Sexual Harassment and Retaliation at JRM Construction Management

On March 24, 2025, The Law Office of David H. Rosenberg P.C. (“Firm”) filed a verified complaint of sex discrimination and retaliation on behalf of its female client (“Complainant”) against Respondents JRM Construction Management (111 West 33^rd Street, New York, NY, 10120); male CEO Joseph Romano (“Romano”), female graphic designer Alyssa Stacom (“Stacom”), female director of human resources Anna Levitt, female graphic designer Carolina Pena (“Pena”), female senior marketing specialist Emily Patterson (“Patterson”), and male director of marketing Sunny Khan (“Khan”), with The New York State Division of Human Rights. 

As alleged in the verified complaint, Complainant commenced employment in September 2023. Complainant was a dedicated, hard worker who was also well-liked by co-workers and customers. Notwithstanding this, Complainant was discriminated against on account of sex and retaliated for opposing discriminatory practices. 

According to the verified complaint, Stacom offered a drink to Complainant on December 20, 2023, at the holiday party. Complainant said “No”. Stacom, in front of the entire marketing team of Khan; male senior innovation manager James Ward; Pena, Patterson, Bailey Jordan (“Jordan”, female marketing coordinator); and Alexis Moore (“Moore”), female graphic designer, and all together as (“Team”), told Complainant, “People who don’t drink are so boring,  I better not have too much to drink, or I’ll end up bringing someone to the office to fuck again.” Stacom turned to Khan and said, “What, I can talk about it, HR can’t fire me, I’ve been here six years.” Stacom turned back to Complainant and said, “Do you want to take this outside?” Complainant said, “No.” 

As alleged in the verified complaint, Stacom said to Complainant, “I won’t suck a dick unless it’s eight inches, I feel sorry for anyone who does” on or around March 22, 2024. On or around April 22, 2024, Complainant was using headphones for work but could still hear Pena say to Stacom, “I hope she goes deaf from those stupid headphones, then she won’t need them.” 

According to the verified complaint, on May 15, 2024, at a Team lunch celebrating the close May birthdates of Moore and Complainant, Stacom said words to the effect of:

“Oh you’re so young, if I were you, I’d fuck as many guys as possible before settling down. I went on over 200 dates before I settled with my boyfriend. Oh my God, you got your steak cooked well done; that’s disgusting. I hate when people get well done when they have never even tried medium cooked steak.”

Stacom then put her medium-cooked steak onto Complainant’s plate, grabbed Complainant’s arm, and said, “Eat it, you need to try it, just try it.” Complainant said, “No.” 

In reference to a conversation Complainant was having, Stacom asked, “What the hell is Bluey?” Complainant said, “It’s a show I watch it with my brother” to which Stacom responded, “That show sounds retarded, it must be a show for retarded kids, your brother must be retarded.” Complainant told Stacom to stop, to which Stacom replied, “Oh, sorry, I didn’t mean it in a bad way. I have a retarded cousin myself.” 

According to the verified complaint,, on June 3, 2024, Complainant said to Khan generally:

“I felt extremely uncomfortable at lunch. Alyssa made fun of me for ordering a well-done steak and tried to basically force-feed me her medium-cooked steak by putting it on my plate and grabbing my arm. Then, when I was explaining what Bluey was, she called the show retarded, and that my brother must be retarded.”

Khan said words to the effect of, “I know. I saw. Alyssa was out of control. I’ll talk to her, and it’s best we handle this internally.” 

As alleged in the verified complaint, on June 7, 2024, Khan told Complainant generally:

“I spoke with Alyssa, everything should be fine going forward. Between you and me, her dad is a vice president of another construction company we need, and this team was the only one from the Company that would take her, and keep that between us, but, I wouldn’t worry moving forward.”

According to the verified complaint, Stacom, aware that Complainant’s male significant other was in dental school, said to Pena at a volume loud enough for Complainant to hear on June 12, 2024, “Did you know dentists are the number one profession to commit suicide, I feel bad for their husband or wives.”  

As alleged in the verified complaint, on June 20, 2024, Stacom said to Pena in a voice loud enough for Complainant to hear, “Benjamin Blanck put tentative for yoga he’s so fucking fat, how is he even going to touch his toes, why did he even sign up?” Pena responded, “I don’t know why people let themselves get that fat, it’s disgusting.”

According to the verified complaint, Patterson said to Stacom and Pena on July 21, 2024, at a volume loud enough for Complainant to hear, “Sunny needs to stop hiring girls; the next person he hires should be a guy,” to which Stacom and Pena nodded their heads in agreement. 

As alleged in the verified complaint, on August 8, 2024, Stacom said to female intern Kiana Jiminez, in a voice loud enough for Complainant to hear, “Can you grab a few things from the supply closet for me, I’m sorry, I’m still drunk from yesterday, so I can’t do it myself right now.”

According to the verified complaint, Patterson asked Pena on September 9, 2024, at a volume loud enough for Complainant to hear, if she had seen Complainant’s hairstyle to which Pena responded, “It’s fucking stupid, it looks like something you get on vacation as a kid.” 

As alleged in the verified complaint, on September 18, 2024, Stacom said to Complainant in a Team Meeting, “Your mom must have had an affair,” in reference to the tiny proximity between Moore’s and Complainant’s May birthdates. Complainant opposed the treatment towards the end of the meeting by saying, generally, “I don’t like your jokes about my family in front of the team; it’s inappropriate.” Stacom replied:

“Girl, you got it twisted. Clearly you don’t know how to talk about things because you want to bring it up at the end of a meeting, which is fucking awkward. Yeah, well, too bad, I’m cursing, you would have to bring HR, you would.”

Later, Stacom sent 14 Team group texts to Complainant, saying generally:

“Thank God I don’t have to work with you. This was a miscommunication because the joke was made to Alex and not you. I’ll never reach out because I never need to. I would never call your brother retarded, and the mom comment was a total joke to Alex. Try to be more understanding because we have opposite personalities.”

Stacom called Complainant twice and left a voicemail saying, generally, “You should be able to talk to me like an adult. You’re going to have to see me every day. You’re going to have to see me tomorrow.” 

According to the verified complaint, on September 19, 2024, Complainant said generally to Khan:

“Alyssa is making work extremely uncomfortable with inappropriate sexist comments. She has been openly bullying me, called my brother retarded, grabbed my arm, tried to force-feed me her steak, she is saying ‘my mom had an affair, it’s escalating and starting to create a domino effect, a group mentality of bullying within the team.”

Khan replied generally: 

“I’m sorry that you feel this way, I hear what you’re saying, Alyssa shouldn’t make comments like that, I’ll have a conversation with her, there’s no excuse for it. It shouldn’t be like that at work.“

Complainant complained to female human resources administrator, Myriah Whitted (“Whitted”), generally:

“Alyssa has been harassing me. At my birthday she made fun of me for ordering steak well done, grabbed my arm, tried to force-feed me, and called my brother retarded for watching Bluey. During a Team meeting, she said my mom must have had an affair. I told her to stop but she got angry, sent 14 angry texts, 2 phone calls to my cell, and left an angry voicemail. At work she makes offensive jokes, including calling an employee too fat for yoga.”

As alleged in the verified complaint, on September 20, 2024, Levitt told Complainant generally:

“I’m sorry, sounds like you’ve been going through this over and over again. Sometimes managers think it’s better to handle things internally, I’m sorry you had to go through this for a couple of months. Everyone on the Team will know that this will not be acceptable.”

According to the verified complaint, on September 26, 2024, Levitt said words to the effect of: 

Sunny and I had a conversation with Alyssa. It landed in the right place for her; she understood and admitted it wasn’t intentional. She is going to work on herself, and I think it was out of her control. She doesn’t realize what she says because she doesn’t even remember, which matches with her voicemails when she totally blacks out on what happened. I told her this needs to stop. She was given a written warning, and if anything happens again, it will be taken very seriously.

Later, at Complainant’s desk in a volume loud enough for Complainant to hear, Stacom said to Pena, “She’s a fucking snitch.”

As alleged in the verified complaint, Pena said to Jordan and Patterson on October 20, 2024 in a voice loud enough for Complainant to hear, “Her pathetic ass went to HR, let (Complainant) send out these emails for the questionnaires from now on, screw her.” Patterson replied, “Yeah.” 

According to the verified complaint, on October 24, 2024, Pena said to Jordan and Patterson, at a volume loud enough for Complainant to hear, “What kind of dumb bitch complains to HR, like hello” to which Patterson replied, “An asshole would.” 

As alleged in the verified complaint, Complainant told Khan generally on October 25, 2024, “I overheard Carolina talking with Bailey and Emily about how they want me to take on emailing these questionnaires to retaliate with more work just because of the fact I went to HR.” 

Notwithstanding this complaint, the hostility at work continued. 

According to the verified complaint, on November 18, 2024, Patterson said to Pena in a voice loud enough for Complainant to hear, “(Complainant), I know dresses like a hobo.” Complainant reported to Khan generally: 

“Carolina, Alyssa, and Emily have been calling me names like asshole and dumb bitch. Recently, Emily and Carolina said we need to hire a guy next and is tired of us always hiring girls. Alyssa, Carolina, and Emily have made the office a hostile work environment for me.”

Khan told Complainant generally that “transitioning” to another job would be best. 

As alleged in the verified complaint, on December 5, 2024, Khan told Complainant she would receive a $2,000.00 bonus. On December 6, 2024, Complainant received the following text from a sender not in her contact list: 

“Hey, I need you to write something. Is that too much for you? Fucking idiot, nobody will care when you’re gone, loser. Cry about it to the boss or HR. JRM needs someone who isn’t fucking stupid like you. Thanks, bitch. [kiss emoji] [heart emoji] This is what you and your family look like to us in case you think anyone gives a fuck about you.”

As also alleged, the text also contained a graphic close-up image of a hairy anus and vagina. After blocking the number, Complainant reported this incident to Khan, who instructed her to report it to Levitt. Complainant repeated the incident to Levitt, who said, “I will let IT know immediately, but is this your work phone or personal?” to which Complainant confirmed it was her work phone. 

According to the verified complaint, in response to Complainant having received $1,500 instead of $2,000 in bonus, Khan told Complainant on December 20, 2024:

“The number was Marc’s fuck up, not mine, it was $1500, but I think when we were looking at the sheet, I must have mixed something up, or he must have mixed something up. The actual number in the sheet that he had was supposed to be $1500. I’m sorry.”

Also, according to the verified complaint, on January 6, 2025, as Complainant was eating a snack, Pena said to Patterson, at a volume loud enough for Complainant to hear, “It’s so fucking loud” to which Patterson replied, “Yeah, she’s like a pig on a farm.” 

As alleged in the verified complaint, on January 13, 2025, Khan told Complainant she would be terminated as of February 7, 2025. 

According to the verified complaint, on February 7, 2025, Romano terminated Complainant on account of sex and in retaliation of her opposition to discriminatory practices.

Also, according to the verified complaint, the Firm is seeking all available damages under those statutes, including those covering compensatory, emotional, and punitive damages, together with maximum civil penalties, fines, and a reinstatement order from New York State. 

If you or someone you know is suffering at work, contact the Firm at (516) 741-0300.

The information and allegations cited to herein comes directly from publicly filed documentation and are meant as a means of attorney advertising. 

The information and allegations cited to herein comes directly from publicly filed documentation and are meant as a means of attorney advertising.