Case 1:21-cv-00531 Document 1 Filed 03/01/21 Page 1 of 63
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`Plaintiff,
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`DEMAND FOR JURY TRIAL
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`undersigned counsel, Wigdor LLP, as and for the Complaint in this action against Defendants
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`Amazon.com, Inc., Amazon Web Services, Inc. (“AWS”) (together, “Amazon” or the
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`“Company”), Andres Maz, Steve Block, and Shannon Kellogg, in their individual and
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`professional capacities, (collectively, “Defendants”) hereby states and alleges as follows:
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`PRELIMINARY STATEMENT
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`1.
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`Amazon and its Chief Executive Officer (“CEO”), Jeff Bezos, hold themselves
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`out as among the foremost, most innovative companies and business leaders in the United States
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`and the world. They have made “customer obsession” their top leadership principle. Driven by
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`profits and greed, Amazon and Mr. Bezos are not, however, “employee-obsessed” in the same
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`way. Their practices when it comes to hiring and promoting Black people and other
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`underrepresented minorities to high-level positions (and paying them commensurately)
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`perpetuate decades-old patterns of discrimination. Like so many other Black and female
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`employees at Amazon, Charlotte Newman was confronted with a systemic pattern of
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`insurmountable discrimination based upon the color of her skin and her gender. While Amazon
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`UNITED STATES DISTRICT COURT
`DISTRICT OF COLUMBIA
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`CHARLOTTE NEWMAN,
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`AMAZON.COM, INC., AMAZON WEB
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`SERVICES, INC., ANDRES MAZ, STEVEN
`BLOCK, and SHANNON KELLOGG, in their
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`individual and professional capacities, :
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`Defendants.
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`Plaintiff Charlotte Newman (“Plaintiff” or “Ms. Newman”), by and through her
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`Civil Action No.:
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`COMPLAINT
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`Case 1:21-cv-00531 Document 1 Filed 03/01/21 Page 2 of 63
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`may be the largest on-line retailer and Mr. Bezos one of the richest men in the world, they are
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`not above the law. Ms. Newman, therefore, files this Complaint in an effort to hold Amazon and
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`its executives accountable for their unlawful and discriminatory practices.
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`2.
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`Four years ago, Amazon hired Ms. Newman as a Public Policy Manager (a Level
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`6 position at Amazon), despite the fact that she had applied and was qualified for a higher-level
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`position called Senior Manager (Level 7). Within months of starting at the Company, she in fact
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`was assigned and doing the work of a Senior Manager-level employee while still being paid at
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`and having the title of the Manager level. To make matters worse, and in defiance of the anti-
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`discrimination laws, Ms. Newman was paid significantly less than her white coworkers,
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`particularly in valuable Amazon stock. If that were not bad enough, unlike her colleagues, Ms.
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`Newman had to wait more than two and a half years for a promotion to the level at which she
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`should have been hired in the first place, and at which level she had already been performing
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`work for more than two and a half years.
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`3.
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`Many of Ms. Newman’s colleagues observed a consistent practice of paying
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`Black employees less than similarly situated white employees, and a near-total lack of Black
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`representation in and very few women in the upper echelons of the group’s leadership. A group
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`of Public Policy employees in Ms. Newman’s group grew so demoralized and troubled by the
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`lack of attention to these openly unequal conditions that, in or around September 2019, they
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`composed a lengthy memorandum that made a series of highly detailed policy proposals to
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`address racial and gender-based imbalances.
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`4.
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`Ms. Newman certainly is not alone among Amazon’s corporate workforce in
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`facing discriminatory treatment. Based upon numerous conversations with other Amazon
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`employees who are persons of color and/or women, the “de-leveling” of Black employees when
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`2
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`they are hired (i.e., dropping them a level below the job they applied and were qualified for or
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`will be performing) is common, as is a longer wait for promotions for Black employees and
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`women (particularly to high-level positions at Director (L8) and above).
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`5.
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`Ms. Newman reported her concerns about the impact of her race and gender on
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`her employment to the Company on multiple occasions. She talked with her managers
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`repeatedly about how perceptions of Black and female employees on the part of managers could
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`prevent them from succeeding at the Company, including how stereotypical views based upon
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`characteristics such as race and gender can affect employees’ advancement (and that she
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`believed it had affected her, too). She also participated in the creation of a document submitted
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`to Amazon management on behalf of underrepresented minority employees pointing out
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`significant systemic diversity-related issues at AWS. In June 2020 she filed a written complaint
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`about the vile and aggressive sexual assault and harassment committed against her by a senior
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`male employee (which had distinct racial aspects as well), as well as regarding discriminatory
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`attitudes by her managers and their impact on her. Finally, in September 2020 Ms. Newman
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`filed an administrative complaint with the Washington, DC Office Human Rights regarding
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`racial and sexual harassment and discrimination at the Company.
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`6.
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`Recent reporting strongly confirms Ms. Newman’s experiences, and conclusively
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`shows that Amazon and AWS harbor Company-wide trends and attitudes that adversely impact
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`Black employees and applicants. See https://www.vox.com/recode/2021/2/26/22297554/bias-
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`disrespect-and-demotions-black-employees-say-amazon-has-a-race-problem (last visited
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`February 26, 2021). This information comes not only from rank-and-file employees, but from
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`diversity and inclusion managers at the Company.
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`3
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`7.
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`These practices and trends include frequent slotting of Black employees into jobs
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`and “levels” that do not reflect their skills and qualifications (and pay them much less), much
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`longer paths to promotion, and disinterest by some in Amazon leadership (including some on
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`Jeff Bezos’s elite “S-Team”) when it comes to changing set practices that appear to have
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`negative racial impact or listening to employees about how to address Amazon’s issues on race,
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`particularly regarding Black employees.
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`8.
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`Black employees who Ms. Newman talked with, as well as many Black
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`employees who talked with reporters, consistently found that they and Black coworkers were
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`slotted into Amazon job levels and compensation lower than their experience and credentials
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`supported (unlike the general experience of white colleagues). This longstanding practice affects
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`Black employees’ job authority, compensation (including stock awards), and prospects for
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`promotion. As with Ms. Newman, being put into a lower level has a strong negative, downward
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`effect on an employee that echoes for years and can cost them millions of dollars in
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`compensation.
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`9.
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`It is astounding that even highly specific instances of harassment that Ms.
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`Newman has experienced as a Black woman at Amazon, such as a senior employee yanking on
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`her hair or being told by a manager she is “too direct” and “scary,” are echoed in incidents
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`involving other Black female employees. Other Black women at Amazon, and AWS
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`specifically, report having coworkers touch their hair without consent or asking and being
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`criticized for not smiling or being friendly enough (or being singled out as a Black woman who
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`is “safe”). Other Black women also reported, as has Ms. Newman, having applied for jobs that
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`the Company said were at a higher level, and then being hired by the Company at a lower level, a
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`practice known as “down-leveling” or “de-leveling.” See
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`4
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`https://www.vox.com/recode/2021/2/26/22297554/bias-disrespect-and-demotions-black-
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`employees-say-amazon-has-a-race-problem (last visited February 26, 2021).
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`10.
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`For the first three years of Ms. Newman’s tenure at Amazon, 2017-2019,
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`Amazon’s Public Policy team did not hire a Black employee at the L8 level or promote any
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`Black employees to L8. From the Public Policy team’s inception in the mid-2010s until
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`December 2018, Amazon Public Policy did not hire any Black employees at the L7 level. The
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`first Black employees hired at the L8 level in Public Policy joined on or around September 21,
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`2020.
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`11.
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`Amazon’s discriminatory conduct was not limited to paying Ms. Newman less
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`than her white peers and discriminatorily failing to promote her for years after she had already
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`taken on a more senior role. Underlining Ms. Newman’s vulnerable position at the Company, a
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`senior male coworker also felt free to sexually harass Ms. Newman and at times in plain view of
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`others.
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`12.
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`Racial and sexual discrimination exists in Amazon’s corporate corridors, not just
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`its warehouses—it simply takes a different form. Amazon has failed to seriously grapple with
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`these issues among its management.
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`5
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`13.
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`On May 31, 2020, six days after the murder of George Floyd under the knee of a
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`Minneapolis police officer, Amazon posted the following tweet:
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`14.
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`The day before, on May 30, 2020, CEO Jeff Bezos posted a message on
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`Instagram quoting an essay describing the strain and terrible impact on Black Americans caused
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`by the killings of unarmed Black men and women by law enforcement (as well as other blatant
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`displays of racism) in the United States, and the incompatibility of such stress with expectations
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`of unflagging professionalism.1
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`15.
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`Andy Jassy is the CEO of AWS and is slated to succeed Mr. Bezos as CEO of
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`Amazon in or around August 2021. Also on May 30, 2020, Mr. Jassy also posted a message on
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`June 2020, decrying police violence against Black Americans: “*What* will it take for us to
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`refuse to accept these unjust killings of black people? How many people must die, how many
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`1 See https://www.instagram.com/p/CAzG5h8nWg5/ (last visited February 11, 2021).
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`6
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`generations must endure, how much eyewitness video is required? What else do we need? We
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`need better than what we're getting from courts and political leaders.”2
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`16. Many of Amazon’s employees and the public called out these superficial gestures,
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`and recognized that they were far outweighed by Amazon’s mistreatment of its Black workforce,
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`including the vast majority of its Black employees who work in its warehouses and fulfillment
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`facilities. Just as Mr. Jassy expects better of the legal and political leaders of the United States,
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`Ms. Newman and Amazon’s employees expect better from their employer’s executive and
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`managerial leaders.
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`17.
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`Behind closed doors, Amazon and its leadership are more focused on attacking
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`Black workers who speak up—and managing the public relations (“PR”) fallout—than on
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`addressing the conditions that led Black employees to protest and file legal claims.
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`18.
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`For example, Jeff Bezos participated in a March 2020 meeting in which the
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`Company’s General Counsel, David Zapolsky, openly mocked and strategized character
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`assassination against a Black employee, Christian Smalls. Mr. Smalls was fired after starting to
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`organize employees at a warehouse on Staten Island and leading protests against unsafe work
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`conditions during the pandemic. Mr. Zapolsky said of Mr. Smalls, among other things: “He’s
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`not smart or articulate, and to the extent the press wants to focus on us versus him, we will be in
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`a much stronger PR position.”3 These degrading and vindictive statements, which reek of racial
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`stereotypes and condescension, were confirmed by Mr. Zapolsky’s own leaked notes. Neither
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`2 See https://twitter.com/ajassy/status/1266847181891203072 (last visited February 11, 2021).
`3 See https://www.vice.com/en/article/5dm8bx/leaked-amazon-memo-details-plan-to-smear-fired-warehouse-
`organizer-hes-not-smart-or-articulate (last visited December 11, 2020).
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`7
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`Amazon nor Mr. Bezos ever repudiated or expressed regret for these remarks. Instead, in a
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`blatant act of retaliation, Mr. Smalls was fired.4
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`19.
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`Later in April 2020, a group of Amazon employees from across various wings of
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`the Company sent an impassioned email to Mr. Bezos and his S-Team (of which Andy Jassy is a
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`member), personally expressing the employees’ shock and sorrow at Mr. Zapolsky’s statements
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`about Mr. Smalls, which they found unmistakably racially offensive, as well as noting that the
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`Company had done nothing to address the impact of the discriminatory statements on Black
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`employees’ concerns about how they fit in at Amazon. The email outlined dozens of concrete,
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`highly detailed policy and process changes and ideas that would help ensure that
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`underrepresented minorities and women are equitably treated at Amazon, including but not
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`limited in connection with promotions. To Ms. Newman’s knowledge, the Company did not
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`issue any public response to the employees’ email or implement any of even the smallest
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`measures recommended by the employees. Ms. Newman also is unaware of any response to the
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`employees’ email from Mr. Bezos.
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`20.
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`In early June 2020, right after Amazon posted its ostensible support for Black
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`individuals and opposition to injustice (and Mr. Bezos recommended that managers acknowledge
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`Black employees’ trauma), Donald Archie II, a Black janitorial contractor at a Los Angeles
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`Amazon warehouse, was fired by the Company for taking a photo of racist graffiti in one of the
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`facility’s bathrooms (unbelievably, for supposedly violating a policy on cell phone use).5
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`4 Incidentally, an essay/editorial penned by Mr. Smalls in The Guardian shows that Mr. Zapolsky was wrong about
`Mr. Smalls on all counts. See https://www.theguardian.com/commentisfree/2020/apr/02/dear-jeff-bezos-amazon-
`instead-of-firing-me-protect-your-workers-from-coronavirus (last visited December 11, 2020).
`5 See https://www.nytimes.com/2020/06/24/technology/amazon-racial-inequality.html and
`https://www.theroot.com/jeff-bezos-says-black-lives-matter-but-will-he-make-a-1844169214 (both last visited
`December 11, 2020).
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`8
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`21.
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`Amazon’s workforce is fighting back against these consistent abuses, and in
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`December 2020 the National Labor Relations Board (NLRB) ordered the Company to go
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`forward with its first unionization vote in six years, at a warehouse facility in Bessemer,
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`Alabama. See https://www.cnbc.com/2020/12/22/amazon-moves-closer-to-facing-its-first-
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`unionization-vote-in-six-years.html (last visited January 6, 2021). The NLRB also found in
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`December 2020 that Amazon had unlawfully terminated Staten Island warehouse employee
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`Gerald Bryson in retaliation for his legally protected collective activity, soon after he had
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`participated in and led protests of unsafe conditions and organizing efforts in March and April
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`2020. See https://www.theguardian.com/technology/2020/dec/17/amazon-fired-warehouse-
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`worker-nlrb-gerald-bryson (last visited January 6, 2021). Mail-in balloting at the Alabama
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`facility begins on February 8, 2021.6
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`22.
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`Punching down from the boardroom at Black employees who are pleading for a
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`better, safer, more inclusive workplace does not match Amazon’s and Mr. Bezos’s professed
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`dedication to social justice for Black Americans.
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`23. When a company’s top leaders traffic in stereotypes of Black employees and fail
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`to condemn intimidation tactics, managers farther down the chain will take note of that modus
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`operandi and behave accordingly.
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`24.
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`Black Americans are an afterthought in Amazon’s operations to such an extent
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`that it is even demonstrated in how the Company develops and sells technology. Rekognition,
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`which is a brand of facial recognition software developed and launched by Amazon in or around
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`November 2016, has been found to misidentify Black individuals at a far greater rate than white
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`persons. At least one study found that, using photos of members of Congress, the Rekognition
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`6 See https://www.washingtonpost.com/technology/2021/02/02/amazon-union-warehouse-workers/ (last visited
`February 11, 2021).
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`9
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`software had an alarming rate of matching up photos to a database of criminals incorrectly (and
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`this rate was much higher for Black individuals). Yet, for years, Amazon widely sold the
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`product to police departments and law enforcement agencies across the United States—exposing
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`the public, and Black citizens in particular, to arrest and lethal danger. Mr. Jassy, AWS’s top
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`executive, in a PBS television interview said of the sale of Rekognition to police departments,
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`“Let’s see” whether law enforcement would “abuse the technology.”7
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`25.
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`At an AWS Public Policy off-site meeting in September 2019, Ms. Newman
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`publicly raised her concern to managers that there were no Black or female employees involved
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`in formulating policy positions regarding Rekognition. Her concern and suggestion were
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`rebuffed.
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`26.
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`It was not until a public outcry arose over Rekognition’s hazardous flaws and how
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`it could impact Black people, potentially leading to unjust arrests and convictions and
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`endangering lives, that Amazon announced that it would even temporarily, for one year, stop
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`selling the software (without owning up to the racially disparate impact of the product or ceasing
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`sales to federal law enforcement).8 In addition, Ring, an Amazon subsidiary that sells doorbell
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`surveillance software and hardware, has partnered with approximately 1,300 police departments
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`nationwide, forming a huge, warrantless surveillance network that also fuels suspicion and fear
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`of Black and brown people in local communities.9 Mr. Jassy later, in September 2021,
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`acknowledged in a Twitter thread that, “We still don’t get it in the US. If you don’t hold police
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`7 See https://www.nytimes.com/2021/02/03/technology/andy-jassy-amazon-ceo-jeff-
`bezos.html#:~:text=SEATTLE%20%E2%80%94%20In%202002%2C%20Andy%20Jassy,founder%20of%20the%2
`0online%20bookstore.&text=The%20idea%2C%20she%20said%2C%20was,thinking%20and%20anticipate%20his
`%20questions. (last visited February 11, 2021).
`8 See https://www.nytimes.com/2020/06/24/technology/amazon-racial-inequality.html;
`https://www.theguardian.com/technology/2018/may/22/amazon-rekognition-facial-recognition-police (both last
`visited December 11, 2020).
`9 See https://www.theguardian.com/technology/2020/jun/09/amazon-black-lives-matter-police-ring-jeff-bezos (last
`visited December 11, 2020).
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`10
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`depts accountable for the murdering of black people, we will never have justice and change, or
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`be the country we aspire (and claim) to be.”10
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`27.
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`Until August 2020, the elite management team curated by Mr. Bezos (the vaunted
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`“S-Team”) did not (unsurprisingly, given the above) have a single Black executive among its
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`approximately two dozen members (as recently as 2017, only one woman was among its 18
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`members at the time), and Amazon’s Board of Directors includes only one Black person (and has
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`had only one other Black person on it in its 25-year history). These trends in Amazon’s
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`leadership and workforce demographics show that Black people and other underrepresented
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`persons of color are being kept out of the Company’s upper ranks.
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`28. Mr. Bezos has expressed reluctance and resisted calls for him to take bold steps to
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`reinvent and diversify his S-Team, saying that, “I’m very happy that we don’t have a lot of
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`turnover on the S-team … I don’t intend to change that — I like you guys [on the S-Team] a lot.
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`I would expect any transition there to happen very incrementally over a long period of time.”11
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`29.
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`The lack of Black representation in top management is all the more glaring and
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`suggestive when considering that Amazon reports that approximately 26.5% of its employees
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`identify as Black or African-American,12 with the vast majority of the Company’s Black
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`employees (around 85% of them in 201413) working in its warehouses.
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`30.
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`There is a distinct ceiling for Black employees in Amazon’s corporate jobs. The
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`top Levels from Director (L8) on up, particularly in Ms. Newman’s area, have nearly zero Black
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`10 See https://www.nytimes.com/2021/02/03/technology/andy-jassy-amazon-ceo-jeff-
`bezos.html#:~:text=SEATTLE%20%E2%80%94%20In%202002%2C%20Andy%20Jassy,founder%20of%20the%2
`0online%20bookstore.&text=The%20idea%2C%20she%20said%2C%20was,thinking%20and%20anticipate%20his
`%20questions. (last visited February 11, 2021).
`11 See https://www.cnbc.com/2018/11/19/bezos-new-shadow-adviser-at-amazon-is-a-woman-of-chinese-
`descent.html (last visited December 11, 2020).
`12 See https://www.aboutamazon.com/news/workplace/our-workforce-data (last visited December 11, 2020).
`13 See https://www.welcometothejungle.com/en/articles/racism-big-tech-amazon-warehouse-workers-speak (last
`visited December 11, 2020).
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`11
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`senior employees, and few women as well. This imbalance and segregation of roles speaks
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`volumes about the low priority placed by the Company on advancing and hiring Black
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`employees into corporate roles, and how it makes the climb of even an excellent candidate and
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`employee like Charlotte Newman that much more steep.
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`31.
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`The root cause of this sustained pattern of underrepresentation of Black and
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`female employees in Amazon’s upper ranks can be detected in and traced to the stereotypical
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`perceptions of the Company’s management. Ms. Newman has observed and experienced these
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`racially and sexually discriminatory attitudes personally.
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`32.
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`In November 2019, a coworker of Ms. Newman made the revolting remark that
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`Ms. Newman looked “like a gorilla” in a black jacket. Such shocking racial insensitivity is
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`fostered by management’s neglect of racial equity issues and the Company’s lack emphasis on
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`workplace training and robust anti-discrimination policies. This was by far not the only instance
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`of racially offensive and dismissive conduct Ms. Newman experienced from coworkers and
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`managers.
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`33.
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`Charlotte Newman currently works at Amazon as a Senior Manager (Level 7).
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`She started at the Company in early 2017 after years of experience as a top advisor to U.S.
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`Senator Cory Booker and multiple members of the House of Representatives on financial
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`regulation and legislation. Despite being qualified for and having applied for a role at the level
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`of Senior Manager (L7), however, Ms. Newman was hired only at the level of Manager (L6),
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`which naturally also came with substantially lower compensation.
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`34. Ms. Newman was paid at that lower level for nearly all of her first three years at
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`the Company, despite the fact that she was given and did the work of employees at the higher L7
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`level (including taking on assignments across North and South America, as opposed to only in
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`12
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`the United States). Worse, this lower job level came with much lower awards of valuable
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`Amazon stock units, which have greatly increased in value and therefore magnify the
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`discriminatory pay disparity as time goes on.
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`35.
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`Amazon touts on its website its supposed record on pay equity, claiming that:
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`“A review of the compensation awarded in 2019 at Amazon,
`including base, cash bonuses, and stock, shows that women earned
`99.3 cents for every dollar that men earned performing the same
`jobs, and minorities earned 99.1 cents for every dollar that white
`employees earned performing these same jobs. We continue to
`prioritize pay equity.”14
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`By using these broad statistics, however, Amazon is hiding the ball. Even if
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`36.
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`employees who are Black and/or female are in the “same job” (i.e., title or Amazon Level) as
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`white and male employees, they are consistently being slotted into lower titles and job levels that
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`do not reflect their qualifications or true role and responsibilities. They are consistently being
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`underpaid for their qualifications and/or the work they are actually doing, while Amazon hides
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`this putting Black and female employees into lower titles and Levels where their white and male
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`coworkers also make less (but are functionally doing a lower-level job).
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`37.
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`Only Amazon employees who are at the Director (Level 8) level or higher have
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`access to detailed demographic and leveling data for the Company’s workforce, contributing to
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`the lack of transparency and a feeling that management is relatively indifferent to employees’
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`input and desire regarding addressing diversity concerns. Indeed, Amazon is out of step with
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`many of its peers at the top of the tech industry in this respect, as companies such as Facebook
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`(https://diversity.fb.com/read-report/) and Salesforce (https://equalitydata.herokuapp.com/ -
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`including a link to that company’s annual EEO-1 Report) openly provide access to much more
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`detailed workforce data.
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`14 See https://www.aboutamazon.com/news/workplace/our-workforce-data (last visited December 11, 2020).
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`13
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`38.
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`Amazon’s discriminatory hiring, compensation, and promotion practices in
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`corporate jobs reflect larger systemic racial and gender discrimination in the country. Black
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`women suffer an even larger pay gap as compared to white males than white women, and those
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`disparities grow when looking at higher-paying jobs that require more education and experience.
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`Black women with a Bachelor’s degree and/or advanced degrees statistically earn 38% less than
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`white men with the same level of education. See https://leanin.org/data-about-the-gender-pay-
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`gap-for-black-women (see footnote 5; last visited January 6, 2021). In fact, 2019 Census data
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`shows that in “Professional and related occupations,” Black women make a median annual
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`income of $51,974 and average income of $66,782, while white men make a median annual
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`income of $81,860 and $110,059 on average. See https://www.census.gov/data/tables/time-
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`series/demo/income-poverty/cps-pinc/pinc-06.2019.html (last visited January 6, 2021).
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`39.
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`Black women suffer a tremendous loss in earnings over their lifetimes to racial
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`and gender discrimination combined, and this fact has been established in other studies as well,
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`which noted unconscionable gaps in pay between white men and Black women with professional
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`degrees (approximately $80,000 for Black women and $130,000 for white men annually—a gap
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`of 39%), and which noted that the pay gap for Black women in Washington, DC is among the
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`very worst in the nation (second only to Louisiana). See https://nwlc.org/press-releases/the-
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`wage-gap-costs-black-women-a-staggering-946120-over-a-40-year-career-nwlc-new-analysis-
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`shows/ (last visited January 6, 2021); https://nwlc.org/wp-content/uploads/2019/08/Wage-Gap-
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`for-Black-Women.pdf (last visited January 6, 2021). See also
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`https://www.payscale.com/data/gender-pay-gap (gender pay gap widens with career progression;
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`last visited January 6, 2021); https://www.shrm.org/resourcesandtools/hr-
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`topics/compensation/pages/racial-wage-gaps-persistence-poses-challenge.aspx (noting that Black
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`women’s representation in high-wage occupations is less than half their representation in the
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`
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`overall workforce; last visited January 6, 2021); https://iwpr.org/wp-
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`content/uploads/2020/08/Black-Women-Equal-Pay-Day-Policy-Brief.pdf (noting that if current
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`statistical trends continued, the pay gap for Black women as compared to white men would not
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`close for 110 years—in the year 2130; last visited January 6, 2021).
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`40. Ms. Newman and other Black and female employees in corporate roles at
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`Amazon have spent years doing work beyond the Level at which the Company has hired them,
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`and they languish at these lower Levels and titles, falling behind their white and male
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`comparators in compensation and promotions. Therefore, Ms. Newman and other Black and
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`female employees are underpaid, even if the others working at the same assigned “Level” are
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`paid approximately the same amount—because, again, they and their white and male coworkers
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`at the same Level are not doing the same job.
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`41. Ms. Newman has worked extremely hard to advance the Company’s interests and
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`expand the reach of AWS’s products inside and outside the United States, making inroads for its
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`cloud-based products and services through meetings with the highest banking authorities in
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`countries including Argentina, Brazil, Canada, Chile, Colombia, and Mexico.
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`42. Ms. Newman has a track record of successful initiatives for AWS in the
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`Americas, establishing relationships with high-ranking banking authorities, and securing
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`approval for use of AWS’s products with financial regulatory authorities.
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`43. While doing her job and doing it extremely well, however, Ms. Newman also has
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`had to contend with entrenched attitudes on the part of managers who are skeptical of and
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`discount the contributions of Black and female employees at Amazon.
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`44.
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`On various occasions, Ms. Newman’s then-direct manager at AWS, Steven Block,
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`used stereotypical racial tropes when criticizing her about how she speaks in meetings, calling
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`her “aggressive,” “too direct,” and (shockingly) “just scary.” Of course, these loaded critiques
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`were directed at her despite the fact that being a contributor to group discussions is rewarded and
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`praised among the Company’s predominantly white and male workforce in her Public Policy
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`group. Ms. Newman immediately and sadly recognized these racial stereotypes and coded
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`comments for what they were, but forged ahead.
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`45.
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`Other female employees also were subject to baseless, vague, and unwarranted
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`judgments by managers, such as being deemed too “intense,” despite male employees being
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`praised for such personality traits.
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`46.
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`Amazon management’s dismissive attitude towards Black and female employees
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`like Ms. Newman left her vulnerable to sexual harassment and assault by a senior coworker,
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`Andres Maz. Mr. Maz, seemingly sensing her lower place in the pecking order and lack of
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`protection or prioritization by management, engaged in repeated sexual harassment of Ms.
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`Newman including repeated incidents of inappropriate, unwelcome touching and sexual assault.
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`47.
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`In January 2018, Mr. Maz felt free, at a dinner in Washington, D.C. with a third
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`colleague present, to put his hand under a restaurant table and press on Ms. Newman’s lap, close
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`to her genitalia, and grab and grope her upper thigh. Ms. Newman bolted from the table and
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`returned only after some time, taking a seat away from Mr. Maz. Apparently undeterred, Mr.
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`Maz later harangued Ms. Newman outside the restaurant as she waited for her rideshare home,
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`telling her to instead go home with him to have sex. Ms. Newman told Mr. Maz that she would
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`do no such thing.
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`48. Months later, during a work trip to Seattle, Mr. Maz yanked on Ms. Newman’s
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`hair, which was in long braids, when she announced that she was leaving a bar where various
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`coworkers had gathered, telling her to stay or leave her hair behind—a particular insult for a
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`Black woman. Later that evening, outside a different establishment, Mr. Maz unwelcomely put
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`his arm around Ms. Newman and said to her, “Let’s pretend we’re boyfriend and girlfriend.”
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`49.
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`These are only two of the various incidents of harassment that Ms. Newman had
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`to deal with from Mr. Maz while they worked together.
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`50. Ms. Newman is not alone among Amazon’s c