Superior Court of the District of Columbia CIVIL DIVISION CIVIL ACTIONS BRANCH INFORMATION SHEET Nyree ©. Wright 7 Case Number: _ vs Date; 1722/19 cle anes ZI One of the defendants is being sued in their official capacity Name: Please Pra Relatonsip fo Tawa ‘aids eeenan a ED Attomey for Plant Rain Ghazi Newnan & Fitch, PC ao CO other: TYPE OF CASE: S Nomury 6 Person tury © 12 Person Jury Demand: $ Te be determined at trial on PENDING CASE(S) RELATED TO THE ACTION BEING FILED Case No.: NA Judge: Calendar #:_ a Case No. Judge: Calendaré NATURE OF SUIT: (Check One Box Only) A. CONTRACTS COLLECTION CASES Blot Breach of Contract 114 Under $25,000 Pit Grants Consent [16 Under $25,000 Consent Denied Dior Breach of Warranty B17 over $25,000 Pi. Grants Consent 18 OVER $25,000 Consent Denied (lo Negoriableinsteument 27 Insurance/Subrogation 26 insurance/Subrogation B07 Personal Property ‘Over $25,000 Pir Grants Consent Over $28,000 Consent Denied ©] 13 Employment Discrimination [7] 07 nsurance/Subrogation [As Insurance/Subrogation EIS Special Education Fees Under $25,000 Ph Grants Consent’ Under $25,000 Consent Denied 28 Motion to Confiem Arbitration ‘Award (Colleton Cases Only) B, PROPERTY TORTS 01 Auomorite os Destruction of Private Property CI 05 Trespass or comersion 0s Propeny Damage Co7 hoping, D.C. Code § 27-102) C. PERSONAL TORTS 101 Abuse of Process 1 totnvasion of Privacy 17 Personal tjury- (Not Avomtil, (i? Alienation ot ffetion — ]11 Libel and Slander Not Mapractie) 13 Assault and Batery t2Miaticoas terrence 18 Wrong Death (Not Malpractice) (4 Automobite- Personal Injury. I 13 Maficious Proscuton 19 Wrongful Evietion (5005 Deceit atsvepresentaton) | E14 Malpractice Leza 20 Friendly suit [06 Fale Accusation CES pms Nt sng Wns) EI21 Asbestos Cor rats anes [16 Negtigence-(Not Autamobite, [] 22 ToxiiMass Tons Dos Fras Not Malpractice) (5123 Tobacco [124 Lead Paint SEE REVERSE SIDE AND CHECK HERE X IFUSED cv-s96ihme 2015Information Sheet, Continued . OTHERS, 01 Accounting 1 IMMercPersomel Act(OEA) (02 Ate Before ludgment (D-Code Tite 1, Chapter 6) 105 Fjecmene 1 ts Produc iti lo» special Weiv Warrants (WC Code § 11-941) 24 Application Conti, Modi. C0 trate Agjusication Vacate Arbiation Award (DC Code § 16-4401) 111 WrivorReplevin 29 Mert Personnel Act(OHR) C12 Enforce Mechanics Lien I 31 Housing Code Regulations is declaratory Judgment) 32 Qui Tam 53 Whistebiower 0 Tos change ofNane 11 Lite of afrmation Tos Forign iadgmenvDomesic CI 19 Ener Administrative Order ss {Rule 28-1 ()) (os Foreign iadgmenviwemations! Judges D.C. Code § Ti 2 Release Mechanis Li C13 Conection of Bi Certificate 2-1802.03 (8) 0F32-181 9(@)] I 28 Rule2Ma\1) TM Conetion of Mariage] 20 Maser Meter(D.C. Code § ‘empetate Testimony) Cenitiate 42.3301, 69) 124 Pettin for StucuredSeement 26 Potition for Civil Asset Fortsture(Vehiale) 25 Patton for Liquidation 27 Petition or Civil Asset Forfeiture (Currency) 28 Petition for Civil Asset Forfeiture (Other) D. REAL PROPERTY [09 Real Property-Real Estate 08 Quiet Title 12 Specific Performance: 225 Liens: Tax / Water Consent Granted [4 Condemnation (rine Damsiny (150 Liem: Tax / Water Consent Denied 10 Mortgage Foreclosure/Judicial Sale] 31 Tax Lien Bid Off Certificate Consent Granted 511 Psion for Chit Asst Fores (RP) Attorney's Signature Date LE (cv-496! une 2015,Court of the District of Columbia CIVIL DIVISION Civil Actions Branch Avenue, N.W., Suite S000 Washi me: (202) 879-1133 Websit 2, D.C. 20001 ew. deeourts.gov Pla Case Number Omnicom Public Relations Group, Inc. Defendant SUMMONS To the above named Defendant You are hereby summoned and required to serve an Answer to the attached Complaint, either personally or through an attorney, within twenty one (21) days after service of this summons upon you, exclusive of the day of service. If you are being sued as an officer or agency of the United States Government or the District of Columbia Government, you have sixty (60) days after service of this summons to serve your Answer. A copy of the Answer must be mailed to the attorney for the plaintiff who is suing you. The attomey’s name and address appear below. If plaintiff has no attomey, a copy of the Answer must be mailed to the plaintiff at the address stated on this Summons, You are also required to file the original Answer with the Court in Suite 5000 at 500 Indiana Avenue, N.W., between 8:30 am, and 5:00 p.m., Mondays through Fridays or between 9:00 a.m, and 12:00 noon on Saturdays. You may file the original Answer with the Court either before you serve a copy of the Answer on the plaintiff or within seven (7) days after you have served the plaintiff. If you fail to file an Answer, judgment by default may be entered against you for the relief demanded in the complaint Clerk of the Court Deputy Clerk Date phone JOR RITE (202) 679-4828 Veuiez appeter au 4828 pow une traduction Dc mit bi dich, hy gi (202) 870-4828 wo4s AHO} A}2,(202)879-4028 SIFEMIALE vaerc® cr aePNY (202) 879-4828 store IMPORTANT: IF YOU FAIL TO FILE AN ANSWER WITHIN THE TIME STATED ABOVE, OR IF, AFTER YOU ANSWER, YOU FAIL TO APPEAR AT ANY TIME THE COURT NOTIFIES YOU TO DO SO. A JUDGMENT BY DEFAULT MAY BE ENTERED AGAINST YOU FOR THE MONEY DAMAGES OR OTHER RELIEF DEMANDED IN. THE COMPLAINT. IF THIS OCCURS, YOUR WAGES MAY BE ATTACHED OR WITHHELD OR PERSONAL PROPERTY OR REAL ESTATE YOU OWN MAY BE TAKEN AND SOLD TO PAY THE JUDGMENT. IF YOU INTEND TO OPPOSE THIS ACTION, DO NOT FAIL TO ANSWER WITHIN THE REQUIRED TIME If you wish to talk to lawyer and feel that you cannot afford to pay a lawyer, promply comtact one ofthe offices ofthe Legal Aid Society (202-628-1161) or the Neighborhood Legal Services (202-279-5100) for help or come to Suite S000 at $00 Indiana Avenue, N.W., for more information concerning places where you may ask for such help. See reverse side for Spanish translation ‘Vea al dorso la traduccion al espaol V-5110 Rev. June 2017] Super. Ct. Civ. RASuperior Court of the District of Columbia CIVIL DIVISION Civil Actions Branch 300 Indiana Avenue, N.W., Suite 5000 Washington, D.C. 20001 Telephone: (202) 879-1133 Website: www.decourts:gov ‘Plaintift Case Number Omnicom Group, Inc. Defendant MMONS To the above named Defendant You are hereby summoned and required to serve an Answer to the attached Complaint, either personally or through an attorney, within twenty one (21) days after service of this summons upon you, If you are being sued as an officer or agency of the United States Government er service of this summons to serve your exclusive of the day of servic or the District of Columbia Government, you have sixty (60) days af Answer. A copy of the Answer must be mailed to the attomey for the plaintiff who is suing you, The 1v. If plaintiff has no attorney, a copy of the Answer must be mailed attomey’s name and address appear bel to the plaintiff at the address stated on this Summons You are also required to file the original Answer with the Court in Suite 5000 at S00 Indiana Avenue, N.W,, between 8:30 a.m, and 5:00 pun., Mondays through Fridays or between 9:00 a.m, and 12:00 noon on Saturdays. You may file the original Answer with the Court either before you serve a copy of the Answer on the plaintiff or within seven (7) days after you have served the plaintiff: If you fail to file an Answer, judgment by default may be entered against you for the relief demanded in the complaint James Eisenmann Clerk of the Court Name of Painti's Aton ~ By _ _ Deputy Clerk Date z Telephone same AIT EE (202) 870-4828, ‘Veuilez appear au (202) 8794828 pourune wadueion 2 mit bi de a7o828 igs 2) (200)879-40208 BEMIS eHoMCH Herr gers (202) 879-4828 ser IMPORTANT: IF YOU FAIL TO FILE AN ANSWER WITHIN THE TIME STATED ABOVE, OR IF, AFTER YOU ANSWER. YOU FAIL TO APPEAR AT ANY TIME THE COURT NOTIFIES YOU TO DO SO. A JUDGMENT BY DEFAULT MAY BE ENTERED AGAINST YOU FOR THE MONEY DAMAGES OR OTHER RELIEF DEMANDED IN THE COMPLAINT. IF THIS OCCURS, YOUR WAGES MAY BE ATTACHED OR WITHHELD OR PERSONAL PROPERTY OR REAL ESTATE YOU OWN MAY BE TAKEN AND SOLD TO PAY THE JUDGMENT. IF YOU INTEND TO OPPOSE Tt ACTION, DO NOT FAIL TO ANSWER WITHIN THE REQUIRED TIME I you wish to talk to a lawyer and feel that you cannot afford to pay a fee toa lawyer, promptly contact one ofthe (202-628-1161) or the Neighborhood Legal Services (202-279-5100) for help or come to Suite $000 at 500 N.W,, for more information conceming places ay ask for such help, Legal Aid Soci Indiana Aveo See reverse side for Spanish translation I dorso la traduccion al espaol Super. Ct Civ. R4 V-3110 [Rev. JuSuperior Court of the District of Columbia CIVIL DIVISION Civil Actions Branch 500 Indiana Avenue, N.W., Suite 5000 Washington, D.C. 20001 Telephone: (202) 879-1133 Website: www.decourts-gov Nyree D. Wright Praia Case Number Porter Novelli Public Service Inc. Defendant SUMMONS To the above named Defendant: You are hereby summoned and required to serve an Answer to the attached Complaint, either personally or through an attorney, within twenty one (21) days after service of this summons upon you, exclusive of the day of service. If you are being sued as an officer or agency of the United States Government or the District of Columbia Government, you have sixty (60) days after service of this summons to serve your Answer. A copy of the Answer must be mailed to the attorney for the plaintiff who is suing you. The attorney's name and address appear below. If plaintiff has no attomey. a copy of the Answer must be mailed to the plaintiffat the address stated on this Summons You are also required to file the original Answer with the Court in Suite 5000 at 500 Indiana Avenue, N.W.. between 8:30 a.m, and 5:00 p.m., Mondays through Fridays or between 9:00 a.m. and 12:00 noon on Saturdays. You may file the original Answer with the Court either before you serve a copy of the Answer on. the plaintiff or within seven (7) days after you have served the plaintiff. If you fail to file an Answer, judgment by default may be entered against you for the relief demanded in the complaint. James Eisenmann Clerk of the Court Name of Paint? Atorney By Deputy Clerk ee Date Telephone so, TO (202) 870.2028 ‘Veuilezappeler au (202) 879-£828 pour une reduction ant idk PIS AMAR (202/879-4020 ISAS when ergy aw (202) 879-4828 sc IMPORTANT: IF YOU FAIL TO FILE AN ANSWER WITHIN THE TIME STATED ABOVE, OR IF, AFTER YOU ANSWER. YOU FAIL TO APPEAR AT ANY TIME THE COURT NOTIFIES YOU TO DO SO, A JUDGMENT BY DEFAULT MAY BE ENTERED AGAINST YOU FOR THE MONEY DAMAGES OR OTHER RELIEF DEMANDED IN THE COMPLAINT. IF THIS OCCURS, YOUR WAGES MAY BE ATTACHED OR WITHHELD OR PERSONAL PROPERTY OR REAL ESTATE YOU OWN MAY BE TAKEN AND SOLD TO PAY THE JUDGMENT. IF YOU INTEND TO OPPOSE THIS. ACTION, DO NOT FAIL. TO ANSWER WITHIN THE REQUIRED TIME If you wish to talk to a lawyer and feel that you cannot afford to pay a fee toa lawyer, promptly contact one ofthe offices o Legal Aid Society (202-628-1161) or the Neighborhood Legal Services (202-279-5100) for help or come to Suite 5000 at 500 Indiana Avenue, N.W., for more information concerning places where you may ask for such help. See reverse side for Spanish translation ‘Vea al dorso la traduccidn al espaol CV-3110 [Rev, June 2017] Super. C1. Civ. RAjor Court of the Distriet of Columbi: CIVIL DIVISION Civil Actions Branch 500 Indiana Avenue, N.W., Suite 5000 Washington, D.C. 20001 Telephone: (202) 879-1133 Website: ww.decourts gov Supe Nyree D. Wright Plaintitt — Case Number Jennifer Swint Defendant MMONS To the above named Defendant You are hereby summoned and required to serve an Answer to the attached Complaint, either personally or through an attorney, within twenty one (21) days afier service of this summons upon yot sued as an officer or agency of the United States Governmer exclusive of the day of service. If you are being or the District of Columbia Government, you have sixty (60) days after service of this summons to serve your mailed to the attorney for the plaintiff who is suing you. The intiff has no attorney. a copy of the Answer must be mailed Answer. A copy of the Answer must attomey’s name and address appear below. If pl to the plaintiff at the address stated on this Summons. You are also required to file the original Answer with the Court in Suite 5000 at 500 Indiana Avenue, N.W.., between 8:30 a.m, and 5:00 pam., Mondays through Fridays or between 9:00 a.m. and 12:00 noon on Saturdays. You may file the original Answer with the Court either before you serve a copy of the Answer on the plaintiff or within seven (7) days after you have served the plaintiff. If you fail to file an Answer, complaint. judgment by default may be entered against you for the relief demanded in t James Eisenmann Clerk of the Court Name of PlaintilPs Attorney : By — - Deputy Clerk Date - Telephone sam BR, RIT AK 202) 670-4828 \Vouile appler au (202) 879-4828 pour une traduction 1 sm ih hy gi (202) 679.4828 Yew Qerri?> (202) 879-4828 80h eto Het A, (20287948288 EIRALMLE then IMPORTANT: IF YOU FAIL TO FILE AN ANSWER WITHIN THE TIME STATED ABOVE, OR IF, AFTER YOU ANSWER. YOU PAILTO APPEAR AT ANY TIME THE COURT NOTIFIES YOU TO DO SO. A JUDGMENT BY DEFAULT MAY BE ENTERED AGAINST YOU FOR THE MONEY DAMAGES OR OTHER RELIEF DEMANDED IN THE COMPLAINT. IF TIS OCCURS, YOUR WAGES MAY BE ATTACHED OR WITHHELD OR PERSONAL PROPERTY OR REAL ESTATE YOU OWN MAY BE TAKEN AND SOLD TO PAY THE JUDGMENT. IF YOU INTEND TO OPPOSE THIS ACTION, DO NOT FAIL TO ANSWER WITHIN THE REQUIRED TIME I'you wish to talk to a lawyer and feel that you cannot afford to pay a fee toa lawyer, prompily contact one ofthe offices ofthe Legal Aid Society (202-628-1161) o the Neighborhood Legal Services 100} for help oF come to Suite $000 at S00 Indiana Avenue, N.W., for more inforintion concerning places where you may ask for such help. See reverse side for Spanish translation Vee al dors la traduccin al espaol Super. C1. Civ. R 4 (€V-3110 (Rev. JuneIN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA. CIVIL DIVISION NYREE D. WRIGHT, Plaintiff, ‘Action No. JURY DEMAND PUBLIC SERVICES INC. 1615 L Street N.W. Suite 1150 Washington, D.C. 20036 SERVE Registered Agent: Corporation Service Company 80 State Street Albany, NY 12207, and OMNICOM PUBLIC RELATIONS GROUP, INC. 655 Madison Ave., 12" Floor New York, NY 10065 SERVE Registered Agent: Corporation Service Company 80 State Street Albany, NY 12207, and OMNICOM GROUP, INC. 437 Madison Ave. New York, NY 10022 SERVE: John Wren, CEO 437 Madison Ave. New York, NY 10022 andJENNIFER SWI Defendants. COMPLAINT OF RACE DISCRIMINATION, RACE PLUS SEX DISCRIMINATION, NEGLIGENT MISREPRESENTATION, TORTIOUS INTERFERENCE WITH ‘(CONTRACTUAL/BUSINESS RELATIONS, AND BREACH OF CONTRACT. NATURE OF ACTION Plaintiff, Nyree D. Wright (“Plaintiff” or “Ms. Wright”) brings this action against her former employer, Porter Novelli Public Services Inc. (“Porter Novelli”), Omnicom Public Relations Group, Ine. (“Omnicom PR Group”). Omnicom Group, Inc. (“Omnicom Group”), and Jennifer Swint (“Defendant Swint”), collectively (“Defendants”), to redress willful violations of the District of Columbia Human Rights Act (“DC HRA”) D.C. Code § 2-1401.01 et seq. and § 2-1403.16, breach of contract, negligent misrepresentation, and tortious interference with contractual and business relations. Ms. Wright seeks to recover all lost wages, salary. employment benefits, bonuses and any other compensation denied or lost due to Defendants” violations of the DC HRA, negligent misrepresentation, tortious interference with contractual and business relations, and breach of contract; pre- and post-judgment interest, compensatory damages, consequential damages, punitive damages, and appropriate injunctive and equitable relief JURISDICTION AND VENUE 2. This Court has subject matter jurisdiction over this Complaint pursuant to the D.C. Human Rights Act, D.C. Code §§ 2-1402.1 1(a)(1). Defendants business activities and transactions inthe District of Columbia establish the minimum contacts required for personal jurisdiction. See D.C. Code §§ 13-423(a)(1), (2) and (3). Venue is proper in the District of Columbia because all of the events or omissions giving rise to the claims asserted herein occurred in the District of Columbia and because at all relevant times, Defendants were doing business in the District of Columbia. PARTI 4, Plaintiff Nyree D. Wright is a United States citizen and resides at 5725 Heritage Hill Ct. Alexandria, VA 22310. Atalll times relevant to this Comp! . Ms. Wright was employed by Defendant Porter Novelli as a Consultant. Ms. Wright is an African-American female. 5. Defendant Porter Novelli is a public relations firm with an office in Washington, D.C. Atall times relevant to this Complaint, Defendant Porter Novelli was doing business in the District of Columbia through its office located at 1615 L Street N.W., Washington, D.C. 20036. 6. Omnicom Public Relations Group is a New York corporation, with its principal place of business at 655 Madison Ave., 12" Floor, New York, NY 10065. 7, Defendant Porter Novelli is a wholly-owned subsidiary of Omnicom Public Relations Group. 8. Omnicom Group is a New York corporation, with its principal place of business at 437 Madison Ave., New York, NY 10022. 9, Defendant Porter Novelli is a wholly-owned subsidiary of Omnicom Group. 10. Atall times relevant to this Complaint, Jennifer Swint! was the Global President and Chief Client Officer for Defendant Porter Novelli. Defendant Swint is or was an agent of Defendants who had actual authority, apparent authority, or both, to act on behalf of Defendants in relation to its employees in matters of scheduling, performance appraisals, " Defendant Swint separated from Defendant Porter Novelli effective October 31, 2019. 3compensation, promotions, discipline and terminations, hiring/firing, or some combination thereof. FACTUAL ALLEGATIONS Defendants Actively Recruit and Subsequently Hire Ms. Wright In the summer of 2018, Defendant Porter Novelli began actively recruiting Ms. Wright for a Senior Vice President position with the company. Prior to joining Defendant Porter Novelli, Ms. Wright was the Senior Vice President of MSLGROUP, an international public relations firm. At the time, Ms. Wright was a highly sought-after, high-profile executive, widely recognized for her abilities in the public relations arena . On August 16, 2018, Ms, Wright met with Defendant Swint, the Global President and Chief Client Officer for Defendant Porter Novelli, to interview for the position of Senior Vice President. Ms. Wright had several follow-up interviews and meetings with high-level executives in Defendant Porter Novelli’s DC and New York offices. After those meetings, Sean Smith, the Executive Vice President of Reputation Management at Porter Novelli, as well as other high- level executives, determined that Ms. Wright was too senior for a Senior Vice President role and that the proper role for her would be Executive Vice President. . Due to budgeting constraints, Defendants extended an offer to Ms. Wright on September 20, 2018 to start her employment with Defendant Porter Novelli as a consultant in an Executive Vice President capacity. However, Defendants assured Ms. Wright that she would be extended the Executive Vice President position in the first quarter of 2019, Defendant Swint ‘was well-aware of Ms. Wright’s background and experience at the time Defendants extended this Employment Agreement to her.15. Ms. Wright is a top Washington, DC public relations counselor. A small sample of her successful work includes her having a critical, senior role helping to manage communications during the bankruptcy and recovery of General Motors beginning in 2009. She played a critical role helping to manage communications during the bankruptcy and recovery of General Motors beginning in 2009. Additionally, she served on National Grid’s crisis communications leadership team and was onsite during Hurricane Sandy—the deadliest and most destructive hurricane of the 2012 Atlantic hurricane season. Ms. Wright was also one of the key counselors helping Firestone Liberia communicate its efforts in combating the Ebola outbreak in West Africa. 16. Ms. Wright discussed the terms of the Employment Agreement associated with the Consultant position with Marie Gordon, Vice President, North American Talent Acquisition at Defendant Porter Novelli, at length. Ms. Gordon not only discussed the position with Ms. Wright, she also discussed the Statement of Work, which outlined Ms. Wright’s scope of work, prior to Ms. Wright signing the Employment Agreement 17, Defendants extended Ms. Wright a written Employment Agreement dated September 25, 2018. Ex. | 18, This agreement covered the time period of October 15, 2018 through December 31, 2018, with an option to extend the agreement from January 2, 2019 to March 31, 2019. Ms. Wright ‘was to receive compensation in the amount of $15,000.00 per month under the terms of the Employment Agreement. 19. On September 26, 2018, Defendant Porter Novelli extended Ms. Wright a letter of intent to “extend a full-time employment offer” to her, to commence “no later than April 1, 2019,” forthe position of “Executive Vice President, Reputation Management,” with an annual compensation of $225,000.00. Ex. 2. 20. On September 27, 2018, only after receiving this letter of intent, did Ms. Wright execute the ‘September 25, 2018 Employment Agreement on September 27, 2018. Defendants executed the agreement on September 25, 2018. 21. The Employment Agreement included a “Statement of Work,” which outlined Ms. Wright's job duties and responsibilities in detail. Ex. 3. 22, Per the Statement of Work, Ms. Wright was to “serve as a senior business development consultant and subject matter expert for corporate communications in the areas of reputation, issues management and crisis to include crisis preparedness planning, rapid response media relations, war room management crisis simulations, media training, mergers, acquisitions, bankruptcy, IPO’s, Litigation, Executive Visibility, Thought Leadership and Corporate Social Responsibility.” 23. Ms, Wright began working for Defendants on October 15, 2018. She reported directly to Defendant Swint, the Global President and Chief Client Officer for Defendant Porter Novelli Ms. Wright’s reputation in the community 24, Prior to starting with Defendants, Ms. Wright was the Senior Vice President at MSLGROUP, ‘a prestigious global public relations firm, 25, Ms. Wright is recognized as a top Washington, DC publie relations counselor, with numerous accolades to her name, including Washington Life Magazine’s “The Young & the Guest List 2014,” as well as the National Press Club’s coveted Vivian Award for years 2013, 2014 and 2017. Most recently, Ms. Wright was featured in Diverse Voices: Profiles in Leadership.26. 21. 28. 29. 30. book designed to help communications leaders and professionals better understand the challenges faced by minorities in the communications profession. Ms. Wright’s Early Outstanding Performance Less than three weeks into the position, Ms. Wright brought in a significant client—The University of the District of Columbia (“UDC”), with a contract initially worth approximately $110,000.00. This was not a one-time assignment with UDC, but the start of a significant relationship between UDC and Defendants, which Ms. Wright was to lead. Ms. Wright received numerous accolades from colleagues , supervisors and even Defendant Porter Novelli’s CEO, Brad MacA fee, because of her outstanding performance within an incredibly short time of commencing work for Defendants. Defendants Terminate Ms. Wright Without Cause On or about October 29, 2018, Defendant Swint began pressing Ms. Wright to accept a new business opportunity with the American Public Transportation Association (APTA), work that was completely outside Ms. Wright's Statement of Work. Defendant Swint asked Ms. Wright to spearhead a public affairs and policy campaign for this new client. However, Ms. Wright’s Statement of Work makes no mention of public affairs or policy work. Indeed, the Statement of Work makes it clear Ms. Wright was to “serve as a senior business development consultant and subject matter expert for corporate ‘communications in the areas of reputation, issues management and crisis...” Defendant Swint also gave Ms. Wright an objectively short time frame of ten days to get the ‘campaign up and running,31. Defendant Swint knew when she hired Ms. Wright that Ms, Wright’s background was in public relations, not public affairs and policy. Also, this was made clear during Ms. Wright's interview process. Public relations and public affairs are two completely different fields. Public relations refers to the professional maintenance of a favorable public image by a company or other organization or a famous person, while public affairs generally refers to the building and development of relationships between an organization and poli ians, governments, and other decision-makers. Ms. Wright alerted Defendant Swint to the fact that her background was in public relations, as well as the fact that APTA campaign/new business effort fell outside the Statement of Work, per her Employment Agreement. Defendant Swint responded that this was “not a problem,” which Ms. Wright took to mean that she did not have to lead this campaign/new business effort. 32. However, Defendants terminated Ms, Wright on November 27, 2018, alleging that Ms. Wright was not a good fit for the position. Ms. Wright turned down another lucrative job offer to work for Defendants 33. At the time she accepted the position with Defendants, Ms. Wright turned down a competitive offer from Markstein & Co., a public relations agency, to serve as President, Markstein Mid-Atlantic. Ms. Wright suffers reputational harm as a result of her termination 34, When Defendants summarily terminated Ms. Wright, news of her termination spread quickly among her peers and professional network of high-level executives and leaders within the industry. 35. Being terminated after only a few weeks with Defendants made it appear that Ms. Wright had done something to warrant termination36. Ms. Wright’s reputation was one reason why Defendants hired her, but now that reputation has been tarnished as a result of Defendants’ abrupt and arbitrary dismissal of Ms. Wright. Causes of Action COUNT I RACE DISCRIMINATION IN VIOLATION OF THE DC HUMAN RIGHTS ACT 37. Ms. Wright incorporates by reference the allegations stated in paragraphs 1-36 of her ‘Complaint. 38. As set forth herein, Ms. Wright was at all times relevant to this action an employee, and Defendants an employer, within the meaning of the DC Human Rights Act (“DC HRA”). 39, Ms. Wright is African American, and therefore a member of a protected class. Defendant Swint is white. Defendants’ actions discriminated against Ms. Wright by reason of her race, in iolation of the DC HRA, D.C. Code §§ 2-1401 ef seg. and § 2-1403.16. Defendants’ termination of Ms. Wright was based solely on her race and not her performance. 40. Asa result of Defendants’ conduct, Ms. Wright suffered substantial damages, including, but not limited to, loss of income, pain and suffering, emotional distress, humiliation, and reputational harm, COUNT I RACE PLUS SEX DISCRIMINATION IN VIOLATION OF THE DC HUMAN RIGHTS ACT 41, Ms. Wright incorporates by reference the allegations stated in paragraphs 1-36 of her Complaint.42. As set forth herein, Ms. Wright was at all times relevant to this action an employee, and Defendants an employer, within the meaning of the DC Human Rights Act (“DC HRA”). 43. Ms, Wright is an African American female, and therefore a member of a protected class. Defendant Swint is white, Defendants’ actions discriminated against Ms. Wright by reason of her race plus sex, in violation of the DC HRA, D.C. Code §§ 2-1401 et seg. and § 2-1403.16. Defendants’ termination of Ms. Wright was based solely on her race plus sex and not her performance. 44, Asa result of Defendants’ conduct, Ms. Wright suffered substantial damages, including, but not limited to, loss of income, pain and suffering, emotional distress, humiliation, and reputational harm. COUNT IIL NEGLIGENT MISREPR! ‘TATION 45. Ms, Wright incorporates by reference the allegations stated in paragraphs 1-36 of her Complaint. 46. Defendants falsely stated on September 25, 2018 that Ms. Wright had been hired to serve as a subject matter expert for corporate communications in the areas of reputation, issues management and crisis, when in fact, the position required public policy expertise. 47. Defendants made this representation both in writing and telephonically. Ms. Gordon, Vice President, North American Talent Acquisition at Defendant Porter Novelli, also represented the scope of work would be limited to what was outlined in the Statement of Work. 48. The project Defendants assigned to Ms. Wright —a public affairs and policy client campaign, was clearly outside the scope of work outlined in the Statement of Work in Ms. Wright's Employment Agreement49, Ms. Wright reasonably relied upon Defendants’ false and misleading statements and representations about the scope of work and expectation of becoming Executive Vice President in the first quarter of 2019 when she declined a promising and lucrative offer from Markst & Company, a public relations firm, to come work for Defendants. Defendants were aware of this offer from Markstein & Company. 50. Ms. Wright had a reasonable expectation that the position and work would be consistent with Defendants’ written and oral representations to Ms. Wright through written and oral communications and the Employment Agreement the Statement of Work. Defendants negligently mistepresented the nature of work expected of Ms. Wright. 51. If Ms. Wright had known the foregoing, she would have not accepted employment with the Defendants but rather would have accepted employment with Markstein & Company. 52. As a result of Defendants false promises to employ Ms, Wright as a subject matter expert for corporate communications in the areas of reputation, issues management, and crisis, Ms. Wright turned down the position with Markstein & Company and was harmed. 53. Defendants are therefore liable to Ms. Wright for damages, the exact amount to be proved at trial, COUNT IV TORTIOUS INTERFERENCE WITH CONTRACTUAL/BUSINESS RELATIONS 54. Ms. Wright incorporates by reference the allegations stated in paragraphs 1-36 of her Complaint 55. On September 26, 2018, Defendants extended Ms. Wright a letter of intent to “extend a full- time employment offer” to her, to commence “no later than April 1, 2019.”56, On September 27, 2018, Ms. Wright entered into an Employment Agreement with Defendants, which covered the time period of October 15, 2018 through December 31, 2018, with an option to extend the agreement from January 2, 2019 to March 31, 2019, Defendants signed the agreement on September 25, 2018, This agreement included a Statement of Work, which outlined Ms. Wright’s scope of work in detail. 57. Shortly after Ms. Wright started working for Defendants, Defendant Swint began pressing Ms. Wright to accept an assignment completely outside the agreed upon Statement of Work; giving her an objectively short time frame of ten days to get it up and running, Ms. Wright expressed concerns about accepting the assignment because of lack of experience in public affairs and policy, which Defendants were fully aware of when they hired her. Defendants hired Ms. Wright to serve as a “subject matter expert for corporate communications in the areas of reputation, issues management and crisis,” when in fact, the position required public policy expertise. 58, Defendant Swint terminated Ms. Wright on November 27, 2018, alleging Ms. Wright was “not a good fit” for the position and that Ms. Wright’s role was “not working” for Defendant ‘Swint, However, Defendant Swint assigned Ms. Wright a task which was clearly outside the scope of her Statement of Work, knowing Ms. Wright did not have expertise in public policy. Ms. Wright never refused to take on the assignment. In fact, Defendant Swint, in response to concerns Ms. Wright raised about the assignment, told Ms. Wright not to worry about the assignment. 59. Ms. Wright reasonably relied upon Defendants’ false statements and representations when she declined a lucrative offer from a prestigious firm to come work for Defendants, assuming, the position would be consistent with Defendants’ written and oral representations of the60, 61 62. 63. work. Moreover, it was only after she received the letter of intent from Defendants, did Ms. Wright accept Defendants’ offer and execute the Employment Agreement. In other words, Ms. Wright relied on Defendants’ Statement of Work and letter of intent to employ her as an Executive Vice President for Reputation Management no later than April 1, 2019, in forgoing, other opportunities and accepting the position. Defendants are therefore liable to Ms. Wright for damages, the exact amount to be proved at trial. COUNT V BREACH OF CONTRACT Ms. Wright incorporates by reference the allegations stated in paragraphs 1-36 of her Complaint. (On September 27, 2018, Ms. Wright entered into an Employment Agreement with Defendants, which covered the time period of October 15, 2018 through December 31, 2018, with an option to extend the agreement from January 2, 2019 to March 31, 2019. This agreement included a Statement of Work, which outlined Ms. Wright’s scope of work. Ms. Wright was to receive compensation in the amount of $15,000.00 per month under the terms of this agreement. Ms. Wright and Defendants intended to be bound by the terms of the Employment Agreement. Per the agreement, Defendants could only terminate Ms. Wright based on the following four grounds: 1) if Ms. Wright is convicted of any crime or offense; 2) if Ms. Wright fails or refuses to comply with the written policies or reasonable directive of Defendants; 3) if Ms. Wright is guilty of serious misconduct in connection with the performance under the agreement; or 4) if Ms. Wright materially breaches provisions of the agreement64. Ms. Wright did not breach or violate any of the four grounds listed in the agreement, yet Defendants still terminated her on November 27, 2018. Defendants terminated her agreement without cause. 65. Defendants are therefore liable to Ms. Wright for damages, the exact amount to be proved at trial. Relief Requested 66. Ms. Wright requests the following relief: a. A finding and declaratory judgment that Defendants have discriminated against Ms. Wright; b. Preliminary and permanent injunctive relief to restore Ms. Wright as nearly as possible to the position she would have held had the prohibited personnel practices not occurred: c. Equitable relief to ensure that Defendants’ workplaces are free from unlawful discrimination by directing Defendants to take such affirmative action as is necessary to censure that the effects of those unlawful employment practices are eliminated and do not continue to affect Ms. Wright’s employment and advancement opportunities; d. Back pay, in an amount to be determined at trial; e. Front pay, as a result of the damages done to Ms. Wright's employability; f. Monetary damages for breach of contract; g. Compensatory damages for injury to Ms. Wright's reputation and her mental and physical health related to Defendants’ unlawful race and sex tion, in an amount to be proven at trial; h. Punitive damages; i. Pre-and post-judgment interest;his action; and j. Reasonable attorney fees, costs, and expenses of bringi k. Such other relief as the Court determines is just and appropriate. Jury demand 67. Ms. Wrigl t requests a trial by jury / James Eis James Eisenmann (D.C. Bar No. 435456) Kalijarvi. Chuzi, Newman & Fitch, P.CSeptember 25, 2018 Personal & Confidential Nyree Wright Re: Engagement of Nyree Wright as Service Provider ("Consultant") Dear Nyree: This letter agreement (the "Consulting Agreement”) is to confirm the terms of Consultant's engagement as a provider of services (collectively, the "Services"), as reasonably directed by Porter Novelli, inc. ("PN") 1. The term of this Consulting Agreement shall commence on October 15, 2018 and will continue through December 31, 2018 (the "Term"), itis understood that PN has the right to terminate this Consulting Agreement for any reason, and at ‘any time. PN at anytime may terminate this Consulting Agreement without prior written notice if Consultant: (is convicted of any crime or offense; i) fas or refuses to comply with the written policies or reasonable directive of PN; {i's uity of serious misconduct in connection withthe performance hereunder; of, (3v) materially breaches provisions ofthis Consulting Agreement. It further understood that Consutant has the rght to terminate this Consulting ‘Agreement for any reason, and at any time 2. (a) The parties hereto shall enter into separate Statements of Work, in the form attached hereto as Exhibit A, contemplating the specific Services, projects, assignments, schedules and budgets for the PN Client (each, a “Statement ‘of Work’). It is expressly agreed upon by the parties that if any term of a Statement of Work conflicts aris otherwise inconsistent with the terms of this Consulting Agreement, the terms of this Consulting Agreement shall prevail (b) Consultant represents and warrants that: (i) all Services will be performed in a professional and workmanlike manner with due care; (i) the Services and any deliverables will conform to the Statement of Work and any specifications provided: (iit shall comply with al laws, rules, regulations, terms of use, and applicable third-party agreements, felating to the deliverables, or performance of the Services hereunder and obtain all applicable licenses, permits, releases, permissions, etc. necessary to perform the Services hereunder; (v) time is of the essence in performing the Services; () it wll use reasonable physical and electronic security measures in association with the performance of the Services and in handling any PN and PN Client information appropriate to the nature of such information disclosed to or “accessible by Consultant in order to protect such information from unauthorized access, destruction, use, modification or disclosure, and that it shall promptly notify PN in writing in the event any unauthorized access to information is suspected and permit PN to control any public notifications, with the reasonable assistance of Consultant, and at Consultant's expense ifsuch unauthorized access was a result of Consultant's negligence; and (vi) the Services, deliverables, and Consultant materials and intellectual property shal not infringe the rights of any third party including any patent, trademark, trade secret, or right or privacy or publicity right. {c) Consultant agrees to obtain PN’s prior written consent to utilize Consultant's own employees (if any) to assist Consultant in providing the Services contemplated herein. Should Consultant utilize Consultant's own employees, with the written consent of PN, Consultant shall be solely responsible for furnishing the necessary materials to fulfill the Services under this Consulting Agreement and Consultant shall be solely responsible for such costs associated with Consultant's employees, including but not limited to salary, benefits and employee business expenses. 1 Exhibit 13. (a) As the sole form of compensation in consideration of the Services pursuant 10 this Consulting Agreement, itis understood and agreed that PN shall pay Consultant only those fees and expenses specifically set forth in the applicable Statement of Work, (b) Consultant agrees to submit invoices on the 15" and last day ifthe month, Invoices must be itemized with client/projectbiling codes consistent with PN's accounting procedures. Consultant agrees to also submit detailed time ‘accounting on a semi-monthly basis via Porter Novell's electronic timesheet system. PN will endeavor to satisfy all ‘undisputed invoices within a reasonable time period. Consultant invoices will be paid by PN according to 30-day payment terms upon receipt of a valid invoice. () PAs acting as an agent on behalf of PN Client, a disclosed principal, either named herein or otherwise identified to Consultant. PN will only be liable forthe cost ofthe goods and services purchased and other obligations to Consultant to the extent we have been paid by our PN Client for any amount payable to Consultant under this Agreement. For amounts not paid to PN by PN Client, Consultant will seek payment solely from our PN Client (and not from PN). Any terms in your invoices, documents, purchase orders, or ate cards to the contrary, and any modifications Consultant ‘makes to this Agreement in contravention of this section are of no force or effect, 4. (a) Consultant agrees that it will perform its obligations under this Consulting Agreement as an independent contractor of PN, Consultant, and Consultant's employees and agents (if any, shall nat be considered for any purposes {8 an officer or employee of PN or any PN Client. Consultant, and Consultant's employees and agents, willmake no representations contradicting this status. Consultant and Consultant's employees and agents, will nct be entitled to the benefit of any employee plans or programs including insurance of PN or PN Client. Consultant acknowledges and agrees that any and all arrangements or agreements that it may negotiate or be involved with for PN, shall be subject to ‘acceptance only by an authorized officer of PN and to be evidenced by execution by an authorized officer for PN. Consultant does not have any authority to bind PN, PN Client, or any other client of PN, either by oral or written ‘agreement. Consultant further acknowledges and agrees that itis solely responsible for all costs associated with its ‘employees, agents and representatives, including but not limited to salary, benefits and employee business expenses. (b) Consultant may represent that it renders or has rendered services to PN. However, Consultant may not lst, refer or otherwise represent that it renders or has rendered services to PN Client, or any other client of PN, if such listir referral or representation isin connection with, or in any way related to, this Consulting Agreement, without the prior written consent of PN. (c) Consultant acknowledges and agrees that, as an independent contractor, it will be responsible for the withholding, and payment of all Federal, State and Local income taxes, Social Security taxes and the payment ofall workers’ compensation, state disability and unemployment contributions or premiums or other taxes or contributions under any benefit program mandated by applicable law, associated with the fees Consultant receives and the employees Consultant hires. Consultant further acknowledges and agrees that, as an independent contractor, it will hold PN. harmless against liability Incurred with respect to such taxes, contributions or premiums and Consultant agrees to indemnify PN for any costs or liabilities, including reasonable attomey’s fees, arising from Consultant's allure to withhold and pay such taxes, contributions or premiums. 5. (a} Consultant agrees to keep confidential and not to disclose or use for Consultant's own benefit or for the benefit of any third party, any PN or PN Client information, documents, trade secrets, or other materials (including the terms and 2‘existence of this Agreement, the Services, and all products and work product produced and/or provided by Consultant ‘under this Agreement) which are provided, or otherwise made available, to Consultant, in any form whatsoever. The confidentiality obligations in the preceding sentence, however, shall not extend to any information, documents, or ‘materials that (a) become publicly available without breach of this provision, (b) are received from a third party without ‘restriction, or (c) are independently developed without reference to information received hereunder from PN or PN Client without breach of this Agreement. (b} Consultant agrees not to circumvent, avoid, reduce the volume of the business relationship, or bypass PN and enter into an agreement with any clients of PN introduced to Consultant by PN, whichis for services and/or products of the type contemplated in this Agreement. {c) Throughout the term ofthis Agreement, and fora perio of one (1) year following the termination or expiration of this Agreement, Consultant unconditionally agrees not to directly or indirectly approach any PN Client, which Consultant ‘was involved, forthe purpose of providing services similar to those services contemplated inthis Agreement. 6, Consultant acknowledges and agrees that the Services may be required to support certain services being provided by PN to PN Client. As a condition to providing such Services to PN Client, Consultant understands and agrees that PN ‘and/or PN Client may require that Consultant, and Consultant’s employees and agents {i any), be bound in writing, to certain terms and conditions that are substantially similar to those certain terms and conditions that PN is bound to with ®N Client, including but not necessarily limited to terms and conditions involving confidentiality, ownership of material, ‘and conflict of interests. Consultant further understands and acknowledges that PN Client may have the right to enforce such obligations. 7. In entering this Agreement, Consultant hereby grants to PN, or its designee, including PN Client, all rights, titles and Interest in and to any intellectual property, including copyrighted materials, conceived or produced specifically for PN or PN Client by Consultant under this Agreement and any Statement of Work under this Agreement, and Consultant agrees ‘that such materials are works made for hire exclusively for PN under the laws of the United States. Without limiting the foregoing, Consultant hereby assigns PN, or'ts designee, al rights titles and interests in such work and to execute whatever assignment of copyright and ancillary and confirmatory documents as may be required or appropriate to transfer exclusive ttle n such work to the copyright therein to PN, or its designee. Furthermore, to the extent that any moral rights accrue to Consultant or any of its employees or agents, it shall waive all such moral rights throughout the ‘world relating to work or materials created relating to this Agreement, 8, Consultant agrees to indemnify, defend and hold harmless PN, and PN Client, and the collective parent, subsidiary and affliated companies, and respective employees, officers, directors, shareholders, licensees and agents against all liabilities, losses, deficiencies, damages or expenses, including reasonable attorney's fees and costs, which such indemnified party may incur as the result of any claim, sult or proceeding brought or threatened against PN, PN Client, ‘or any other indemnified party: (i) caused by acts of commission or omission of Consultant, its employees, subcontractors, or agents; (i) pertaining to Consultant's breach or alleged breach ofthis Agreement and any Statement ‘of Work under this Agreement; and/or ili) pertaining to the negligence or wilful misconduct of Consultant, its employees, subcontractors, or agents. 9. Consultant may not delegate or subcontract any portion of Consultant's obligations set forth herein to a third party without the expressed written consent of PN. Should PN authorize in writing, Consultant's delegation or subcontracting ‘of any portion of Consultant’s obligations to any third party, Consultant shall require such thd party, asa condition to 3their engagement, to agree to be bound by provisions substantially the same as those contained in this Consulting [Agreement and any Statement of Work under this Consulting Agreement, and any amendments. 10. Consultant represents and warrants to PN that during the Term of this Agreement, Consultant shall not be engaged in providing services to any clients whose business is competitive with those of PN Client. Both parties agree to use reasonable efforts to identify, discuss and seek to resolve any possible conflicting assignments that may have existed prior to, and may arise during, the Term of this Agreement. Nothing in this section, however, shall affect PN’s ability to ‘terminate this Agreement pursuant to the terms of herein. 1LL. This Consulting Agreement may not be assigned by Consultant without the prior written consent of PN, and any such purported assignment shall be vos. 422. Consultant shall at all times during the term maintain in effect () a commercial general lability policy of insurance, including coverage for premises/operations; products/completed operations, including coverage for copyright infringement and other intellectual property rights; violation of privacy laws; advertising liability; general errors and ‘omissions coverage and contractual liability; (i) automobile liability (if automobiles will be used in the performance of ‘ervices) and (ii) Workers’ Compensation insurance in the statutory amounts required by the applicable state law with respect to its employees and Employers’ Llabllity insurance. Consultant's insurance shall be primary over any other insurance covering PN of Client and shall remain in effect continuously for the term of this Agreement. Consultant shall name PN and Client as adsitional insureds to such insurance policies (except workers’ compensation/employers! liability). Consultant will promptly provide to PN certificate(s) of insurance from its insurers indicating the insurance coverage and limits required by this contract, additional insured status of PN and Client and the effective and expir date of each applicable policy. Consultant shall provide PN with new certificates of insurance upon the renewal or replacement of any policy. No such insurance policy wll be cancelled, non-renewed or reduced in coverage or limits ‘during the Term without thirty (30) days’ prior written notice to PN by the insurance carriers). 113. any provision of this Consulting Agreement is held invalid, illegal or unenforceable, the validity, legality or enforceability of the remaining provisions shall in no way be affected or impaired thereby. 14. In the event that there is a conflict between this Agreement and a Statement of Work, this Agreement shall control Unless the Statement of Work specifically identifies the section of this Agreement to modify. 15. A party's failure or delay in enforcing any provision of the Agreement will not be deemed a waiver of that party's rights with respect to that provision or any other provision of the Agreement. 16. Consultant acknowledges that money damages would be not calculable and an insufficient remedy for any breach of this Agreement by Consultant and that any such breach would cause PN irreparable harm. Accordingly, Consultant also agrees (i) that in the event of any breach or threatened breach of this Agreement, PN, in addition to any other remedies at law or in equity t may have, shall be entitled, without the requirement of posting a bond or other security, to ‘equitable relief, including injunctive relief and specific performance, and (i) to pay reasonable attorney's fees and ‘expenses incurred by PN in any action or proceeding to enforce this Agreement. 117. This Consulting Agreement represents our entire agreement and supersedes all prior agreements between us. This Consulting Agreement will be governed and construed under the laws of the Washington, D.C. without giving effect toconflict of laws principles, and the parties hereto consent to the exclusive jurisdiction by the state and federal courts sitting in Washington D.C. of any dispute arising out of or relating to this Consulting Agreement. Please affirm acceptance of this Consulting Agreement by signing two (2) copies ofthis Consulting Agreement, with the attached Statement of Work, and returning both originals of each separate agreement to Marie Gordon. Sincerely, ‘Marie Gordon. Agreed and Accepted: ant (Porter Novel wats Apes Wage npg Soh Brinted Name: Nyree Wright Date:_ 927/18 Printed Name: Marie Gordon “Title: VP Talent Acquisition Date: September 25, 2018PORTER NOVELLI > September 26, 2018 Nyree Wright °y ei Dear Nyree: This letter reviews Porter Novell's (the "Company’) intent to extend a fulltime employment offer to you in the fist quarter of 2019, provided both you and the Company are in agreement to do so at that time and all needed approval to extend the offer is obtained. ‘The Position The position is Executive Vice President, Reputation Management, in our Washington, D.C. office. The position will report to the Managing Director of the Washington office, with a dotted line to the Global Reputation Management Practice Leader. As a condition of employment, you will be required to sign the Company's Confidential Information, Work for Hire and Covenant Agreement. Start Date ‘The position start date will be a mutually agreed upon date, no later than April 1, 2019, provided that you clear the Company's background and reference checks. Under federal law, the Company is required to establish the employment authorization and identity of ‘each employee. Compensation The annual compensation for the position will be $225,000, less all applicable taxes and withholdings. The Company's standard payroll practice is to pay all employees twice monthly, on the 15 and last working day of each month. In fight of the nature and level of the position, you will be exempt from overtime laws. Accordingly, your annual salary would be your total compensation for all hours that you work, You willbe eligible to participate in an incentive program based on lead generation. Exhibit 2PORTER NOVELLI > Benefits ‘You will be eligible for a to be determined number of PTO days, subject to the Company's time off policy, in addition to paid holidays. ‘You will also be eligible to participate in the Company's employee benefits programs, for its employees generally or for all employees at your organizational level, subject to the Company's right to modify or terminate such benefit plan or program and the eligibility requirements and rules of such benefit plan or program. The Company currently offers. medical and dental insurance, disabiity insurance, group life insurance and the 401(k) plan, subject to the eligibility requirements and rules of each such plan or program. Nyree, | look forward to working with you. Sincerely, Colleen A Connore Colleen Connors Executive Vice President, Global Talent LeaderEXHIBIT A. STATEMENT OF WORK September 25, 2018 Personal & Confidential Nyree Wright “This Work Order Agreement between Porter Novelli Inc. and Nyree Wright (“Consultant”) serves as Consultant's authorization to support Porter Novelli with Freelance efforts. This Work Order Agreement is governed by the terms and conditions of the Consulting Agreement dated September 25, 2018 by and between the parties, which are incorporated by reference herein. Consultant is authorized by Parter Novelli Inc. to conduct the following intiative(s} from no later than October 15, 2018 through approximately December 31, 2018 (revocable by either party at any time and extendable from Jan 2, 2019 to Mar 31, 2019), ’As the sole form of compensation in consideration of the Services pursuant to this Consulting Agreement, itis ‘understood and agreed that PN shall pay Consultant only those fees and expenses specifically set forth below: ‘+ $15,000 per month during the term of this Agreement, excluding any travel time to any of PA's offices as may be directed, Other expenses may be reimbursed, if pre-approved, in writing, by Porter Novell zo Fee ‘OOP Total Budget Seope: $315,000 per ‘+ Serves a senior business development consultant and subject matter expert for corporate communications in the areas of reputation, issues management and crisis to. include crisis preparedness planning, rapid response media relations, war room management, crisis simulations, media training, mergers, acquisitions, bankruptcy, 10's, Litigation, Executive Visibility, Thought Leadership and Corporate Social Responsibility. Develop new business strategy and positioning In this space for the ‘Washington., OC office and the broader corporate communications sector. ‘© Contribute to the new business pipeline through lead generation inthe areas of reputation isues management and crisis to include crisis preparedness planning, rapid response media relations, war room ‘management, crisis simulations, media training, mergers, acquisitions, bankruptcy, PO's, Litigation, Executive Visibility, Thought month Exhibit 3Leadership and Corporate Social Responsibility Advise and participate in the new business pitch process, as needed, toa successful outcome. © Work in close partnership with Sean Smith and Washington DC senior leadership. «Provide senior level account service and pitch support to the agency's Bayer business across the work streams of Consumer Thought Leadership, Reputation Management, Issue ‘Advocacy, Crop Science Executive Visibility, Day One Suppor for the merger with ‘Monsanto, integrated Weed Management Issues Support and other corporate ‘communication accounts as needed. + Alead generation incentive for any new lead ‘that you generate that is converted into a signed contract/SOW during the term of this agreement, The incentive payment will be 5% of the total cash collected during the first 6 months of fee generation. This incentive will bbe AGGREGATED AND paid on a quarterly basis. + To qualify fora Lead Generation bonus, the lead must be with a BRAND OR company not doing business with Porter Novelli or Voce at the start of the consulting agreement. The Lead must be converted toa signed contract/SOW within 12 months of documentation. Start date: October 15, 2018 End date: December 31, 2018 (revocable by either party at any time and extendable from Jan 2, 2019 to Mar 31, 2019) Hours/timeframe for project: Hours will be approximately 40 hours/week TOTAL Consultant agrees not to exceed the budgets set forth above without Porter Novell, Inc's prior written consent. Consultant further agrees to secure Porter Novelli, Inc’s approval in writing before any work commences on any ‘additional projects not included in this Work Order Agreement.CONSULTANT: oe “yp ea 9/27/18 Name: Nyree Wright Date Title: EVP Consultant September 25, 2018 Name: Marie Gordon Date Title: VP Talent Acquisition