In July 2017, the claimant, a student at Southern Methodist University, in Dallas, entered into an employment contract with International Direct Mail Consultants Inc. (doing business as International Direct Marketing Consultants Inc.), which was owned by Lee McNutt III. The job required her accompany McNutt on business trips. The student originally met McNutt while babysitting for local families. McNutt offered the student various forms of work, including babysitting his children, dog sitting, and modeling. He then offered the student an internship with the “Silicon Valley Growth Syndicate,” for which she provided labor and services, beginning in January 2017. Eventually, the student was hired by International Direct Mail Consultants, which was also owned by McNutt. Her employment contract required to travel. During that time, the student continued to perform work on behalf of the Syndicate. Pursuant to her responsibilities for both the Syndicate and International Direct Mail Consultants, the student traveled to La Jolla, Calif., for an investor meeting in August 2017. However, she claimed that while in La Jolla, McNutt subjected her to harassing behavior. One month later, in August 2017, while in the employment of International Direct Mail Consultants and performing work on behalf of the Syndicate, the student discovered that McNutt had taken pictures of her without her permission. She also discovered numerous photographs of other young women that appeared to be taken without permission. The student later discovered that McNutt had sent a revealing photo and video of her to another man and that McNutt had discussed whether the other man should bring the student to California. As a result of past incidents, the student refused to stay with McNutt on a trip to Florida in January 2018. Two months later, her first lawyer sent McNutt a complaint alleging violations of state laws, and suggesting that the student be put on paid leave while they tried to resolve her complaints. The student was ultimately dismissed from the companies in June 2018. The student filed an administrative complaint with plaintiff the Department of Fair Employment and Housing, alleging that McNutt sexually harassed her while in California in July 2017. Following an investigation, the Department of Fair Employment and Housing determined that the McNutt and his companies violated the Fair Employment and Housing Act and Civil Code § 51.9. The Department of Fair Employment and Housing sued McNutt; International Direct Mail Consultants; Silicon Valley Growth Syndicate I, L.L.C.; Silicon Valley Growth Syndicate Fund I, L.P.; and the Syndicate’s co-founders, Russell Lewis and William Bunker. The Department of Fair Employment and Housing alleged that the defendants’ actions constituted sexual harassment, failure to prevent sexual harassment, and a violation of Civil Code § 51.9. The student filed a complaint-in-intervention against McNutt, alleging that McNutt’s actions constituted an invasion of privacy and an intentional infliction of emotional distress. Bunker and Lewis were ultimately dismissed from the lawsuit. The claimant alleged that, more than once, McNutt subjected her to unwanted sexual touching and comments, beginning on the trip to Fort Lauderdale, Fla., in July 2017. She also alleged that during the business trip to California in August 2019, McNutt again subjected her to harassing behavior, including pushing money between her thighs, taking her to a nude beach, and massaging her buttocks. She further alleged that, during that same month, she discovered that McNutt had taken pictures of her in public places without her permission. In addition, the claimant alleged that rather than putting her on paid leave until the companies completed their investigation of her complaints, as suggested by her first lawyer, the defendants dismissed her from the companies in June 2018. Defense counsel asserted that the claimant had a one-year employment contract with International Direct Mail Consultants, which required the claimant to travel and that between July 2017 and November 2017, the claimant accompanied McNutt on business trips to Ft. Lauderdale, Fla.; Reno, Nev.; San Diego; Austin, Texas; and New Orleans. Counsel contended that despite the claimant alleging that she was harassed in July 2017 and August 2017, and alleging that she discovered photos of her taken without her permission in August 2017, the claimant continued to join McNutt on the three remaining business trips. Defense counsel further contended that two months after the claimant refused to stay with McNutt on the Florida trip, she stopped going to work. In addition, counsel asserted that after the claimant’s first lawyer sent the complaint letter to McNutt, the claimant’s one-year employment contract ended in June 2018 and was not renewed., The claimant alleged that she suffered from emotional distress as a result of the incidents. The Department of Fair Employment and Housing sought injunctive relief and recovery of attorney fees. It also sought recovery of compensatory damages for the claimant’s alleged past and future emotional pain and suffering.