discrimination;
b. Compensatory damages;
c. An award of costs;
____________________________
Rafael E. Lázaro
Catherine Roland
rlazaro@lazarolawgroup.com
croland@lazarolawgroup.com