A link to the original complaints

On or about May 2003, Defendant BILL O'REILLY called Plaintiff at her home to ask her if she thought he was a boxers or briefs type of guy. Plaintiff expressed disinterest and eventually O'REILLY revealed that he alternates between both boxers and briefs. O'REILLY went on to mention that he briefly dabbled in wearing no undergarments, but he ultimately decided it was not for him. Plaintiff felt she did not need this information.

On or about early September 2003, Defendant BILL O'REILLY sat down for lunch with Plaintiff in the Fox News cafeteria. During the course of the meal, O'REILLY made a lewd gesture with his hot dog, which then slipped from his hand into his lap in a most comical way. Ketchup stains were still visible on his suit when he appeared on "The O'Reilly Factor" later that evening. Plaintiff found the experience upsetting but humorous.

On or about November 2003, Defendant BILL O'REILLY called Plaintiff to invite her over to look at a "really cool" logo he had just drawn for "The O'Reilly Factor." O'REILLY felt he had "really nailed" the illustration of himself holding an American flag, but he could not quite get the eagle right. Plaintiff told O'REILLY that she is not an artist and cannot help him.

On or about early December 2003, Defendant BILL O'REILLY spotted Plaintiff Christmas shopping at a local mall. Plaintiff tried to signal that she was not interested in small talk by giving O'REILLY the most dismissive of acknowledgements and walking away, but O'REILLY did not pick up on Plaintiff's cue and followed alongside her, describing a case of mistaken identity he had once faced in a New Delhi brothel. Before leaving, O'REILLY gave Plaintiff an awkward hug. Plaintiff felt uncomfortable.

On or about Casual Friday, January 9, 2004, Defendant BILL O'REILLY wore to the office a bawdy t-shirt which suggested that he was too inebriated to engage in sexual activity. When asked by O'REILLY what Plaintiff thought of the shirt, Plaintiff told him she thought it was juvenile. Plaintiff was upset when she later spotted O'REILLY showing his shirt to a group of interns, who then laughed uproariously.

On or about early February 2004, O'REILLY called Plaintiff in an attempt to figure out the name of a song he had just heard on the radio. O'REILLY proceeded to sing some of the lyrics, which were full of sexual innuendos. Plaintiff told O'REILLY she did not have any idea what song it might be. O'REILLY grumbled under his breath and hung up.

On or about late May 2004, Defendant BILL O'REILLY, apparently intoxicated, called Plaintiff from a house party thrown by [FOX President] Roger Ailes. O'REILLY complained that Mr. Ailes' assertion that he would know a lot of people at the party was incorrect. O'REILLY said he was having a terrible time and what he really needed was just to hear a friendly voice. Plaintiff was annoyed, but felt sorry for the big galoot.