PENNSYLVANIA RECORD

A former manager of creative services at a Northampton County-based advertising firm claims she endured approximately two years of sexual discrimination, harassment and retaliatory behavior from her supervisors before her wrongful termination in April 2013.

Dawn Motolese, of Schnecksville, Pa., seeks unspecified compensation against Viamedia and four supervisors working out of the company's Bethlehem, Pa., offices. The plaintiff claims that her civil rights were violated by the actions of Jeff Frank, Annette Zerbe, Todd Kuhn and Jerri Tacket and that the corporation negligently failed to step in and correct the hostile workplace created by the defendants.

According to the complaint, Motolese began working for Viamedia in October 2006 as a part-time office assistant and worked her way up to manager of creative services. Despite her positive performance reviews, the suit says, Motolese began to experience unwanted sexual harassment and discrimination from Frank, a sales director for the company.

The suit says that Frank would make disparaging remarks about overweight women and announce a "hottest fat chicks" contest. After her objections were ignored by Frank, Motolese reported the behavior in May 2012 to Zerbe, human resources manager for Viamedia. According to the complaint, no corrective actions were taken against Frank, who continued his behavior and began to retaliate against Motolese by berating her in front of other employees.

Motolese reported the behavior again in October 2012, the claim says, and allegedly told by Zerbe that she would need to get along with Frank and tolerate his behavior. The complaint says that Motolese continued to experience retaliatory and discriminatory actions by Frank, such as disparaging comments about her weight and the encouragement of other employees to harass the plaintiff.

The suit says that Motolese took her complaints to Kuhn, the general manager, and Tacket, human resources director at corporate headquarters in Kentucky. Instead of offering a remedial solution, the claim says, Tacket forwarded the complaint to Zerbe, who berated Motolese for going over her head.

Motolese's employment was terminated on April 2, 2014, with no warning or proper pretext, according to the complaint. The court document says that Viamedia still had a substantial need for the work provided by the plaintiff and fired her as retaliation for filing grievances against another employee, an action protected by federal and state statutes.

By failing to take proper actions against Frank, Viamedia and its executives allowed a hostile and discriminatory workplace to exist, the complaint says.

The plaintiff is represented by David Deratzian at Hahalis & Kounoupis in Bethlehem, Pa.

The federal case ID is 5:14-cv-06698-JLS.