Case No. BC318102

Attorney K. Arianne Jordan

First Amended Complaint For Damages

1. Sexual harassment

2. Retaliation

This is a classic case of quid pro quo sexual harassment in which Scott Taylor, the President of several adult entertainment companies, pursued and became obsessed with a salacious sexual relationship with his 18 year old employee, Deena DeRosa. Despite the fact that Ms. DeRosa was him employee and more than 20 years his junior, Mr. Taylor used his power and position as President of the Defendant Companies to entice her into a lurid sexual relationship in which Mr. Taylor demanded that Ms. DeRosa make herself available for sexual trysts at all times convenient for him, notwithstanding the effect that this would have on Ms. DeRosa’s ability to perform her job duties. When the sexual relationship between Ms. DeRosa and Mr. Taylor ended, the Defendants retaliated against her by demoting her from Vice President of Sales to data processing assistant, a position that paid substantially less, with the goal of forcing her to resign from the Defendant’s employ. In addition to this treatment, Ms. DeRosa was forced to work in an environment pervaded by sexual hostility towards women including…offensive behavior and comments. The unfair and illegal treatment that Ms. DeRosa was subjected to by the Defendants has caused her substantial psychological and economic damages.

11. Ms. DeRosa was initially employed as an assistant to Leilani Whitney, the managing director of the companies. Thereafter, due to her exemplary performance, she was promoted to Vice President of Sales in or about March 2001.

12. Beginning in or about January 2001, Defendant Taylor initiated and pursued an obsessive intimate relationship with Ms. DeRosa. The relationship lasted approximately two years. Defendant Taylor’s affair with Ms. DeRosa included unannounced visits to her apartment very late at night during the work week. Defendant Taylor initiated sexual liaisons in his office before work, during work hours, and on weekends. Defendant Taylor took Ms. DeRosa to numerous locations to have sex including, but not limited to, a Hyatt hotel at a “Park-n-Ride” location in Porter Ranch and in a parking lot at Chatsworth Park. Defendant Taylor bought Ms. DeRosa expensive jewelry and other gifts and contributed monthly payments for her apartment. Defendant Taylor communicated with Ms. DeRosa during the work day by instant messaging her and by calling her into his office whenever he desired. These communications and visits to Defendant Taylor’s office decreased Ms. DeRosa’s ability to generate telephone sales, which was her primary function as Vice President of Sales.

13. Defendant Taylor spied on Ms. DeRosa in order to know what she was doing at all times when he was not with her. He demanded that employees of Defendant Companies report to him regarding their knowledge of Ms. DeRosa’s personal life. As a result of Defendant Taylor’s actions, Ms. DeRosa was worried and concerned that if she did not participate in the relationship, that her job as well as that of her mother (who also worked for the Defendant), would be placed jeopardy.

14. The intimate relationship between Defendant Taylor and Ms. DeRosa ended in or about March or April 2003. Defendant Taylor’s wife discovered their relationship and demanded that Defendant Taylor end it. Defendant Taylor’s wife also demanded that he fire Ms. DeRosa as soon as possible.

15. In or about April 2003, Ms. DeRosa was demoted…and her salary was reduced from $20 per hour to $12…

16. [I]n April 2004, Ms. DeRosa filed her administrative complaints with the California Department of Fair Employment & Housing (DFEH). Ms. DeRosa was placed on paid administrative leave.

17. Ms. DeRosa’s mother, Penny DeRosa, was terminated from her position at Defendant companies in or about late March or April 2004. Ms. DeRosa is informed and believes and thereon alleges that the termination of her mother’s employment was a further act of retaliation against her for her complaints of sexual harassment and for her termination of her sexual relationship with Defendant Taylor.

18. Ms. DeRosa is informed and believes and thereon alleges that Defendant Companies and Does 1 through 25 knew or reasonably should have known that Defendant Taylor was sexually harassing, discriminating, and retaliating against her and that, as a direct and proximate result of those violations, she would suffer injuries as alleged herein. Moreover, Defendant Companies and Does 1 through 25 created and fostered a sexually hostile work environment wherein offensive and derogatory statements and conduct were directed towards women.

21.

C. Defendant Taylor’s expectation that Plaintiff engage in sexual relations with him in return for preferential treatment in the workplace.

D. Defendant Taylor’s unwelcome visits to Plaintiff’s apartment very late on week nights and insistence that Plaintiff make herself available to him for sexual relations very early in the morning before work.

F. Defendant Taylor’s inappropriate sexual comments to Plaintiff including comments about giving her a “birthday spanking.”

H. Defendants’ acts of permitting male employees to watch sexually explicit films in the workplace, unrelated to their work duties, and allowing those employees to openly make comments in the workplace about the “sluts” and “skanky hos” in the films.

I. Defendants’ acts of permitting male employees to write sexually offensive and derogatory comments about women on posters bearing their likeness that were posted on walls in the workplace.

48. Plaintiff has been caused to suffer and continues to suffer severe emotional and mental distress, anguish, humiliation, embarrassment, shock, discomfort, and anxiety. The exact nature and extent of said injuries is presently unknown to Plaintiff, who will seek leave of Court to assert the same when they are ascertained. Plaintiff does not know at this time the exact duration or performance of said injuries but is informed and believe, and thereon alleges, that some of the injuries are reasonably certain to be permanent in nature.

I don’t think any porn company owner in the past decade has had more porn women than New Sensations owner Scott Taylor, who is married with kids. A handsome charismatic guy with a ton of money, Scott has gone through porn stars by the bushel as well as some of his attractive female employees.

Scott had a long-running affair with one employee, Deena DeRosa, who was only 18 when it began (she’s 20 years younger than Scott). It lasted two years. Soon after it broke up, he fired her and then her mom Penny. Deena then sued him for sexual discrimination in the Spring of 2004.

Other porn company owners who have had more than their share — Gabor Esterhazy of Heat Wave (particularly likes black women, has probably had more than 100 porn girls), John Bowen, and, back in the day, Steve Hirsch.

From a www.adultbeat.com interview with Scott Taylor January 8, 2004

A former long-haired rock musician, Scott Taylor started in porn in 1985 as a salesman selling videos to video stores over the phone. “It didn’t matter that you had long hair. I started with a one-stop distributor after that called National Video Supply. Through the profits of the distribution company, I started New Sensations (about 1990). For a long time, I was just doing Video Virgins, a one-room pro-am thing. We released nine movies a year. I started Digital Playground [in 1993]. We did that for five years together. I was the president of the company. I started with the guy who calls himself Joone.”

What do you do in your spare time?

“Family time. I’m married with kids. I’ll put in long days at the office five days a week, but on the weekend, it is time to go to the toy store, construction site, the park…”