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Charging Party alleges that on or about, January 6, 2016, she received her civil service
appointment as Police Officer, Police Department City of New York.

Charging Party alleges that the terms of conditions of employment included the successful
completion of a two-year supervised probationary period.

Charging Party alleges that the successful completion of a two-year supervised probationary
period is contingent upon Respondent THE CITY OF NEW YORK through its agent
supervisors' approval.

Charging Party alleges that on or about July 6, 2016, after successfully completing the Recruit
Training School aka Police Academy, Respondent THE CITY OF NEW YORK transferred her
to the Housing Bureau Police Service Area No.: 5.

Charging Party alleges that Respondent ERIC HERNANDEZ (Commanding Officer), assigned
her to Squad B-2, supervised by Respondent MATTHEW WEINBERGER (Sergeant — Squad B-
2).

Charging Party alleges that shortly thereafter, she noticed Respondent JOHNATHAN BLATT
(Lieutenant, Second Platoon Commander) giving her 'too much attention.'

Charging Party alleges that shortly thereafter, she noticed Respondent JOHNATHAN BLATT
(Lieutenant, Second Platoon Commander) giving Police Officer Ariana Ortiz 'too much
attention.'

Charging Party alleges that on or about January 29, 2017, acting as agent of Respondent THE
CITY OF NEW YORK, Respondent JOHNATHAN BLATT handpicked she and Police Officer
Ariana Ortiz, then post changed them to work an outside detail with him.

Charging Party alleges that on or about February 15, 2017, Respondent JOHNATHAN BLATT
handpicked her to perform her police duties as his Operator in a marked police vehicle.

Charging Party alleges that as Operator, requires her to drive Respondent JOHNATHAN
BLATT on patrol within Police Services Area No.: 5, area of responsibility.

Charging Party alleges that although she felt uncomfortable, she did not complain about
Respondent JOHNATHAN BLATT giving her "too much attention" because she was on
probation and afraid of retaliation.

Charging Party alleges that while performing her duties as Operator, Respondent JOHNATHAN
BLATT asked, "Hey, would you ever have a threesome? It is ok because my wife gave me the
go ahead."

Charging Party alleges that although she felt mortified, she did not complain about Respondent
JOHNATHAN BLATT'S sexually offensive conduct because she was on probation and afraid of
retaliation.
Charging Party alleges that shortly thereafter, Respondent JOHNATHAN BLATT handpicked
her to perform her police duties as his Operator in a marked police vehicle.

Charging Party alleges that although she felt uncomfortable, she did not complain about
Respondent JOHNATHAN BLATT giving her "too much attention" because she was on
probation and afraid of retaliation.

Charging Party alleges that while performing her duties as Operator, Respondent JOHNATHAN
BLATT asked her "Would you ever give a `Blumpkin.' According to Respondent
JOHNATHAN BLATT, a `Blumpkin' is performing a blow job while seated on the toilet.

Charging Party alleges that although she felt mortified, she did not complain about Respondent
JOHNATHAN BLATT'S sexually offensive conduct because she was on probation and afraid of
retaliation.

Charging Party alleges that shortly thereafter, Respondent JOHNATHAN BLATT handpicked
her to perform her police duties as his Operator in a marked police vehicle.

Charging Party alleges that although she felt uncomfortable, she did not complain about
Respondent JOHNATHAN BLATT giving her "too much attention" because she was on
probation and afraid of retaliation.

Charging Party alleges that while performing her duties as Operator, Respondent JOHNATHAN
BLATT, he commented about Police Officer Ariana Ortiz's "nice ass that really fills out those
administrative pants."

Charging Party alleges that although she felt mortified, she did not complain about Respondent
JOHNATHAN BLATT'S sexually offensive conduct because she was on probation and afraid of
retaliation.

Charging Party alleges that on or about February 22, 2017, Respondent JOHNATHAN BLATT
handpicked her to perform her police duties as his Operator in a marked police vehicle.

Charging Party alleges that although she felt uncomfortable, she did not complain about
Respondent JOHNATHAN BLATT giving her "too much attention" because she was on
probation and afraid of retaliation.

Charging Party alleges that while performing her duties as Operator, Respondent JOHNATHAN
BLATT ordered her to drive him outside of the Police Service Area No.: 5, area of responsibility
to a dentist located in Manhattan for a cleaning.

Charging Party alleges after some time, Respondent JOHNATHAN BLATT re-entered the
marked police vehicle and moved closely to her face, asking, "If his teeth look good." He also
commented, the female dental staff found him to be sexy.

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Charging Party alleges that although she felt mortified, she did not complain about Respondent
JOHNATHAN BLATT'S sexually offensive conduct because she was on probation and afraid of
retaliation.

Charging Party alleges that on or about April 20, 2017, Respondent JOHNATHAN BLATT
handpicked Police Officer Kenneth Darlington to perform his police duties as his Operator in a
marked police vehicle. She seated in the rear passenger seat.

Charging Party alleges that although she felt uncomfortable, she did not complain about
Respondent JOHNATHAN BLATT giving her "too much attention" because she was on
probation and afraid of retaliation.

Charging Party alleges that while performing her duties, Respondent JOHNATHAN BLATT
asked her, "Have you ever had sex with a Black Man?"

Charging Party alleges that Respondent JOHNATHAN BLATT then turned to Police Officer
Kenneth Darling and asked, "Maresca looks like she can take a horse cock, right?"

Charging Party alleges that although she and Police Officer Kenneth Darlington both felt
mortified, they did not complain about Respondent JOHNATHAN BLATT'S sexually offensive
conduct because they were on probation and afraid of retaliation.

Charging Party alleges that shortly thereafter, while inside of Police Service Area No.: 5,
Respondent JOHNATHAN BLATT acting as the Desk Officer, in front of other police
supervisors commented, "Maresca, it looks like you are putting on weight and filling out your
administrative pants nicely."

Charging Party alleges while visibly upset yelled, "Can you just fucking not!"

Charging Party alleges that the other police supervisors did not intervene.

Charging Party alleges that the other police supervisors did not notify the NYPD Office of
Equity and Inclusion or the Internal Affairs Bureau as required by department policy.

Charging Party alleges that although she felt mortified, she did not complain about Respondent
JOHNATHAN BLATT'S sexually offensive conduct because she was on probation and afraid of
retaliation.

Charging Party alleges that she began contemplating resigning from the NYPD.

Charging Party alleges that on or about August 12, 2017, in retaliation for continually refusing
Respondent JOHNATHAN BLATT'S sexually offensive conduct, ordered Respondent
MATTHEW WEINBERGER to assign her an arrest of a violent Emotionally Disturbed Person
(EDP).

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Charging Party alleges that Respondent MATTHEW WEINBERGER told her, "I am sorry but, I
have to give it to you."

Charging Party alleges that upon arrival at Police Service Area No.: 5, Respondent
JOHNATHAN BLATT acting as the Desk Officer, in front of other police supervisors
commented," I hope you learned your lesson."

Charging Party alleges that the EDP eventually became so violent, immobilized using the
Emergency Services Unit and transported to Bellevue.

Charging Party alleges that while assigned to guard the EDP, the EDP assaulted her.

Charging Party alleges that on or about August 14, 2017, in further retaliation for continually
refusing Respondent JOHNATHAN BLATT'S sexually offensive conduct, he commented, "I
have a fun job for you, your girl misses you."

Charging Party alleges that Respondent JOHNATHAN BLATT then ordered Respondent
DEREON U. WILLIS to assign her to transport the EDP from Bellevue to Elmhurst.

Charging Party alleges that she immediately contacted Police Benevolent Association Delegate
Police Officer Johnathan Kelly, while hysterically crying she disclosed Respondent
JOHNATHAN BLATT'S sexually offensive conduct and requested information about her rights
to file for resignation.

Charging Party alleges that shortly thereafter, Police Officer Johnathan Kelly referred her to
Respondent SARAH RAMOS-TILLMAN (Equal Employment Opportunity Liaison).

Charging Party alleges that Respondent SARAH RAMOS-TILLMAN was lees than helpful and
did not act upon Respondent JOHNATHAN BLATT'S sexually offensive conduct.

Charging Party alleges that Respondent SARAH RAMOS-TILLMAN explained, she confronts
Respondent JOHNATHAN BLATT or sue him in federal court.

Charging Party alleges that Respondent SARAH RAMOS-TILLMAN did not notify the NYPD
Office of Equity and Inclusion or the Internal Affairs Bureau as required by department policy.

Charging Party alleges that Police Officer Johnathan Kelly told her, Respondent SARAH
RAMOS-TILLMAN is a "fucking idiot." He then instructed her to contact the NYPD Office of
Equity and Inclusion on her own.

Charging Party alleges that on or about August 18, 2017, she contacted the NYPD Office of
Equity and Inclusion.

Charging Party alleges that on or about August 25, 2017, she and Police Officer Johnathan Kelly
met with Detective Elixandra DeJesus, assigned to the NYPD Office of Equity and Inclusion.

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Charging Party alleges that while describing Respondent JOHNATHAN BLATT'S sexually
offensive and retaliatory conduct to Detective Elixandra DeJesus, she had an emotional
breakdown.

Charging Party alleges that after composing herself, she told Detective Elixandra DeJesus that
she did not feel safe working under Respondent JOHNATHAN BLATT.

Charging Party alleges that Detective Elixandra DeJesus ensured her that Respondent
JOHNATHAN BLATT would not have knowledge of the complaint.

Charging Party alleges that despite filing a complaint against Respondent JOHNATHAN
BLATT, Respondent THE CITY OF NEW YORK did not transfer him and she continued to
work under him.

Charging Party alleges that on or about September 25, 2017, acting as the Desk Officer
Respondent JOHNATHAN BLATT handed her a notification to meet with Housing Bureau
Investigations regarding the complaint she filed about his misconduct.

Charging Party alleges that while waiting outside the Housing Bureau Investigations office,
Respondent JOHNATHAN BLATT intentionally walked near her and gave her the death stare.

Charging Party alleges that shortly thereafter, she contacted the NYPD Office of Equity and
Inclusion to file a complaint about Respondent JOHNATHAN BLATT retaliating against her.

Charging Party alleges that the NYPD Office of Equity and Inclusion did not contact her.

Charging Party alleges that shortly thereafter, again she contacted the NYPD Office of Equity
and Inclusion to file a complaint about Respondent JOHNATHAN BLATT retaliating against
her.

Charging Party alleges that again the NYPD Office of Equity and Inclusion did not contact her.

Charging Party alleges that shortly thereafter, in retaliation for reporting Respondent
JOHNATHAN BLATT'S sexually offensive conduct to the NYPD Office of Equity and
Inclusion and other misconduct to the Housing Bureau Investigations Unit, Respondent
JOHNATHAN BLATT ordered Respondent MATTHEW WEINBERGER to issue a command
discipline against her for one-minute lateness to Roll Call.

Charging Party alleges that Respondent ERIC HERNANDEZ immediately dismissed the
command discipline.

Charging Party alleges that Respondent ERIC HERNANDEZ did not notify the NYPD Office of
Equity and Inclusion or the Internal Affairs Bureau as required by department policy.

Charging Party alleges that shortly thereafter, Respondent THE CITY OF NEW YORK
transferred Respondent JOHATHAN BLATT.

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Charging Party alleges that upon transfer, Respondent JOHNATHAN BLATT contacted Former
Police Officer Ryan McGowan for information to discredit her.

Charing Party alleges that in May 2018, Respondent THE CITY OF NEW YORK transferred her
to Police Service Area No.: 9.

Charging Party alleges that on or about July 25, 2018, the NYPD Office of Equity and Inclusion
notified her that the Police Commissioner has determined the allegation of sexual harassment
SUBSTANTIATED.

Charging Party alleges that the Police Commissioner demoted Respondent JOHNATHAN
BLATT from Probationary Lieutenant to Sergeant.

Charing Party alleges that the Police Commissioner directed the department to issue Respondent
JOHNATHAN BLATT Charges and Specifications and attend the Tactical Communications
Course taught at the Police Academy.

Charging Party alleges that the Police Commissioner has determined the allegation of retaliation
UNSUBSTANTIATED.