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occurring within UTA, which were undertaken by or with
the authorization and ratification of, defendants
BENEDEK, BERKUS, STEVENS, ZIMMER, and COSAY. Over a
period of several months, Plaintiff made known to
defendants BENEDEK, BERKUS, STEVENS, ZIMMER, and COSAY
Plaintiff’s concerns that these acts and practices were
wrongful and/or illegal and could expose UTA to
liability, condemnation within the industry, loss of
clients, and general damage and harm. * * * The acts
and practices about which Plaintiff complained
included, but were not limited to, the following:
A. The defrauding of UTA clients through
misrepresentation that commission rates were in most
instances non-negotiable at 10% and uniform for all
clients, while in truth, UTA agreed to special reduced
commission deals with selected and favored clients;
* * * * * * *
D. Illegally recording, as phony “loans”
that were interest-free and never intended to be paid
back to UTA, payments made by UTA to [names redacted]
to cover country club fees, among other things, so as
to disguise income to said persons for tax purposes;
and
E. Condoning and tolerating illegal use of
controlled substances by UTA employees * * * and by one
member of the [redacted] who participated in the
illegal use of drugs with other employees of UTA at a
company retreat.
16. In response to Plaintiff’s complaints about
their improper and illegal conduct, defendants BENEDEK,
BERKUS, STEVENS, ZIMMER, and COSAY failed to put a stop
to the conduct and, in fact, gave every indication that
the conduct would continue.
* * * * * * *
21. * * * the conduct [of Mr. Polone] alleged [by
UTA] was not at variance with and in no instances worse
than the standards of conduct tolerated at UTA by
defendants in view of the fact that defendants had
themselves routinely committed sexual, for example,
misconduct in connection with their employment,
including sexual liaisons between [name redacted] and
various subordinate employees of UTA, and unwelcome
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