> 8. During this time, however, Plaintiffs became concerned with Lee's mental wellbeing and his ability to lead LTM and PIA. Plaintiffs noticed that Lee was a habitual user of marijuana and cocaine, and would frequently abuse drugs in the office in front of his employees. Lee often combined his drug use with alcohol and would act erratically.
> For example, he told-LTM 18 employees that he wanted to hire a female candidate simply because he wanted to have sex with 19 her. Similarly, Lee expressed his desire to set up a "modeling agency" in the Hollywood Hills that 20 would actually be a front for illegal prostitution (i.e., the "models" would be paid escorts). To that 21 end, Lee circulated a memo to male LTM executives advising them to make sure and wear 22 condoms when having sex with the "models." Lee went so far as to state that he planned to move 23 LTM's offices to the Hollywood Hills mansion once the "modeling agency" was set up.
I've been watching too many podcasts sponsored by ExpressVPN (Yes I'm aware Lee's VPN provider is PIA) and the host saying "Protect your data with ExpressVPN" played in my head, but modified to "Protect your junk with 22 condoms!".
> 102. Lee's increasingly erratic behavior made LTM a miserable place to work. In
addition to the long hours and high-stress environment at LTM, Lee's conduct made employees
uncomfortable and fearful for both their own wellbeing and the continued viability of the
company.
> 103. Lee would frequently use cocaine in front of LTM's clients, colleagues, certain
employees, and trusted advisors. Plaintiffs Ken, Jane, Michael, John, and James all personally
observed Lee's pervasive drug use.
> 104. Lee would regularly leave cocaine and marijuana residue in the office. Ken, who .
was typically the first to arrive in the office every morning, would find Lee's leftover food, drugs,
and alcohol bottles on work stations, and would clean everything up before other L TM personnel
arrived.
> 105. Lee made a habit of barging into Ken's living quarters in the middle of the night to
play loud music, entertain random women, and use drugs.
> 106. In or around February 2015, Lee wanted to hire an assistant. After interviewing a
particular female candidate, Lee-a married man-insisted on hiring her because he wanted to
have sex with her. Ken and Park talked Lee out of it, advising Lee that his requested conduct was
wrong and could cost L TM in a potential lawsuit. Lee retorted that he did not care about any
sexual harassment suit or potential liability for LTM because. he would pay any settlement out of
his own pocket.
> 107. Lee also stated that he wanted to start a "modeling agency" under the L TM
umbrella called "Breakout Agency." Lee rented a house in the Hollywood Hills for the "models"
to live in. Before renting the house and starting the agency, Lee circulated a draft memo to the
male LTM executives advising them to make sure to "wear a condom" when having sex with the
"models." The draft memorandum was outrageous and, like the incident above, could form the
basis of a potential sexual harassment suit. Again, Ken and Park were forced to talk with Lee and
insist that he refrain from sending such communication.
> 108. Lee further indicated to LTM personnel that he planned to move the company's
workspace to the house in Hollywood Hills, where they would work alongside the models. All
LTM personnel recognized that moving the company would create an unstable and unprofessional
work environment; and Jane in particular, as one of LTM's few female employees, was not
comfortable with the rampant sexism that this move presaged.
> 109. Making matters worse, Lee also had an ongoing relationship with a mistress that he
brought to company functions and the LTM offices, despite people knowing that he was married.
Lee met his mistress through a company offering female companionship for money. Lee
abandoned his wife and newborn child to spend time with this woman, and their relationship was
toxic. His mistress was physically and verbally abusive towards Lee, erratic and unpredictable,
and caused Lee to act over-emotionally.
> 110. The two fought on a daily basis. And this happened in front of LTM employees,
including Plaintiffs. For example, a few days after the February 2015 Meeting, Lee and his
mistress had a violent altercation at a club in front of Park, Ken, James, and other L TM personnel.
His mistress became infuriated and violent when Lee did not pay attention to her to attend to a
conference call concerning L TM business. She punched Lee in the face, causing Lee to lose a
tooth.
> 8. During this time, however, Plaintiffs became concerned with Lee's mental wellbeing and his ability to lead LTM and PIA. Plaintiffs noticed that Lee was a habitual user of marijuana and cocaine, and would frequently abuse drugs in the office in front of his employees. Lee often combined his drug use with alcohol and would act erratically.