STATE OF CONNECTICUTCOMMISSION ON HUMAN RIGHTS AND OPPORTUNITIES

AFFIDAVIT OF ILLEGAL DISCRIMINATORY PRACTICE

Date: CHRONo.:

My name is Shelly Sindlandand I reside at 44 Mayflower Street. West Hartford. CT 06110The respondent is Tribune Company d/b/a Fox 61 Newswhose business address is One Corporate Center. Hartford, CT 06103

I was• denied reasonable accommodation on the basis of as disability on or about_• terminated on or about • suspended on or about_• laid off on or about • not recalled on or about• demoted on or about • harassed on or about

X poorly evaluated on or about 6/12/09 • warned on or about

X sexually harassed on or about 1/8/09 and continuing • denied a raise on or about,X earning unequal pay on or about 1/8/09 and continuing O transferred on or about_X delegated unequal duties on or about 1/8/09 and continuing • not hired on or about.• placed on probation on or about • not promoted on or about• given reduced hours on or about • less trained on or about_• denied equal services on or about X retaliated against on or about 6/12/09 and

continuingX other deduction in pay on or about 6/14/09

and believe that my(x)age (d.o.b.) 4/28/69 (x)marital status single• physical disability • race• learning disability • color_• mental disability • national origin,• sexual orientation • ancestry• religion • alienage.(V)sex female • Pregnancy(x) having previously opposed discriminatory conduct • prior criminal record

was/were in part a factor(s) in this action. I believe that the respondent violated thefollowing Connecticut General Statutes and Acts listed below:

(x)46a-58(a) • 46a-60(a)(8)( )( ) (x) 46a-60(a)(4) (x)46a-60(a)(1)• 46a-60(a)(7) D46a-81( )( ) • 46a-70( ) • 46a-64(a)• 46a-80 • 46a-75(x) Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. 2000e and the Civil Rights Act

of 1991 {15 or more employees}(x) Age Discrimination in Employment Act, of 1967,29 U.S.C. 621-634 {20 or more employees and

over age 40 years old}• Americans With Disabilities Act, 42 U.S.C. 12101 et seq.• Rehabilitation Act of 1973(x) Equal Pay Act of 1964, U.S.C. 206 • Other

I provide the following particulars:

1. My name is Shelly Sindland. My mailing address is 44 Mayflower Street, West

Hartford, Connecticut 06110.

2. The respondent, the Tribune Company (hereinafter "Tribune") d/b/a Fox 61 News

(hereinafter "respondent", "Fox 61", or "the station"), is a Delaware corporation with a

headquarters and place of business located at One Corporate Center, Hartford,

Connecticut 06103.

3. The respondent employs more that 15 persons.

4. My date of birth is April 28, 1969 and I am forty (40) years old.

5. I am a woman who was discriminated against by the respondent based on my age (40),

based on my gender, and based on negative stereotypes about my gender, including my

status as an unmarried and single parent of a two-year old daughter.

6. I am a woman who was retaliated against by the respondent for engaging in the

protected activity of opposing the respondent's discriminatory practices and filing internal

complaints and participating in internal investigations with respect to that discriminatory

activity.

7. I have been employed by the respondent since approximately 1995 through the present,

as a Reporter. I have a degree in Communications/Journalism from Seton Hall University.

8.1 am the most senior Reporter at Fox 61 with more than fourteen years at the station and

more than eighteen years of total reporting experience. Throughout my career, I have

interviewed a wide variety of public figures, including former President Bill Clinton, Former

Senator Hillary Clinton, Former Vice President Al Gore, Senator and Former Presidential

candidate John McCain, Former President George H.W. Bush, the Queen of Jordan, actor

Christopher Reeve, Former Vice President Dick Cheney, and Former First Lady Laura

Bush.

9. In addition, throughout my career, I have covered many high-profile stories and also

have received several awards for my work. For example, in approximately 1996,1 reported

on the TWA Flight 800 Crash off Long Island. In approximately 1996 I reported on male

breast cancer and received a public service award from the Associated Press for my

coverage. In approximately 1997,1 pitched a story about Chernobyl and traveled there to

report on the efforts of a humanitarian group, and received an award forthat coverage from

the Society of Professional Journalists. In approximately 2000, I started a consumer

reporting program called "Shelly Show Me," which I developed and executed on my own

in order to test various consumer products and report on my results. In approximately

2003, I reported extensively on the corruption trial of Mayor Joe Ganim of Bridgeport and

received an award for that coverage from the Associated Press. In approximately 2004,1

reported on the plea agreement between the state and former Governor John Rowland

concerning charges made against Rowland. In 2005, I was selected as one of only five

reporters in the state to witness the execution of Michael Ross. I received an Associated

Press Award for my coverage of the Ross Execution.

10. In approximately 2005,1 became the respondent's political reporter, and have worked

in that capacity since. As the political reporter, I have been a guest on several occasions

on the Colin McEnroe political radio show which was broadcasted on WTIC-1080 AM.

11. Throughout my employment with the respondent, up to and including the present, I

have always carried out my responsibilities with dedication and loyalty. Until June 2009,

I have received consistently good performance reviews.

12. On or about June 27, 2005, Rich Graziano became the General Manager at Fox 61.

On or about March 30, 2009 Graziano was also named publisher of the Hartford Courant

which the Tribune Company owns.

13. Since January 2006, in addition to my weekly reporting responsibilities, I have been

the host of "Beyond the Headlines," a weekend political roundtable discussion news show

(now called "The Real Story"). Since on or about July 2007, I have been responsible for

much of the production duties for the weekend show. In or about September 2007, News

Director Bob Rockstroh and Assistant News Director Amy Fabozzi-Mattison informed me

that I could continue the show, but that I would receive no producers and would have to

produce the show on my own. I complained to Human Resources Director Hillary Patz

about the fact that I had no producers for this show, while Rick Hancock, the male reporter

in charge of the show immediately prior to my taking over the show, did have producers.

Since that conversation, up to and including the present, I have had to produce all of the

weekend shows on my own, with no outside support.

14. Throughout the winter of 2006, Graziano and I spent time together socially, including

going out for drinks and for dinner. I believed that these meetings were of a social, but not

romantic, nature. In late February 2006, however, I became concerned that my coworkers

may have believed the relationship to be romantic in nature, and approached Graziano with

that concern. Graziano's response was to tell me that "if anything were to happen, [I]

couldn't tell anyone."

15. In March 2006,1 complained during my contract negotiations that I believed that I was

being underpaid in comparison to my male counterparts. During the negotiations with

Graziano, I was offered a salary increase. In addition, Graziano stated that the respondent

had reviewed the pay scale and determined that as the longest-tenured reporter at the

station, I was indeed underpaid. Following negotiations, I signed a three-year contract with

the respondent, from June 2006 through June 2009.

16. Following contract negotiations, in June 2006, I disclosed to the respondents my

coworkers that I was pregnant and due to have a baby in December 2006. I was not

married when I got pregnant, at any time prior to getting pregnant, or at any time since

becoming pregnant.

17. During my pregnancy, Graziano joked to my coworkers that he was the father of my

baby. He was not the father of my baby. Graziano also told at least one other reporter to

start the rumor stating how "cool" it would be if the news reported that the General

Manager of the station got the Political Reporter pregnant. On a few occasions, I played

along with Graziano's statement in a joking manner, in part because I felt pressure to stay

in Graziano's good graces since he was my boss.

18. My daughter was born on or about December 18, 2006. I took maternity leave from

on or about December 18, 2006 through on or about April 9, 2007.

19. In April 2007, when I first returned from my maternity leave, my direct supervisor, Bob

Rockstroh, stated that I needed to stop telling people that Graziano was the father of my

baby and to stop e-mailing Graziano. I stated that I had not started that joke.

20. Following this April 2007 conversation with Rockstroh, including my return from

maternity leave and throughout the duration of my employment, I kept a greater distance

between myself and Graziano, including limiting personal communications outside the

workplace.

21. Throughout my maternity leave, I received phone calls, emails and text messages from

Graziano seeking to touch base and asking me to "give him a buzz." I received most of

these communications between 6 p.m.-11 p.m. I responded to many of these requests for

communication.

22. Several months following my return from maternity leave, in approximately fall 2007,

one of the respondent's photographers, Earl Glazier, told several people on more than one

occasion that I had gotten fat and that someone needed to tell me I was fat. When I was

told about this comment, I immediately went to Human Resources and filed a complaint

with Human Resources Manager Hillary Patz. On information and belief, no corrective

action was taken and I was required to continue working with Glazier.

23. Following the birth of my daughter, in approximately June 2007, the father of my baby

terminated his parental rights and was not and is not involved in my daughter's life at all.

24. On or about December 28, 2007,1 was informed by news Director Bob Rockstroh that

Laurie Perez, a reporter with no children and with less experience than me, would go to

Iowa to cover the Iowa Caucus. I had pitched this story several times. I asked Rockstroh

why, as the political reporter, I was not selected to go to Iowa, and I also expressed my

disappointment that Laurie, and not I, was selected to go. On or about December 31,

2007, Rockstroh replied that he and Assistant News Director Amy Fabozzi-Mattison had

not selected me because of "childcare issues," including that I had "stress" about getting

to the daycare center on time. I did not then, and do not now, have my daughter in a

daycare center.

25. On or about December 2007, Sam Zell became the President and Chief Executive

Officer of the Tribune Company. On or about January 2008, Zell sent a memo to

employees titled "The C-Word." On information and belief, the "c-Word" is a widely used

term in the news and media industry for the word "cunt," which is considered an incredibly

offensive term that reporters at the station have been instructed never to use. Zell's

January memo used the phrase "the c-word" throughout the memo, and the memo

expressed concern that station employees were using that term. The last sentence of the

memo stated that the "c-word" actually referred to the word "can't."

26. On or about January 18, 2008, the respondent distributed a memorandum to

employees titled "Creative Harassment." The memo contained examples of what

constitutes sexual harassment, and what does not. The memo stated: "Here's a copy of

the just-released 'Tribune Policy Manual & Employee Handbook," which goes out of its way

to (re) define 'Harassment, Sexual & Otherwise." Among other things, the new policy

stated "working at Tribune means accepting that sometimes you might hear a word that

you, personally, might not use. You might experience an attitude that you don't share.

You might hear a joke that you might not consider funny. That is because a loose, fun,

non-linear atmosphere is important to the creative process. This should be understood,

should not be a surprise and is not considered harassment. Harassment means that you

are being told that a raise, promotion or other benefit is dependent on you going on a date

with your boss or some other activity. . . . Some people don't know the line between

lighthearted fun and annoying behavior." On information and belief, the creative

harassment policy was one of many changes to the respondent's employee policy manual,

which included the statement: "Essentially, as of December 20, 2007, Tribune company

is a new company. Therefore, it's fair to give you some help understanding the new culture

we will be creating together, and how your judgment will be judged."

27. On or about February 6, 2008, Fabozzi-Mattison brought up an issue relating to the

biological father of my baby in front of me and my coworkers and asked me several very

personal questions regarding the situation. This was extremely embarrassing to me.

28. In approximately August 2008, I set up a facebook page that serves, among other

functions, as promotion for Fox 61. On information and belief, I was one of the first Fox

61 news reporter to set up a public facebook page without first being told to do so.

29. In approximately September 2008, I approached Rockstroh about my concerns that

the respondent was committing ethical violations related to receiving payment for news

stories. I was told by Rockstroh that "you are not going to win this one."

30. In approximately October 2008, I changed the name of my weekend news show to

"The Real Story." Despite my repeated requests, the station never promoted the show as

promised or per my suggestions in order for the show to receive better ratings. One of my

repeated suggestions and requests was that my show be moved to a better time slot, at

10 a.m. Sunday, which would follow national political show with Chris Wallace.

31. In approximately October 2008, in part due to my frustration with the station's lack of

promotion for "The Real Story," I started a blog, "Pampers and Politics." I update the blog

and add content on my free time and use a computer and other equipment that I

purchased. My blog coverage includes many Fox 61 promotions. On information and

belief, I was the first Fox 61 reporter to start a blog. To date, I have had approximately

50,000 "hits," or visitors, to my blog.

32. A few months after starting my blog, in approximately January 2009, twenty-six year

old reporter Jennifer Lahmers, who is frequently promoted by the respondent in her own

TV spots, started a blog called "Jen and the City." On information and belief, the

respondent hired a professional photographer to take pictures of Jennifer for her blog.

Despite my requests, I have never been professionally photographed for my blog. I take

all blog pictures with my personal digital camera.

33. In approximately January 2009, thirty eight-year old weekend anchor Laurie Perez was

removed as the weekend anchor and replaced by approximately twenty-three year old

Sarah French. On information and belief, Graziano stated to Perez that if Perez was upset

about the removal as weekend anchor, that she could quit, since Graziano could hire two

new younger reporters for Perez's salary.

34. On information and belief, French is a recent college graduate and former beauty

pageant competitor. On information and belief, in approximately February 2009, news

director Bob Rockstroh and General Manager Rich Graziano were showing male

employees bikini pictures of French from her pageant competitions.

35. On or about January 30, 2009, during a meeting with reporters and anchors, on

information and belief, Rockstroh stated that the Friday newscasts looked like "Big Boob

Fridays," and that as a result of at least one female reporter wearing a tighter shirts on

Fridays, the station's ratings did well on Fridays. On information and belief, Graziano was

present and stated "hey, whatever works."

36. On or about February 25, 2009 the respondent held a photo shoot for several of its

news anchors to be used in promotional pieces. During this shoot, on information and

belief, the female anchors were told to be more "sexy." On information and belief, male

anchors were not instructed to be sexy.

37. In approximately February 2009,1 again approached Rockstroh regarding my concerns

that the respondent was committing ethical violations related to receiving payment for news

stories.

38. On or about March 13, 2009, as required by my 2006-2009 contract with the

respondent, Rockstroh approached me regarding contract renegotiations. I asked about

the contract renewal process generally given the change in management and financial

circumstances with the respondent, and mentioned that I would be willing to take a pay

freeze given the tough economic times.

39. On or about March 14, 2009, I attended the Hartford St. Patrick's Day Parade on

behalf of the respondent. The station rented two convertibles to drive the two-mile long

parade route. I brought my daughter along with me to ride in the convertible through the

parade. When I arrived, new news anchor, Erika Arias, who is younger than I, was

directed by Rockstroh and promotions director Joseph Schiltz, to ride in the convertible

along with male weather reporter Garrett Argianas. I was instructed to walk the two mile

parade route holding my daughter. In addition and on information and belief, reporter

Laurie Perez, who was reporting on the event for the respondent, was instructed by Schiltz

to "concentrate on the newer girls" when the Fox 61 team passed by.

40. In approximately April 2009, I heard Rockstroh promise to give twenty-five year old

Rachel Frank a clothing allowance. During the past two years, I have asked the

respondent for clothing allowances. Prior to my daughters birth, I had received a one-time

clothing allowance. On information and belief, I am the only on-air female personality

without a clothing allowance.

41. On or about April 13, 2009, I once again approached Rockstroh regarding my

concerns that the respondent was committing ethical violations related to receiving

payment for news stories.

42. In approximately April 2009, then thirty-four year old weekday morning news anchor

Rebecca Stewart was removed as the weekday anchor and placed as the weekend

anchor, a program with less prestige. Stewart was replaced by twenty-three year old

French, who was moved from the weekend anchor spot to take Stewart's position. The

respondent stated publicly that Stewart chose to transfer to the weekend show in order to

spend more time with her son. On information and belief, Stewart never requested nor

wanted to be removed from the morning show, and indeed, considered the move to the

weekend show to be a major demotion.

43. On information and belief, prior to Stewart's removal as weekday morning anchor, on

or about March 2009, Stewart refused the respondent's directive that she appear on the

news as though she were naked as part of a promotional campaign for her news reporting

on April 1, but Stewart's male co-anchor was not asked to appear as though he were

naked on April 1. This request was referred to by the respondent as "Naked News."

44. On or about April 20,2009, on information and belief, news anchor Susan Christensen

was in the midst of contract renegotiations with the respondent. She stated to me: "Oh my

God, they want me gone...I'm sorry I got old." She further stated that she had received a

bad review after thirteen years of positive reviews. She additionally stated that the station

was asking her to take a significant pay cut.

45. Following my conversation with Christensen, on or about April 20,2009,1 approached

Rockstroh and asked him about the status of my contract, which was scheduled to expire

on June 14, 2009. I received no substantive response.

46. On or about May 1, 2009, I was notified by Human Resources Manager Hillary Patz

that a hostile work environment complaint had been filed against Fox 61. On information

and belief, the complaint was filed by a long-tenured female News Anchor greater than

forty years old.

47. On or about May 1, 2009, Patz asked me to participate in the hostile work environment

investigation and I agreed. During the investigation, Patz interviewed me and asked me

questions about many incidents. I answered candidly and truthfully, to the best of my

ability.

48. On or about May 1, 2009, during the investigation, Patz asked me whether I had felt

harassed by Graziano when, during 2006 and 2007, Graziano stated that he was the father

of my baby. I stated that I had felt "thrown under the bus by Graziano" and then felt that

he embarrassed and further harassed me by falsely accusing me of starting that rumor.

49. During the May 1st meeting, Patz also asked me whether I believed Fox 61 was a

hostile work environment. I answered in the affirmative, stating that I had never before felt

less valued at Fox 61, based in large part on my age and my gender. I then pointed to the

promotional "Meet the Team" poster, featuring Fox 61 news anchors Sarah French and

Erika Arias, and reporters Jennifer Lahmers and Rachel Lutzger. I told Patz that I was not

asked to be part of this "Meet the Team" promotion, and that the older women at the

station were not featured on the poster.

50. Also during the May 1st meeting, Patz also brought up the incident involving Glazier,

the photographer who called me fat following my return from maternity leave. Patz asked

me if I believed the situation was handled properly, and I stated that it was not. I also

stated, when asked by Patz, that Glazier had never apologized to me. Glazier is still

employed by the respondent.

51. On or about May 13,2009, the respondent, Tribune Company, received approval from

a Chapter 11 Bankruptcy judge to provided more than $13 million in bonuses to

approximately 700 employees. In addition, in May 2009, Fox 61 began construction of a

new, multi-million dollar state of the art studio at the Hartford Courant.

52. In approximately mid-May 2009, I approached Patz regarding my concerns that the

respondent was committing ethical violations related to receiving payment for news stories.

Patz stated to me that if she looked into the allegations, it would "only make matters worse

for [me]" and that she was "worried about my daughter and [me] and that [I] needed my

job."

53. On or about May 20, 2009, I emailed Rockstroh to inquire about the status of my

contract. Though Rockstroh indicated via email that he would give me a proposal the next

day, I did not receive a proposal the next day.

54. On or about May 23, 2009, I was the only local Connecticut reporter invited to the

White House Rose Garden to report on a bill signing regarding credit card reform act

legislation sponsored by Senator Christopher Dodd. That reporting was never used in any

type of promotional materials. I was never commended on or acknowledged in any way

for this invitation or my coverage of the event. On information and belief, at the same time

as this coverage, the station was running promotional spots for younger female reporters

as well as male reporters.

55. On or about June 5, 2009, Graziano sent a memo that announced that Patz had been

promoted to the Director of Human Resources for Fox 61-TV, our sister station WTXX, and

the Hartford Courant.

56. On or about June 11, 2009, I was notified via voice mail from Rockstroh that my

annual review was ready. Thereafter, on or about June 11, 2009, I wrote an email to

Fabozzi-Mattison and Rockstroh, and copied the email to Patz, Graziano and director of

content manager Jeffrey Levine stating my concerns about being given a review a few days

before my contract was set to expire, as well as my concerns that I had not received any

word on the status of my contract renewal or negotiations. I also stated my concern that

I was receiving my annual review in June when, on information and belief, I should have

received the review in December 2008.

57. On or about June 12, 2009, I was given orally my annual review from Fabozzi-

Mattison. Fabozzi-Mattison stated that my attitude is bad and that I complain. This review

was the first negative performance review I have received with the station and stands in

stark contrast to my 2006 and 2007 performance reviews that commend my role at the

station, including stating that I was a "true team player."

58. On or about June 14, 2009, my 2006-2009 contract expired without receipt of a new

contract from the respondent.

59. On or about June 15, 2009, Fox 61 announced that Christensen was leaving the

station on June 19,2009. The station announced that Christensen was leaving the station

because she wanted to spend more time with her family. This left me as the oldest female

reporter at Fox 61.

60. On or about June 15, 2009,1 was informed via email from programing supervisor Pete

DiMatteo that "The Real Story," my weekend show, was being moved from 8:30am on

Sunday to 10:30 a.m., after the newly created "The Stan Simpson Show," which would air

at 10 a.m. on Sundays, the time slot I have been asking the respondent to give me for "The

Real Story" for the past few years. Stan Simpson is a male reporter.

61. On or about June 17, 2009, two producers were assigned to work on "The Stan

Simpson Show".

62. On or about June 19, 2009, five days after the expiration of my prior contract, the

respondent gave me a new contract dated June 10, 2009 that included a significant pay

cut and only a one-year contract term. My former, three-year (2006-2009) contract

included a salary of $67,837 for June 2008-June 2009, and an additional $100 per show

for my work on "The Real Story" which could amount to an additional $5,200 per year. The

2009-2010 contract offered to me on June 19, 2009, provided for one year of work at

$60,000 per year. In addition, the new contract provided no additional funds for my work

on the weekend show, "The Real Story," but required me to continue my work as the host

of "The Real Story," as well as to continue to produce the show myself.

63. The contract provided to me by the respondent on or about June 19, 2009,

represented a pay cut of nearly $13,000, from approximately $73,000 per year to

approximately $60,000 per year - a nearly 18% cut in pay. In addition, the term of the

contract was one year, and not three years. I expressed my concern and surprise at the

significant pay cut, and told the respondent that the $13,000 cut would mean that I did not

have the money to cover childcare expenses for my daughter.

64. When I questioned Rockstroh on June 19, 2009 about the one-year term in my

contract, he stated that it was due to Chapter 11 bankruptcy proceedings. On information

and belief, however, Rockstroh offered a male reporter a three-year contract.

65. On or about July 6, 2009, the respondent announced that Erika Arias was selected

to be the permanent 10:00 p.m. co-anchor to replace Christensen. On information and

belief, Arias is approximately ten years younger than Christensen.

66. ! believe that the unequal treatment in terms and conditions of employment I have

experienced, including with respect to compensation, as well as the recent reduction of my

pay, were based upon: (1) My sex; (2) Gender stereotypes, including my marital status

(single; unmarried mother); (3) My age (40); and (4) In retaliation for my participation in and

initiation of internal investigations regarding the respondent's discriminatory employment

practices. As a result, the respondent has violated the Connecticut Fair Employment

Practices Act, Conn. Gen. Stat. Sec. 46a-60(a)(1), (a)(4), and (a)(9), etseq. .Title VII of the

Civil Rights Act of 1964, as amended, 42 U.S.C. Sec. 2000 et seq., and the Age

Discrimination in Employment Act (ADEA).

67. As a result of the respondent's discriminatory conduct, I have suffered lost wages and

benefits, and have experienced emotional distress.

I request the Connecticut Commission on Human Rights and Opportunities investigate mycomplaint, secure for me my rights as guaranteed to me under the above cited laws andsecure for me any remedy to which I may be entitled.

Shelly Sindland being duly sworn, on oath, states that she is the Complainant herein, thatshe has read the foregoing complaint and knows the content thereof; that the same is trueof her own knowledge, except as to the matter herein stated on information and belief andthat as to these matters she believes the same to be true.

Dated at Hartford, Connecticut this 7th day of July, 2009.

Complainant's Signature

Subscribed and sworn to before me this 7th day of July, 2009.

Commissioner of the Superior" C'burt