Rose Exhibits

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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK
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Katherine Brooks Harris, Sydney McNeal and :
Yuqing ("Chelsea") Wei, Index No. 154172/2018
Plaintiffs,
PLAINTIFFS'
: AFFIRMATION OF
- against - PLAINTIFFS'
COUNSEL IN SUPPORT OF
: MOTION TO COMPEL DISCOVERY
Charlie Rose Inc., and Charles Peete Rose Jr.
a/k/a Charlie Rose, :
Defendants. :
---------------------------------- X
I, KENNETH A. GOLDBERG, hereby affirm as follows:
1. I am counsel for Plaintiffs in the above-referenced matter. I make this affirmation
Plaintiffs'
in support of motion to compel discovery.
2. Attached hereto as Exhibit 1 is a true and correct copy of the Complaint filed in
"Compl."
this action (cited as or NYSCEF #1).
3. Attached hereto as Exhibit 2 are true and correct copies of Affidavits previously
filed by Plaintiffs in this action (NYSCEF ## 63-65).
4. Attached hereto as Exhibit 3 are true and correct copies of excerpts from the
transcript (unsigned) of the November 14, 2019 deposition of Mr. Rose. Certain pages contain
Plaintiffs'
redactions with respect to certain matters that are not cited in motion.
Defendants'
5. Attached hereto as Exhibit 4 is a true and correct copy of counsel's
December 6, 2019 letter with written objections to various deposition questions. For the Court's
Plaintiffs'
convenience, counsel has numbered the specific objections from 1 through 29.
6. Attached hereto as Exhibit 5 is a true and correct copy of a Washington Post
Plaintiffs'
article, dated November 20, 2017, marked as Deposition Exhibit 26.
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7. Attached hereto as Exhibit 6 is a true and correct copy of a document produced by
Plaintiffs'
Plaintiffs, marked as Deposition Exhibit 7.
8. Attached hereto as Exhibit 7 is a true and correct copy of a document produced by
Plaintiffs'
Plaintiffs, marked as Deposition Exhibit 28.
9. Attached hereto as Exhibit 8 is a true and correct copy of an e-mail from Mr. Rose
Plaintiffs'
to Plaintiff Wei, marked as Deposition Exhibit 12.
10. Attached hereto as Exhibit 9 is a true and correct copy of an e-mail from Mr. Rose
Plaintiffs'
to CBS, marked as Deposition Exhibit 14.
11. Attached hereto as Exhibit 10 is a true and correct copy of a Washington Post
Plaintiffs'
article, dated May 3, 2018, marked as Deposition Exhibit 36.
12. Attached hereto as Exhibit 11 are true and correct copies of excerpts from the
transcript (unsigned) of the October 28, 2019 deposition of Kyle Godfrey-Ryan.
13. Attached hereto as Exhibit 12 are true and correct copies of the Affidavits of
Joana Matthias and Molly Broughton Peter, stamped with Bates Numbers P1223-P1227.
14. Attached hereto as Exhibit 13 is a true and correct copy of a document stamped
with Bates Numbers P0059-P0063.
15. Attached hereto as Exhibit 14 is a true and correct copy of an e-mail (and
Plaintiffs' Defendants'
attachment) from counsel to counsel, dated September 20, 2019.
16. Attached hereto as Exhibit 15 is a list of deposition questions identified in
Plaintiffs'
memorandum of law as to questions/lines of questioning raised in the motion.
I declare under penalty of perjury that the foregoing is true and accurate to the best of my
knowledge, information and belief.
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Dated: New York, New York
January 6, 2020
By: /s/ Kenneth A. Goldberg

Kenneth A. Goldberg
488 Madison Avenue, Suite 1120
New York, New York 10022
Telephone: (212) 983-1077
Facsimile: (212) 973-9577

kgldbrg@aol.com
Attorneys for Plaintiffs
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Yuqing ("Chelsea") Wei,

: Index No.
Plaintiffs,
:
- against - SUMMONS
:
CBS News Communications Inc., CBS News
Inc., Charlie Rose Inc., and Charles Peete Rose : Date Index No. Purchased:
Jr. a/k/a Charlie Rose, May 4, 2018
:
Defendants.
----------------- --- --- --- --- --- -- x
To The Above Named Defendant(s):
CBS News Communications Inc.

CBS News Inc.
51 West 52nd Street
Charlie Rose Inc.

Charles Peete Rose Jr. a/k/a Charlie Rose
781 Fifth Avenue
You are hereby summoned to answer the complaint in this action and to serve a copy of
your answer, or, if the complaint is not served with this summons, to serve a notice of appearance
on the Plaintiff's Attorney within 20 days after the summons, services
exclusive of this
of the day
of service (orwithin thirty days after the service is complete if this summons is not personally
delivered to you within the State of New York); and in case of your failure to appear or answer,
judgment will be taken against you by default for the relief demanded in the complaint.
The basis of venue location of incident/occurrence which is New York County.
May 4, 2018
Yours, etc.,
/s/ Kenneth A. Goldberg

Kenneth A. Goldberg
Goldberg & Fliegel, LLP

192 Lexington Avenue, Suite 902
(212) 983-1077
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Yuqing ("Chelsea") Wei,

:
Plaintiffs, COMPLAINT
:
- against -
:
CBS News Communications Inc., CBS News
Inc., Charlie Rose Inc., and Charles Peete Rose :
Jr. a/k/a Charlie Rose,
:
Defendants.
---------------------------------- X
NATURE OF THE ACTION
1. This case is about blatant and repeated sexual harassment committed by Charlie
Rose, a 70+ year old powerful American television journalist and talk show host, against three
junior female employees in their 20s, and subsequent unlawful retaliation -including deplorable
conduct that has been widely reported by, among others, the Washington Post.
OVERVIEW OF THE NEW YORK CITY HUMAN RIGHTS LAW
2. This action is brought under the New York City Human Rights Law, as amended
("NYCHRL"), N.Y.C. Admin. Code § 8-101 et seq., which is widely considered to be among the
broadest and most protective laws against discrimination in the nation.
3. Under the NYCHRL, "discrimination shall play no role in decisions relating to
employment." (1"
Williams v. NYC Hous. Auth., 61 A.D.3d 62, 78 Dep't 2009), lv. to appeal
denied, 13 N.Y.3d 702 (2009) (emphasis supplied).
4. Under the NYCHRL, liability arises when a plaintiff is "treated less well because
her"
of protected status. Id.
effect."
5. The NYCHRL is to be applied to "maximum deterrent Bennett v. Health
Mgmt. Sys., Inc., 92 A.D.3d 29, 43 (1st Dep't 2011), lv. to appeal denied, 18 N.Y.3d 811 (2012).
6. The NYCHRL "shall be construed liberally for the accomplishment of the
thereof."
uniquely broad and remedial purposes Loeffler v. Staten Island Univ. Hosp., 582 F.3d
268, 278 (2d Cir. 2009), quoting N.Y.C. Admin. Code § 8-130.
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7. The liberal, uniquely broad and remedial purposes of the NYCHRL shall be
applied "regardless of whether federal or New York State civil and human rights laws, including
]"
those laws with provisions comparably-worded [ . . . ] have been so construed [ . . . . Id.; see
also Williams, 61 A.D.3d 62, 66 (the protections provided by the NYCHRL go beyond those of
federal and state civil rights laws).
THE PARTIES
8. Plaintiff Katherine Brooks Harris is an adult female residing in New York.
9. Plaintiff Sydney McNeal is an adult female residing in Texas.
10. Plaintiff Yuqing ("Chelsea") Wei is an adult female residing in New York.
11. Defendant CBS News Communications Inc. is a New York domestic business
corporation, doing business in New York, New York and having a principal place of business
and/or address in New York, New York.
12. Defendant CBS News Inc. is a foreign business corporation, doing business in
New York, New York and having a principal place of business and/or address in New York, New
York.
13. Defendants CBS News Communications Inc. and CBS News Inc. are individually
"CBS."
and collectively referred to herein as
14. Defendant Charlie Rose Inc. is a foreign business corporation, doing business in
New York, New York and having a principal place of business and/or address in New York, New
York.
15. Defendant Charles Peete Rose Jr. a/k/a Charlie Rose, and referred to herein as
Rose,"
"Mr. is an adult male, residing in New York.
16. Charlie Rose Inc. and Charlie Rose are individually and collectively referred to as
"Rose."
"Companies,"
17. CBS and Rose are referred to herein as the are jointly and severally
employers."
liable herein, and are also liable herein as "joint
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JURISDICTION AND VENUE
18. The events giving rise to the claims set forth herein occurred within the State of
New York and the City of New York.
Plaintiffs'
19. This Court has jurisdiction over NYCHRL claims under the NYCHRL.
20. This Court has jurisdiction over Defendants pursuant to New York law, including
without limitation Sections 301 and/or 302 of the New York Civil Practice Law and Rules (the
"C.P.L.R.").
21. Venue is proper in this County pursuant to New York law, including without
limitation Section 503 of the C.P.L.R.
BACKGROUND
A. CBS
22. CBS is a longstanding American television and radio service and its broadcasts
include, among others, the CBS Evening News, CBS This Morning, CBS Sunday Morning, 60
Minutes, 48 Hours, Face The Nation and other programs.
23. CBS has broadcasting studios in New York City at 524 W 57th St., New York,
NY 10019 ("CBS Studios").
B. Rose
24. Mr. Rose is 70+ year old American television journalist and former talk show
host.
25. During the 1980s, Mr. Rose co-anchored the CBS program Nightwatch.
26. From about 1991 to 2017, Mr. Rose was the host and executive producer of his
own talk show Charlie Rose.
27. That show was produced by Charlie Rose Inc. (Mr. Rose's independent television
production company), was filmed at Bloomberg LP headquarters at 731 Lexington Avenue, New
York, New York ("Charlie Rose Studios"), and was distributed by PBS.
28. From about 2012 to 2017, Mr. Rose also co-anchored CBS This Morning.
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29. At times, Mr. Rose substituted for the anchor of the CBS Evening News.
30. For years, and at various times, Mr. Rose was a correspondent for the shows 60
Minutes and its spinoff 60 Minutes H.
31. Upon information and belief, in November 2017, Mr. Rose's employment at CBS
was terminated and his talk show Charlie Rose was cancelled.
32. Upon information and belief, CBS had a history of workplace sexual harassment
against women over a period of decades from at least the 1980s forward.
33. Upon information and belief, Mr. Rose himself sexually harassed more than two
dozen women at CBS over a period of decades from at least the 1980s forward.
34. As noted above, during the 1980s, Mr. Rose anchored Nightwatch.
35. Upon information and belief, in 1986, during Mr. Rose's tenure with Nightwatch,
seven female employees that worked for CBS on that program, filed a lawsuit against CBS
alleging sexual harassment by the executive producer and other managerial employees, captioned
Balsam v. CBS, Inc., CA07220-86 (Superior Court, District of Columbia, Civil Division).
36. Upon information and belief, CBS was fully aware of Mr. Rose's sexual
harassment and other sexual harassment but failed to take any remedial action for decades and
allowed Mr. Rose and others to continue to engage in sexual harassment for decades.
C. Ms. Harris
37. In or about January 2016, Ms. Harris, in her low 20s, joined CBS as a Broadcast
Associate for CBS This Morning, at the CBS Studios.
38. Ms. Harris was assigned to work the night shift and thereafter was briefly assigned
to work in the CBS Studios during the morning hours.
39. Ms. Harris, while working in the CBS Studios during the morning hours, noticed
that Mr. Rose, then a co-anchor on CBS This Morning, was there and was staring at her.
40. Mr. Rose approached Ms. Harris and said that he had heard that she was smart
and had talked to Ryan Kadro (Executive Producer) about her.
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41. Mr. Rose then began taking her to lunch at expensive restaurants, where he
bought her wine and floated job opportunities at 60 Minutes and at Charlie Rose, his PBS show.
42. In March 2017, Rose verbally offered Ms. Harris employment with Charlie Rose
letter"
Inc., based in Manhattan, and, on or about April 11, 2017, issued an "offer to her.
43. The offer letter stated, among other items, "I want you to be at the center of my
day," celebrate"
professional world....", "You help me get through the "we will and "I look
lives."
forward to the most exciting year of our
44. In the offer letter, Rose misrepresented and falsely inflated the position being
offered to Ms. Harris, to lure Ms. Harris to work for Rose.
45. Ms. Harris advised Mr. Kadro of Rose's offer.
46. Upon information and belief, Mr. Kadro knew that Mr. Rose had a history of
sexual harassment, but did not warn Ms. Harris about him.
47. Instead, Mr. Kadro encouraged Ms. Harris to accept Rose's offer.
48. Ms. Harris joined Rose and, from April-November 2017, Ms. Harris worked as an
Associate Producer for Rose.
49. At all relevant times, Ms. Harris was qualified for her position.
D. Ms. McNeal
50. In or about April 2017, Ms. McNeal, in her low 20s, joined Rose as an Executive
Assistant, a position based in Manhattan.
51. From April-November 2017, Ms. McNeal worked as an Executive Assistant for
Rose.
52. At all relevant times, Ms. McNeal was qualified for her position.
E. Ms. Wei
53. In September 2015, Ms. Wei, in her low 20s, joined CBS, as a News Associate for
CBS This Morning, at the CBS Studios.
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54. Ms. Wei was initially assigned to the Broadcast Associate Desk, an entry level
position for interns and recent college graduates.
55. Ms. Wei performed well and was promoted.
56. From April 2016 to early May 2017, Ms. Wei worked as an Executive Assistant to
Mr. Kadro.
57. Beginning in or about January 2017, CBS (by Mr. Kadro) directed Ms. Wei to
also provide support to Mr. Rose, then a co-anchor on CBS This Morning.
58. On or about May 10, 2017, CBS (by Mr. Kadro) reassigned Ms. Wei to report
directly to Mr. Rose.
59. Upon information and belief, Mr. Kadro knew that Mr. Rose had a history of
sexual harassment, but did not warn Ms. Wei about him.
60. From about May 10, 2017 through November 2017, Ms. Wei worked as a
Broadcast Associate (a/k/a Anchor Assistant) for CBS This Morning, reporting to Mr. Rose.
61. At all relevant times, Ms. Wei was qualified for her position.
F. Examples Of Sexual Harassment
62. As noted above, at various times in 2017 through and including November 2017,
Plaintiffs, all in their low 20s, all interacted with and/or reported to Mr. Rose, in his mid-70s.
63. Plaintiffs, due to their assigned positions and/or assigned job duties, were required
to spend a substantial amount of time working with Mr. Rose, a well-known, powerful American
television journalist and talk show host.
Plaintiffs'
64. During employment, Mr. Rose subjected Plaintiffs to repeated, ongoing
and unlawful physical and verbal sexual harassment, including without limitation: (a) sexual
touching; (b) sexual comments; and (c) sexual advances.
65. A few examples of Mr. Rose's unlawful conduct include:
(a) Mr. Rose advised Ms. Harris and Ms. McNeal that they were hired
women,"
because he likes "tall i.e., he was attracted to them.
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(b) Ms. Harris wore a mini skirt with images of roses on it and Mr. Rose
advised Ms. Harris that the roses on her skirt are his roses.
(b) Mr. Rose repeatedly sexually touched Plaintiffs, including without

limitation caressing and touching their arms, shoulders, waist and back,
pulling them close to his body, and kissing them on the cheek.
(d) Mr. Rose repeatedly required Ms. Harris to have lunch and/or dinner with
him and, during those occasions, Mr. Rose sexually touched Ms. Harris,
including placing his hands on her thigh and kissing her cheek. He
pointed at other women and called them prostitutes.
(e) Mr. Rose required Ms. McNeal to join him and Ms. Harris for dinner and
Mr. Rose sexually touched Ms. McNeal, including placing his hands on
her thigh and kissing her cheek.
(f) Mr. Rose repeatedly asked Ms. Harris and Ms. McNeal about their sex
lives and directed them to share details with him.
(g) Mr. Rose repeatedly boasted of his sexual conquests, telling Plaintiffs
words to the effect of "you should have seen the women that I was with
younger."
when I was
(h) Mr. Rose suggested to Ms. Harris and Ms. McNeal that they have sex with
each other and told them words to the effect of, "You just need to become
already,"
lovers indicating that he was having sexual fantasies about them.
(i) Mr. Rose ordered Ms. Harris and Ms. McNeal to visit his home in
Bellport, N.Y., allegedly for an errand. He told them "I better not hear any
together"
stories about two young women swimming naked in his
swimming pool, indicating that he was having sexual fantasies about them.
Doll,"
(j) Mr. Rose referred to Ms. Wei as "China a fetish term.
(k) Mr. Rose caressed Ms. Wei's arms when she handed him papers and
that."
would say "I love the way you do
(1) Mr. Rose whispered, in Ms. Wei's ear, in a sexual manner, "Happy
Dear."
Birthday
(m) Mr. Rose, while at the CBS Studios, insisted on kissing his three female
subordinates, including Ms. Wei, before leaving for a Summer vacation.
(n) Mr. Rose demanded that Ms. Harris to come to his apartment late at night.
66. Mr. Rose openly engaged in unlawful sexual harassment against Plaintiffs during
business hours, at the CBS Studios, at Charlie Rose Studios, as well as offsite.
Defendants'
67. conduct, and in particular Mr. Rose's conduct, was unwelcome and
offensive and created a hostile work environment.
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68. CBS Management, numerous broadcasters and studio staff witnessed Mr. Rose's
unlawful conduct, while he was employed by CBS.
69. Plaintiffs opposed, objected to and/or complained about Mr. Rose's unlawful
behavior and complaints were made to, among others, Mr. Kadro and Maria Cottone ("Ms.
Cottone"), Human Resources, CBS.
70. For example, Ms. Wei complained to Mr. Kadro about Mr. Rose requiring Ms.
Harris to frequently leave the CBS Studios to have private meals with him, and that the amount
of attention that Mr. Rose was paying to Ms. Harris outside of the office was unusual.
71. Ms. Wei also told Mr. Kadro words to the effect of "I'm telling you in case you
hands."
have a lawsuit on your
72. Defendants knew or should have known of the unlawful conduct.
73. However, Defendants unlawfully failed and refused to take any remedial action
Defendants'
and allowed Mr. Rose to continue to sexually harass Plaintiffs and female
employees.
74. Defendants also unlawfully retaliated against Plaintiffs.
75. At various times, Mr. Rose threatened to fire Plaintiffs, intimidated them and/or
verbally abused them as part of his predatory behavior, sexual dominance over them, and
retaliation against them. A few examples of his conduct include:
(a) Mr. Rose told Ms. Harris that she lacked skills and talent and "I didn't
kindergartner;"
know that I hired a fucking
(b) Mr. Rose told Ms. McNeal "you can't be a fucking idiot and have this
job"; and
idiot"
(c) Mr. Rose told Ms. Wei she was a "fucking for booking a flight on a
plane that did not have flat folding seats, when Ms. Wei had previously
advised Mr. Rose of same before booking the flight.
76. Moreover, Mr. Kadro himself physically harassed Ms. Wei at work.
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77. During the week of May 2, 2017, Mr. Kadro approached Ms. Wei from behind,
while Ms. Wei was seated at her desk and as an act of sexual harassment, kicked and shoved Ms.
Wei's chair with substantial force, startling, intimidating and scaring Ms. Wei.
G. Washington Post Articles, Termination And Ongoing Retaliation
78. On or about November 20, 2017, the Washington Post published an article (the
"November 2017 Article") about Mr. Rose's sexual harassment, entitled "Eight women say
Charlie Rose sexually harassed them - with nudity, groping and lewd
calls."
79. According to the November 2017 Article, eight women alleged that Mr. Rose
sexually harassed them:
Eight women have told The Washington Post that longtime television host Charlie
Rose made unwanted sexual advances toward them, including lewd phone calls,
walking around naked in their presence, or groping their breasts, buttocks or
genital areas. The women were employees or aspired to work for Rose at the
Rose"
"Charlie show from the late 1990s to as recently as 2011. They ranged in
age from 21 to 37 at the time of the alleged encounters. Rose, 75, whose show airs
Morning"
on PBS and Bloomberg TV, also co-hosts "CBS This and is a
Minutes."
contributing correspondent for "60 There are striking commonalities in
the accounts of the women, each of whom described their interactions with Rose
in multiple interviews with The Post. For all of the women, reporters interviewed
friends, colleagues or family members who said the women had confided in them
about aspects of the incidents. Three of the eight spoke on the record.
80. The November 2017 Article identified several victims by name.
81. The November 2017 Article can be found at:
https://www.washingtonpost.com/investigations/eight-women-say-charlie-rose-sexually-harassed
-them--with-nudity-groping-and-lewd-calls/2017/11/20/9bl68de8-caec-11e7-8321-481fd63f174d
_story.html?noredirect=on&utm_term=.afodle3739d6
82. At all relevant times, Mr. Rose has maintained a Twitter Account.
83. On or about November 20, 2017, Mr. Rose published the following written
statement on his Twitter Account at https://twitter.com/charlierose?lang=en, admitting among
behavior"
other items, that he had engaged in "inappropriate toward women with whom he
worked:
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Statemerit from Charlie Rose:
In my 45 years of journalism, I have prided myself on being an advocate for the careers of
the women with whom I have worked. Neverthek=ss, in the past few days, claims have been
made about my behavior toward some former female colleagues.
It is essentbl that these women krlow I hear them and that I deeply apologize for my
irlappropriate behavior. Eam greatly em barrassed. I have behaved insensitively at times, and
I accept responsibility for that, though I do not believe that alt of these allegations are
accurate. I always felt that I was pursuing shared feelings, even though I now realize I was
mistaken.
I have leamed a great deal as a result of these events, and I hope others will too. All of us,
including me,. are coming to a rlewer and deeper recognition of the pairi caused by conduct
in the past, and have came to a profourid new respect for womeri and their lives.
84. In addition, when the November 2017 Article was published, Mr. Rose held a
meeting with his staff and adr:iacd that he had sexually harassed female employees, stating
true."
among other items, words to the effect of "some of the stories are
85. While Mr. Rose knows that he engaged in üñlawfal sexual harassment, he feels no
remorse for his conduct.
86. On or about November 20, 2017, while Mr. Rose was walking toward the
entrance of his apartment building, a reporter approached him.
87. A video of the encounter can be found at:
http://www.tmz.com/2017/11/21/charlie-rose-sexual-assault harassment/
88. According to the video, the reporter asked Mr. Rose about the allegations of
wrongdoing against him and Mr. Rose, in an unscripted moment, grinned and replied that there
"wrongdoings,"
were no demonstrating that he feels no remorse for his üñlawfal conduct.
89. On or about November 22, 2017, the New York Post published an article entitled
scene,"
"Ex-intern says Rose made her watch S&M movie which can be found online at:
https://nypost.com/2017/11/22/ex-intern-says-rose-made-her-watch-sm-scene-in-movie/?_ga=2.2
29166367.2025837284.1523114083-amp-I271B9yBfpxxsHv4go8jBfLCzBi_ht_Cy0sC_-FElubvl
QKp8WDyZ80wtPHo0gzZ
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90. Upon information and belief, in November 2017, CBS terminated Mr. Rose's
employment because the Washington Post's publication of the November 2017 Article widely
exposed Mr. Rose's unlawful sexual harassment, spanning decades, during his tenure with CBS.
91. Rose, after the November 2017 Article, subsequently terminated the employment
of Ms. Harris and Ms. McNeal.
92. CBS did not offer alternate positions to Ms. Harris or Ms. McNeal.
93. Notwithstanding the above, Rose continued to seek to contact Plaintiffs by
telephone and e-mail.
94. For example, on or about November 24, 2017, Mr. Rose sent an e-mail to Ms.
Wei stating, among other items, "my relationship with you is the man I am in all my
relationships."
95. On or about November 30, 2017, Ms. Wei filed a complaint with Ms. Cottone
(Human Resources, CBS) against Mr. Rose and Mr. Kadro.
96. At that time, Ms. Wei was working as an Anchor Assistant on CBS This Morning.
97. Ms. Cottone told Ms. Wei that CBS would immediately disclose her complaint to
Mr. Kadro, would investigate the complaint, and would get back to Ms. Wei.
98. Upon information and belief, CBS immediately disclosed Ms. Wei's complaint to
Mr. Kadro, did not investigate the complaint, and did not take any remedial action.
99. CBS never got back to Ms. Wei about her complaint.
100. Instead, CBS, including without limitation by the actions of Mr. Kadro,
unlawfully retaliated against Ms. Wei, examples of which are below.
101. In January 2018, CBS questioned the accuracy of Ms. Wei's timesheets.
102. On or about January 30, 2018, CBS told Ms. Wei that she will be replaced as an
Anchor Assistant and is ineligible to apply for an open Anchor Assistant position supporting
Anchor John Dickerson.
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103. On or about February 12, 2018, CBS told Ms. Wei that she will no longer be
working with the Anchor Teams.
104. Ms. Wei became ill as a result of CBS's unlawful conduct.
105. Ms. Wei was absent from work from February 13, 2018 to February 25, 2018.
106. On February 13, 2018, CBS sent an e-mail to Ms. Wei indicating that her personal
property would be removed from the Anchor Assistant desk where she had previously worked.
107. In mid-February 2018, Plaintiffs, by their counsel, sent a letter to Defendants.
108. On February 26, 2018, Ms. Wei returned to work.
109. CBS continued its unlawful conduct against Ms. Wei.
110. At that time, CBS confined Ms. Wei to an entry level position at the Broadcast
Associate Desk and then falsely accused her of being derelict in her duties, stating: "You are
you?"
supposed to be at the BA Desk and I don't see
111. Ms. Wei's health further declined as a result of CBS's unlawful conduct.
112. On or about March 1, 2018, Ms. Wei commenced a medical leave of absence.
113. In or about mid-March 2018, CBS contacted Ms. Harris and Ms. Wei.
114. Upon information and belief, CBS did so to deter Plaintiffs from pursuing claims.
115. Upon information and belief, at various other times, CBS: (a) discriminated
against and harassed other female employees; (b) retaliated against other employees that engaged
in protected activity, and (c) intimidated and/or threatened victims of discrimination and
retaliation to deter them from pursuing their protected legal rights as victims.
116. Upon information and belief, in addition to the eight (8) victims of Mr. Rose's
sexual harassment identified by November 2017 Article, there were many more victims of such
conduct.
117. Upon information and belief, in addition to Mr. Rose, one or more other high
level male executives at CBS committed acts of sexual harassment against women.
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118. On May 3, 2018, the Washington Post published a second article, entitled Charlie
Rose's misconduct was widespread at CBS and three managers were warned, investigation finds,
which article can be found at
https://www.washingtonpost.com/charlie-roses-misconduct-was-widespread-at-cbs-and-three-ma
nagers-were-warned-investigation-finds/2018/05/02/80613d24-3228-11e8-94fa-32d48460b955_s
tory.html?utm_term=.a9ble8dd2ffa
H. Summary
119. Defendants unlawfully discriminated against Plaintiffs in compensation, terms,
conditions and/or privileges of employment, because of gender and sex and unlawfully retaliated
and discriminated against them because they engaged in protected activity.
120. Defendants unlawfully harassed Plaintiffs.
121. Plaintiffs engaged in protected activity by opposing, objecting to and/or
complaining about unlawful discrimination/harassment.
122. Defendants failed to investigate the matter and/or failed to timely investigate the
matter.
123. Defendants failed to take any remedial action, failed to timely take remedial
action and/or failed to take proper remedial action.
124. Defendants unlawfully discriminated against, harassed and retaliated against
Plaintiffs.
125. Defendants treated Plaintiffs less well, differently, and less favorably, than other
employees and employees outside their protected classes, and subjected them to discrimination,
harassment and retaliation not perpetrated against other employees and employees outside their
protected classes.
126. Discrimination, harassment and retaliation played a role in decisions regarding
Plaintiffs'
employment.
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127. Defendants knew or should have known of the unlawful discrimination,
harassment and retaliation and failed to exercise reasonable care to prevent and correct same.
128. Defendants engaged in, caused, perpetrated, committed, authorized, directed,
participated in, supported, ratified, approved, condoned and/or coerced the unlawful conduct
alleged herein.
129. Defendants aided, abetted, incited, compelled or coerced unlawful discrimination
and/or unlawful retaliation, or to attempted to do so.
Defendants'
130. proffered reason for the conduct was a pretext for unlawful
discrimination and unlawful retaliation.
Defendants'
131. As a result of unlawful conduct, each Plaintiff has suffered and
continues to suffer damages.
COUNT ONE
(NYCHRL - DISCRIMINATION AND HARASSMENT)
132. Plaintiffs repeat and reallege every allegation in the preceding paragraphs of this
Complaint with the same force and effect as though fully set forth herein.
133. This Count is brought under the NYCHRL, N.Y.C. Admin. Code § 8-101 et seq.
"employer,"
134. At all relevant times herein, CBS and Rose are each an "covered
entity" "person" employers."

and a within the meaning of the NYCHRL, and are liable as "joint
"person"
135. At all relevant times herein, Mr. Rose and each Plaintiff were each a
within the meaning of the NYCHRL.
Defendants'
136. conduct, as alleged herein, constituted unlawful discriminatory
practices, unlawful discrimination based on gender and sex, unlawful harassment, and unlawful
aiding and abetting thereof, in violation of the NYCHRL.
Defendants'
137. conduct, as alleged herein, amounts to willful or wanton negligence
or recklessness or involves a conscious disregard of the rights of others or conduct so reckless as
to amount to such disregard.
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"employer"
138. Defendants are each liable for the unlawful conduct herein both as an
abetting" 8-
under NYCHRL § 8-107(1) and under the "aiding and provisions of NYCHRL §
107(6).
Defendants'
139. As a result of unlawful conduct, Plaintiffs have suffered and continue
to suffer injury, with resulting monetary, economic and other damages, including without
attorneys'
limitation, lost wages and bonuses, lost benefits, lost interest and fees and costs.
Defendants'
140. As a further result of unlawful conduct, Plaintiffs have suffered and
continue to suffer, among other items, injury, impairment and damage to their good name and
reputation, emotional distress, mental anguish, emotional pain, suffering, inconvenience, loss of
enjoyment of life, and lasting embarrassment and humiliation. Plaintiffs are entitled to recover
damages for such injuries from the Defendants.
141. Plaintiffs are entitled to recover such monetary and other damages, punitive
attorneys'
damages, interest, and fees and costs from the Defendants.
COUNT TWO
(NYCHRL -
RETALIATION)
142. Plaintiffs repeat and reallege every allegation in the preceding paragraphs of this
Complaint with the same force and effect as though fully set forth herein.
143. This Count is brought under the NYCHRL, N.Y.C. Admin. Code § 8-101 et seq.
Defendants'
144. conduct, as alleged herein, constituted unlawful retaliation, and
unlawful aiding and abetting thereof, in violation of the NYCHRL.
Defendants'
145. conduct, as alleged herein, amounts to willful or wanton negligence
or recklessness or involves a conscious disregard of the rights of others or conduct so reckless as
to amount to such disregard.
"employer"
146. Defendants are each liable for the unlawful conduct herein both as an
abetting" 8-
under NYCHRL § 8-107(1) and under the "aiding and provisions of NYCHRL §
107(6).
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Defendants'
147. As a result of unlawful conduct, Plaintiffs have suffered and continue
to suffer injury, with resulting monetary, economic and other damages, including without
attorneys'
limitation, lost wages and bonuses, lost benefits, lost interest and fees and costs.
Defendants'
148. As a further result of unlawful conduct, Plaintiffs have suffered and
continue to suffer injury, among other items, injury, impairment and damage to their good name
and reputation, emotional distress, mental anguish, emotional pain, suffering, inconvenience, loss
of enjoyment of life, and lasting embarrassment and humiliation. Plaintiffs are entitled to
recover damages for such injuries from the Defendants.
149. Plaintiffs are entitled to recover such monetary and other damages, punitive
attorneys'
damages, interest, and fees and costs from the Defendants.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs request judgment on all Counts, as follows:
(A) Enter a judgment in favor of each Plaintiff on her claims against Defendants;
(B) Award each Plaintiff as against Defendants, jointly and severally, the amount of
wages, including without limitation wages, back pay, front pay, bonuses, benefits, and interest
Defendants'
lost as a result of unlawful conduct;
(C) Award each Plaintiff as against Defendants, jointly and severally, consequential
Defendants'
damages for losses resulting from unlawful conduct;
(D) Award each Plaintiff as against Defendants, jointly and severally, compensatory
damages for, among other items, injury, impairment and damage to her good name and
reputation, emotional distress, mental anguish, emotional pain, suffering, inconvenience, loss of
enjoyment of life, lasting embarrassment and humiliation, and other pecuniary and nonpecuniary
losses;
(E) Award each Plaintiff as against Defendants, jointly and severally, punitive
damages;
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(F) Award each Plaintiff as against Defendants, jointly and severally, the costs of this
attorneys'
action, together with reasonable fees;
(G) Award each Plaintiff any and all other damages provided by the applicable
statutes and applicable law; and
(H) Award each Plaintiff such further legal relief as may be just and proper.
May 4, 2018
GOLDBERG & FLIEGEL LLP
By: /s/ Kenneth A. Goldberg
Kenneth A. Goldberg
192 Lexington Avenue, Suite 902
(212) 983-1077
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COUNTY OF NEW YORK
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x
Plaintiffs,
: AFFIDAVIT OF PLAINTIFF KATHERINE
- against - BROOKS HARRIS IN OPPOSITION TO
DEFENDANTS'
: MOTION TO DISMISS
Defendants. :
-------------------------------- X
STATE OF GEORGIA )
: ss.:
COUNTY OF CAMDEN )
KATHERINE BROOKS HARRIS, being duly sworn, deposes and says:
1. I am a Plaintiff in the above-referenced matter.
2. I make this affidavit in opposition to the motion of Defendants Charlie Rose Inc.
and Charles Peete Rose Jr. a/k/a Charlie Rose ("Defendants") to dismiss and to supplement the
Complaint with additional examples of the conduct of Charlie Rose ("Rose") during my
employment.
A. Additional Examples Of Discrimination
3. During my employment, Rose engaged in acts of physical and verbal sexual
harassment against me numerous times and I also witnessed Rose engage in such conduct against
other women including among others, Plaintiff Sydney McNeal.
4. As noted in the Complaint, Rose repeatedly touched me in an unwelcome,
offensive and inappropriate manner. Rose did so at least once a week and often multiple times
each week. He looked for opportunities to touch me.
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5. In addition to the examples of such conduct outlined in the Complaint, set forth
below are additional examples of Rose's conduct during my employment.
6. Rose would regularly summon me to speak with him within his corporate offices,
just outside the broadcast studio. He would sit on the bench outside the broadcast studio and
would require me to sit next to him. On at least one occasion, I was wearing a skirt and, as I sat
down, Rose intentionally placed his hand on the bench so that my buttocks landed on his hand
and he kept his hand under me. On at least one other occasion, I was wearing a skirt and, after I
sat down on the bench, Rose sat down and intentionally slid his hand under my buttocks.
7. Rose, when speaking to me, would repeatedly approach me and stand too close to
me. He would constantly touch me and squeeze me in a dominating and degrading manner. He
would put his arm around my body, put his hand on my waist, pull me close and hold me tight.
He would often pull me so close that my body would be touching his body.
8. Rose would grab my upper arm and squeeze it. He would put his hands on my
shoulder, squeeze my shoulder and press down on my shoulder and keep his hands there. Rose
would often grab onto me while he was sitting down, wrap his arms around my hips and waist,
pull me close and hold me tight. Rose kept his hands on me for the duration of the conversation.
9. Rose did not touch male employees in the way that he touched me.
10. Rose repeatedly required me to have lunch and/or dinner with him at various
restaurants in Manhattan, and engaged in acts of sexual harassment at those restaurants. The
restaurants included, among others: Nello; Le Bilboquet; Avra Madison Estiatorio; Cipriani; and
Lavo. He also required me to dine with him at Eddie V's (California) and there asked me if I
"together,"
thought the other people in the restaurant thought we were i.e., romantically involved.
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11. On at least three occasions, Rose undressed in front of me and Ms. McNeal,
removing his dress shirt and exposing his naked upper body (he did not wear an under shirt).
12. Rose could have changed his shirt in a nearby restroom, but intentionally
undressed in front of me and Ms. McNeal, because he wanted us to see his naked upper torso.
13. Rose also required me to open his closet and select a dress shirt for him to wear.
14. On at least 12 occasions, Rose hugged and kissed me and Ms. McNeal, often after
dining at a restaurant or when he left the office for a business trip or vacation. He would grab
both my shoulders, pull me close to him, and plant a wet kiss on my cheek, close to my lips.
15. Rose required me to come to his residential apartment and watch videotapes of his
60 Minutes interviews.
Defendants'
16. Rose required me to come into his private office within corporate
offices and touch him on his shoulder to awaken him from naps.
17. Submission to Rose's conduct was a term and condition of my employment.
18. Rose's conduct was unwelcome and offensive and created an environment
Defendants'
degrading to women and showed expectations of a woman's role in the workplace.
B. Additional Examples Of Protected Activity And Retaliation
19. I opposed, objected to and/or complained about Rose's unlawful conduct.
20. Despite my opposition, no remedial action was taken.
21. For example, during Rose's sexual harassment I communicated my disapproval
"Charlie"
by, among other acts, rolling my eyes, looking at Rose with disapproval, saying in a
tone of disapproval, changing the subject, changing my physical stance, and attempting to move
away from Rose. Rose knew or should have known from my reactions that I disapproved of his
conduct.
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22. For example, in or about August 2017, I complained to Yvette Vega, Executive
Producer of the Charlie Rose Show, about Rose's sexual comment about Ms. McNeal and I
swimming naked together in his swimming pool.
23. Ms. Vega knew that Rose's conduct was unwelcome and offensive, but replied
Charlie"
with words to the effect of "that's Charlie being and did not take any remedial action.
24. As noted in the Complaint, at various times, Rose threatened to fire me,
intimidated me and/or verbally abused me as part of his predatory behavior, desire for sexual
dominance over me, and retaliation against me.
25. In addition to the examples outlined in the Complaint, Rose threatened to fire me
was"
on multiple occasions and told me words to the effect of that I "wasn't the girl he thought I
job."
and that I "didn't seem to care about my
Defendants'
26. retaliatory conduct against me was subsequent to and close in time to
my protected activities.
C. Additional Information
27. Upon information and belief, Rose is President, Chief Executive Officer, owner,
an employee, and/or agent of his company Charlie Rose Inc.
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Dated: MarchÖ_, 019
By:
Katherine Brooks Harris
Sworn to before me
_ day of March, 2019
Notary Public
XPTRES .
: GEORGIA
eÛ ". MAY 20, 2019 ..
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COUNTY OF NEW YORK
----------------- --- --- --- --- --- -- x
Plaintiffs,
: AFFIDAVIT OF PLAINTIFF SYDNEY
- against - McNEAL IN OPPOSITION TO
DEFENDANTS'
: MOTION TO DISMISS
Defendants. :
---------------------------------- X
STATEOFTEXAS )
: ss.:
COUNTY OF TRAVIS )
SYDNEY McNEAL, being duly sworn, deposes and says:
employment.
harassment against me numerous times and I also witnessed Rose engage in such conduct against
other women including among others, Plaintiff Katherine Brooks Harris.
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restaurants in Manhattan, and engaged in acts of sexual harassment at those restaurants. The
restaurants included, among others: Nello; Le Bilboquet; Cipriani; and Lavo.
10. On at least three occasions, Rose undressed in front of me and Ms. Harris,
removing his dress shirt and exposing his naked upper body (he did not wear an under shirt).
undressed in front of me and Ms. Harris, because he wanted us to see his naked upper torso.
12. Rose also required me to open his closet and select a dress shirt for him to wear.
13. On at least 12 occasions, Rose hugged and kissed me and Ms. Harris, often after
dining at a restaurant or when he left the office for a business trip or vacation. He would grab
both my shoulders, pull me close to him, and plant a wet kiss on my cheek, close to my lips.
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Defendants'
"Charlie"
by, among other acts, rolling my eyes, looking at Rose with disapproval, saying in a
tone of disapproval, changing the subject, changing my physical stance, and attempting to move
away from Rose. Rose knew or should have known from my reactions that I disapproved of his
conduct.
19. For example, in or about August 2017, Ms. Harris complained to Yvette Vega,
Executive Produce of the Charlie Rose Show, about Rose's sexual comment about Ms. Harris
and I swimming naked together in his swimming pool. Ms. Vega knew that Rose's conduct was
Charlie"
unwelcome and offensive, but replied with words to the effect of "that's Charlie being
and did not take any remedial action. I witnessed Ms. Harris's complaint and Ms. Vega's reply.
20. As noted in the Complaint, at various times, Rose threatened to fire me,
intimidated me and/or verbally abused me as part of his predatory behavior, desire for sexual
Defendants'
dominance over me, and retaliation against me. retaliatory conduct against me was
subsequent to and close in time to my protected activities.
an employee, and/or agent of his company Charlie Rose Inc.
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Dated: MarchÛ 2019
By:
Sydney Mc al
Sworn to before me
this19_th day of March, 2019
MISCHELE BUERKLE
Notary Public
* * STATE OF TEXAS
. My Comm. Exp. 03-04-23
Notary Pubhc Notary ID # 12844447-8
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COUNTY OF NEW YORK
----------------- --- --- --- --- --- -- x
Plaintiffs,
: AFFIDAVIT OF PLAINTIFF CHELSEA
- against - YUQING WEI IN OPPOSITION TO
DEFENDANTS'
: MOTION TO DISMISS
Defendants. :
---------------------------------- X
STATE OF NEW YORK )

: ss.:
COUNTY OF NEW YORK )
CHELSEA YUQING WEI being duly sworn, deposes and says:
2. At the time the lawsuit was filed, my legal name was Yuqing Wei.
3. Since filing the lawsuit, I have changed my legal name to Chelsea Yuqing Wei.
employment.
harassment against me numerous times.
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10. On at least two occasions, Rose hugged and kissed me when he left the office for
a business trip or vacation. He would grab both my shoulders, pull me close to him, and plant a
wet kiss on my cheek, close to my lips.
Defendants'
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COUNTY CLERK
CLERK 01/06/2020
04/01/2019 09:07
09: 18 PM INDEX
INDEX NO.
NO. 154172/2018
154172/2018
PM)
NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 108
65 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 01/06/2020
04/01/2019
by, among other acts, rolling my eyes, looking at Rose with disapproval, changing the subject,
changing my physical stance, and attempting to move away from Rose. Rose knew or should
have known from my reactions that I disapproved of his conduct.
17. As noted in the Complaint, at various times, Rose intimidated me and/or verbally
abused me as part of his predatory behavior, desire for sexual dominance over me, and retaliation
against me.
Defendants'
18. retaliatory conduct against me was subsequent to and close in time to
my protected activities.
an employee, and/or agent of his company Charlie Rose, Inc.
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FILED:
FILED : NEW YORK
NEW YORK COUNTY
COUNTY CLERK
CLERK 01/06/2020
04/01/2019 09:07
09:18 PM
PM)
INDEX
INDEX NO.
NO. 154172/2018
154172/2018
NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 108
65 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 01/06/2020
04/01/2019
Dated: March 27, 2019
By:
elsea Yuqing Wei
Sworn to before me
this27 th day of March, 2019
Notary Public
KENNETHAGOLDBERG
Public, Stateof New Yist
No. 02005061677
in New York
EmpiresJuly27,
364 of
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4
EXHIBIT 3
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Page 1
2 SUPREME COURT OF THE STATE OF NEW YORK
3 COUNTY OF NEW YORK
4 Index No. 154172/2018
5 -----------------------------------x
6 KATHERINE BROOKS HARRIS, SYDNEY McNEAL and

" "
7 Y U Q I N G ( C H E L S E A ) WE I ,
8 Plaintiffs,
9 - against -
10 CHARLIE ROSE INC., and CHARLES PEETE ROSE
11 JR. a/k/a/ CHARLIE ROSE,
12 Defendants.
13 -----------------------------------x
14 November 14, 2019
15 9:31 a.m.
1 6
17 ***Pages 285 through 287 are deemed
18
Attorneys' Eyes and bound under
Only
19 separate cover.
2 0
Deposition of CHARLES P. ROSE,
21 JR., taken by Plaintiffs, pursuant to
Notice, held at the offices of Goldberg &
22 Fliegel LLP, 488 Madison Avenue, New York,
New York, before Jineen Pavesi, a
23 Registered Professional Reporter,

Registered Merit Reporter, Certified
24 Realtime Reporter and Notary Public of the
State of New York.
2 5
Veritext Legal Solutions
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Page 2
2 A P P E A R A N C E S :
4 GOLDBERG & FLIEGEL LLP
5 488 Madison Avenue, Suite 1120
6 New York, New York 10022
7 Attorneys for Plaintiffs
8 BY: KENNETH A. GOLDBERG, ESQ.
9 kgldbrg@aol.com
10 MICHELLE FLIEGEL, ESQ.
1 1
1 2
13 SHAPIRO ARATO BACH LLP
14 500 Fifth Avenue, 40th Floor
16 Attorneys for Defendants
17 BY: JONATHAN P. BACH, ESQ.
18 jbach@shapiroarato.com
19 CYNTHIA ARATO, ESQ.
20 carato@shapiroarato.com
21 ERIN MARIE JAMES, ESQ.
22 ejames@shapiroarato.com
2 3
24 ALSO PRESENT:
25 BROOKS HARRIS
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Page 3
2 CPLR STIPULATIONS
3 IT IS HEREBY STIPULATED AND AGREED,
4 by and between the attorneys for the
5 respective parties hereto, that:
6 All rights provided by the
7 CPLR, and Part 221 of the Uniform Rules
8 for the Conduct of Depositions, including
9 the right to object to any question,
10 except as to form, or to move to strike
11 any testimony at this examination, are
12 reserved; and, in addition, the failure to
13 object to any question or to move to
14 strike any testimony at this examination
15 shall not be a bar or waiver to make such
16 motion at, and is reserved for, the trial
17 of this action.
18 IT IS FURTHER STIPULATED AND AGREED
19 that this examination may be sworn to by
20 the witness being examined before a Notary
21 Public other than the Notary Public before
22 whom this examination was begun, but the
23 failure to do so or to return the original
24 of this examination to counsel shall not
25 be deemed a waiver of the rights provided
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1
2 by Rule 3116, CPLR, and shall be
3 controlled thereby.
4 IT IS FURTHER STIPULATED AND AGREED
5 that the filing and certification of the
6 original of this examination are waived.
7 IT IS FURTHER STIPULATED, a
8 copy of this examination shall be
9 furnished to the attorney for the witness
10 being examined without charge.
11
12 * * *
13
14
15
16
17
18
19
20
21
22
23
24
25

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Page 5
1
2 C H A R L E S P. R O S E, J R.,
3 having first been duly sworn by a Notary
4 Public of the State of New York, was
5 examined and testified as follows:
6 EXAMINATION BY
7 MR. GOLDBERG: 09:31:31AM
8 Q. Good morning, Mr. Rose. 09:31:31AM
9 A. Morning. 09:31:36AM
10 Q. My name is Kenneth Goldberg, an 09:31:36AM
11 attorney, and I represent the plaintiffs 09:31:40AM
12 in this lawsuit. 09:31:41AM
13 The plaintiffs are Katherine 09:31:42AM
14 Brooks Harris, Sydney McNeal and Chelsea 09:31:43AM
15 Wei. 09:31:46AM
16 You're one of the defendants in 09:31:46AM
17 this case and you're here in my office 09:31:48AM
18 today so that I can take your deposition. 09:31:49AM
19 The court reporter has sworn 09:31:53AM
20 you in, so you're under oath today and 09:31:55AM
21 your job is to provide truthful and 09:31:58AM
22 complete answers. 09:32:00AM
23 Do you agree to do so? 09:32:01AM
24 A. Yes. 09:32:03AM
25 Q. If you don't understand a 09:32:04AM

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1 ROSE
2 question, let me know and I will try to 09:32:05AM
3 rephrase it. 09:32:07AM
4 If you don't say that you don't 09:32:08AM
5 understand a question, we will assume that 09:32:10AM
6 you understand the question. 09:32:12AM
7 If your attorney asserts an 09:32:14AM
8 objection, I would suggest you let your 09:32:15AM
9 attorney put his objection on the record 09:32:18AM
10 and then answer the question unless your 09:32:19AM
11 attorney tells you not to answer the 09:32:22AM
12 question. 09:32:23AM
13 What is your legal name? 09:32:25AM
14 MR. BACH: Before we begin, 09:32:26AM
15 just let me say one thing very briefly on 09:32:28AM
16 the record. 09:32:31AM
17 We have asked plaintiffs' 09:32:31AM
18 counsel if they will agree to execute the 09:32:34AM
19 protective order, we have presented them 09:32:37AM
20 with a form, we have sent it to them a 09:32:40AM
21 couple of times in the last two weeks and 09:32:43AM
22 we have not heard back from them. 09:32:45AM
23 I just raised the issue with 09:32:47AM
24 Mr. Goldberg again; he has declined to 09:32:48AM
25 execute the protective order stating there 09:32:52AM

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1 ROSE
2 is a prior form that he has presented and 09:32:54AM
3 that our form is not acceptable. 09:32:56AM
4 Mr. Goldberg, we expect you, in 09:32:58AM
5 the absence of a protective order, to 09:33:01AM
6 abide by the agreement that you're not 09:33:03AM
7 going to use this information for any 09:33:05AM
8 purpose other than this litigation, we 09:33:08AM
9 have that understanding in an e-mail and I 09:33:13AM
10 would simply like you to confirm that. 09:33:14AM
11 MR. GOLDBERG: We certainly 09:33:16AM
12 have an exchange of e-mails in terms of 09:33:16AM
13 confidentiality and we have been trying to 09:33:19AM
14 confer with you on the form of protective 09:33:22AM
15 order and we're certainly willing to 09:33:24AM
16 confer with you, not today because I'm 09:33:26AM
17 starting the deposition, but we have 09:33:29AM
18 stamped some documents confidential as 09:33:31AM
19 well, we have been using the information 09:33:33AM
20 provided from this litigation and I assume 09:33:34AM
21 you have, as well. 09:33:37AM
22 MR. BACH: And the 09:33:39AM
23 understanding is it will not be used for 09:33:39AM
24 any other purpose, correct? 09:33:41AM
25 MR. GOLDBERG: Well, we are not 09:33:43AM

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1 ROSE
2 -- I don't think that we're globally 09:33:45AM
3 stamping the entirety today as 09:33:46AM
4 confidential, but if there are parts of 09:33:48AM
5 the deposition that you feel merit 09:33:51AM
6 confidential treatment, certainly let me 09:33:54AM
7 know. 09:33:56AM
8 MR. BACH: That's not my 09:33:57AM
10 The question was, in the 09:33:58AM
11 absence of the protective order, you have 09:33:59AM
12 stated before in e-mail that you will not 09:34:01AM
13 be using any information obtained in this 09:34:04AM
14 matter for any purpose other than the 09:34:06AM
15 purpose of this litigation. 09:34:08AM
16 MR. GOLDBERG: I thought that 09:34:14AM
17 we had had a back and forth in terms of 09:34:14AM
18 two documents; are you saying that our 09:34:19AM
19 e-mails spoke beyond the scope of document 09:34:22AM
20 production? 09:34:25AM
21 MR. BACH: Yes, yes; in other 09:34:26AM
22 words, what we do not want you to do is to 09:34:27AM
23 take the deposition or any other 09:34:31AM
24 information that you obtain in this 09:34:35AM
25 litigation and go to the press with it. 09:34:36AM

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1 ROSE
2 We want you to use the 09:34:40AM
3 information solely for any purpose as you 09:34:42AM
4 like and as broadly as you like, we 09:34:46AM
5 believe you can use that information to 09:34:48AM
6 pursue this lawsuit and for purposes of 09:34:49AM
7 the litigation, we have no wish to tie 09:34:53AM
8 your hands with respect to your 09:34:55AM
9 representation of your client in 09:34:57AM
10 connection with the lawsuit. 09:34:58AM
11 But we understand the agreement 09:34:59AM
12 to be that you cannot go to the press 09:35:00AM
13 about today's deposition and you have told 09:35:04AM
14 us in the past that you don't do that and 09:35:08AM
15 you do not plan to do that and we simply 09:35:10AM
16 want to put that on the record. 09:35:13AM
17 If you plan to take this to the 09:35:14AM
18 press, we would like to know. 09:35:16AM
19 (Pause.) 09:36:26AM
20 MR. GOLDBERG: Jonathan, I 09:36:27AM
21 certainly stand behind whatever 09:36:31AM
22 representations I made to you before in 09:36:33AM
23 terms of our e-mail exchanges and I don't 09:36:36AM
24 remember what those exchanges are, but 09:36:39AM
25 what they are I certainly stand behind it. 09:36:40AM

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1 ROSE
2 Of course the plaintiffs 09:36:42AM
3 reserve the right to use any information 09:36:44AM
4 obtained in this deposition with respect 09:36:47AM
5 to any claims that the plaintiffs may have 09:36:49AM
6 relating to the events that are alleged in 09:36:53AM
7 the complaint. 09:36:55AM
8 But I certainly stand behind 09:36:56AM
9 what I have said to you before. 09:36:58AM
10 MR. BACH: Fair enough. 09:36:59AM
11 MR. GOLDBERG: That hasn't 09:37:00AM
12 changed. 09:37:01AM
13 MR. BACH: Understood. 09:37:02AM
14 And if you do plan to go to the 09:37:02AM
15 press, we ask you to let us know in 09:37:05AM
16 advance so that we can raise that with the 09:37:12AM
17 court. 09:37:14AM
18 Thank you. 09:37:15AM
19 MR. GOLDBERG: Understood. 09:37:17AM
20 Again, our intention is to use 09:37:19AM
21 information obtained today with respect to 09:37:20AM
22 any claims that the plaintiffs may have 09:37:22AM
23 related to the facts alleged in the 09:37:25AM
24 complaint. 09:37:27AM
25 BY MR. GOLDBERG: 09:37:29AM

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1 ROSE
2 you are not truthful? 09:39:09AM
3 A. No, not that I can think about. 09:39:13AM
4 Q. Did you review any documents to 09:39:18AM
5 prepare for this deposition? 09:39:20AM
6 MR. BACH: I am going to 09:39:22AM
7 object; counsel, I believe that's our work 09:39:23AM
8 product and beyond your prerogative. 09:39:24AM
9 I will instruct the witness not 09:39:27AM
10 to answer. 09:39:29AM
11 MR. GOLDBERG: If he reviewed 09:39:30AM
12 documents with you, I am not trying to 09:39:31AM
13 invade attorney-client privilege, but I'm 09:39:32AM
14 asking Mr. Rose, did you review on your 09:39:34AM
15 own any documents to prepare yourself for 09:39:36AM
16 today. 09:39:38AM
17 MR. BACH: I'm going to object 09:39:39AM
18 to the question as beyond your prerogative 09:39:40AM
19 and I am going to assert our privilege and 09:39:45AM
20 work product protection and instruct the 09:39:47AM
21 witness not to answer. 09:39:49AM
22 MR. GOLDBERG: Okay. 09:39:51AM
23 I understand your objection, 09:39:52AM
24 Mr. Bach. 09:39:54AM
25 Keep in mind that to the extent 09:39:55AM

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1 ROSE
2 you instruct your client not to answer a 09:39:58AM
3 question, we may end up making a motion to 09:40:00AM
4 compel a response to that question. 09:40:02AM
5 MR. BACH: I fully understand 09:40:03AM
6 that and you understand where there is a 09:40:04AM
7 question that goes to privilege and work 09:40:08AM
8 product, I have an obligation to protect 09:40:09AM
9 the privilege and work product. 09:40:11AM
10 MR. GOLDBERG: It is our 09:40:13AM
11 position that the documents reviewed for 09:40:13AM
12 preparation of the deposition, those are 09:40:16AM
13 not privileged; we're not asking for 09:40:18AM
14 discussions with your client. 09:40:21AM
15 MR. BACH: You are entitled to 09:40:22AM
16 your position; the law is the law. 09:40:23AM
17 Q. Mr. Rose, you attended the 09:40:27AM
18 deposition of plaintiffs Harris and McNeal 09:40:29AM
19 in this lawsuit, correct? 09:40:33AM
20 A. Yes. 09:40:36AM
21 Q. During the deposition of 09:40:45AM
22 Ms. Harris, were you using a laptop? 09:40:47AM
23 A. Yes. 09:40:53AM
24 Q. Were you listening to news 09:40:54AM
25 broadcasts or other broadcasts through 09:40:55AM

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1 ROSE
2 where you owned property and rented it 11:04:26AM
3 out? 11:04:28AM
4 A. No, but -- not that I know, 11:04:29AM
5 but you would have to check with the 11:04:32AM
6 accountant. 11:04:33AM
7 Q. Mr. Rose, did you ever have any 11:05:01AM
8 romantic relationship with any women that 11:05:04AM
9 worked for you? 11:05:06AM
10 MR. BACH: Objection. 11:05:08AM
11 You can answer that yes or no. 11:05:12AM
12 A. Yes. 11:05:16AM
13 Q. With whom did you have a 11:05:17AM
14 romantic relationship? 11:05:20AM
15 MR. BACH: Counsel, we have 11:05:21AM
16 romantic relationships, it is not material 11:05:24AM
17 or necessary and we will object to that 11:05:27AM
18 question and instruct him not to answer. 11:05:29AM
19 MR. GOLDBERG: We believe that 11:05:32AM
20 it is relevant, discoverable, and that 11:05:34AM
21 we're entitled to know the name of any 11:05:36AM
22 woman that he had a romantic relationship 11:05:38AM
23 with that worked with him and we're asking 11:05:40AM
24 again for an answer to our question. 11:05:43AM
25 MR. BACH: I stand by our 11:05:46AM

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1 ROSE
2 objection. 11:05:47AM
3 MR. GOLDBERG: Please 11:05:48AM
4 understand that to the extent you instruct 11:05:49AM
5 your client not to answer, I think you're 11:05:51AM
6 violating the CPLR, I think you're 11:05:53AM
7 violating the broad nature of depositions, 11:05:55AM
8 and you are creating a situation where 11:05:57AM
9 motion to compel may be filed to reopen 11:06:01AM
10 and continue this deposition and to have 11:06:03AM
11 you and your clients bear the costs and 11:06:05AM
12 fees associated with us doing so. 11:06:08AM
13 So I would ask you again to let 11:06:09AM
14 your client answer my questions and not to 11:06:11AM
15 object and direct him not to answer unless 11:06:14AM
16 we're talking about an attorney-client 11:06:17AM
17 privilege. 11:06:18AM
18 MR. BACH: So, Mr. Goldberg, 11:06:19AM
19 you have asked him who he had romantic 11:06:22AM
20 relationships with and we're going to 11:06:24AM
21 stand by our objection. 11:06:27AM
22 I understand that you have 11:06:28AM
23 broad rights in a deposition. 11:06:30AM
24 We invite you to exercise those 11:06:32AM
25 broad rights, we invite you to ask 11:06:34AM

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1 ROSE
2 questions about your clients and about 11:06:36AM
3 their work experiences with Mr. Rose, you 11:06:38AM
4 have not asked a single question about 11:06:41AM
5 your clients or their work experiences 11:06:42AM
6 with Mr. Rose to this point. 11:06:45AM
7 If you're asking generally 11:06:47AM
8 about who he has had romantic 11:06:49AM
9 relationships with, we will stand by our 11:06:51AM
10 objection and instruct the witness not to 11:06:52AM
11 answer. 11:06:54AM
12 MR. GOLDBERG: Please mark it 11:07:00AM
13 for a ruling, Jineen, thank you. 11:07:00AM
14 Q. Mr. Rose, did you ever have a 11:07:08AM
15 romantic relationship with any woman that 11:07:10AM
16 worked for you at the Bloomberg building, 11:07:12AM
17 731 Lexington? 11:07:16AM
18 MR. BACH: Same objection; 11:07:17AM
19 object to this question on the ground it 11:07:20AM
20 seeks information that's not material and 11:07:22AM
21 necessary in the adjudication of the 11:07:24AM
22 claim, on the ground it seeks information 11:07:29AM
23 about private and confidential matters 11:07:31AM
24 involving third parties unrelated to this 11:07:34AM
25 case, and we're going to object on the 11:07:36AM

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1 ROSE
2 ground that it is plainly improper and 11:07:38AM
3 simply seeks to prejudice and humiliate 11:07:40AM
4 Mr. Rose. 11:07:42AM
5 While we object to this 11:07:44AM
6 question, we will invite you to ask 11:07:46AM
7 questions about Ms. Harris, Ms. McNeal, 11:07:48AM
8 their work experience with Mr. Rose and 11:07:53AM
9 urge you to do so. 11:07:55AM
10 I am going to instruct the 11:08:00AM
11 witness not to answer the question as 11:08:01AM
12 posed. 11:08:03AM
13 MR. GOLDBERG: Mark for a 11:08:04AM
14 ruling, Jineen. 11:08:05AM
15 Q. Mr. Rose, did you ever provide 11:08:09AM
16 training to any of your employees at 11:08:11AM
17 Charlie Rose in the area of 11:08:13AM
18 discrimination, harassment, equal 11:08:15AM
19 employment opportunity? 11:08:18AM
20 A. Not that I know of. 11:08:18AM
21 Q. Did you ever provide any 11:08:20AM
22 employee working for you with written 11:08:21AM
23 employment policies or handbooks or 11:08:24AM
24 manuals? 11:08:26AM
25 A. Not that I know of, but they 11:08:27AM

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1 ROSE
2 may have been available in some other way. 11:08:29AM
3 Q. Did you ever have a romantic 11:08:37AM
4 relationship with any woman that worked 11:08:38AM
5 with you at CBS? 11:08:40AM
6 MR. BACH: Same objection, 11:08:41AM
7 object to the question on the ground that 11:08:44AM
8 it seeks information that's not material 11:08:46AM
9 and necessary to adjudicate the claim 11:08:48AM
10 that's been brought in this dispute. 11:08:53AM
11 We object on the ground that it 11:08:55AM
12 seeks information about private and 11:08:57AM
13 confidential matters involving third 11:08:59AM
14 parties unrelated to this case. 11:09:01AM
15 We object on the grounds that 11:09:03AM
16 the question is plainly improper and seeks 11:09:05AM
17 to prejudice and humiliate Mr. Rose. 11:09:07AM
18 We therefore instruct the 11:09:11AM
19 witness not to answer. 11:09:13AM
20 While we are instructing the 11:09:14AM
21 witness not to answer this question, we 11:09:16AM
22 are inviting you, Mr. Goldberg, to use 11:09:17AM
23 this deposition to explore the facts 11:09:21AM
24 relating to the claim that your clients 11:09:24AM
25 have brought, to ask questions about their 11:09:26AM

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1 ROSE
2 experience with Mr. Rose, questions about 11:09:28AM
3 that. 11:09:31AM
4 MR. GOLDBERG: Mr. Bach, rather 11:09:35AM
5 than eat up the time in this deposition, 11:09:36AM
6 if you have a stock objection, I invite 11:09:38AM
7 you to come up with some wording so that 11:09:40AM
8 the court reporter knows that you're 11:09:42AM
9 asserting the same stock objection. 11:09:44AM
10 Otherwise you're eating up part 11:09:46AM
11 of the seven hours that we had agreed to 11:09:48AM
12 and I would ask you to stop doing that. 11:09:49AM
13 I am going to step out for a 11:09:51AM
14 minute off the record and speak to my 11:09:52AM
15 partner and come back in and continue the 11:09:54AM
16 deposition. 11:09:56AM
17 (Recess taken.) 11:10:00AM
18 MR. BACH: We will allow him to 11:17:47AM
19 answer yes or no the question whether he 11:17:49AM
20 ever had a romantic relationship with 11:17:53AM
21 someone who worked at CBS. 11:17:56AM
22 You're welcome to pose the 11:18:03AM
24 MR. GOLDBERG: I will repeat 11:18:09AM
25 that question, and as I said, Jonathan, I 11:18:09AM

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1 ROSE
2 am not going to stop you from making 11:18:14AM
3 objections, but in respect of the time of 11:18:15AM
4 the deposition, if you have a standard 11:18:18AM
5 objection, like the one you have been 11:18:21AM
6 reading, I would ask you to say something 11:18:23AM
7 to the court reporter that says please 11:18:24AM
8 insert this objection, give it a name, and 11:18:26AM
9 then she will know to put it in there, 11:18:29AM
10 because that's a long speaking objection 11:18:31AM
11 and I think that, you know, it is not 11:18:34AM
12 necessary to take that valuable time. 11:18:37AM
13 You can just assert the 11:18:40AM
14 objection and the court reporter will put 11:18:41AM
15 it in. 11:18:43AM
16 MR. BACH: I will say one word 11:18:43AM
17 very tersely, understood. 11:18:45AM
18 Q. Mr. Rose, did you ever have a 11:18:49AM
19 romantic relationship with anyone that 11:18:50AM
20 worked for you at CBS? 11:18:52AM
21 MR. BACH: You may answer yes 11:18:53AM
22 or no. 11:18:54AM
23 A. Yes. 11:18:54AM
24 Q. Who was that person? 11:18:55AM
25 MR. BACH: Same objection that 11:18:57AM

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2 I recited before and all the grounds. 11:18:58AM
3 (Standard objection by Mr. 11:18:58AM
4 Bach: Object to this question on the 11:07:20AM
5 ground it seeks information that's not 11:07:21AM
6 material and necessary in the adjudication 11:07:24AM
7 of the claim, on the ground it seeks 11:07:27AM
8 information about private and confidential 11:07:30AM
9 matters involving third parties unrelated 11:07:33AM
10 to this case, and we're going to object on 11:07:36AM
11 the ground that it is plainly improper and 11:07:38AM
13 Mr. Rose.) 11:07:42AM
14 Q. Mr. Rose, you met the 11:19:14AM
15 plaintiff, Brooks Harris, in 2016, 11:19:16AM
16 correct? 11:19:18AM
17 A. Yes. 11:19:18AM
18 Q. Ms. Harris was a W-2 employees 11:19:20AM
19 of CBS at the time, right? 11:19:24AM
20 A. I assume so. 11:19:27AM
21 Q. She was in her low 20s, right? 11:19:28AM
22 A. I assume so. 11:19:31AM
23 Q. You met her while she was 11:19:36AM
24 working in the CBS studios, the CTM 11:19:37AM
25 studios, during the day shift, right? 11:19:42AM

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2 CTM. 11:21:50AM
3 Q. You knew she was a low level 11:21:56AM
4 employee at CBS, right? 11:21:59AM
5 A. I didn't know that, no. 11:22:00AM
6 Q. Were you looking to hire her as 11:22:03AM
7 an executive producer for your show? 11:22:05AM
8 A. No. 11:22:07AM
9 Q. Were you looking to hire her as 11:22:08AM
10 some sort of assistant? 11:22:10AM
11 A. Yes, with some experience in 11:22:12AM
12 social media, which she was doing when I 11:22:22AM
13 met her. 11:22:24AM
14 Q. Did you have a nickname in the 11:22:27AM
15 studio, Charlie fuck'n Rose? 11:22:28AM
16 A. I've heard that, yes. 11:22:33AM
17 Q. Did you ever call yourself 11:22:34AM
18 that? 11:22:35AM
19 A. No. 11:22:35AM
20 Q. People in the studio -- 11:22:42AM
21 A. In fact -- 11:22:45AM
22 Q. Sorry? 11:22:45AM
23 A. I just wouldn't do that. 11:22:46AM
24 Q. I'm not interrupting you, Mr. 11:22:47AM
25 Rose; if there is something you want to 11:22:50AM

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2 say, I will wait. 11:22:51AM
3 Did Gayle King refer to you in 11:22:52AM
4 that way? 11:22:54AM
5 A. Yes. 11:22:54AM
6 Q. How about Norah O'Donnell, did 11:22:55AM
7 she use that term with you? 11:22:58AM
8 A. I could imagine she did, but I 11:23:00AM
9 don't remember specifically. 11:23:01AM
10 Q. Did you ever flirt with Gayle 11:23:07AM
11 King? 11:23:08AM
12 A. Yes. 11:23:11AM
13 Q. Did you flirt with Norah 11:23:12AM
14 O'Donnell? 11:23:14AM
15 A. Yes. 11:23:14AM
16 Q. Did you flirt with Erica Hill? 11:23:17AM
17 A. Erica Hill only worked there 11:23:22AM
18 for a very short time, I didn't know her 11:23:24AM
19 as well. 11:23:27AM
20 Q. How about Bianna Golodryga, did 11:23:27AM
21 you ever flirt with her? 11:23:30AM
22 A. Yes. 11:23:31AM
23 Q. You did that in the middle of 11:23:36AM
24 the CTM studio, right? 11:23:38AM
25 A. Yes. 11:23:40AM

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2 Q. Did you think that behavior was 11:23:44AM
3 acceptable? 11:23:46AM
4 MR. BACH: Object to the form 11:23:46AM
5 of the question. 11:23:47AM
6 A. I'm sorry, repeat that 11:23:56AM
8 Q. Did you think that behavior was 11:23:57AM
9 appropriate? 11:23:59AM
10 A. No one seemed to object. 11:24:01AM
11 Q. Did you ever flirt with Chelsea 11:24:14AM
12 Wei? 11:24:21AM
13 A. Sure. 11:24:21AM
14 Q. What did you do to flirt with 11:24:23AM
15 Chelsea Wei? 11:24:25AM
16 A. Show interest in her 11:24:31AM
17 intelligence and curiosity. 11:24:35AM
18 Q. What words did you use to flirt 11:24:43AM
19 with Chelsea Wei? 11:24:44AM
20 A. Conversations about China. 11:24:48AM
21 Q. What did you say to Chelsea Wei 11:24:51AM
22 that you consider flirting? 11:24:53AM
23 A. I'm interested in doing some 11:24:55AM
24 programs on China and she expressed some 11:24:56AM
25 interest in that. 11:25:02AM

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2 Q. Did you use any other words 11:25:08AM
3 with Chelsea that you considered flirting? 11:25:09AM
4 A. Nothing comes to mind. 11:25:13AM
5 Q. Did you flirt with Chelsea Wei 11:25:25AM
6 with any physical behavior? 11:25:28AM
7 A. Are you referring to something 11:25:40AM
8 specific? 11:25:41AM
9 Q. I am asking you. 11:25:42AM
10 I will get to some specific 11:25:42AM
11 questions, but I am asking you any 11:25:44AM
12 physical behavior, any physical action 11:25:48AM
13 that you took that you consider flirting? 11:25:50AM
14 A. No, nothing comes to mind. 11:25:52AM
15 Q. What about flirting with Gayle 11:25:54AM
16 King or Norah O'Donnell physically, 11:25:56AM
17 anything that you did that was physical? 11:25:59AM
18 A. All of us would in one way or 11:26:05AM
19 the other touch each other, on the arm, 11:26:08AM
20 hug each other. 11:26:10AM
21 Q. Kissing? 11:26:11AM
22 A. If we were greeting each other, 11:26:15AM
23 saying hello or if we were saying goodbye. 11:26:18AM
24 Q. And that's flirty behavior, 11:26:20AM
25 right? 11:26:23AM

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2 they came to the set, in greeting I would 11:27:41AM
3 hug them. 11:27:44AM
4 Q. And kissing too? 11:27:44AM
5 A. On the cheek, yes. 11:27:45AM
6 Q. How about kissing on the lips? 11:27:46AM
7 A. No, I don't remember that. 11:27:48AM
8 I'm saying it might be some 11:27:52AM
9 special circumstances, but I don't 11:27:56AM
10 remember. 11:27:57AM
11 Q. How about Bonnie Raitt, did you 11:27:57AM
12 kiss her on the lips? 11:27:59AM
13 A. I might have, I have known 11:28:00AM
14 Bonnie Raitt for a long time. 11:28:02AM
15 Q. Did you ever date her? 11:28:03AM
17 of the question and same stock objection 11:28:06AM
18 as before. 11:28:08AM
19 I instruct the witness not to 11:28:12AM
20 answer. 11:28:14AM

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7 Mr. Rose.) 11:07:42AM
8 Q. Norah O'Donnell, did you hug 11:28:16AM
9 and kiss her at times? 11:28:18AM
10 A. In the context of kissing on 11:28:20AM
11 the cheek when I said hello or goodbye. 11:28:21AM
12 If we unexpectedly saw each 11:28:28AM
13 other. 11:28:32AM
14 Q. Did you put your arms around 11:28:32AM
15 Gayle King or Norah O'Donnell? 11:28:34AM
16 A. I would hug them, yes. 11:28:38AM
17 Q. How about Bianna Golodryga, hug 11:28:44AM
18 and kiss her? 11:28:48AM
19 A. Yes, I would imagine so, I 11:28:48AM
20 can't remember specifically, but I know 11:28:50AM
21 her. 11:28:53AM
22 Q. Put your arms around her? 11:28:53AM
23 A. Hug her; hug is a form of 11:28:56AM
24 greeting. 11:29:04AM
25 Q. Did you hug and kiss Chelsea 11:29:08AM

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2 Wei? 11:29:12AM
3 A. I would imagine so, I don't 11:29:12AM
4 remember specific instances. 11:29:15AM
5 Q. Did you hug and kiss Brooks 11:29:16AM
6 Harris? 11:29:18AM
7 A. Yes, I would think so. 11:29:19AM
8 Q. Did you hug and kiss Sydney 11:29:20AM
9 McNeal? 11:29:22AM
10 A. Hug and kiss saying hello and 11:29:24AM
11 on departing, if we were going away or on 11:29:27AM
12 some occasion that we had come together 11:29:32AM
13 for some reason -- 11:29:36AM
14 Q. This -- 11:29:39AM
15 A. -- like a meal. 11:29:40AM
16 Q. This was behavior you did with 11:29:42AM
17 female employees that worked with you? 11:29:44AM
20 A. Female and male. 11:29:48AM
21 Q. What males did you hug and 11:29:50AM
22 kiss? 11:29:51AM
23 A. Not hug, I can't remember, but 11:29:52AM
24 people that I know. 11:29:57AM
25 Hugging is an act of 11:29:59AM

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2 friendship, an act of affirmation. 11:30:02AM
3 Q. Are there any males that you 11:30:09AM
4 kissed? 11:30:10AM
5 A. I'm sure there are. 11:30:11AM
6 Q. What are their names -- 11:30:12AM
7 A. I don't remember right off. 11:30:13AM
8 MR. BACH: Let him finish his 11:30:14AM
9 question and then you can answer the 11:30:16AM
11 THE WITNESS: Okay. 11:30:19AM
12 Q. Name the males that you hugged 11:30:24AM
13 and kissed. 11:30:27AM
14 A. I will try to think about some 11:30:28AM
15 and get back to you, but certainly I come 11:30:29AM
16 from a background in which, when you greet 11:30:34AM
17 male friends, you hug them. 11:30:39AM
18 Q. And you kissed them on the 11:30:41AM
19 cheek like you kissed -- 11:30:43AM
20 A. I have -- 11:30:44AM
21 MR. BACH: Let him finish the 11:30:46AM
23 Q. Name the males that you hugged 11:30:49AM
24 and kissed on the cheek in CTM studios in 11:30:50AM
25 2017. 11:30:53AM

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2 MR. BACH: Object, asked and 11:30:53AM
3 answered. 11:30:54AM
4 Q. You can answer again; can you 11:30:56AM
5 name any males that you hugged and kissed 11:31:01AM
6 on the cheek in the CTM studios in 2017? 11:31:02AM
7 A. I'm sure I can, but they don't 11:31:05AM
8 come to mind at this moment. 11:31:07AM
9 Q. How about naming males that you 11:31:08AM
10 hugged and kissed on the cheek in the 11:31:11AM
11 Bloomberg building, 731 Lexington, in 11:31:12AM
12 2017? 11:31:17AM
13 A. I would say the same thing. 11:31:19AM
14 Q. Did you hug and kiss Beth 11:31:35AM
15 Haram? 11:31:44AM
16 A. I don't remember, no, I don't 11:31:44AM
17 remember Beth Haram. 11:31:46AM
18 Q. You started taking Brooks 11:31:53AM
19 Harris to lunch as early as January 2017, 11:31:54AM
20 right? 11:31:57AM
23 A. Yes. 11:32:04AM
24 Q. And you took her to lunch 11:32:05AM
25 January 25, 2017, to a place called Nello, 11:32:06AM

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2 have done because I try to be interested 11:46:26AM
3 in terms of what people want to do. 11:46:29AM
4 Q. Did you invite any of your 11:46:33AM
5 staff to your Bellport home that summer? 11:46:35AM
6 A. I don't remember in 2014 11:46:40AM
7 summer, but I can imagine that I did. 11:46:42AM
8 Q. You don't -- 11:46:46AM
9 A. But not individually. 11:46:47AM
10 Q. But not individually? 11:46:49AM
11 A. I don't remember; in the past 11:46:50AM
12 we've had parties there. 11:46:53AM
13 Q. There have been times when you 11:46:54AM
14 have had a single female employee of yours 11:46:56AM
15 come to your Bellport home, right, sir? 11:46:58AM
16 A. Yes. 11:47:00AM
17 Q. One of those people is Reah 11:47:02AM
18 Bravo, right? 11:47:05AM
19 MR. BACH: Objection, 11:47:06AM
20 objection. 11:47:06AM
21 I am going to instruct the 11:47:07AM
22 witness not to answer the question and I 11:47:10AM
23 am going to object on the ground it is 11:47:12AM
24 seeking information not material or 11:47:15AM
25 necessary for the adjudication of this 11:47:16AM

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2 claim and I am going to recite the same 11:47:19AM
3 grounds as my prior objection. 11:47:22AM
14 Mr. Rose.) 11:07:42AM
15 MR. GOLDBERG: It is sufficient 11:47:24AM
16 for me, Mr. Bach, if you say, you know, I 11:47:24AM
17 am asserting my long objection and the 11:47:27AM
18 court reporter will simply put that in. 11:47:29AM
19 (Discussion off the record.) 11:48:15AM
20 Q. Did you know Reah Bravo? 11:48:16AM
21 MR. BACH: I am going to 11:48:18AM
22 object, same standard objection. 11:48:19AM

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9 Mr. Rose.) 11:07:42AM
10 MR. BACH: I ask you, counsel, 11:48:21AM
11 to limit your questions to the time frame, 11:48:22AM
12 at or about the time -- 11:48:26AM
13 Q. Did you ever have an employee 11:48:28AM
14 that worked for you by the name of Reah 11:48:31AM
15 Bravo? 11:48:35AM
16 MR. BACH: Answer that question 11:48:35AM
17 yes or no. 11:48:36AM
18 A. Yes. 11:48:39AM
19 Q. Getting back to Sydney McNeal, 11:48:44AM
20 do you recall that she joined -- she came 11:48:47AM
21 to work for you about the same day that 11:48:49AM
22 Brooks Harris began working for you? 11:48:51AM
23 A. Yes. 11:48:55AM
24 Q. And Ms. McNeal's position was 11:48:56AM
25 executive assistant? 11:48:58AM

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2 A. I don't remember instructing 12:17:02PM
3 people to do anything. 12:17:03PM
4 To be honest with you, I never 12:17:08PM
5 really knew who was going to show up when 12:17:10PM
6 I participated in an event like that, 12:17:13PM
7 because people would come out of 12:17:15PM
8 curiosity. 12:17:17PM
9 Q. You mentioned Ms. Vega a couple 12:17:24PM
10 of minutes ago. 12:17:26PM
11 For how long did Ms. Vega work 12:17:27PM
12 for you? 12:17:28PM
13 A. I think a little more than 20 12:17:32PM
14 years. 12:17:35PM
15 Q. She began working for you in 12:17:35PM
16 the 1990s? 12:17:37PM
17 A. Yes. 12:17:37PM
18 Q. And she was your executive 12:17:39PM
19 producer? 12:17:41PM
20 A. Eventually. 12:17:43PM
21 Q. That was her final position? 12:17:45PM
22 A. Yes. 12:17:46PM
23 Q. Do you remember when she became 12:17:50PM
24 executive producer? 12:17:52PM
25 A. I don't. 12:17:54PM

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2 Q. Did she have power to hire and 12:18:03PM
3 fire employees? 12:18:04PM
4 A. She did, certainly in areas 12:18:09PM
5 that I was not involved in. 12:18:18PM
6 Q. Do you know if she was being 12:18:23PM
7 paid through Bloomberg like Ms. Harris and 12:18:24PM
8 Ms. McNeal? 12:18:27PM
9 A. Yes. 12:18:31PM
10 Q. The answer is yes? 12:18:33PM
11 A. Yes. 12:18:34PM
12 Q. Did you ever hug and kiss Ms. 12:18:37PM
13 Vega? 12:18:40PM
14 A. Yes. 12:18:41PM
15 Q. Do you consider her to be a 12:18:42PM
16 friend? 12:18:45PM
17 A. Yes. 12:18:46PM
18 Q. Are you god-father to her 12:18:49PM
19 children? 12:18:51PM
20 A. Yes. 12:18:52PM
21 Q. Is she a beneficiary of your 12:18:54PM
22 will? 12:18:56PM
23 MR. BACH: I'm going to object 12:18:57PM
24 to that question and instruct the witness 12:18:59PM
25 not to answer. 12:19:02PM

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2 Q. You have a close relationship 12:19:05PM
3 with Ms. Vega, right, Mr. Rose? 12:19:06PM
4 A. Yes, I've worked with her for a 12:19:08PM
5 long time. 12:19:18PM
6 Q. Did you ever have any sort of 12:19:22PM
7 intimate relationship with her? 12:19:23PM
8 MR. BACH: Same standard 12:19:31PM
9 objection. 12:19:33PM
10 (Standard objection by Mr. 12:19:33PM
20 Mr. Rose.) 11:07:42AM
21 Q. We talked earlier about hugging 12:19:41PM
22 and kissing and your testimony will speak 12:19:44PM
23 for itself. 12:19:46PM
24 Did you, in addition to hugging 12:19:47PM
25 and kissing, what about just making 12:19:51PM

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2 made to Ms. McNeal in April 2017? 02:13:13PM
3 A. Yes. 02:13:17PM
4 Q. I will take that back. 02:13:19PM
5 And Ms. McNeal accepted the job 02:13:21PM
6 offer, right? 02:13:23PM
7 A. Yes. 02:13:25PM
8 Q. Mr. Rose, prior to November 02:13:27PM
9 20th of 2017, did you have information 02:13:30PM
10 that the Washington Post was going to 02:13:36PM
11 publish an article about you? 02:13:38PM
12 A. Prior to? 02:13:42PM
13 Q. Prior to the Washington Post 02:13:43PM
14 publishing its article of November 20, 02:13:46PM
15 2017, the article that talked about you, 02:13:48PM
16 did you know that that article was coming 02:13:53PM
17 out, did you have advance information? 02:13:55PM
18 A. I think I was informed, 02:13:57PM
19 officially informed, about 14 hours 02:14:02PM
20 before. 02:14:06PM
21 Q. Who gave you that notice 14 02:14:06PM
22 hours before? 02:14:08PM
23 A. One of the reporters. 02:14:09PM
24 Q. The article was titled "Eight 02:14:13PM
25 Women Say Charlie Rose Sexually Harassed 02:14:16PM

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2 Them With Nudity, Groping and Lewd Calls." 02:14:18PM
3 Who is the reporter that 02:14:22PM
4 indicated the article was coming out? 02:14:24PM
5 A. I think it was Amy Brittain. 02:14:29PM
6 Q. Did you speak with Ms. Brittain 02:14:33PM
7 on the phone? 02:14:35PM
8 A. No. 02:14:36PM
9 Q. Was it a written exchange? 02:14:36PM
10 A. I didn't -- it was an e-mail. 02:14:37PM
11 Q. She sent an e-mail to you? 02:14:39PM
12 A. Yes. 02:14:41PM
13 Q. Did you respond to her e-mail? 02:14:41PM
14 A. I responded with a tweet. 02:14:44PM
15 Q. Just so I understand the 02:14:59PM
16 sequence, about 14 hours before the 02:15:00PM
17 Washington Post article of November 20th, 02:15:02PM
18 2017, about 14 hours before the article 02:15:04PM
19 was published, Amy Brittain e-mailed you 02:15:08PM
20 to let you know the article was going to 02:15:11PM
21 be published? 02:15:13PM
22 A. Yes. 02:15:14PM
23 Q. And prior to Amy Brittain's 02:15:14PM
24 e-mail, did you have any communication 02:15:17PM
25 with the Washington Post about the 02:15:19PM

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2 allegations that were going to be in that 02:15:21PM
3 article? 02:15:23PM
4 A. No. 02:15:23PM
5 Q. Prior to that 14-hour notice, 02:15:26PM
6 did you have any -- 02:15:28PM
7 A. 14 hours, meaning somewhere 02:15:29PM
8 late Sunday afternoon, with a deadline the 02:15:32PM
9 next day. 02:15:35PM
10 Q. Did Amy Brittain seek to, in 02:15:38PM
11 her e-mail to you, did she ask to speak 02:15:41PM
12 with you or address the allegations? 02:15:43PM
13 A. In a limited way she did 02:15:52PM
14 address the allegations, as I remember. 02:15:54PM
15 Q. Do you still have a copy of 02:15:58PM
16 that e-mail somewhere? 02:16:00PM
17 A. I might, I suspect I do. 02:16:01PM
18 Q. Was it sent to your CR at 02:16:05PM
19 Charlie Rose dot com? 02:16:08PM
20 A. I think so. 02:16:09PM
21 Q. Did you write back to Amy 02:16:13PM
22 Brittain? 02:16:16PM
23 MR. BACH: Asked and answered. 02:16:16PM
24 Q. You said you answered with a 02:16:17PM
25 tweet, but did you write back to Amy 02:16:19PM

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2 Brittain? 02:16:21PM
3 A. No, it was in a tweet. 02:16:22PM
4 I don't remember asking her, 02:16:24PM
5 but -- personally I didn't have any 02:16:25PM
6 conversation with her, personally. 02:16:28PM
7 MR. GOLDBERG: We will mark as 02:16:33PM
8 Exhibit 7 a document with Bates No. P 02:16:34PM
9 0001. 02:16:43PM
10 (Plaintiffs' Exhibit 7, Bates 02:16:43PM
11 No. P 0001, was marked for identification, 02:16:43PM
12 as of this date.) 02:16:54PM
13 (Witness perusing document.) 02:16:54PM
14 Q. Is this the tweet you're 02:16:54PM
15 referring to in your testimony? 02:16:56PM
16 A. Yes. 02:16:57PM
17 Q. Mr. Rose, tell me if I'm 02:17:00PM
18 correct. 02:17:02PM
19 Did you put this tweet out 02:17:03PM
20 after the Washington Post article came 02:17:07PM
21 out? 02:17:09PM
22 A. No, before. 02:17:12PM
23 Q. All right, so you're saying -- 02:17:13PM
24 A. Because I think it was included 02:17:15PM
25 within their story. 02:17:20PM

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2 Q. I see. 02:17:22PM
3 So this tweet, you put this 02:17:48PM
4 tweet out on November 20, 2017, correct, 02:17:50PM
5 sir? 02:17:53PM
6 A. What day of the week is it, the 02:17:54PM
7 20th? 02:17:56PM
8 Q. I would have to check. 02:17:58PM
9 Did you draft this tweet that's 02:18:04PM
10 plaintiffs' -- 02:18:07PM
11 A. Monday, Tuesday, I think -- 02:18:07PM
12 Q. Let me back up a step. 02:18:15PM
13 A. Okay. 02:18:16PM
14 Q. Plaintiffs' Exhibit 7 is a 02:18:16PM
15 tweet that you drafted? 02:18:23PM
16 A. Someone -- November 20th is 02:18:25PM
17 what day of the week? 02:18:27PM
18 Q. The exhibit, which is Exhibit 02:18:31PM
19 No. 7, Plaintiffs' Exhibit No. 7, that is 02:18:33PM
20 a tweet that you issued, correct, sir? 02:18:36PM
21 A. Yes. 02:18:37PM
22 Q. You issued it on November 20, 02:18:38PM
23 2017, right? 02:18:41PM
24 A. Right. 02:18:42PM
25 Q. Did you draft this document 02:18:44PM

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2 yourself? 02:18:45PM
3 A. In consult with a lawyer and a 02:18:47PM
4 communications advisor. 02:19:01PM
5 Q. Is the lawyer Dick Beatie? 02:19:03PM
6 A. Yes. 02:19:04PM
7 Q. Who is the communications 02:19:05PM
8 advisor? 02:19:07PM
9 A. I think his name was -- I can 02:19:07PM
10 get it for you, I think it was somebody 02:19:15PM
11 that Mr. Beatie knew. 02:19:17PM
12 Q. We will put a blank in the 02:19:19PM
13 transcript to fill in the name of the 02:19:20PM
14 communications person. 02:19:22PM
15 A. Sure. 02:19:24PM
16 (Insert.) 02:19:24PM
17 __________________________________________ 02:19:24PM
18 _________________________________________. 02:19:25PM
19 Q. Do you stand behind the 02:19:25PM
20 contents of Exhibit 7? 02:19:26PM
21 A. Yes. 02:19:27PM
22 Q. Is the contents of Exhibit 7 02:19:29PM
23 true and accurate? 02:19:32PM
24 A. Yes. 02:19:33PM
25 Q. Is it your recollection that 02:19:41PM

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2 you issued this tweet, Exhibit 7, prior to 02:19:42PM
3 reading the article that Amy Brittain and 02:19:45PM
4 Irin Carmon published? 02:19:53PM
5 A. Yes, except in the e-mail from 02:19:56PM
6 Ms. Brittain, I don't remember what, but 02:20:06PM
7 references to several things that would be 02:20:14PM
8 included. 02:20:17PM
9 Q. So Ms. Brittain advised you in 02:20:19PM
10 her e-mail some of the substance that 02:20:21PM
11 might be published? 02:20:24PM
12 A. A little bit, one page. 02:20:25PM
13 Q. We believe that November 20th, 02:20:27PM
14 2017, is a Monday. 02:20:29PM
15 A. Right. 02:20:31PM
16 Q. Your consultation with a 02:20:46PM
17 communications person that helped you 02:20:47PM
18 draft Exhibit 7, was that in writing or 02:20:49PM
19 verbal or both? 02:20:52PM
20 A. Verbal. 02:20:52PM
21 Q. And your consultation with 02:20:56PM
22 Richard Beatie, I called him Dick Beatie, 02:20:58PM
23 but Richard Beatie, was that verbal, 02:21:01PM
24 written or both? 02:21:03PM
25 A. I would say both probably. 02:21:04PM

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2 Q. Was Mr. Beatie functioning as 02:21:12PM
3 your attorney at that point or just as an 02:21:13PM
4 advisor or friend -- 02:21:15PM
5 A. I didn't have another attorney 02:21:20PM
6 at that time. 02:21:21PM
7 Q. Did you consider Mr. Beatie to 02:21:21PM
8 be acting as your lawyer at that time? 02:21:23PM
9 A. He was a lawyer and a friend. 02:21:24PM
10 Q. Was he retained to help you 02:21:31PM
11 prepare the response? 02:21:33PM
12 A. He had been retained over the 02:21:34PM
13 years. 02:21:35PM
14 Q. Were you anticipating being 02:21:37PM
15 involved in litigation on November 20th of 02:21:40PM
16 2017? 02:21:42PM
17 A. No. 02:21:43PM
18 Q. So Mr. Beatie had been a lawyer 02:21:49PM
19 and a friend and you turned to him for 02:21:51PM
20 help to prepare Exhibit 7, is that right? 02:21:53PM
21 A. I turned to him for help and 02:21:57PM
22 counsel. 02:21:59PM
23 Q. Did he charge you for helping 02:22:00PM
24 with Exhibit 7? 02:22:02PM
25 A. I don't know, I assume. 02:22:03PM

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2 Q. But you don't recall? 02:22:04PM
3 A. I don't recall. 02:22:05PM
4 Q. Exhibit No. 7, if we can look 02:22:27PM
5 at that together, it says, "In my 45 years 02:22:31PM
6 of journalism, I have prided myself on 02:22:35PM
7 being an advocate for the careers with the 02:22:38PM
8 women with whom I have worked." 02:22:40PM
9 Were there any particular women 02:22:42PM
10 that you were referring to in that 02:22:44PM
11 sentence or thinking about when you wrote 02:22:45PM
12 that sentence? 02:22:47PM
13 A. I was thinking more of a 02:22:52PM
14 general way that I have recommended women 02:22:53PM
15 for fellowships and for other kinds of 02:22:58PM
16 things or have given them career advice, 02:23:02PM
17 that kind of thing. 02:23:05PM
18 Q. So 45 years of journalism 02:23:09PM
19 brings us back to the Seventies, right, 02:23:10PM
20 sir? 02:23:12PM
21 A. 45 years would bring you back 02:23:15PM
22 to the Seventies, yes. 02:23:17PM
23 Q. In the next sentence it says, 02:23:18PM
24 "Nevertheless, in the past few days claims 02:23:20PM
25 have been made about my behavior towards 02:23:23PM

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2 some former female colleagues." 02:23:25PM
3 Is that a reference to the 02:23:27PM
4 substance of the Washington Post article 02:23:30PM
5 of November 20th, 2017? 02:23:33PM
6 A. Not specifically, no. 02:23:35PM
7 Q. Are there particular former 02:23:37PM
8 female colleagues that you were referring 02:23:39PM
9 to in that sentence? 02:23:40PM
10 A. As I remember that day, it was 02:23:42PM
11 more of a sense of things that I had heard 02:23:45PM
12 on the Internet and had been said to me in 02:23:49PM
13 the last, you know, few days, some people 02:23:52PM
14 had mentioned. 02:23:55PM
15 Q. This Twitter statement, this 02:23:56PM
16 tweet, you believe you issued this 02:23:59PM
17 publicly before the Washington Post 02:24:03PM
18 article was published? 02:24:06PM
19 A. I believe that, because, as I 02:24:08PM
20 said, they included it in there. 02:24:10PM
21 Q. In the next sentence it says, 02:24:13PM
22 "It is essential that these women know I 02:24:14PM
23 hear them, that I deeply apologize for my 02:24:17PM
24 inappropriate behavior." 02:24:19PM
25 Does that sentence refer to any 02:24:21PM

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2 particular women? 02:24:22PM
3 A. No, it refers to people that 02:24:23PM
4 had been associated with me and I might 02:24:25PM
5 have had some kind of relationship with 02:24:26PM
6 over my -- in my years of working as a 02:24:28PM
7 journalist. 02:24:38PM
8 Q. You say "my inappropriate 02:24:38PM
9 behavior." 02:24:41PM
10 What inappropriate behavior are 02:24:42PM
11 you referring to? 02:24:44PM
12 A. Well, I'm saying inappropriate 02:24:46PM
13 because the fact I had relationships with 02:24:48PM
14 people in the workplace over those 45 02:24:55PM
15 years and, you know, we have now come to 02:24:58PM
16 understand and appreciate and had by then 02:25:02PM
17 that romantic relationships or intimacies 02:25:07PM
18 were not appropriate in the workplace 02:25:16PM
19 because, you know, because there was power 02:25:19PM
20 and balance, and you were in some cases 02:25:22PM
21 the boss and you had a relationship that 02:25:31PM
22 was defined within the workplace. 02:25:44PM
23 Q. Is this sentence, again, when 02:25:56PM
24 you say these women, are you referring to 02:25:58PM
25 any particular women? 02:26:01PM

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2 A. No, referring to women that -- 02:26:02PM
3 I was not referring to a particular woman, 02:26:06PM
4 but I was referring to where I might have 02:26:08PM
5 had a relationship. 02:26:10PM
6 Q. So you were referring to women 02:26:12PM
7 with whom you had had a romantic 02:26:14PM
8 relationship or intimate relationship? 02:26:16PM
9 A. Some kind of intimacy, yes. 02:26:18PM
10 Q. That reference, when you say 02:26:34PM
11 romantic and intimate, that's over the 02:26:37PM
12 course of your 45 years in journalism? 02:26:39PM
13 A. Yes. 02:26:41PM
14 Q. It then says, "I am greatly 02:26:49PM
15 embarrassed. I have behaved insensitively 02:26:51PM
16 at times." 02:26:55PM
17 What behavior are you referring 02:26:57PM
18 to? 02:26:58PM
19 A. Embarrassed to have, you know, 02:26:59PM
20 to have had romantic -- the fact that I 02:27:04PM
21 had romantic relationships with people 02:27:10PM
22 that work with you, because we have come 02:27:12PM
23 to understand that it is inappropriate to 02:27:16PM
24 have those kind of relationships in the 02:27:20PM
25 workplace and for me not to be sensitive, 02:27:21PM

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2 you know, to the fact that you're the 02:27:26PM
3 boss, to that kind of relationship was 02:27:32PM
4 insensitive. 02:27:36PM
5 Q. You then wrote, "I always felt 02:27:39PM
6 that I was pursuing shared feelings even 02:27:41PM
7 though now I realize I was mistaken." 02:27:44PM
8 That's a reference to these 02:27:47PM
9 romantic relationships and intimate 02:27:48PM
10 relationships? 02:27:50PM
11 A. It is a reference to the fact 02:27:51PM
12 that we now know that we might have 02:27:53PM
13 thought that, but some people have stepped 02:27:57PM
14 forward to say, well, that it was in the 02:27:59PM
15 workplace and therefore, you know, it 02:28:05PM
16 wasn't necessarily shared by definition. 02:28:08PM
17 Q. In other words, some people 02:28:12PM
18 might have said it wasn't consensual, is 02:28:14PM
19 that what you mean? 02:28:16PM
20 MR. BACH: Object to the form 02:28:17PM
21 of the question. 02:28:18PM
22 Q. Is that what you mean, Mr. 02:28:20PM
23 Rose? 02:28:23PM
24 A. I mean, yes, in essence; that 02:28:23PM
25 some people might not in the workplace 02:28:27PM

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2 feel it was consensual. 02:28:29PM
3 But insensitive not to know 02:28:32PM
4 that. 02:28:35PM
5 Q. Are any of the women that 02:28:38PM
6 you're thinking of when you wrote this 02:28:40PM
7 women that were mentioned in the 02:28:42PM
8 Washington Post article of 02:28:44PM
9 November 20th -- 02:28:46PM
10 A. I wasn't thinking about 02:28:47PM
11 specific people, I was thinking of my own 02:28:48PM
12 sense of passion, my history and respect 02:28:50PM
13 for women, my sense of emotional 02:28:54PM
14 connection to gender equality, my idea of 02:28:56PM
15 always being a champion and in that 02:29:01PM
16 capacity. 02:29:08PM
17 Q. Just so I'm clear on what you 02:29:09PM
18 mean, are you saying that the tweet, 02:29:11PM
19 Exhibit 7, is not intended to be a 02:29:18PM
20 response to the allegations against you 02:29:21PM
21 that were published by the Washington Post 02:29:25PM
22 on November 20th, 2017? 02:29:26PM
25 A. It was a broader sense of my 02:29:32PM

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2 own -- in 45 years of journalism. 02:29:33PM
3 Q. The Washington Post article had 02:29:40PM
4 mentioned three women by name, Reah Bravo, 02:29:41PM
5 Kyle Godfrey-Ryan, Megan Creydt. 02:29:44PM
6 Does your Exhibit 7, your 02:29:48PM
7 tweet, relate in whole or in part to any 02:29:53PM
8 of those women? 02:29:55PM
11 A. I was thinking more in the 02:29:58PM
12 sense of really without specific women, I 02:29:59PM
13 wanted to apologize -- 02:30:07PM
14 Q. Were any of the -- 02:30:08PM
15 A. -- for romantic relationships. 02:30:09PM
16 Q. Were any of the women in the 02:30:11PM
17 Washington Post article, specifically Reah 02:30:13PM
18 Bravo, Kyle Godfrey-Ryan or Megan Creydt, 02:30:15PM
19 women with whom you claim you had a 02:30:18PM
20 romantic relationship? 02:30:20PM
21 MR. BACH: Same standard, 02:30:22PM
22 objection and instruct the witness not to 02:30:23PM
23 answer. 02:30:27PM

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10 Mr. Rose.) 11:07:42AM
11 Q. Did you read the article that 02:30:33PM
12 the Washington Post published, "Eight 02:30:35PM
13 Women Say Charlie Rose Sexually Harassed 02:30:37PM
14 Them with Nudity, Groping and Lewd 02:30:39PM
15 Comments"? 02:30:42PM
16 A. I did. 02:30:43PM
17 Q. Did you discuss that article 02:30:43PM
18 with anyone? 02:30:44PM
19 A. Mr. Beatie for sure and the 02:30:47PM
20 advisor, his name was Steven something. 02:30:54PM
21 Q. We will leave a blank in the 02:30:58PM
22 transcript and when you recall the full 02:30:59PM
23 name, we'll certainly appreciate knowing 02:31:01PM
24 the name of the communications person. 02:31:03PM
25 And if he is connected to a 02:31:06PM

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2 communications business, we would like to 02:31:08PM
3 know the name of that. 02:31:09PM
4 (Insert.) 02:31:09PM
5 __________________________________________ 02:31:09PM
6 _________________________________________. 02:31:11PM
7 Q. Mr. Beatie, when you discussed 02:31:11PM
8 the article with him, he was just again 02:31:12PM
9 functioning as your long-term friend, a 02:31:14PM
10 lawyer that you had used for other 02:31:17PM
11 matters? 02:31:19PM
12 A. Yes. 02:31:23PM
13 Q. Were you consulting Mr. Beatie 02:31:24PM
14 for legal advice when you discussed the 02:31:25PM
15 article with him? 02:31:26PM
18 A. I would assume I was 02:31:30PM
19 considering; I was talking to him in the 02:31:33PM
20 context he was a lawyer. 02:31:35PM
21 Q. Were you anticipating 02:31:36PM
22 litigation when you spoke to him? 02:31:37PM
23 A. No. 02:31:39PM
24 Q. Did you discuss the article 02:31:49PM
25 with the communications person? 02:31:51PM

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2 A. He was on the phone, yes. 02:31:52PM
3 Q. So you had a phone call with 02:31:54PM
4 the communications person and Mr. Beatie? 02:31:56PM
5 A. Yes. 02:31:58PM
6 Q. Did you have a similar phone 02:31:59PM
7 call for preparing the tweet, Exhibit 7? 02:32:01PM
8 A. It was all part of the same 02:32:10PM
9 time. 02:32:13PM
10 I wanted to make a statement 02:32:17PM
11 about how I felt about women, my great and 02:32:19PM
12 long-felt admiration about women and at 02:32:26PM
13 the same time I understood that, as I 02:32:29PM
14 said, I have learned a great deal in the 02:32:32PM
15 result of these events and I hoped others 02:32:35PM
16 would too, all of us are coming to a newer 02:32:38PM
17 and deeper recognition of pain caused by 02:32:40PM
18 that conduct. 02:32:43PM
19 Q. The reason I was asking you 02:32:43PM
20 about a separate call is because, as I 02:32:45PM
21 understood your testimony, you issued the 02:32:47PM
22 tweet before the Washington Post article 02:32:49PM
23 came out. 02:32:51PM
24 So I was trying to make sure -- 02:32:52PM
25 A. With a little bit of knowledge 02:32:54PM

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2 of what might be in it. 02:32:55PM
3 Q. So you had a three-way phone 02:32:56PM
4 call with Beatie and the communications 02:32:58PM
5 person to prepare the tweet, is that 02:33:01PM
6 right? 02:33:06PM
9 A. Yes. 02:33:08PM
10 Q. And after you read the article, 02:33:09PM
11 you had another call with them to discuss 02:33:11PM
12 the article from the Washington Post of 02:33:12PM
13 November 20th? 02:33:14PM
14 A. You're asking me for a very 02:33:15PM
15 tense period of wanting to respond to what 02:33:19PM
16 was going on and sort of to capture my own 02:33:23PM
17 emotional feeling and my own deep profound 02:33:28PM
18 feelings I had about women. 02:33:33PM
19 Q. It is fair to say that there is 02:33:37PM
20 at least one three-way phone call you had, 02:33:39PM
21 right, with Mr. Beatie and the 02:33:41PM
22 communications individual? 02:33:43PM
23 A. Yes. 02:33:48PM
24 Q. Did the tweet go through 02:33:51PM
25 drafts, do you know whether there were 02:33:54PM

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2 prior drafts of this Exhibit 7? 02:33:55PM
3 MR. BACH: I object to the form 02:34:00PM
5 A. I don't remember whether there 02:34:01PM
6 were drafts or not. 02:34:03PM
7 I remember we were trying to -- 02:34:03PM
8 MR. BACH: Please don't discuss 02:34:11PM
9 the content of conversations that 02:34:12PM
10 Mr. Beatie participated in. 02:34:16PM
11 MR. GOLDBERG: If there is a 02:34:19PM
12 three-way phone call with Mr. Beatie, Mr. 02:34:20PM
13 Rose and a communications person, our 02:34:24PM
14 position is that's not a privileged phone 02:34:26PM
15 call because the communications person is 02:34:28PM
16 presumably not a lawyer and not acting as 02:34:30PM
17 a lawyer, so I would like to know what 02:34:32PM
18 took place in that three-way phone call, 02:34:33PM
19 if Mr. Rose remembers. 02:34:35PM
20 MR. BACH: We disagree with 02:34:36PM
21 your position. 02:34:37PM
22 MR. GOLDBERG: Mark that for a 02:34:39PM
23 ruling. 02:34:41PM
24 Q. On November 20th, which was a 02:34:42PM
25 Monday, am I correct that you called in 02:34:44PM

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2 Internet. 02:38:29PM
3 Q. Were there any particular 02:38:30PM
4 stories that you recall hearing that you 02:38:31PM
5 felt, okay, that one was true? 02:38:34PM
7 of the question and I'm going to assert my 02:38:39PM
8 standard objection and instruct the 02:38:47PM
9 witness not to answer. 02:38:49PM
20 Mr. Rose.) 11:07:42AM
21 Q. How long was the staff meeting, 02:38:56PM
22 Mr. Rose? 02:38:57PM
23 A. I would say I don't know, so I 02:39:02PM
24 would be guessing. 02:39:05PM
25 Q. Do you remember anything you 02:39:06PM

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2 said to the staff at that meeting? 02:39:07PM
3 A. I was sorry this had happened. 02:39:09PM
4 Q. Were you apologizing for your 02:39:11PM
5 behavior? 02:39:13PM
6 A. I was apologizing for the fact 02:39:14PM
7 that all of our lives would be disrupted. 02:39:16PM
8 Q. Were you apologizing to the 02:39:19PM
9 staff for your behavior? 02:39:20PM
12 A. I was apologizing because there 02:39:25PM
13 were these accusations out there that had 02:39:28PM
14 led somebody to fire me, which led me to 02:39:31PM
15 lose the show, which led all of us to lose 02:39:34PM
16 our jobs. 02:39:37PM
17 Q. Did you consider some of the 02:39:38PM
18 accusations to be true? 02:39:39PM
19 MR. BACH: Standard objection, 02:39:42PM
20 instruct the witness not to answer. 02:39:44PM

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7 Mr. Rose.) 11:07:42AM
8 MR. GOLDBERG: Mark for a 02:39:47PM
9 ruling. 02:39:49PM
10 A. There is no -- 02:39:51PM
11 MR. BACH: I have instructed 02:39:52PM
12 you not to answer. 02:39:54PM
13 Q. Do you remember telling people 02:40:06PM
14 at the staff meeting that you made some 02:40:08PM
15 mistakes in the past and you made some 02:40:09PM
16 misjudgments? 02:40:12PM
17 A. I don't remember that, but, you 02:40:12PM
18 know, if I did, I'm sure that I would have 02:40:14PM
19 -- if I said I made mistakes, it had to 02:40:20PM
20 do with having any kind of relationships 02:40:22PM
21 in the workplace, period. 02:40:26PM
22 Q. At the time that you put out 02:40:47PM
23 this tweet, November 20, 2017, Mr. Rose, 02:40:48PM
24 CBS had not yet terminated your 02:40:55PM
25 employment, right? 02:40:57PM

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2
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6
7
8
9
10
11
12
13
14
15
16
17
18
19 Q. After, Mr. Rose, after reading 02:44:09PM
20 the Washington Post article of November 02:44:11PM
21 20th of 2017, "Eight Women Say Charlie 02:44:14PM
22 Rose Sexually Harassed Them with Nudity, 02:44:19PM
23 Groping and Lewd Calls," did you feel any 02:44:21PM
24 remorse towards the women that were 02:44:23PM
25 identified in that article? 02:44:25PM

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2 MR. BACH: Object, my standard 02:44:27PM
3 objection, instruct the witness not to 02:44:30PM
4 answer. 02:44:31PM
15 Mr. Rose.) 11:07:42AM
16 Q. Mr. Rose, do you remember being 02:44:44PM
17 confronted at The Sherry-Netherland by 02:44:46PM
18 someone with a video camera, and you said 02:44:49PM
19 "it is not wrongdoings," it was on TMZ, do 02:44:52PM
20 you remember that occurring on November 02:44:57PM
21 20th? 02:44:58PM
22 A. Yes. 02:44:58PM
23 Q. And you said -- they said what 02:45:00PM
24 do you think, and you said words to the 02:45:02PM
25 effect of it's not wrongdoings, right, 02:45:04PM

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2 form of the question. 02:46:30PM
3 Mr. Goldberg, are you referring 02:46:35PM
4 to your clients or are you referring to 02:46:37PM
5 the women in the Washington Post article, 02:46:41PM
6 what are you referring to? 02:46:43PM
7 MR. GOLDBERG: We will go 02:46:44PM
8 through each one. 02:46:45PM
9 Q. As to the allegations in the 02:46:45PM
10 Washington Post, did you consider yourself 02:46:47PM
11 to have committed any act of sexual 02:46:49PM
12 harassment? 02:46:51PM
13 MR. BACH: My standard 02:46:54PM
14 objection, plus it calls for a legal 02:46:55PM
15 conclusion, instruct the witness not to 02:46:56PM
16 answer. 02:46:58PM

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3 Mr. Rose.) 11:07:42AM
4 Q. When you read the article in 02:47:07PM
5 the Washington Post, did you feel that you 02:47:08PM
6 had engaged in any inappropriate conduct 02:47:10PM
7 towards any of the women referenced in the 02:47:12PM
8 Washington Post article? 02:47:13PM
9 MR. BACH: Same standard 02:47:15PM
10 objection, instruct the witness not to 02:47:16PM
11 answer. 02:47:18PM
22 Mr. Rose.) 11:07:42AM
23
24
25

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2
3
4
5
6
7
8 Q. Prior to the Washington Post 02:47:49PM
9 article of November 20th, 2017, did you or 02:47:50PM
10 anyone on your behalf try to persuade the 02:47:55PM
11 Washington Post not to publish their 02:48:01PM
13 A. No, not that I know of. 02:48:08PM
14 Q. Did you make any threats -- 02:48:10PM
15 A. I had no conversations with 02:48:12PM
16 them. 02:48:13PM
17 Q. Did you or anybody on your 02:48:13PM
18 behalf make any threats of litigation 02:48:15PM
19 against the Washington Post? 02:48:17PM
20 A. No, not that I know of. 02:48:18PM
21 Q. I think earlier today you said 02:48:33PM
22 that you had spoken with Chris Licht about 02:48:34PM
23 the fact that the lawsuit was filed, I may 02:48:38PM
24 be wrong, but I seem to remember that from 02:48:40PM
25 this morning. 02:48:42PM

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2 Did Mr. Licht ever talk to you 02:48:43PM
3 about a complaint he received about your 02:48:47PM
4 conduct towards a female employee? 02:48:49PM
5 MR. BACH: I am going to 02:48:52PM
6 object, interpose my standard objection, 02:48:56PM
7 and instruct the witness not to answer. 02:48:59PM
18 Mr. Rose.) 11:07:42AM
19 Q. Mr. Rose, did you issue around 02:49:31PM
20 November 21st an e-mail to the staff 02:49:35PM
21 setting forth an apology? 02:49:41PM
22 A. I don't remember; if you have 02:49:46PM
23 an apology you would like me to look at, 02:49:49PM
24 I'd be happy to. 02:49:51PM
25 Q. Exhibit 10, this will be CR 02:49:58PM

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2 MR. BACH: Let him ask a 02:51:54PM
3 question. 02:51:56PM
4 Q. Do you see that that's an 02:51:56PM
5 e-mail circulated to the staff from 02:51:58PM
6 Ms. Vega, November 21, 2017? 02:51:59PM
7 A. Yes. 02:52:04PM
8 Q. Essentially your draft with a 02:52:05PM
9 few typos corrected; you don't have to 02:52:06PM
10 hunt for the typos, I'm just saying, do 02:52:12PM
11 you see it is essentially your draft? 02:52:15PM
12 A. Yes. 02:52:16PM
13 Q. I will take that back, Mr. 02:52:21PM
14 Rose. 02:52:22PM
15 Mr. Rose, subsequent to that 02:52:32PM
16 staff meeting on November 20th, did you 02:52:35PM
17 ever return to the Bloomberg studio at 731 02:52:38PM
18 Lexington or did you not go back? 02:52:41PM
19 A. I don't think I went back, but 02:52:46PM
20 -- I don't remember going back. 02:52:51PM
21 If I went back one time, I've 02:52:56PM
22 just forgotten about it. 02:52:58PM
23 Q. Did you have an employee named 02:52:59PM
24 Sarah Gordon? 02:53:01PM
25 MR. BACH: Time frame? 02:53:04PM

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2 Q. There was a period of time that 02:53:06PM
3 you had an employee named Sarah Gordon in 02:53:08PM
4 the early 2000s? 02:53:10PM
5 MR. BACH: Early 2000s? 02:53:11PM
6 MR. GOLDBERG: Yes. 02:53:12PM
7 MR. BACH: You can answer yes 02:53:13PM
8 or no. 02:53:14PM
9 A. A, I don't remember, but there 02:53:21PM
10 may have been an employee named Sarah 02:53:24PM
11 Gordon or an intern named Sarah Gordon. 02:53:26PM
12 Q. An intern named Sarah Gordon? 02:53:29PM
13 A. Yes. 02:53:31PM
14 Q. Did you read the article that 02:53:31PM
15 came out on November 22, 2017, "Ex intern 02:53:33PM
16 says Rose made her watch S&M movie scene"? 02:53:35PM
17 A. I've seen that, yes. 02:53:39PM
18 Q. Did you discuss that with 02:53:40PM
19 anyone? 02:53:41PM
20 A. No one in particular. 02:53:44PM
21 Q. Did you have her come to your 02:53:55PM
22 apartment to watch the movie that she 02:53:56PM
23 described in her article? 02:53:58PM

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2 MR. GOLDBERG: Will you let him 02:54:04PM
3 answer any questions about his conduct 02:54:06PM
4 towards Sarah Gordon, regarding Mr. Rose's 02:54:09PM
5 conduct towards Sarah Gordon? 02:54:14PM
6 MR. BACH: No. 02:54:16PM
7 MR. GOLDBERG: No? 02:54:17PM
8 MR. BACH: No. 02:54:17PM
9 MR. GOLDBERG: Mark that for a 02:54:18PM
10 ruling. 02:54:19PM
11 Q. Is Sarah Gordon a woman with 02:54:32PM
12 whom you had a romantic relationship or 02:54:33PM
13 intimate relationship? 02:54:36PM

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2 Mr. Rose.) 11:07:42AM
3 MR. GOLDBERG: We will mark 02:54:45PM
4 that for a ruling. 02:54:45PM
5 Q. Mr. Rose, have you or anyone on 02:55:08PM
6 your behalf had any contact with Sarah 02:55:10PM
7 Gordon since the article regarding her of 02:55:12PM
8 November 22, 2017? 02:55:21PM
9 MR. BACH: You can answer. 02:55:23PM
10 A. I haven't. 02:55:24PM
11 Q. Has anybody on your behalf? 02:55:25PM
12 A. No. 02:55:26PM
13 Q. Do you have her contact 02:55:27PM
14 information? 02:55:29PM
15 MR. BACH: We consider, as 02:55:31PM
16 should be clear from my objections, this 02:55:34PM
17 to be off limits, it is not material or 02:55:36PM
18 necessary, same standard objection, 02:55:39PM

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6 Mr. Rose.) 11:07:42AM
7 Q. Mr. Rose, after CBS terminated 02:55:49PM
8 your employment, you have explained this 02:55:52PM
9 morning that CBS terminated your 02:55:55PM
10 employment, PBS canceled the show and 02:55:56PM
11 Bloomberg canceled the rebroadcasting, 02:55:59PM
12 after these events, did you continue to 02:56:02PM
13 have contact with Ms. Harris, Ms. McNeal 02:56:03PM
14 or Ms. Wei? 02:56:06PM
15 A. I think there was -- yes. 02:56:10PM
16 Q. Were you aware that Ms. McNeal 02:56:18PM
17 made a complaint about you to Bloomberg, 02:56:22PM
18 to the Bloomberg company? 02:56:24PM
19 A. No. 02:56:26PM
20 Q. Did anyone from Bloomberg ever 02:56:31PM
21 discuss a complaint by Ms. McNeal about 02:56:33PM
22 you? 02:56:36PM
23 A. Not that I remember. 02:56:44PM
24 MR. GOLDBERG: We will mark as 02:56:56PM
25 Exhibit 12 Bates No. CRI 00471869. 02:56:56PM

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2 A. No, I am not sure what they 03:04:17PM
3 did, whether they worked for technical or 03:04:21PM
4 whether they worked for me. 03:04:23PM
5 Q. When you say technical, you 03:04:24PM
6 mean Bloomberg? 03:04:26PM
7 A. Yeah. 03:04:27PM
8 Q. Just to follow up on where I 03:04:30PM
9 was about to go, you called Sydney McNeal, 03:04:34PM
10 just like you called Brooks Harris, after 03:04:36PM
11 CBS terminated your employment, right, 03:04:39PM
12 sir? 03:04:40PM
13 A. Correct. 03:04:41PM
14 Q. You let her know that she was 03:04:45PM
15 being let go, she will be paid to the end 03:04:46PM
16 of the year, yes? 03:04:48PM
17 A. Yes. 03:04:50PM
18 Q. And you told her to stay close? 03:04:51PM
19 A. Yes, my communication to almost 03:04:52PM
20 everybody was essentially the same. 03:05:01PM
21 MR. GOLDBERG: I am going to 03:05:07PM
22 mark Exhibit 14, Bates No. CRI 00489952. 03:05:07PM
23 (Plaintiffs' Exhibit 14, Bates 03:05:13PM
24 No. CRI 00489952, was marked for 03:05:13PM
25 identification, as of this date.) 03:05:17PM

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2 Q. Is this an e-mail you sent to 03:05:17PM
3 Ryan Kadro, December 1, 2017? 03:05:19PM
4 A. Yes. 03:05:27PM
5 Q. The e-mail says, "I wanted to 03:05:31PM
6 apologize to you and everyone hurt by 03:05:33PM
7 behavior by me." 03:05:35PM
8 What behavior were you talking 03:05:37PM
9 about in your e-mail to Mr. Kadro? 03:05:39PM
10 A. I don't remember specifically, 03:05:44PM
11 but probably whatever I had done that 03:05:45PM
12 might have precipitated -- that might 03:05:51PM
13 have been unfair, whatever it might have 03:05:56PM
14 been. 03:06:05PM
15 I don't remember, I clearly 03:06:05PM
16 sent this and I don't remember in the 03:06:10PM
17 moment what I was saying; a general 03:06:12PM
18 apology. 03:06:17PM
19 Q. Was it your understanding that 03:06:19PM
20 CBS terminated you because of the 03:06:20PM
21 substance of the Washington Post article 03:06:22PM
22 of November 20, 2017? 03:06:25PM
25 A. I don't know. 03:06:31PM

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2 received -- 03:10:49PM
3 A. I have one. 03:10:50PM
4 Q. I apologize; there is an 03:10:52PM
5 e-mail, there is two exhibits. 03:10:54PM
6 (Witness perusing documents.) 03:10:58PM
7 A. The question is? 03:11:23PM
8 Q. Are these e-mails you received 03:11:24PM
9 from the Washington Post on the dates 03:11:25PM
10 indicated in the e-mails? 03:11:27PM
11 A. Yes. 03:11:34PM
12 Q. The first e-mail has the name 03:11:35PM
13 Steven Lipin; is that the communications 03:11:38PM
14 person that you mentioned earlier today? 03:11:41PM
15 A. Yes. 03:11:42PM
16 Q. And it says Gladstone Place, I 03:11:44PM
17 don't know what that means, is that the 03:11:47PM
18 name of his business? 03:11:48PM
19 A. I think so or was. 03:11:49PM
20 Q. So Amy Brittain sent the e-mail 03:11:52PM
21 to you and cc'd Steven Lipin, that's 03:11:54PM
22 Richard Beatie next and Irin Carmon. 03:11:57PM
23 Did you respond to either of 03:12:02PM
24 these e-mails? 03:12:04PM
25 A. Yes. 03:12:07PM

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2 Q. Did you respond in writing? 03:12:10PM
3 A. No, I responded I think in an 03:12:12PM
4 e-mail. 03:12:15PM
5 Q. You sent an e-mail back? 03:12:17PM
6 A. Yes. 03:12:23PM
7 Q. I haven't seen that e-mail in 03:12:25PM
8 your document production. 03:12:28PM
9 Are you able to tell me when 03:12:29PM
10 you sent an e-mail? 03:12:30PM
11 A. She referred to the e-mail; 03:12:36PM
12 whether it was an e-mail or phone call, 03:12:37PM
13 but I think it was an e-mail, basically 03:12:39PM
14 when I said it was inaccurate and unfair, 03:12:41PM
15 she incorporated that in the story that 03:12:45PM
16 appeared, that's all it was. 03:12:50PM
17 Q. I see. 03:12:51PM
18 Did you read the second article 03:13:06PM
19 from the Washington Post dated May 3, 03:13:07PM
20 2018? 03:13:09PM
21 A. I did. 03:13:11PM
22 Q. It was titled "Charlie Rose's 03:13:12PM
23 Misconduct Was Widespread at CBS and Three 03:13:13PM
24 Managers Were Warned of Investigation and 03:13:15PM
25 Fines." 03:13:19PM

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2 Did you discuss that article 03:13:20PM
3 with anyone? 03:13:21PM
4 A. Mr. Beatie for sure. 03:13:27PM
5 Q. Did you discuss it with 03:13:32PM
6 Mr. Beatie and anybody else present? 03:13:33PM
7 A. You know, I don't remember, but 03:13:37PM
8 -- I don't remember anyone else. 03:13:43PM
9 Q. Was he acting as your friend at 03:13:45PM
10 that point? 03:13:47PM
11 A. Yes. 03:13:48PM
12 MR. BACH: I object to the form 03:13:50PM
14 Q. What did you say to Mr. Beatie 03:13:52PM
15 and what did he say to you? 03:13:54PM
16 MR. BACH: I am going to assert 03:13:58PM
17 the attorney-client privilege and instruct 03:14:00PM
18 the witness not to answer. 03:14:03PM
19 Q. Had you retained Mr. Beatie as 03:14:05PM
20 your attorney at this time, May 3, 2018? 03:14:07PM
21 A. Mr. Beatie had sort of been my 03:14:14PM
22 attorney constantly. 03:14:17PM
23 Q. Are you changing your testimony 03:14:22PM
24 from earlier today, when you say 03:14:23PM
25 constantly? 03:14:25PM

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2 MR. BACH: No, he is not 03:14:26PM
3 changing his testimony. 03:14:27PM
4 MR. GOLDBERG: I think he is. 03:14:27PM
5 MR. BACH: Well, that's your 03:14:28PM
6 argument to make. 03:14:29PM
7 Q. Did Mr. Beatie bill you for 03:14:30PM
8 your time spent discussing the May 3rd -- 03:14:31PM
9 A. Have I -- I'm saying that 03:14:34PM
10 Mr. Beatie was my friend and an attorney 03:14:37PM
11 who I had consulted over the years, that's 03:14:40PM
12 what I'm saying. 03:14:42PM
13 Q. When you read the May 3rd 03:14:45PM
14 article, were you anticipating litigation? 03:14:49PM
15 A. No. 03:14:52PM
16 Q. What was the purpose of your 03:14:59PM
17 speaking with Mr. Beatie about the 03:15:00PM
19 A. Mr. Beatie has a reputation as 03:15:03PM
20 a good and wise man. 03:15:08PM
21 MR. BACH: Let's take a break. 03:15:13PM
22 MR. GOLDBERG: Sure. 03:15:15PM
23 (Recess taken.) 03:17:35PM
24 BY MR. GOLDBERG: 03:30:02PM
25 Q. Mr. Rose, did you or anyone on 03:30:07PM

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2 So, earlier you identified Reah 03:38:36PM
3 Bravo as a former employee of yours, 03:38:41PM
4 right, sir? 03:38:43PM
5 MR. BACH: Record speak for 03:38:45PM
6 itself. 03:38:47PM
7 Q. You remember Reah Bravo was a 03:38:48PM
8 former employee of yours? 03:38:50PM
9 MR. BACH: Answer yes or no. 03:38:51PM
10 A. Yes. 03:38:52PM
11 Q. Kyle Godfrey-Ryan, she is a 03:38:53PM
12 former employee of yours? 03:38:55PM
13 MR. BACH: Answer yes or no. 03:38:56PM
14 A. Yes. 03:38:57PM
15 Q. She was an assistant, right? 03:38:57PM
16 MR. BACH: I am not -- 03:39:00PM
17 standard objection and instruct the 03:39:11PM
18 witness not to answer, and that's going to 03:39:13PM
19 be true of the witnesses in the November 03:39:15PM
20 20, Washington Post or the people who were 03:39:19PM
21 quoted -- 03:39:21PM
22 MR. GOLDBERG: I am just going 03:39:23PM
23 to go through the names to see if they 03:39:24PM
24 were former employees. 03:39:25PM

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11 Mr. Rose.) 11:07:42AM
12 Q. Karrina Collins, former 03:39:27PM
13 employee of yours? 03:39:28PM
14 A. I think so, I don't remember 03:39:33PM
15 whether she was an intern or employee. 03:39:34PM
16 Q. I'm using the word employee and 03:39:37PM
17 intern interchangeably for these 03:39:39PM
18 questions. 03:39:41PM
19 Megan Creydt, former employee? 03:39:41PM
20 A. Yes. 03:39:44PM
21 Q. Chelsea Royal, former employee? 03:39:44PM
22 A. Yes. 03:39:46PM
23 Q. Erin Carter was a CBS employee, 03:39:46PM
24 right? 03:39:50PM
25 A. Yes. 03:39:51PM

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2 Q. Celine Moussadezeh, former 03:39:51PM
4 A. Yes. 03:39:54PM
5 Q. Courtney Litz, former employee 03:39:55PM
6 of yours? 03:39:57PM
7 A. Yes. 03:39:59PM
8 Q. Charlotte Morgan, former 03:40:00PM
10 A. Yes. 03:40:03PM
11 Q. Rosie Guerin, former employee? 03:40:04PM
12 A. Yes. 03:40:07PM
13 Q. Tamara Sepper? 03:40:07PM
14 A. Yes. 03:40:10PM
15 Q. Juanita Dillard? 03:40:11PM
16 A. No. 03:40:15PM
17 Q. Jayme Hall? 03:40:19PM
18 A. I don't know whether she was an 03:40:25PM
19 employee of mine. 03:40:28PM
20 Q. You identified earlier Gina 03:40:31PM
21 Riggi, you said she was a contractor? 03:40:33PM
22 A. Yeah, and if I can, for the 03:40:35PM
23 record, Ms. Dillard I think is a makeup 03:40:38PM
24 person at Bloomberg in Washington. 03:40:40PM
25 Q. Ms. Riggi, she was a makeup 03:40:43PM

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2 person for you? 03:40:45PM
3 A. She was an independent 03:40:46PM
4 contractor. 03:40:47PM
5 Q. For about 20 years? 03:40:48PM
6 A. Yes. 03:40:50PM
7 Q. How about did you know Patrece 03:40:54PM
8 Williams? 03:40:56PM
9 A. Yes, she was -- 03:40:58PM
10 Q. Was she a former employee of 03:41:01PM
11 yours? 03:41:02PM
12 A. No, I think Patrece is the 03:41:02PM
13 makeup person at CBS This Morning. 03:41:07PM
14 Q. Sophie Gaytor, former employee? 03:41:10PM
15 A. No. 03:41:12PM
16 Q. She was CBS? 03:41:13PM
17 A. Yes, I think, I don't know who 03:41:14PM
18 she worked for. 03:41:16PM
19 I think CBS News for sure. 03:41:19PM
20 Q. Chitra Wadwhani was a former 03:41:21PM
22 A. And also at CBS News. 03:41:27PM
23 Q. She was on the staff list. 03:41:29PM
24 A. But she works at -- 03:41:31PM
25 Q. Did you know a Maria Cascione? 03:41:33PM

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2 A. I think she was one of the ones 03:41:37PM
3 you went over. 03:41:38PM
4 Q. Yes, former employee? 03:41:39PM
5 A. Yes, but, again, I am not sure 03:41:42PM
6 whether it was technical side or not. 03:41:44PM
7 Q. Kelly Burkhard, she was a 03:41:47PM
8 personal assistant of yours? 03:41:50PM
10 Q. Ashley Sullivan? 03:41:58PM
11 A. Yes. 03:42:00PM
12 Q. Another former employee, Megan 03:42:01PM
13 Merritt? 03:42:04PM
14 A. Yes. 03:42:04PM
15 Q. How about Bonnie Hung, former 03:42:07PM
17 A. Worked on a project. 03:42:13PM
18 Q. How about somebody named Helen 03:42:20PM
19 Habtenarian, did you know a person by that 03:42:22PM
20 name? 03:42:25PM
21 A. Yes. 03:42:26PM
22 Q. Was she a former employee of 03:42:26PM
23 yours? 03:42:28PM
24 A. Yes. 03:42:28PM
25 Q. Sarah Gordon, was she a former 03:42:35PM

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3 A. She may have been an intern. 03:42:41PM
4 Q. I think that's right, I think 03:42:43PM
5 she was an intern. 03:42:45PM
6 How about Nikki Amirsaleh? 03:42:47PM
7 A. I have to see the name, from 03:42:53PM
8 the pronunciation, I can't. 03:42:55PM
9 Q. How about Mickey Williams? 03:42:57PM
11 Q. Xarissa Holdaway? 03:43:00PM
12 A. Yes. 03:43:02PM
13 Q. Former employee, right? 03:43:04PM
14 A. Yes. 03:43:05PM
15 Q. Victoria Brown, former 03:43:06PM
16 employee? 03:43:09PM
17 A. Yes. 03:43:10PM
18 Q. Jaclyn Dellagati, former 03:43:10PM
20 A. Yes. 03:43:13PM
21 Q. Emma McCormick Goodheart? 03:43:14PM
22 A. Yes. 03:43:16PM
23 Q. Former employee? 03:43:17PM
24 A. Yes. 03:43:18PM
25 Q. How about Bobby Owens, she was 03:43:18PM

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2 a sound person? 03:43:22PM
3 A. That's technical. 03:43:23PM
4 Q. Technical would not be your 03:43:25PM
6 A. Unless it was employed as a 03:43:28PM
7 camera person on a remote. 03:43:33PM
8 MR. GOLDBERG: Mr. Bach, I am 03:43:41PM
9 going to read a list of questions and ask 03:43:42PM
10 you whether you will let your client 03:43:49PM
11 answer them, I think you're going to say 03:43:51PM
12 no, so I want to make sure I get that list 03:43:55PM
13 on the record and be efficient with our 03:44:01PM
14 time. 03:44:06PM
15 So for the women I just 03:44:08PM
16 mentioned, I want to ask Mr. Rose 03:44:09PM
17 questions about his conduct towards those 03:44:11PM
18 women; are you going to allow him to 03:44:12PM
19 answer those questions? 03:44:15PM
20 MR. BACH: Are they 03:44:18PM
21 contemporaries of your clients? 03:44:20PM
22 MR. GOLDBERG: Excuse me? 03:44:22PM
23 MR. BACH: Are they 03:44:23PM
24 contemporaries of your clients? 03:44:23PM
25 MR. GOLDBERG: I don't have all 03:44:25PM

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2 the dates of their employment. 03:44:25PM
3 MR. BACH: It is hard for me to 03:44:27PM
4 answer in general terms -- 03:44:34PM
5 MR. GOLDBERG: Then I will go 03:44:35PM
6 through each one of these people; here we 03:44:36PM
7 go. 03:44:38PM
8 Off the record for a minute. 03:44:50PM
9 (Pause.) 03:45:06PM
10 MR. GOLDBERG: Mr. Bach, what I 03:46:14PM
11 am going to do first is go through people 03:46:15PM
12 that were employed at the time of the 03:46:17PM
13 plaintiffs and ask my questions. 03:46:22PM
14 Then I can tell you the people 03:46:23PM
15 that I don't think overlapped with the 03:46:25PM
16 plaintiffs, I will go that way. 03:46:26PM
17 Q. Mr. Rose, let's talk about each 03:46:33PM
18 of these women. 03:46:36PM
19 Erin Carter worked for CBS at 03:46:37PM
20 CTM while you were at CTM, correct, sir? 03:46:41PM
21 A. Repeat the question. 03:46:48PM
22 Q. You know who Erin Carter is? 03:46:49PM
23 A. Yes. 03:46:51PM
24 Q. She was working at CTM while 03:46:53PM
25 you were working at CTM, right? 03:46:55PM

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2 A. You know, Erin Carter came to 03:47:00PM
3 work directly with me, but not at the 03:47:04PM
4 beginning. 03:47:06PM
5 Q. But you were working at the CBS 03:47:07PM
6 This Morning studio in 2017 and Erin 03:47:09PM
7 Carter was there too? 03:47:12PM
8 A. Yes. 03:47:13PM
9 Q. Did you find her to be 03:47:14PM
10 attractive? 03:47:15PM
11 MR. BACH: I am going to object 03:47:16PM
12 to that question, you're not going to go 03:47:17PM
13 through this list of employees and ask him 03:47:20PM
14 if he finds them attractive. 03:47:22PM
15 MR. GOLDBERG: I am going to go 03:47:23PM
16 through my questions and move to compel 03:47:25PM
17 every single one that you're obstructing 03:47:26PM
18 this deposition on and move for fees and 03:47:28PM
19 costs, it is coming, that motion is on its 03:47:29PM
20 way. 03:47:32PM
21 Q. Did you find her to be 03:47:32PM
22 attractive? 03:47:33PM
23 MR. BACH: Object to that 03:47:34PM
24 question, instruct the witness not to 03:47:35PM
25 answer. 03:47:36PM

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2 Q. Did you ever hug and kiss Erin 03:47:38PM
3 Carter? 03:47:42PM
4 MR. BACH: Answer that 03:47:42PM
6 A. I'm sure I have in greeting and 03:47:46PM
7 saying goodbye. 03:47:50PM
8 Q. Did you put your hands on her? 03:47:50PM
9 A. I'm sure I've touched her arm. 03:47:52PM
10 Q. Touch her shoulder? 03:47:54PM
11 A. I assume so. 03:47:56PM
12 Q. Touch her back? 03:47:57PM
13 A. Maybe. 03:47:59PM
14 Q. Pull her close to you? 03:48:01PM
15 A. No. 03:48:02PM
16 Q. Make any comments on her 03:48:03PM
17 appearance? 03:48:05PM
18 A. I may have, but I don't 03:48:08PM
19 remember any. 03:48:11PM
20 Q. Celine Moussadezeh, she was an 03:48:20PM
21 employee of yours, right? 03:48:23PM
22 A. Yes. 03:48:24PM
23 Q. What was her position? 03:48:27PM
24 A. I don't remember title, it 03:48:30PM
25 might have been associate producer, but 03:48:32PM

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2 Q. Ever touch any of her private 03:49:22PM
3 parts? 03:49:24PM
4 MR. BACH: Is there an 03:49:25PM
5 allegation in this case that he ever 03:49:26PM
6 touched any of your clients' private 03:49:27PM
7 parts? 03:49:29PM
8 MR. GOLDBERG: There is an 03:49:30PM
9 allegation that he wrapped his arms around 03:49:30PM
10 women touching their breasts. 03:49:32PM
11 MR. BACH: In this case? 03:49:34PM
12 MR. GOLDBERG: And touching the 03:49:34PM
13 buttocks of Ms. Harris. 03:49:35PM
14 Q. Did you ever touch their 03:49:37PM
15 private parts, Mr. Rose? 03:49:38PM
16 A. No. 03:49:40PM
17 Q. Touch the private parts of Erin 03:49:40PM
18 Carter? 03:49:42PM
19 A. No. 03:49:42PM
20 Q. If any of the women from the 03:49:46PM
21 Washington Post articles come to trial and 03:49:47PM
22 say you touched them, are they lying? 03:49:49PM
24 to that question and assert my standard 03:49:53PM

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2 Please watch your tone. 03:49:57PM
13 Mr. Rose.) 11:07:42AM
14 Q. How about Courtney Litz, she 03:50:00PM
15 was an intern and then a producer with 03:50:02PM
16 you? 03:50:06PM
17 A. She was a producer, yes. 03:50:06PM
18 Q. Did you hug and kiss her? 03:50:08PM
19 A. I'm sure I hugged her. 03:50:12PM
20 Q. Did you put your hands on her? 03:50:17PM
21 A. As a conversation gesture and 03:50:19PM
22 perhaps for emphasis. 03:50:23PM
23 Q. Did you touch her shoulder, 03:50:24PM
24 arm, back? 03:50:25PM
25 A. I may have, but, again... 03:50:28PM

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2 A. Arm. 03:58:58PM
3 Q. Did you ever hug and kiss her? 03:59:00PM
4 A. I don't remember, but maybe. 03:59:03PM
5 Q. Did you ever hug and kiss Gina 03:59:05PM
6 Riggi? 03:59:08PM
7 A. I don't remember, but I may 03:59:08PM
8 have hugged her. 03:59:10PM
9 Q. I believe the following 03:59:22PM
10 individuals were -- I don't think the 03:59:23PM
11 following individuals overlapped with the 03:59:29PM
12 plaintiffs. 03:59:31PM
13 Reah Bravo, Kyle Godfrey-Ryan, 03:59:32PM
14 Corrina Collins, Megan Creydt, Juanita 03:59:35PM
15 Dillard, Jayme Hall, Sophie Gaytor, Kelly 03:59:42PM
16 Burkhard, Ashley Sullivan, Megan Merritt, 03:59:48PM
17 Helen Habtenarian, Bonnie Hung, Sarah 03:59:53PM
18 Gordon, Bobby Owens, Victoria Brown, 03:59:56PM
19 Jaclyn Delligatti, Emma 04:00:01PM
20 McCormick-Goodhart. 04:00:07PM
21 MR. GOLDBERG: Mr. Bach, if I 04:00:07PM
22 want to ask these questions as to these 04:00:08PM
23 individuals, will you let Mr. Rose answer 04:00:09PM
24 questions as to his conduct towards them. 04:00:11PM
25 MR. BACH: I will instruct him 04:00:13PM

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3 MR. GOLDBERG: I will consider 04:00:17PM
4 that to be your position on those 04:00:18PM
5 questions as to those individuals. 04:00:21PM
6 Q. Mr. Rose, Chelsea Royal, she 04:00:25PM
7 was your personal assistant in 2012 to 04:00:28PM
8 2015? 04:00:32PM
9 A. Yes. 04:00:32PM
10 Q. So she separated before the 04:00:33PM
11 plaintiffs reported to you? 04:00:35PM
12 A. Yes. 04:00:37PM
13 MR. GOLDBERG: Mr. Bach, I want 04:00:38PM
14 to ask questions about Chelsea Royal, will 04:00:39PM
15 you allow your client to answer those 04:00:41PM
16 questions? 04:00:43PM
17 MR. BACH: No, I will instruct 04:00:43PM
18 him not to answer. 04:00:44PM
19 Q. Mr. Rose, did you ever refer to 04:01:09PM
20 Ms. Vega as the Mexican Marilyn Monroe? 04:01:10PM
21 MR. BACH: I'm going to object 04:01:15PM
22 to that question and instruct him not to 04:01:16PM
23 answer, nothing to do with the allegations 04:01:18PM
24 in this case. 04:01:20PM
25 MR. GOLDBERG: We consider that 04:01:23PM

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2 question to be within the scope of 04:01:24PM
3 discovery, so we would like an answer. 04:01:25PM
4 MR. BACH: You can go to the 04:01:29PM
5 judge and tell her that you need to know 04:01:30PM
6 whether Yvette Vega was called the Mexican 04:01:31PM
7 Marilyn Monroe. 04:01:35PM
8 MR. GOLDBERG: We're entitled 04:01:36PM
9 to sexual comments that Mr. Rose made to 04:01:37PM
10 females working for him, we consider that 04:01:41PM
11 to be within the realm of discovery. 04:01:42PM
12 You're saying that comment, you 04:01:48PM
13 will not let him answer the question, is 04:01:50PM
14 that correct? 04:01:56PM
15 MR. BACH: That is correct. 04:01:56PM
16 Are you saying that comment was 04:02:07PM
17 made in the presence of your clients? 04:02:09PM
18 MR. GOLDBERG: I don't know who 04:02:11PM
19 was in the room when he said that, but it 04:02:12PM
20 is out there and we want to ask, this is 04:02:16PM
21 his deposition. 04:02:18PM
22 Q. Mr. Rose, did you know a Joana 04:02:31PM
23 Matthias? 04:02:35PM
25 to that question and instruct the witness 04:02:36PM

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3 MR. GOLDBERG: Not even let him 04:02:37PM
4 answer if he knew the person? 04:02:39PM
5 MR. BACH: Not from 40 years 04:02:40PM
6 ago, no. 04:02:41PM
7 Q. Did you know a Molly Peter? 04:02:42PM
8 MR. BACH: Object to that 04:02:44PM
9 question and instruct the witness not to 04:02:45PM
10 answer. 04:02:46PM
11 MR. GOLDBERG: We have 04:02:54PM
12 questions, let's make clear on the record, 04:02:55PM
13 we have questions to ask about Joana 04:02:57PM
14 Matthias and Molly Peter, but given Mr. 04:03:01PM
15 Bach's objection, it is our understanding 04:03:03PM
16 that he will not allow Mr. Rose to answer 04:03:04PM
17 those questions -- 04:03:07PM
18 MR. BACH: My understanding is 04:03:07PM
19 that those names are associated with what 04:03:08PM
20 you allege is conduct in the 1970s, am I 04:03:13PM
21 correct? 04:03:16PM
22 MR. GOLDBERG: Conduct that's 04:03:17PM
23 in the record. 04:03:18PM
24 Q. Mr. Rose, did you know a Beth 04:03:20PM
25 Homan-Ross? 04:03:23PM

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2 MR. BACH: Same objection and 04:03:23PM
4 Q. Did you know an Annmarie Parr? 04:03:54PM
5 MR. BACH: Same objection, 04:03:58PM
7 MR. GOLDBERG: Off the record 04:04:10PM
8 for a couple of minutes. 04:04:10PM
9 Let's make a note of what time 04:04:13PM
10 it is that we're going off the record. 04:04:14PM
12 (The following testimony on
13 pages 285 through 287 was bound under
14 separate cover designated attorneys' eyes
15 only.)
16
17
18
19
20
21
22
23
24
25

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2 Q. Did you tell any male employees 04:22:21PM
3 at Charlie Rose that you had fantasies of 04:22:24PM
4 them swimming naked in your swimming pool? 04:22:26PM
5 A. I haven't said that about any 04:22:28PM
6 employee, period. 04:22:29PM
7 Q. Did you tell any male employees 04:22:31PM
8 that you didn't want neighbors of yours in 04:22:33PM
9 Bellport, any male employees, that you 04:22:34PM
10 didn't want neighbors of yours in Bellport 04:22:37PM
11 to talk about them swimming naked in your 04:22:39PM
12 pool? 04:22:41PM
13 A. No. 04:22:41PM
14 Q. Did you touch the arm of any 04:22:54PM
15 male employee at Charlie Rose and tell 04:22:55PM
16 them that you love the way they hand you 04:22:57PM
17 paper? 04:22:59PM
20 A. No. 04:23:03PM
21 MR. GOLDBERG: Mr. Bach, we 04:23:09PM
22 seek to have Mr. Rose answer questions 04:23:10PM
23 about his conduct, verbal and physical, 04:23:13PM
24 towards various female employees that 04:23:20PM
25 worked with him and for him. 04:23:22PM

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2 As you know from this 04:23:24PM
3 deposition, that includes questions about 04:23:26PM
4 alleged inappropriate conduct, alleged 04:23:28PM
5 sexual harassment, alleged discrimination 04:23:30PM
6 and the like. 04:23:33PM
7 During this deposition you've 04:23:34PM
8 asserted an objection to those questions 04:23:36PM
9 and instructed your client not to answer 04:23:40PM
10 those questions as to many of the female 04:23:42PM
11 employees that we would like to ask Mr. 04:23:46PM
12 Rose about. 04:23:49PM
13 A couple of these female 04:23:51PM
14 employees, just by way of example, include 04:23:53PM
15 Sophie Gaytor, Reah Bravo, Kyle 04:23:55PM
16 Godfrey-Ryan, and others. 04:23:58PM
17 At this point in the 04:24:04PM
18 deposition, are you standing by that 04:24:05PM
19 objection? 04:24:08PM
20 MR. BACH: Yes. 04:24:09PM
21 MR. GOLDBERG: We have advised 04:24:10PM
22 you that we intend to move to compel 04:24:11PM
23 responses to that line of questions as to 04:24:15PM
24 many female employees that Mr. Rose had 04:24:21PM
25 interactions with, including without 04:24:23PM

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2 limitation the ones that we have 04:24:25PM
3 identified in this deposition, and we have 04:24:29PM
4 a lot of questions to ask him and we 04:24:31PM
5 planned to ask those questions today. 04:24:34PM
6 Since we have previously agreed 04:24:36PM
7 to a seven-hour on-the-record time limit, 04:24:41PM
8 and we still have time remaining on those 04:24:49PM
9 seven hours, if you're maintaining your 04:24:51PM
10 objection, we will ask Mr. Rose a few more 04:24:56PM
11 questions about other issues and then it 04:24:59PM
12 is our intention to adjourn this 04:25:02PM
13 deposition and reserve the remaining time 04:25:04PM
14 and any time the court might give us, any 04:25:10PM
15 extra time, for continuation of this 04:25:12PM
16 deposition once the court addresses the 04:25:14PM
17 various disputes that we have with your 04:25:18PM
18 office regarding scope of the deposition. 04:25:23PM
19 And of course at the 04:25:26PM
20 continuation of this deposition, if there 04:25:29PM
21 are any documents that have recently been 04:25:31PM
22 produced or new documents that get 04:25:35PM
23 produced, of course we would reserve the 04:25:37PM
24 right to address those. 04:25:39PM
25 So I just wanted to make our 04:25:40PM

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1 ROSE
2 position clear to you, because I think we 04:25:42PM
3 still have time left on the seven hours 04:25:44PM
4 and we can't proceed with questions that 04:25:49PM
5 are going to get, as we said, the standard 04:25:51PM
7 BY MR. GOLDBERG: 04:25:57PM
8 Q. Mr. Rose, I have a few more 04:25:57PM
9 questions for you unrelated to the items 04:25:58PM
10 that have been responded to by the 04:26:00PM
11 standard objection that your attorney has 04:26:06PM
12 repeated a number of times. 04:26:11PM
13 You said earlier today that you 04:26:12PM
14 hugged, I think you said you hugged and 04:26:15PM
15 kissed male employees. 04:26:17PM
16 We have been here at this 04:26:19PM
17 deposition for hours; are there any male 04:26:20PM
18 employees that you are able to now 04:26:22PM
19 identify at Charlie Rose that you're going 04:26:24PM
20 to say I hugged and kissed on the cheek 04:26:26PM
21 these male employees? 04:26:28PM
22 MR. BACH: I am going to 04:26:29PM
23 object, asked and answered. 04:26:30PM
24 Q. Can you name any of those male 04:26:33PM
25 employees? 04:26:35PM

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1 ROSE
2 A. That I have -- the question is 04:26:40PM
3 male employees that I've hugged? 04:26:42PM
4 Q. Male employees that you hugged 04:26:43PM
5 and kissed on the cheek at Charlie Rose. 04:26:45PM
6 A. No, I would have to go through 04:26:58PM
7 a list of employees and think about it, 04:27:00PM
8 but I've hugged -- 04:27:02PM
9 MR. BACH: That's not the 04:27:10PM
11 Q. Mr. Rose, sitting here today, 04:27:19PM
12 am I correct that at this time you're not 04:27:21PM
13 able to identify by name any such male 04:27:23PM
14 employees? 04:27:26PM
15 A. I can't be for sure without 04:27:29PM
16 thinking about it. 04:27:32PM
17 Q. Are there any male employees 04:27:33PM
18 that you whispered in their ear happy 04:27:35PM
19 birthday? 04:27:38PM
20 A. No. 04:27:42PM
21 MR. GOLDBERG: We're just going 04:27:59PM
22 to step out of the room for one moment and 04:28:00PM
23 we will be right back in. 04:28:02PM
25 MR. GOLDBERG: Mr. Bach, I 04:29:07PM

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1 ROSE
2 don't have any other questions at the 04:29:08PM
3 moment. 04:29:08PM
4 It it is our intention, as I 04:29:11PM
5 said a couple of minutes ago, to note the 04:29:13PM
6 time on the record, the time remaining in 04:29:16PM
7 the seven hours, and reserve our time to 04:29:19PM
8 continue once the court addresses any 04:29:23PM
9 disputes that we have, that have arisen 04:29:26PM
10 today. 04:29:29PM
11 If you choose to question Mr. 04:29:30PM
12 Rose while we're here, that is up to you, 04:29:34PM
13 we might then have questions for him 04:29:37PM
14 arising out of your questions. 04:29:39PM
15 But I leave that to you to 04:29:41PM
16 decide whether you're going to ask him 04:29:43PM
17 questions now or not, that would be up to 04:29:45PM
18 you. 04:29:49PM
19 MR. BACH: I understand that 04:29:49PM
20 you have certain matters that you want to 04:29:50PM
21 pursue with the court. 04:29:53PM
22 You understand that apart from 04:29:54PM
23 those matters, now is your time to depose 04:29:56PM
24 Mr. Rose and as to anything that you 04:29:58PM
25 haven't reserved with the court, that ends 04:30:01PM

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1 ROSE
2 here today, except if I do ask followup 04:30:05PM
3 questions and you want to ask followup on 04:30:07PM
4 that. 04:30:08PM
5 MR. GOLDBERG: Well, our 04:30:12PM
6 position, Jonathan, is that we have 04:30:18PM
7 questions ready to ask Mr. Rose and we 04:30:21PM
8 tried to ask them today obviously, about a 04:30:25PM
9 number of female employees that you have 04:30:27PM
10 instructed him not to answer. 04:30:31PM
11 We have questions and that list 04:30:33PM
12 of those individuals would likely take the 04:30:38PM
13 balance of today's deposition. 04:30:40PM
14 If you were to choose to let us 04:30:43PM
15 do that, I would be concluding the 04:30:44PM
16 deposition right now. 04:30:48PM
17 So those are the issues that 04:30:51PM
18 are in front of us. 04:30:53PM
19 I simply mention that there 04:30:54PM
20 have been a number of document issues that 04:30:57PM
21 have been raised on both sides, we have 04:30:59PM
22 raised a number of document issues, some 04:31:02PM
23 of them are still outstanding, but the 04:31:04PM
24 deposition, if we were to finish it now, 04:31:06PM
25 would be the items that I have been trying 04:31:08PM

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1 ROSE
2 to cover as to other female employees. 04:31:10PM
3 So I understand your position, 04:31:14PM
4 we just don't have other questions to ask 04:31:16PM
5 Mr. Rose right now because the questions 04:31:18PM
6 we want to ask are going to be met with 04:31:20PM
7 objections. 04:31:23PM
8 MR. BACH: Thank you. 04:31:24PM
9 MR. GOLDBERG: So it is up to 04:31:25PM
10 you if you want to question him now or 04:31:26PM
11 not. 04:31:28PM
12 If you do, we might follow up, 04:31:28PM
13 limited to what you cover; otherwise we 04:31:30PM
14 would say to Mr. Rose that you're free to 04:31:32PM
15 leave for today and we will note the time 04:31:34PM
16 that we're adjourning. 04:31:37PM
17 MR. BACH: Why don't we do 04:31:38PM
18 this, if it is okay with you. 04:31:40PM
19 Let's note the time, give us 04:31:41PM
20 five or ten minutes to see if we have any 04:31:43PM
21 followup questions, I don't think we do, I 04:31:45PM
22 am not sure we do; if we do, it is not 04:31:48PM
23 going to be much. 04:31:50PM
24 And we will let you know, come 04:31:51PM
25 back and we will formally adjourn. 04:31:54PM

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1 ROSE
2 MS. ARATO: We have used 301 04:32:14PM
3 minutes and there is 117 minutes left. 04:32:15PM
5 EXAMINATION BY 04:45:47PM
6 MR. BACH: 04:45:48PM
7 Q. You were asked some questions 04:45:48PM
8 earlier today about flirting or office 04:45:50PM
9 banter that you engaged in with Norah 04:45:54PM
10 O'Donnell and Gayle King, do you remember 04:45:57PM
11 that? 04:46:00PM
12 A. Yes. 04:46:00PM
13 Q. From time to time did you 04:46:00PM
14 engage in flirtatious behavior or office 04:46:01PM
15 banter with Ms. King and Ms. O'Donnell? 04:46:06PM
16 A. Yes. 04:46:08PM
17 Q. Did you ever flirt with Chelsea 04:46:08PM
18 Wei in the same way? 04:46:11PM
19 A. No. 04:46:12PM
20 Q. Is flirting the right word to 04:46:13PM
21 describe your interactions with Ms. Wei? 04:46:15PM
22 A. I don't think so. 04:46:17PM
23 MR. BACH: No further 04:46:20PM
24 questions. 04:46:20PM
25 MS. ARATO: We're very close 04:46:54PM

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1 ROSE
2 with you in terms of how much time is 04:46:56PM
3 left, but we're not exactly there. 04:46:58PM
4 We have 112 minutes and you 04:47:00PM
5 guys have 115. 04:47:03PM
6 MS. FLIEGEL: 116. 04:47:06PM
7 MS. ARATO: That was your 04:47:10PM
8 minute. 04:47:10PM
9 MR. BACH: We will take credit 04:47:11PM
10 for it. 04:47:12PM
11 MR. GOLDBERG: I am not 04:47:13PM
12 concerned about the difference between the 04:47:14PM
13 112 and 115, as long as we're that close, 04:47:16PM
14 we're fine. 04:47:20PM
15 (Time noted: 4:48 p.m.) 04:48:37PM
16
17 _____________________
18 CHARLES P. ROSE, JR.
19
20 Subscribed and sworn to before me
21 this day of , 2019.
22
23
24
25

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EXHIBIT 4
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500 Fifth Avenue, 40th Floor New York, NY 10110

Shapiro Arato Bach LLP
phone: 212-257-4880 | fax: 212-202-6417
www.shapiroarato.com
Jonathan P. Bach
jbach@shapiroarato.com
Direct: 212-257-4897
December 6, 2019
Kenneth Goldberg
Goldberg & Fliegel, LLP
New York, NY 10022
Re: Harris v. Rose 154172 (2018)/Specification of Deposition Objections
Dear Mr. Goldberg:
Pursuant to the Court's Order of November 21, 2019, the attached chart identifies the sections of
§ 221.2 that apply to instances in which Mr. Rose followed his counsel's instruction not to
answer questions posed during his November 14 deposition. The information provided below
follows the pagination of the deposition transcript and supplements the objections and related
statements of counsel already set forth therein.
Section 221.2 calls for only a succinct and clear statement of the basis for any objection, and thus
Defendants reserve the right to elaborate upon the bases for their objections in any briefing
before the Court.
In addition to the other grounds noted, Defendants further object to answering the questions
posed because Plaintiffs have refused to execute a standard protective order.
As you will see, based on our review of the transcript, we have noted below certain instances in
which we will allow Mr. Rose to answer questions.
Please let us know if you would like to discuss.
Sincerely
Jc nathan Bach
141 of 226
Specification of Objections
November 14, 2019 Deposition of Charlie Rose
Objection
Reference
Number: Topic
Page Rule Section for Objection
1. 13 Documents reviewed with counsel To preserve a privilege or right of
confidentiality (221.2(a))
The work product doctrine shields

from disclosure counsel's mental
processes, including its selection of

documents for review.
NOTE: We will allow Mr. Rose to

answer the question whether he
reviewed any documents "on his
own"
and not at the direction of
counsel.
2. 22 Communication with attorney To preserve a privilege or right of
3. 61 Tax return To preserve a privilege or right of
Tax returns are generally confidential

and information about Mr. Rose's tax
return is neither material nor
necessary in this gender

discrimination case.
NOTE: We will allow Mr. Rose to

answer the question whether Charlie
Rose Inc. filed a tax return for the
year 2017.
4. 63 Money owed to non-party To preserve a privilege or right of
The question is plainly improper and
would, if answered, cause significant

prejudice to any person (221.2(c))
Information about any funds owed to

a prominent third party is neither
material nor necessary in this gender
discrimination case and could cause
embarrassment.
5. 75-76 Identity of persons with whom had To preserve a privilege or right of

relationship"
"romantic confidentiality (221.2(a))
142 of 226

Discovery as to romantic
relationships involving third parties
and conduct unrelated to this case,
and remote in time, is neither
material nor necessary and seeks
information that is generally private

and confidential and embarrassing if
disclosed.
6. 77 Identity of persons with whom had , To preserve a privilege or right of

relationship"
"romantic confidentiality (221.2(a)).


disclosed.

relationship"
prejudice to any person. (221.2(c))
disclosed.
8. 90 Identity of persons with whom had To preserve a privilege or right of

romantic relationship confidentiality (221.2(a))
143 of 226


disclosed.
9. 107-09 Questions about former employees To preserve a privilege or right of

identified in press confidentiality (221.2(a))

Information about third parties and

conduct unrelated to this case, and
remote in time, is neither material nor
necessary, and generally not

discoverable. Such discovery also
seeks information that is generally
private and confidential and
embarrassing if disclosed.
10. 130 of person with whom had To preserve a privilege or right of
Identity
relationship"
"intimate confidentiality (221.2(a)).

material nor necessary, and seeks
disclosed.
144 of 226
11. 180-81 Race discrimination The question is plainly improper and

prejudice to any person. (221.2(c)).
Discovery as to any race

discrimination is neither material nor
necessary where sole claim concerns

alleged gender discrimination.
In any event, the deponent answered

the question on page 181, so there is
no need to pose it again.
12. 209 Identity of persons with whom had To preserve a privilege or right of
relationship"
Questions about former employees The question is plainly improper and

identified in press would, if answered, cause significant
disclosed. The information sought is
generally not discoverable.
13. 219 Questions about former employees To preserve a privilege or right of

identified in press confidentiality (221.2(a)).




145 of 226
Speci fication of Objections
November 14. 2019 Deposition of Charlie Rose












146 of 226
___




identified in press confidentiality (221.2(a)).



discoverable.
Identity of persons with whom had The question is plainly improper and
"romantic relationship would, if answered, cause significant


discoverable. Similarly,
discovery as to romantic relationships

if disclosed.
embarrassing
235 Questions about contact To preserve a privilege or right of
20.
information for former employees confidentiality (221.2(a))
identified in press ___ _
147 of 226

Information about contacting third

parties unrelated to this case is
neither material nor necessary, and
generally not discoverable, and will

serve only to harass third parties.
21. 250 Communication with attorney To preserve a privilege or right of



discoverable.
23. 267 Question as to whether defendant To preserve a privilege or right of

found certain non-parties to be confidentiality (221.2(a))
"attractive"

Information about Deponent's

perception of non-party is neither
disclosed.


Information about third parties

unrelated to this case, and remote in
148 of 226
November 14. 2019 Deposition of Charlie Rose
time, is neither material nor

discoverable
relationship"
prejudice to any person. (221.2(c)).

disclosed.
identified in press (no specific confidentiality (221.2(a)).
questions posed but stated that
similar questions to others for The question is plainly improper and
which instruction was interposed would, if answered, cause significant
would be asked) prejudice to any person (221.2(c))


(no specific questions posed) confidentiality (221.2(a)).


discoverable.
149 of 226
28. 281-82 Question about contemporaneous We will allow Mr. Rose to answer
employee the question did you ever refer to Ms.
Vega as the Mexican Marilyn
Monroe.

identified in press (no specific confidentiality (221.2(a))
questions posed)



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EXHIBIT 5
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The Washington Post
Investigations
Eight women Charlie Rose harassed them - with

say sexually
nudity, groping and lewd calls
By Irin Carmon and
Amy Brittain
Amy Brittain
Investigative reporter
Email B Bio G Follow W

November 20, 2017
Eight women have told The Washington Post that longtime television host Charlie Rose made
unwanted sexual advances toward them, including lewd phone calls, walking around naked in their
presence, or groping their breasts, buttocks or genital areas.
The women were employees or aspired to work for Rose at the "Charlie Rose"show from the late
1990s to as recently as 2011. They ranged in age from 21 to 37 at the time of the alleged encounters.
Morning"
Rose, 75, whose show airs on PBS and Bloomberg TV, also co-hosts "CBS This and is a
Minutes."
contributing correspondent for "60
There are striking commonalities in the accounts of the women, each of whom described their
interactions with Rose in multiple interviews with The Post. For all of the women, reporters
interviewed friends, colleagues or family members who said the women had confided in them about
aspects of the incidents. Three of the eight spoke on the record.
Five of the women spoke on the condition of anonymity out of fear of Rose's stature in the industry,
his power over their careers or what they described as his volatile temper.
"In my 45 years in journalism, I have prided myself on being an advocate for the careers of the women
worked,"
with whom I have Rose said in a statement provided to The Post. "Nevertheless, in the past
few days, claims have been made about my behavior toward some former female colleagues.
PLAINTIFFS
EXHIBlT
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"It is essential that these women know I hear them and that I deeply apologize for my inappropriate
behavior. I am greatly embarrassed. I have behaved insensitively at times, and I accept responsibility
for that, though I do not believe that all of these allegations are accurate. I always felt that I was
pursuing shared feelings, even though I now realize I was mistaken.
"I have learned a great deal as a result of these events, and I hope others will too. All of us, including
me, are coming to a newer and deeper recognition of the pain caused by conduct in the past, and have
lives."
come to a profound new respect for women and their
Within hours of the publication of this article, PBS and Bloomberg LP immediately suspended
Rose"
distribution of the "Charlie show. CBS announced that it was suspending Rose as it looked into
the matter.
Most of the women said Rose alternated between fury and flattery in his interactions with them. Five
described Rose putting his hand on their legs, sometimes their upper thigh, in what they perceived as
a test to gauge their reactions. Two said that while they were working for Rose at his residences or
were traveling with him on business, he emerged from the shower and walked naked in front of them.
One said he groped her buttocks at a staff party.
Reah Bravo was an intern and then associate producer for Rose's PBS show beginning in 2007. In
interviews, she described unwanted sexual advances while working for Rose at his private waterfront
estate in Bellport, N.Y., and while traveling with him in cars, in a hotel suite and on a private plane.
"It has taken 10 years and a fierce moment of cultural reckoning for me to understand these moments
were," victim."
for what they she told The Post. "He was a sexual predator, and I was his
Kyle Godfrey-Ryan, one of Rose's assistants in the mid-2ooos, recalled at least a dozen instances
where Rose walked nude in front of her while she worked in one of his New York City homes. He also
repeatedly called the then-21-year-old late at night or early in the morning to describe his fantasies of
her swimming naked in the Bellport pool as he watched from his bedroom, she said.
it,"
"It feels branded into me, the details of Godfrey-Ryan said.
She said she told Yvette Vega, Rose's longtime executive producer, about the calls.
times,"
"I explained how he inappropriately spoke to me during those Godfrey-Ryan said. "She would
Charlie.' "
just shrug and just say, 'That's just Charlie being
In a statement to The Post, Vega said she should have done more to protect the young women on the
show.
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them,"
"I should have stood up for said Vega, 52, who has worked with Rose since the show was
them."
created in 1991. "I failed. It is crushing. I deeply regret not helping
Godfrey-Ryan said that when Rose learned she had confided to a mutual friend about his conduct, he
fired her.
Megan Creydt worked as a coordinator on the show from to with Godfrey-

2005 2006, overlapping
Ryan.
mid-thigh,"
"It was quite early in working there that he put his hand on my said Creydt, who agreed to
be interviewed on the record to support other women who were coming forward with what she
deemed to be more serious claims concerning Rose.
She said that during the incident, Rose was driving his Mini Cooper in Manhattan while she was
sitting in the passenger seat.
anything,"
"I don't think I said she said. "I tensed up. I didn't move his hand off, but I pulled my legs
to the other side of the car. I tried not to get in a car with him ever again. I think he was testing me
out."
Her then-boyfriend confirmed to The Post that she told him the story at the time.
In addition to the eight women who say they were harassed, The Post spoke to about two dozen former
employees who spoke on the condition of anonymity. Six said they saw what they considered to be
harassment, eight said they were uncomfortable with Rose's treatment of female employees, and 10
said they did not see or hear anything concerning.
me,"
"He was always professional with said Eleonore Marchand Mueller, a former assistant of Rose's
incidents."
who worked for him from 2003 to 2005. "I never witnessed any unprofessional
The show'ssmall, informal structure, with roughly 15 employees, and the centrality of Rose's authority
on a program he owns led to uncertainty over how to respond, said the women who felt victimized.
uncomfortable,"
"There wasn't anybody to report this to if you felt one of them said.
The employees worked for Charlie Rose Inc., and not Bloomberg LP or PBS, which said they did not
provide human resources support for the show.
The environment brimmed with the young and potentially vulnerable, hungry for scarce television
jobs,"
jobs. "There are so few said one of the women who said Rose groped her. "You know if you don't
you."
behave a certain way, there's someone else behind
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Rose traveled frequently, jetting off to interview world leaders across the globe and splitting time
between two New York residences and homes in Bellport - on Island - and North Carolina.
City Long
Often at his side was a rotating cast of young assistants and producers.
Angels,"
The young women who were hired by the show were sometimes known as "Charlie's two
former employees said. Rose frequently gave unsolicited shoulder rubs to several of them, behavior
paw,"
referred to among employees as "the crusty a former employee said.
Rumors about Rose's behavior have circulated for years. One of the authors of this report, Outlook
contributing writer Irin Carmon, first heard and attempted to report on the allegations involving two
of the women while she was a journalist at Jezebel in 2010 but was unable to confirm them. In the past
several weeks in the wake of accusations against Harvey Weinstein, Carmon and Post investigative
reporter Amy Brittain jointly began contacting dozens of men and women who had worked on the
Rose"
"Charlie show or interviewed for jobs there.
A woman then in her 30s who was at the Bellport home in 2010 to diseüss a job opportunity said Rose
appeared before her in an untethered bathrobe, naked underneath. She said he subsequently
attempted to put his hands down her pants. She said she pushed his hands away and wept throughout
the encounter.
"ritual"
A woman who began as an intern in the late 1990s and was later hired full time described a of
young women at the show being summoned by Rose to his Manhattan apartment to work at a desk
there. The woman described a day when Rose went into the bathroom, left the door open and turned
on the shower.
She said he began to call her name, insistently. She ignored him, she said, and continued working.
Suddenly, he came out of the bathroom and stood over her. She turned her head, briefly saw skin and
Rose with a towel and jerked back around to avoid the sight. She said he said, "Didn't you hear me
you?"
calling
She said she told someone in the office, and word got around. A few days later, she said, a male
trick."
colleague approached her, laughing, "Oh, you got the shower The woman's sister confirmed that
her sibling had told her about the shower incident soon after it occurred.
Another woman said that during her internship in the early2000s, Rose groped her breasts and
stomach as she drove him from Bellport back to Manhattan. Her then-boyfriend, now husband,
confirmed that she described the incident to him immediately after it occurred. When Rose invited her
to work regularly and stay overnight at Bellport, her boyfriend told her to refuse the offer, and she did,
both told The Post.
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Prestige and fear
Rose's eponymous show, with its trademark black background and round oak table, has been in
Rose"
production since 1991. What it lacks in mass viewership, the "Charlie show makes up for in
prestige and high-profile bookings of the likes of former president Barack Obama, Oprah Winfrey and
Warren Buffett. Rose's show is produced by Charlie Rose Inc., an indepéñdéñt television production
company, and distributed by PBS. It is filmed at Bloomberg headquarters in Manhattan.
Rose's stature has only grown in recent years.
Morning,"
CBS tapped him in 2011 to help revamp its ailing morning show, now called "CBS This
Minutes"
expanding his audience. He has also been a contributing correspondent for "60 for nearly a
decade. His 2013 interview of Syria's president won Emmy and Peabody awards. (None of the women
who made accusations against Rose to The Post worked for PBS or CBS.)
Representatives from PBS, CBS and Bloomberg said they have no records of sexual harassment
complaints about Charlie Rose.
When Time magazine named Rose one of its 100 most influential people in 2014, billionaire and
former New York City mayor Michael R. Bloomberg described him as "one of the most important and
journalism."
influential people in
Morning"
Rose, who was divorced in 1980, has long had a reputation as a ladies man. His "CBS This
co-host, Norah O'Donnell, introduced him at a 2014 fundraiser dinner by joking, "We're all here
enough."
because with Charlie Rose, one woman is never
Rose gracicusly accepted honors that night by saying that he was lucky to have worked throughout his
was."
career with "women who were smarter, more thoughtful and more eloquent than I
There was also less flattering coverage. The now-defunct Radar magazine in 2007 called him a "toxic
bachelor"
and repeated an unn amed woman's claim that Rose had "palmed her buttock like a
honeydew."
His then-attorney, David Boies, who has recently drawn criticism for his representation of
Harvey Weinstein, demanded a retraction. The magazine refused.
Rose"
The "Charlie show prides itself on its highbrow intellectual ambition, but his life is glamorous,
full of black-tie galas and famous friends. He can be charming and generous, consulting favored
employees for their opinions on what to ask heads of state or whisking them off to exotic locations for
interviews. But his wrath was swift and often fiercely personal, according to interviews with multiple
former employees.
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him,"
"Everybody is terrified of said one of the women who said that Rose groped her when she was an
intern. "He creates this environment of constant fear. And then he'll shine a spotlight on you and make
amazing."
you feel
Multiple women said they had at first been reassured by the preseñce of Vega, Rose's executive
producer, who has worked with him for decades. Two women who spoke to The Post said they
repeatedly reported Rose's inappropriate sexual behavior to Vega.
Judgment'
'His poor
Rose"
Working for the "Charlie show was a longtime dream for Reah Bravo, who in 2007 was a 29-
year-old graduate student studying international affairs at Columbia University. She struggled to make
ends meet during her unpaid internship, accruing credit card debt and eating free cereal in the
Bloomberg food court.
One day, several months into the internship, Rose offered her a side gig at his home in Bellport on
Long Island.
etc.,"
"Here is the deal: I'll pay you $2,500 for the week plus all expenses for food, movies he wrote to
her on Aug. 9, 2007. "You will be there from Monday August 13-Friday afternoon, August 17. Your
primary responsibilities are to organize and catalogue all my books and tapes and files ... It will help
do."
me a lot, be fun for you, and you will have a car all the time for whatever you need to
Before she left for Bellport, Bravo said Vega told her that personal time with Rose was a key to
becoming part of the team.
Bravo said she took the train to Bellport, where she said Rose met her at the Ronkonkoma station and
took her to a bank to withdraw money to cover her expenses. She stayed at the Bellport home for about
a week, sleeping in a bedroom in the main house. Rose was gone much of the time.
While she was there, Bravo said she received a message from a male producer. If Rose did anything
"sketchy,"
she said he told her, she should not hesitate to call the show's car service to return home.
Late one night, Bravo said, Rose returned home after a night out. She said she tried to hurry out of the
library in the guesthouse to return to her bedroom in the main house before Rose came in, but he
intercepted her. She said he insisted that they have a glass of wine at the dining room table in the main
house.
Then, he suggested they walk out to his dock and look at the moon, Bravo said. Once there, "he came
me,"
up from behind me and he put his arms around she said, remembering that she felt a mix of
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apprehension and confusion. "It reflected his poor judgment. How could a man of his stature and his
reckless."
power be doing something so inappropriate? . . . It seemed
Caught off guard, she said she did not know how to respond and endured his embrace.
A day or two later, Bravo said, Rose drove her back to Manhattan. She said he began to tell her that he
felt very alone in life, despite his wealth and success. He recalled a brush with death a year earlier
during heart surgery in Paris and began to tear up, and she said she patted him on the shoulder to
console him.
it," him.'
"I didn't necessarily buy she said. "I thought, Tll keep my distance and I feel sorry for But I
time."
didn't think of him as a predator at that
Bravo soon returned to Bellport for a second trip. She was working in the guesthouse and caught a
glimpse of Rose rinsing off nude in an unenclosed outdoor shower. She said she quickly averted her
eyes and moved away from the window.
Later, he asked if she had seen him showering, she said, and seemed disappointed when she said no.
While at Bellport, Bravo said Rose repeatedly insisted that he needed to hear that she was comfortable
at Bellport and how much she enjoyed it there.
She emailed him about her work ideas and also mentioned Bellport.
there?"
"Have I told you how much I absolutely enjoy it out she wrote him on Sept 1, 2007. "The
company, the conversation, the comfort...that said I'm happy to go out there for both the remainder of
faster."
this weekend AND parts of the next in an effort to finish the books
That fall, she traveled with Rose to Aspen for a conference. On Oct. 1, after the trip, Bravo wrote an
email to Vega, alluding to earlier issues with Rose:
"On a personal note, I know working for Charlie requires one to embrace his uniqueness and develop a
professional relationship that can account for it. It's taken a couple straight forward conversations
between the two of us, but I feel I'm in a better place than previously. And that's not to say that I was
previously in a really bad place! It all might sound cryptic, but you seem to play somewhat of a
)"
motherly role for staff members and I just wanted you to know that I'm okay :
Vega responded the same day:
"I have some concerns for you especially in what you are trying to tell me in this email. Please know
the following about me, I have worked with Charlie for 16 years, so there is nothing that I haven't
heard or possibly experienced - and that you ever reveal to me would be kept in confidence
anything
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confidence..."
from anyone and from the top down, so that you can feel comfortable in that
Toward the end of 2007, Bravo was given more respoñsibilities and Rose occasionally paid her for
helping him prepare for interviews, speeches and conferences. Her new duties required more travel
with Rose, and he frequently requested her company for working dinners, she said.
Rose would regularly hire drivers to take them around town. On more than one occasion, she said, he
groped her in the back seat. One time, she said, he "grabbed me by my hair, holding a fist of it at the
scalp."
base of my More than once, "he would grip my head tightly while talking to me. He held it so
tightly that I couldn't turn my neck in any direction. I was forced to look at him or to let him talk
..
ear."
directly into my
In Indiana for a speaking engagement in March 2008, Rose summoned Bravo to his hotel suite to
work on his speech. While she was working at a desk in the room, she said, he emerged naked from the
shower and stood before a mirror where she could see him. She said she ignored him and kept
working.
Later, flying on a small private plane alone with Rose, she said he requested that they watch a
documentary about Algeria on a portable DVD player. Suddenly, she said, Rose got out of his seat and
pressed his body onto hers.
air?"
"I felt at a loss. I mean, what am I going to do? We were how many feet up in the she said, adding
me."
that they remained clothed. "I remember him being on top of
"animalistic."
Bravo said Rose's advance was bizarre, brief and Then he returned to his seat.
back,"
"I felt an immense sense of shame that I had greenlighted his actions because I didn't fight she
said.
Bravo said she locked eyes with one of the two pilots as she disembarked. She said she interpreted his
disgust."
expression as one of "sympathy or maybe
Later in 2008, she was hired as an associate producer but was already looking for another job. The
Rose"
same year, Bravo was offered a job that paid three times as much as the one at the "Charlie
show. In response, Rose took her to the Spotted Pig, a well-known restaurant in Manhattan, and
dangled a position as a producer in Washington. She could even live in a Georgetown residence where
he sometimes stayed, she said he told her.
She said she declined.
away,"
"I was leaving beeãüse I was getting she said. "I would never want to live someplace where he
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keys."
had
Since then, Bravo has worked as a corporate speechwriter and now lives in Europe with her husband
and their young son.
In retrospect, Bravo said she feels shame and embarrassment about her warm correspondence with
Rose.
sick,"
"I read old emails, and I sound so sycoph antic, it makes me she said. "But it was what he
wanted, it made my work easier, and to an extent, it was the same game most staff members played.
it."
Male staffers did it, too. They just weren't feeling as pathetic about
Looking back, she is struck by how calculated Rose's approach seemed.
"He most definitely said, on numerous occasions, Tve never forced you to do something you didn't
do,' "
want to she said. "He would say this forcefully and wait for my confirmation after he said this. I
recorded."
remember once wondering if I was being
Blurred lines
Kyle Godfrey-Ryan was in her early 20s and had taken time off from her college studies in the
mid-20oos when a friend offered to introduce her to Charlie Rose. She was unfamiliar with his show
but was soon hired to be his assistant.
From the beginning, there was a blurring of the boundaries between Rose's professional and private
life, she said. On her first day on the job, Rose injured his foot. She tended to him as he recovered.
But soon, Godfrey-Ryan said, he began yelling at her, calling her stupid and incompetent and pathetic.
people,"
"He repeatedly attacked her in front of other recalled a former producer who spoke on the
condition of anonymity. "He once said that because she hadn't gotten a college degree she would never
secretary."
amount to anything better than his
After the bouts of rage, Godfrey-Ryan said, Rose would often be conciliatory.
me,"
"It would usually entail some version of him also touching she said. "A hand on the upper thigh.
breast."
He'd give a hug but touch the side of the
She said she ignored his actions. Then he began calling her as late as midnight and as early as 6 a.m.
life," "
"It would be wanting to know details of my sex she said. Who's next to you? What do you do? Is
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you?' tomorrow.'
he touching And I was like, 'Okay, Charlie, I'll see you I just acted like it wasn't
happening."
fantasy"
She said other calls involved a "very specific, repetitive of her disrobing at the Bellport home
moonlight"
and swimming "back and forth in the pool in the as he watched from his bedroom.
Her boyfriend at the time, now her husband, told The Post that he was often present for these calls but
said he did not know what was being discussed. The content of the calls, however, was openly
discussed in the office and even joked about, according to Godfrey-Ryan and the producer who wórked
there at the time.
Godfrey-Ryan also said Rose would repeatedly walk in front of her naked at one of his New York City
residences. Her husband confirmed that she complained to him about it at the time.
engage,"
She said she ignored the nudity. "He was getting more and more frustrated that I wouldn't
she said.
Godfrey-Ryan said she reported the touching and the calls to Vega, but nothing happened.
girl,"
"She just made me feel like I was being a dramatic little Godfrey-Ryan said. She stopped
reporting the behavior.
Godfrey-Ryan said she eventually confided to a mutual friend outside the show about Rose, and the
friend told Rose.
She said Rose fired her.
that,"
"He took me out to lunch and told me how embarrassed he was, how he didn't treat me like she
anymore."
said. "It was really about how I got it wrong, and, obviously, I couldn't work there
She later went back to school at Columbia. She has since launched her own business, Tune.Studio,
which uses infrasonic wave technology to treat stress and improve moods, leading to "peace and
happiness."
television,"
"It makes me a little upset to see him on she said. "Everything I experienced with
stay."
journalism there made me not want to
A Job interview, then denial
Another woman gave multiple interviews to The Post about her experiêñce with Rose but requested
anonymity out of concern for her privacy.
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In 2009, she was in her mid-30s, looking to break into broadcast journalism after studying politics
and earning her graduate degree in Europe. While working at a cultural foundation in New York City,
her boss offered to put her in touch with Charlie Rose.
Rose responded with interest.
The meetings that followed, she said, were unconventional: a dinner at a restaurant, late at night with
Rose's prominent friends, where he drank a lot of wine. A sudden weekend invitation to lunch
continued with her tagging along as Rose shopped for furniture. When he drove her home, she said
she listened in alarm as he berated a producer over the phone.
that,'
Then he turned to the job applicant. "He put his hand on my knee and said, 'Oh, I'm sorry about
" touchers.' "
she said. "He said, 'I hope you don't mind, I'm from the South, we're
No job offer came, but on June 8, 2010, Rose got back in touch, according to an email the woman
provided. She was still unemployed and the job Rose described sounded ideal.
"He talked about this position, which he referred to as being his intellectual partner, that I would be
content,"
the executive producer for global she recalled.
By now, she had been told the unorthodox interview process was standard because of Rose's packed
schedule and desire to do the hiring for all positions by himself.
As part of the process, she visited Bloomberg's Manhattan office and also discussed the job with Rose
at his apartment.
work,"
"My producers come here all the time to she said he told her.
She said Rose mentioned a salary of $120,000, described the job as involving frequent international
travel and asked for references. Rose soon suggested they see how they traveled together by having her
visit his Bellport house, she said.
On June 18, Rose sent her an email inviting her to the house that evening.
"As I mentioned, I'm going to my place on long island tonight to write...and then coming back
tomorrow for a dinner. This is to invite to visit...
"You have your own wing of the house, or even a guesthouse, It's on the water, plus Olympic pool,
tennis court, plenty of movies and books and sailing and I run on the beach at sunrise and
projects."
sunset...This has no influence on our dialogue about work
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He added near the end of the email: "Bring someone if you like. I'm on deadline, so i will be writing all
the time and will not be entertaining except breaks for exercise and meas: Let me know...before
noon."
Eager to land the job, the woman agreed to travel with Rose to Bellport, which is about 60 miles from
Manhattan.
She gave the following account:
That evening, after stopping for dinner and getting lost, they arrived at the house after midnight. She
did not see anyone else there. Rose proposed she choose a DVD of his show that they could watch
together. After the show, Rose gave her a tour of the property. The guesthouse, she noticed, was
packed with clutter, uninhabitable.
At the pool, Rose dangled his legs in the water and then said that he needed to change because his
pant legs were wet. He returned wearing a white bathrobe, which was open; he wore nothing
underneath.
doomed,"
"I thought, I'm she said. "I was completely panicked. In retrospect, I thought of a million
done."
things I could have
She said she was not intoxicated - Rose had drunk his wine and then hers at the restaurant - but said
he appeared to be. It was nearly 2 a.m. and she was exhausted, she said. She also said she felt alone
and powerless. It was the middle of the night, they were on his secluded property, and she did not
know how to drive.
way,"
"I started talking in this feeble and compulsive she said. "I started talking about power, how the
abuse of power can be. He completely lost it. 'What are you talking about? That's certainly not the
case.' "
She said he then tried to put a hand down her pants.
angry,"
"By the time he touched me the first time, he was already very she said. "I was scared, and I
frozen."
was also kind of
"hazy,"
After that, her memory is she said. They ended up in his bedroom.
"I really, honestly, I've tried so hard, especially recently, since I've been thinking about this, to try to
bed,"
remember what happened between sitting by the pool and being in his she said. "I have no
time."
recollection of how we went from here to there. I do remember I was crying the entire
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Eight women NO. 108
https://www.washingtsapest.com/investigaticñs/cight-womcñ-say-charli.. 01/06/2020
He reached down her pants again, she said, and she pushed his hands away. As she wept, she said,
crying?"
Rose asked her, "Baby, oh baby, why are you
The encounter ended when he appeared to be asleep and she felt she could leave the room, she said.
The next day, she said there was little mention of what had happened. She described the previous
disaster" mean?"
night to him "as a bit of a and he said, "What do you
A few days later, she followed up about the job.
In she "Remainin allowed me to continue what had occurred. It was in

retrospect, said, g silent denying
job."
that state of denial that I wrote to him asking about the
He replied with his regrets.
had,"
"The whole thing was really the most humiliating and most degrading experience I've ever the
"distraught"
woman says now. A friend she confided in at the time described her as having been in
recounting what happened.
distressed,"
"To have been used in the way she was left her feeling really confused and really the friend
told The Post. The friend encouraged her to write about her experience, and she chose to do so as a
short story.
In one of the drafts that she shared with The Post, a tall, drawling television host named "Johnny
Pose"
brings a young woman to his country home on Long Island to discuss a job opportunity.
The woman said she changed some key details about what happened by the pool. And in the story,
unlike in real life, she said, she viewed the host with contempt rather than fear.
She said she submitted the story to several magazine editors in 2010 and 2011. Paris Review editor
Lorin Stein declined to publish the story but wrote to her in March 2011, "It has the ring of truth
(alas)."
Hunt."
The woman titled the story, "The
The double entendre, she said, was intentional.
job," me."
"I was hunting for a she told The Post, "and he was hunting for
Julie Tate and Alice Crites contributed to this report.
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Eight women NO. 108
https://www.washing'erpost-com/iñvatig:ticñs/eight-women-say-charli.. 01/06/2020
Irin Carmon
• Irin Carmon,
Bader
an Outlook
Ginsburg."
contributing
Follow W
writer, is a co-author of "Notorious RBG: The Life and Times of Ruth
Amy Brittain
•
Amy Brittain is a reporter for The Washington Post's investigative team. Her coverage has included
Investigative reporting on sexual harassment, criminal justice issues and the intersection between
President Trump's real estate empire and U.S. government business. Follow W
stetvastingtongst
The story
must betold.
Your subscription supports journalism that matters.
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ggy
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P0022
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EXHIBIT 6
166 of 226
Charlie RoseG @charlierose · 20 Nov 2017 v

My statement in full.
Statement from Charlie Rose:
In my 45 years of journalism, I have prided myself on being an advocate for the careers of
the women with whom I have worked. Nevertheless, in the past few days, claims have been
made a bout my behavior toward some former female colleagues.
It is essential that these women know I hear them and that I deeply apabgize for my
inappropriate behavior. I am greatly embarrassed. I have behaved insensitively at times, and
I accept responsibility for that, though I do not believe that all of these allegations are
accurate. 1 always felt that I was pursuing shared feelings, even though I now realize I was
mistaken.
I have leamed a great deal as a result of these events, and I bope others will too. All of us,
Including me, are coming to a newer and deeper recognition of the pain caused by conduct
in the past, and have come to a profound new respect for woman and their lives.
P0001
4.6K G 3.3K O 5.8K
EXHIBIT N •
DATE: (
JINEENPAVESI,
RPR,RMR,CRR
167 of 226
EXHIBIT 7
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Colleagues,
A short time ago we 16imiñstsd Charlie Rose's empicymsat with CBS News, sffsctive immediate!y. This fc"owM the revelation
yesterday of extremely disturbing and intolerable bshavicr said to have rsvüiv6d around his PBS program.
Despite Charlie's important joume!!stic contribution to our news division, there is absolutely nothing more impartant, in this or any
orgenivanan, than ensuring a safe, prafeeeianal würkpisce--a supportive añvircñment where people feel they can do their best work.
We need to be such a place.
I've often heard that things used to be differeñ‡. And no one be able to correct the past. But what once have been emptad
may may
should not ever have been acceptable.
CBS News has rsportsd on es:êMinary reve!etions at other media compañias this year and last. Our crsdibility in that reporting
requires crsdibi:|ty managing basic standards of behavior. That is why we have taken these actions.
Let's please ismrm½r our obligaticñ5 to each other as ml!==gues. We will have human resources support today and every day, and we
are organizing more personal and direct training which you will hear about from senior management shortly.
I'm deeply disappüistâd and angry that people were vid-imizert--and that even people not cGññseted with these events could see their
hard work undermined. if all of us commit to the best behavior and the best work -that is what we can be known for.
RI Odus CBS News P0093

Davic i President. I @davkigrayrhodes
PLAINTIFFS
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EXHIBIT 8
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From: Charlie Rose <cr@charlierose.com>
Sent: Friday, November 24, 2017 3:36 PM

To: Chelsea Wei <WeiC@cbsnews.com>
Subject: thanks
For all your hard work for me. I hope it was a great learning experieiice for you. I treated you with the respect and
appreciation you deserved. I hope you know the person you knew and my relationship with you is the man I am in all my
relationships. . Best of luck in the future. If there is anything I can do, please let me know.
EXHIBIT N
DATE: /t {
JINEENPAVESI,
RPN,RMR,CRR
Confidential 171 of 226 CRI_00471869

EXHIBIT 9
172 of 226
From: Charlie Rose <cr@charlierose.com>
Sent: Friday, December 1, 2017 3:32 PM
To: Ryan Kadro <kadroR@cbsnews.com>
Bcc: Charlie Rose <cr@charlierase.com>
Subject: moving
Dear Ryan,
As you must know, I reached out via phone to you last week. I wanted to apologize to you and evêryGñe hurt by behavior by
me.
I feel like a tsunami hit and all you can do is apologize for being there and try save everyGñê.
Movers are coming MGñday to take things from 60 and ctm. We called Erin and Chelsea earlier. I think Chelsea reached out
to Ray. How do I f=cilit=te the connection to make this happen as easy as possible on Monday. Thanks C
EXH1BIT 0.:
DATE:
RPR,RMR,CRR
JINEENPAVESI,
Confidential 173 of 226 CRI_00489952

EXHIBIT 10
174 of 226
Charlie Rose's misconduct was widespread at CBS and three managers ... https://www.washingtonpost.com/charlie-roses-misconduct-was-widespr .
The Washington Post
National
Charlie Rose's misconduct was widespread at CBS and three
managers were warned, investigation finds
By Amy Brittain and
Amy Brittain
Investigative reporter
Email E Bio G Follow W
Irin Carmon
May 3
Incidents of sexual misconduct by Charlie Rose were far more numerous than previously known,
according to a new investigation by The Washington Post, which also found three occasions over a
period of30 years in which CBS managers were warned of his conduct toward women at the network.
An additional 27 women
-
14 CBS News employees and 13 who worked with him elsewhere - said
Rose sexually harassed them. Concerns about Rose's behavior were flagged to managers at the
network as early as 1986 and as recently as April 2017, when Rose was co-anchor of "CBS This
Morning,"
according to multiple people with firsthand knowledge of the conversations.
Rose's response to the new allegations was delivered in a one-sentence email: "Your story is unfair and
inaccurate."
The new allegations follow an earlier Post report on Rose's behavior at his namesake PBS program, in
which eight women accused the TV star of making lewd phone calls, walking around naked in their
presence, or groping their breasts, buttocks or genital areas. Rose issued an apology. His PBS show
was canceled and he was fired from CBS News.
The Post's investigation is based on interviews over a five-month period with 107 current and former
CBS News employees as well as two dozen others who worked with Rose at other television programs.
Many of those interviewed for this article spoke on the condition of anonymity because they feared
EXHIBIT
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Charlie Rose's misconduct was widespread at CBS and three managers ... https://www.washingtonpost.com/charlie-roses-misconduct-was-widespr...
retaliation. The Post corroborated specific accounts with witnesses or people in whom they confided.
The new allegations against Rose date to 1976, when, according to a former research assistant, he
exposed his penis and touched her breasts in the NBC News Washington bureau where they worked.
happen,"
"This other personality would come through, and the groping would said the former research
assistant, Joana Matthias, now 63. An NBC Newsspokeswoman declined to comment.
At CBS News, where in addition to the morning show Rose worked as a contributing correspondent for
Minutes,"
"60 some women who said they were harassed said they feared reporting the violations to
executives, whom they viewed as prioritizing the careers of male stars.
went,"
"I had been there long enough to know that it was just the way things said Sophie Gayter, now
Minutes"
27, who worked at "60 in 2013 when, she said, Rose groped her buttocks as they walked
down an office hallway to a recording studio. "People said what they wanted to you, people did what
you."
they wanted to
CBS News, which has said it had no human resources complaints about Rose, issued a statement
Wednesday in response to a request for comment.
"Since we terminated Charlie Rose, we've worked to strengthen existing systems to ensure a safe
work,"
environment where everyone can do their best the statement said. "Some of the actions we have
taken have been reported publicly, some have not. We offer employees discretion and fairness, and we
take swift action when we learn of unacceptable behavior.
"That said, we cannot corroborate or confirm many of the situations described. We continue to look
for ways to improve our workplace and this period of reflection and action has been important to all of
process."
us. We are not done with this
Minutes"
The executive who hired Rose for multiple roles at the network over the years, longtime "60
head and former CBS News chairman Jeff Fager, said via email that he had no knowledge of any
allegations against Rose until The Post's November report.
women,"
"I was never informed that Charlie behaved badly with Fager wrote. "I hired him because he
was one of the best interviewers in the country. Period. If I knew there was this darker side he never
hired."
would have been
The network recently announced the formation of a working group, consisting of a dozen employees,
to "assess our workplace environment and hear ideas and suggestions to make CBS News an even
journalism,"
better place to do important according to an email sent to the staff in April. A CBS News
.
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spokeswoman said that in-person training for sexual harassment is now mandatory for all employees.
In a statement in March, CBS News President David Rhodes said, "I was not aware of harassment by
CBS."
Charlie Rose at
Asked during a forum last month at George Washington University whether CBS News had protected
Rose or known about his behavior, Rhodes responded, "Just to be really clear, there was not
knowledge."
Minutes"
The Post has partnered with "60 over the years, including on an investigation last year of the
Drug Enforcement Administration. None of the investigative reporters or their editors who
Minutes"
collaborated directly with "60 on that article worked on this one.
sex?'
'How often do you like to have
The first instance identified by The Post in which a CBS News employee said a manager was told of
News."
Rose's conduct was in 1986, when he was filling in as an anchor on "CBS Morning
There, Annmarie Parr, a 22-year-old news clerk, delivered a script to Rose. He had made "lewd, little
comments"
about her appearance before, Parr said, but that day Rose took it further. "Annmarie, do
sex?" sex?'"
you like she said he asked her. "Do you enjoy it? How often do you like to have She said
she laughed nervously and left.
Parr said she reported Rose's comments to her boss - a senior producer whom she declined to name
- and said she didn't want to be alone with Rose. The producer Parr and told
laughed, said, her, "Fine,
anymore."
you don't have to be alone with him
That same year seven women sued CBS, claiming that the workplace on the network's overnight
"Nightwatch" hostile"
broadcast was "offensive and to female employees.
The women accused CBS of knowingly tolerating an environment of sexual harassment by the show's
executive producer John Huddy and unidentified other employees. Huddy, who could not be reached
for comment, resigned before the suit was filed.
Rose was a co-anchor for the show in Washington, though he was not mentioned in the lawsuit.
One of the plaintiffs, Beth Homan-Ross, who worked directly with Rose as an assistant producer, told
The Post that Rose frequently made sexual remarks about her breasts and buttocks. When she arrived
at his house to deliver materials or prepare him for work, he would sometimes open the door naked,
holding a towel. More than once, she said, Rose asked her to come into his bathroom while he was
.
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showering. She said she declined, waiting outside.
stepped,"
"It was a sexual land mine everywhere you Homan-Ross, now 61, said of working in the
show's Washington office.
The lawsuit was settled under confidential terms in 1987.
Rose left CBS in 1990 and the next year launched his own show on PBS, which established his brand of
long-form interviews with the famous and powerful.
By the end of the decade, Rose had become a household name. In 1998, he was brought back to CBS as
II,"
a correspondent at "60 Minutes a spinoff of the original program. The arrangement, in which Rose
worked part time for the show, gave him the freedom to keep his show on PBS.
By then, some at CBS were concerned about Rose's conduct toward women.
When Susan MacArthur was interviewing in the late 1990s for a job to be Rose's assistant, she said, a
clear" behavior."
CBS News executive told her to "steer because of the host's history of "questionable
"She looked me dead in the eyes and said, 'You are going to be working alone with this man and being
this,'
alone with this man in his hotel, and you need to think really hard about whether you want to do
"
MacArthur said, declining to name the executive. MacArthur heeded the advice and stopped
returning Rose's calls.
For some of the women who interacted professionally with Rose, it became hard to draw lines between
his roles at CBS and PBS, where, as the show's owner, he was the boss.
In 2003, he brought a 20-year-old intern from his PBS show on a CBS trip to California for a "60
II"
Minutes assignment.
period,"
"You're not just working for a show, you're working for Charlie, said the former intern,
Corrina Collins, who now lives in Montana and works as a transportation planner.
"paw"
On the plane, Collins said, Rose insisted she drink wine and began to her. Collins became
drunk, she said, and threw up in the plane's bathroom.
Rose squeezed her breast during the car ride from the airport, Collins said. She said he insisted that
me."
they work in his hotel room, where he told her, "I want you to ride She quickly left his room. "It
predatory," persist."
felt she said. "I had already said no, but he was going to
Back in New York, Collins said she shared concerns about Rose with Yvette Vega, the executive
.
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producer of Rose's PBS show, who she said replied that he was harmless. Vega did not respond to a
request for comment.
Collins shared her account several years ago with Danna Jackson, a lawyer and family friend in
Montana, who corroborated her account.
Minutes"
In 2008, Rose was brought aboard "60 as a contributing correspondent by Fager, who had
II"
been his boss at "60 Minutes and had been named as the flagship Sunday program's executive
producer.
In 2011, Fager was promoted to be CBS News chairman. Again, he turned to Rose for a marquee
- Morning."
assignment tapping him to co-host the network's struggling morning show, "CBS This
"gut."
Fager later said his decision to tap Rose was based on his
"Charlie, to us,symbolized ... what we are about, you know, we being this strong identity of
pure,"
journalism that is relatively Fager said in a podcast interview last year.
crowd'
'I was nobody, and he picked me out of a
Rose had risen to become one of the news division's biggest stars, with prominent roles as a
Minutes" Morning."
contributor to "60 and as co-host of "CBS This
Morning,"
And soon after he was hired at "CBS This Rose's inappropriate behavior was flagged to a
supervisor - the second time identified in which CBS

by The Post News management was alerted to
his conduct.
Rose hosted a holiday gathering in late 2011 for CBS and PBS staffers at the Spotted Pig, a Manhattan
Morning"
restaurant, and, amid other partygoers, forcibly kissed a "CBS This employee, according to
two people with firsthand knowledge of the incident.
Morning"
The next day, the woman who was kissed told the "CBS This executive producer, Chris Licht,
what happened, but she asked him not to share with the company's human resources department what
she reported.
Licht confirmed in an email to The Post that he was told about the kissing incident with Rose. He said
he abided by the wishes of the employee and spoke with Rose about the incident.
Licht, who has since been promoted to CBS executive vice president and now heads "The LateShow
Colbert,"
With Stephen declined to be quoted and did not provide further details of his conversation
with Rose. He said he received no other complaints about inappropriate sexual behavior by Rose.
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A CBS News spokeswoman said in a statement that Licht's actions were "within the scope of CBS
time" result."
policy at the and that the "employee in question was satisfied with the The spokeswoman
report"
added that CBS revised its policy in 2016 to require supervisors to "promptly harassment
complaints to the human resources department or a compliance officer.
The woman who was kissed declined to comment.
Morning"
Weeks later, in January 2012, a "CBS This paid contributor was on the set with Rose during
an off-air moment when, she said, he drew her close, groped her right buttock and whispered in her
TV."
ear, "Damn, you look good on
The contributor immediately told a friend about the incident. The friend, contacted separately by The
Post, corroborated the conversation.
The third and most recent example identified by The Post in which a CBS News manager was alerted
to Rose's behavior came in early 2017. By then, Licht had been replaced by Ryan Kadro, who remains
Morning."
the executive producer of "CBS This
Brooks Harris, then 24, had been working the night shift when she was briefly assigned to work in the
studio during the morning hours. That's when Rose first approached her.
Rose said that he had heard that Harris was smart and had talked to Kadro about her, according to
Harris. She said Rose also began taking her to lunch at expensive restaurants, where he bought her
Minutes"
wine and floated job opportunities at "60 and at his PBS show.
employees,"
"I was nobody, and he picked me out of a crowd of Harris recalled.
Harris's mother, Heather Harris, told The Post she expressed concern to her daughter about Rose's
guy."
attention, but "all of the indications from the newsroom were that he was a trustworthy And the
younger Harris was ready for a new job.
Minutes"
Within a few weeks, Harris said, Rose sent her to "60 to meet with Alison Pepper, a senior
broadcast manager at the time.
there,"
"She didn't know why I'd showed up Harris said. "I said: 'Oh, Charlie sent me over here to have
me.' "
a meeting with you. He said you were expecting According to Harris, Pepper said she wasn't
sure if the show had the budget for a new position.
Through a CBS News spokeswoman, Pepper declined to comment.
Meanwhile, Kadro's then-executive assistant, Chelsea Wei, said she grew increasingly concerned about
.
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Rose's one-on-one lunches with Harris outside the office.
Wei, who went on to work for Rose's CBS team and still works at the network, said she confided in her
who encouraged her to report her concerns to management - a conversation the boyfriend
boyfriend,
separately recalled to The Post.
Early that April, Wei said, she told Kadro that she was worried that Rose's attention to Harris outside
of the office, including the lunches, seemed unusual. She said she offered Kadro a warning: "I'm telling
hands."
you in case you have a lawsuit on your Kadro, she said, did not seem alarmed.
Kadro, in an email to The Post, acknowledged that Wei came to speak to him about Rose but disputed
her account. "Ms. Wei did not tell me about inappropriate behavior by Charlie Rose towards Ms.
'lawsuit' - word."
Harris at any time. . . . Regarding your question about a I don't believe she used that
Days later, Harris said, Rose offered her a position at his PBS show that paid roughly $20,000 more
than she had been making.
world,"
"It is the best job in the he wrote her in an April 11, 2017, email reviewed by The Post. "I want
you to be at the center of my professional world as I navigate between CHARLIE ROSE, CTM, AND
MINUTES."
SIXTY
'encourage'
Kadro, Harris said, encouraged her to take the job. He denied doing so. "I did not Ms.
Rose,"
Harris to work for Mr. he said in the email.
Rose,"
Once she started working at "Charlie Harris said, his behavior increasingly made her
uncomfortable. She said Rose told her he hired her because he liked tall women and once suggested
she have sex with another female assistant, Sydney McNeal.
McNeal confirmed the remarks in an interview with The Post, adding that working for Rose was
"toxic"
and that it "made me question my intelligence, dignity and worth as a human being almost
day."
every
When the two assistants went on an errand to Rose's Bellport, N.Y., house, Harris said that their boss
remarked jokingly that he didn't want to hear reports of "two young women swimming naked
together"
in his pool.
Rose"
Late one July night last year, after a "Charlie staff gathering, Harris said, Rose asked her to leave
alone with him. She said he took her for drinks at the upscale restaurant Harry Cipriani and
demanded she come up to his apartment. She said Rose was drunk and insisted they sit together at his
Minutes"
desk to watch footage of his "60 interviews with former U.S. presidents.
.
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The situation made her uncomfortable, she said, so she made up an excuse to leave quickly.
Four months later, PBS canceled the program, citing The Post's reporting on sexual harassment there
- the entire staff, Harris, unemployed. CBS News suspended and fired Rose, and
leaving including
Rose."
issued a statement saying it had "no records of any complaint of sexual harassment by Charlie
The network's reporters vowed to follow the story.
In February, Ken Goldberg, an attorney for Harris, Wei and McNeal, sent Rose and CBS a letter
containing their allegations. Among the claims: Rose subjected the women to "repeated physical and
harassment,"
verbal sexual including sexual touching, comments and advances.
"Management, numerous broadcasters and studio staff witnessed Mr. Rose's unlawful conduct, and
made,"
complaints were Goldberg wrote. But, he added, CBS and Rose's separate company "failed and
unabated."
refused to take any remedial action and that conduct continued
Goldberg said that his clients plan to file a lawsuit in the coming days.
Irin Carmon is a contributing writer.
Julie Tate contributed to this report.
Amy Brittain
O
Amy Brittain is a reporter for The Washington Post's investigative team. Her coverage has included
investigative reporting on sexual harassment, criminal justice issues and the intersection between
President Trump's real estate empire and U.S. government business. Follow W
lrin Carmon
. Irin Carmon, an Outlook contributing writer, is a co-author of "Notorious RBG: The Life and Times of Ruth
Ginsburg."
Bader Follow W
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Inside 'Trump me unceur new von nas sesrsmER
Revealed,"
Read stories based on reporting for "Trump a
broad, comprehensive biography of the life of the 45th -var..,
president.
•
Reporting archive: Trump's financial records, TRUMP
depositions and interview transcripts
REVEALED
The Definitive Biography
of the 45th President
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w MARC FISIIER
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EXHIBIT 11
184 of 226
Page 1
2 SUPREME COURT OF THE STATE OF NEW YORK
3 COUNTY OF NEW YORK
4 -------------------------- X
KATHERINE BROOKS HARRIS,

5 SYDNEY MC NEAL, AND YUQING
" "
( C H E L S E A ) WE I ,
P 1 a i n t i f f s ,
vs. Index No.:
8 154172/2018
9 CHARLIE ROSE, INC.,
AND CHARLIE PEETE ROSE, JR.
10 a/k/a CHARLIE ROSE,
11 Defendants.
-------------------------- X
1 2
13 October 28, 2019
14 10:18 a.m.
1 5
1 6
17 Deposition of KYLE GODFREY-RYAN,

18 held at the offices of Goldberg & Fliegel
19 LLP, 488 Madison Avenue, New York, New
20 York, pursuant to Subpoena, before Theresa

21 Tramondo, AOS, CLR, a Notary Public of the
22 State of New York.
23 Reported by:
24 THERESA TRAMONDO, AOS, CLR
25 JOB NO. NY3605704
212-267-6868 www.veritext.com 516-608-2400
185 of 226
Page 2
2 APPEARANCE OF COUNSEL:
4 FOR PLAINTIFF:
5 GOLDBERG & FLIEGEL LLP
6 488 Madison Avenue
8 BY: KENNETH A. GOLDBERG, ESQ.
9 MICHELE L. FLIEGEL, ESQ.
10 Kgldbrg@aol.com
11 212-983-1077
1 2
13 FOR DEFENDANTS:
14 SHAPIRO ARATO BACH LLP
15 500 Fifth Avenue, 40th Floor
17 BY: JONATHAN P. BACH, ESQ.
18 CYNTHIA ARATO, ESQ.
19 JASON WOLF, ESQ.
20 Jbach@shapiroarato.com
21 Carato@shapiroarato.com
22 Jwolf@shapiroarato.com
23 212-257-4897
2 4
2 5
212-267-6868 www.veritext.com 516-608-2400
186 of 226
Page 8
1 Godfrey-Ryan
2 A. Yes.
3 Q. Before you worked as Mr. Rose's
4 assistant, did he have another person
5 working as his assistant?
6 A. I believe he always had people,
7 y e a h .
8 Q. Did you ever hear that he had an
9 assistant before you were his assistant?
10 A. Yes.
11 Q. What was the assistant's name?
12 A. I believe the one before me was
" "
1 3 B o n n i e H u n g ( p h o n e t i c ) . I t h i n k H u n g . I
14 know her first name is Bonnie, but I'm kind
15 of -- I think it's Hung. I never met her.
16 Q. During your employment with
17 Mr. Rose, did he engage in any conduct that
18 you considered to be sexually inappropriate?
19 MR. BACH: Object to the form of
20 the question.
21 Q. You can answer.
22 A. Yes.
23 Q. Did he engage in any physical
24 conduct that you found to be inappropriate?
25 A. Yes.
212-267-6868 www.veritext.com 516-608-2400
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Page 9
1 Godfrey-Ryan
2 Q. I would like you to tell me the
3 conduct that Mr. Rose engaged in, physical
4 conduct that you found to be inappropriate.
5 A. So, yeah. Charlie was always
6 like touching or groping mostly me, but
7 there were times obviously that I saw it
8 with other people as well. Yeah, I mean, he
was -- like if I was next to he

9 sitting him,
10 would like put his hand on my thigh, and
11 like run it up, and then I would stop it
12 obviously before he would (indicating)...
13 He would grab like the outside of my
14 breasts. He would like kiss me very
15 seductive. He -- he treated me physically
16 at times as if I were like a lover or a
17 girlfriend. Like it was -- he

very yeah,
18 was very physical after I started working
19 for him, not when we were interviewing.
20 Q. I understand.
21 So you said that he hugged you?
22 A. but I mean -- yes.

Yes, yeah,
24 the question.
25 Q. Did he kiss you?
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2 A. Not on my lips.
3 Q. Where did he kiss you?
4 A. He would kiss like on the side
5 of my face and my neck (indicating).
6 Q. The side of your face and your
7 n e c k ?
8 A. Yeah.
9 Q. You said he touched your thigh?
10 A. he would if I -- time I
Yes, any
11 was sitting next to him.
12 Q. Did you sometimes travel with
13 Mr. Rose in a car?
14 A. Multiple times a week.
15 Q. Did he touch you inappropriately
16 when you were in a car with him?
17 A. Yes.
18 Q. Do you remember where he touched
19 you when you were in the car with him?
20 A. Yes. If I was sitting next to
21 him, it would be my thigh. It would be like
2 2 my - -
23 Q. Did you take any airplane
24 flights with Mr. Rose?
25 A. Yes.
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1 Godfrey-Ryan
3 on an airplane?
4 A. not on a -- not that I

No, no,
5 can remember.
6 Q. Did you have any meals with
7 Mr. Rose at a restaurant?
8 A. Yes.
9 Q. Did he touch you at a
10 restaurant?
11 A. No. If it was a restaurant, he
12 would be across from me.
13 Q. When he touched you most of the
14 time, it was at the offices of Charlie Rose?
15 A. It was everywhere. So it could
16 be the office. It could be, like, his
17 homes. there wasn't like -- there was

Yeah,
18 nothing, like, secret about it. So it
19 wasn't like it would only happen in a dark
20 corner sort of thing. It was a very, like,
21 out in the open sort of behavior.
22 Q. When you said he touched you at
23 his homes, what homes are you referring to?
24 A. He had an apartment at the
25 Sherry-Netherland, I think it's called, and
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1 Godfrey-Ryan
2 then he had a townhouse on Charles Street.
3 It's like the West Village.
4 Q. Did Mr. Rose touch you
5 inappropriately in front of the staff?
6 A. Yes.
8 in front of guests?
9 A. Yes.
10 Q. Did you ever see Mr. Rose
1 1 n a k e d - -
12 MR. BACH: Objection. Objection
13 to the form of the question.
14 Q. Did you ever see Mr. Rose in the
1 5 n u d e ?
16 A. Yes.
17 Q. Where did you see him in the
1 8 n u d e ?
19 A. In Charles Street.
20 So he had -- I don't know if you
21 guys have, like, been to his home, but
22 like -- or if he still has but the

it, way
23 that he had Charles Street set up was there
24 was an office, and it had two, like, old
25 desks here (indicating), and there was a
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1 Godfrey-Ryan
2 bathroom here (indicating), and for some
3 reason -- his bedroom was upstairs.
4 But for some reason he would
5 shower in this bedroom -- in this one
6 (indicating), which is off the office, like
7 connected (indicating). And then he would
8 sometimes leave with a towel wrapped around
9 him, sometimes not, or like a robe, but not
10 always closed. Like that was --

closed,
1 1 y e a h .
12 Q. From your observations, did he
13 know that you saw him naked?
14 A. Yes.
15 Q. Did you ever reciprocate when
16 Mr. Rose touched you inappropriately?
17 A. No, no.
18 Q. You said a few minutes ago that
19 when he put his hands on your thigh and
20 worked his way up, you would try to move his
2 1 h a n d s ?
22 MR. BACH: Objection.
23 A. Yes.
24 MR. BACH: Objection to the form
25 of the question. Mischaracterizes the
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1 Godfrey-Ryan
2 testimony.
3 Go ahead.
4 Q. You can explain.
5 MR. BACH: I'm going to make
6 objections for the record, but you can
7 answer the question. I just have to
8 make the record.
9 Q. Please explain how you responded
10 when he put his hands on your thigh?
11 A. that was when -- so most

Yeah,
12 of the time when Charlie would touch me, I
13 would pretend it wasn't happening, so I
14 would just freeze up and not respond.
15 But -- but when he would -- I when he

mean,
16 would run his hands up the inside of my
17 that required -- so I would just move

thigh,
1 8 h i s h a n d .
19 Q. So, Ms. Godfrey-Ryan, as you're
20 testifying today, just keep in mind that the
21 court reporter can only take down words, so
22 if you make gestures, it's hard for her to
23 take that down. So make sure you describe
24 to the best of your ability if you're making
25 a gesture what that gesture is.
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1 Godfrey-Ryan
2 A. Yes. I've done a dozen podcasts
3 over the last month for -- for for

my Tune,
4 my work, and I get that comment a lot.
5 They'll be like no one can see what you're
6 doing, you have to use your words. I'm
7 like, I'm sorry.
8 Q. It just helps us to have a clean
9 t r a n s c r i p t .
10 A. Yeah, sorry.
11 Q. Did you ever kiss Mr. Rose back?
12 A. No.
13 Q. Did you ever expose yourself to
1 4 M r . R o s e ?
15 A. No.
16 Q. Was Mr. Rose's conduct that
17 you've just described, did that happen
1 8 o f t e n ?
19 A. Um-hum. Yes, all the time.
20 Q. Did Mr. Rose ever engage in
21 verbal conduct that you felt was sexually
22 inappropriate?
24 the question.
25 A. Only like a handful of times in
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1 Godfrey-Ryan
2 person would he speak sexually towards me.
3 But on the phone, very often, but only very
4 late at night. Like it wouldn't be -- like
5 he wouldn't call the office or talk to me in
6 the middle the day that way. It would have
7 to be -- he would call late at night.

very
8 Q. Could you give me some examples
9 of what Mr. Rose did?
10 A. With that?
11 Q. Yes.
12 A. Yeah, he would call late, and it
13 would always start off with some question
14 about something with work, and then he would
15 ask is there -- do I have someone next to
16 me, what am I doing with them, are they
17 me. And would not -- would not

touching I I
18 respond and respond with like work.
19 Once he called and like
20 explained -- he explained like this very
21 detailed fantasy he had of me. Yeah, this
22 happened not infrequently, like not every
23 week, but maybe at least two or three times
2 4 a mon th .
25 Q. What was the fantasy he
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1 Godfrey-Ryan
2 explained to you?
3 A. It was of me swimming in his
4 pool naked and him watching me swim in his
5 p o o 1 .
6 Q. Was this a phone call?
7 A. That was a phone call, yeah.
8 There was never -- he was never like that
9 descriptive or verbally sexual if I was
10 physical, if I was right in front of him.
11 Q. Were these phone calls often?
12 A. Yeah, I think that's often. I
13 felt often, but not like every day. It
14 wouldn't be every day. And then in the
15 morning, it would be like nothing happened.
16 Q. Did Mr. Rose ever berate you?
17 A. Yes.
19 the question.
20 Q. Can you give me examples of what
21 Mr. Rose did?
22 A. He would call me like
23 incompetent and worthless.
24 MR. BACH: Incompetent and what?
25 MS. FLIEGEL: Incompetent and
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1 Godfrey-Ryan
2 worthless.
3 A. Worthless.
4 He would -- in he
fairness,
5 didn't just do this to me, but he did it to
6 me more than others. But, yeah, when
7 Charlie would be upset, he would like, yeah,
8 just tear me apart.
9 Q. Did he raise his voice?
10 A. Yes, yes.
11 Q. Did he act this way in front of
1 2 t h e s t a f f ?
13 A. Yeah, yeah.
14 Q. Did you speak to Yvette Vega
15 about Mr. Rose's conduct?
16 A. Yes, of course. I spoke to
1 7 e v e r y o n e .
18 Q. I would like to focus on Yvette
19 Vega if we could.
20 Tell me what you recall about
21 speaking to Yvette Vega about Mr. Rose's
22 c o n du c t .
23 A. It was on the first week, my
24 first week working for him. It was kind of
25 an insane week because the first day I
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1 Godfrey-Ryan
2 worked for him, he broke his ankle, and
3 there was this whole thing around it, and he
4 required a lot of care.
5 But at the end of the first
6 week, I spoke to her about it because he was
7 and I -- I talked to her about

very sexual,
8 what I experienced. And she just said,
"It's just Charlie Charlie" and

9 yeah, being
10 that essentially that I should ignore it and
11 it's fine.
12 So we did have a few more
13 conversations. Like it would --

obviously,
14 it came up a few times, and like if she saw
15 me crying or there was like something, like,
16 so big, that she thought I couldn't take
17 care of my work, we would talk about it
18 again, but yeah.
19 Q. Did anyone else in the office
20 convey the message "that's Charlie being
21 Charlie"?
22 A. Everybody in the office did,
23 yeah. I spoke about this stuff all the
24 time, obviously, and they would see it. So
25 everyone was just -- so this is how it was.
VeritextLegalSolutions
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EXHIBIT 12
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COUNTY OF NEW YORK
----------------------------------x
Plaintiffs,
: AFFIDAVIT OF JOANA MATTHIAS
- against -
Defendants. :
-______--------------------------- X
STATE OF NEW YORK )

: ss.:
COUNTY OF NEW YORK )
JOANA MATTHIAS, being duly sworn, deposes and says:
1. I am an adult female, residing in Freeland, Washington.
2. I make this affidavit voluntarily, knowing that it will be used in connection with
the above-captioned lawsuit.
3. In or about the mid 1970s, and for less than one year, I was employed by NBC as
a research assistant at the NBC News Bureau in Washington, D.C.
4. At that time, I was known as Joana M. Johnston, I was in my 20s, and I was
single. I am now married to Steven Matthias and my legal name is now Joana Matthias.
5. During my employment with NBC, I met Charlie Rose ("Rose").
6. Rose worked in the same office as me, as a political correspondent for NBC.
7. At that time, Rose was in his 30s and he was married to Mary Rose.
8. Shortly after I was hired, Rose invited me to his home for a dinner party.
9. I attended the dinner party with my then boyfriend.
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10. During the dinner party, Rose leered at me in a sexual manner.
11. Rose's wife, clearly aware of his sexual conduct, cried during the dinner party.
12. After the dinner party, and over a period of months, Rose repeatedly approached
me while I was working at NBC and he repeatedly sexually harassed me, examples of which are
set forth below.
13. For example, while I was working in the offices of NBC, Rose exposed his penis
to me, Rose repeatedly touched my breasts, and Rose touched other parts of my body.
14. Rose repeatedly touched me in an unwelcome, offensive and inappropriate
manner. He looked for opportunities to touch me.
15. Rose's conduct was unwelcome, offensive and inappropriate.
16. I made it clear to Rose that his conduct was unwelcome, offensive and
inappropriate. However, Rose continued to engage in such conduct towards me.
17. In or about 2012-2013, after I met Steven Matthias, I told Mr. Matthias about my
background, including Rose's sexual harassment of me during my employment with NBC.
Dated: September 18, 2019

By: AOn g . t2ÝÝ oA
Joana Matthias
Sworn to before me
this 18th day of September, 2019
Notary Public
KENNETH A. GOLDBERG
Notary Public, State of New Ybut
Registration No. 0200506167T
Qualified in New York County
Cognmission Expires July 27, 2022
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COUNTY OF NEW YORK
---------------------------------- x
Plaintiffs,
: AFFIDAVIT OF MOLLY BROUGHTON
- against - PETER
:
Defendants. :
---------------------------------- x
STATE OF MARYLAND )
: ss.:
COUNTY OF MONTGOMERY )
MOLLY BROUGHTON PETER, being duly sworn, deposes and says:
1. I am an adult female, residing in Bethesda, Maryland.
2. I make this affidavit voluntarily, knowing that it will be used in connection with
the above-captioned lawsuit.
3. In or about the late 1970s to the early 1980s, when I was in my mid 20s, I was
employed by Post-Newsweek Productions (the "Cossspassy") in Washington, D.C.
4. During that employment, I met Charlie Rose ("Rose") and worked with him,
initially as an assistant and later as an associate producer on a show entitled The Charlie Rose
Show.
5. During my employment, Rose repeatedly engaged in acts of physical and verbal
sexual harassment against me, examples of which are set forth below.
6. Rose repeatedly touched me in an unwelcome, offensive and inappropriate
maññêr. Rose did so at least once a week and often multiple times each week. He looked for
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opportunities to touch me.
9. When Rose was standing near me, he would often wrap his arm around my waist
and he would place his hand so high up on my body as to touch or be very close to my breast.
10. Rose repeatedly pulled me onto his lap, even in meetings with other staff.
restaurants, including among others, The Palm restaurant in Washington, D.C.
12. Rose repeatedly hugged and kissed me, often after dining at a restaurant or when
he left the office for a business trip or vacation. He would grab both my shoulders, pull me close
to him, and plant a wet kiss on my cheek, close to my lips.
14. On multiple occasions, Rose undressed in front of me, removing his dress shirt
and exposing his naked upper body (he did not wear an under shirt).
undressed in front of me.
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16. Rose repeatedly asked me about my boyfriends.
17. Rose required me to come to his home, supposedly for work matters. On multiple
occasions, while I was in Rose's home, he emerged from the bathroom wearing nothing more
than a towel.
18. At some point in the early 1980s, The Charlie Rose Show was cancelled and I was
laid off.
19. Prior to my separation from the Company, I complained to Joel Chaseman, then
Chief Executive Officer of the Post-Newsweek Stations, about Rose's sexual harassment.
character"
20. Chaseman replied with words to the effect of, "he's a and "boys will be
boys."
21. Prior to my separation from the Company, I complained to Rose about his sexual
harassment.
22. Rose replied with open hostility and he threatened my career. He said words to
work" again."
the effect of, "don't look any further for TV and "you'll never work in television
23. After my separation from the Company, I left the media industry. By contrast,
Rose became anchor of CBS News Nightwatch and his career in media continued for decades.
Dated: September /f, 2019
o y Brou ton Peter

Sworn to before me
this/fth d of September, 2019
/Notary Public
KATHLEENL. HYNDMAN
NOTARYPUBLIC
MONTGOMERYCOUNTY
MARYLAND
MY Couy gem EXPIRES 3
SEPTEMBER16,2022
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EXHIBIT 13
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Secret of Charlie Rose | by Reah Bravo | NYR Daily | The Ne...
The Open https://www.nyboob-c:r'±i'y/2018/05/04/the-open-secret-of-charlie-rose
INDEX NO. 154172/2018
FILED: NEW YORK COUNTY CLERK 01/06/2020 09:07 PM
The Open Secret of Charlie Rose

Reah Bravo
Roy Rochlin/Getty Images

Charlie Rose attending a media function in New York City on November 1, 2017; three weeks later CBS and PBS cut their ties with the TV
host after a number of women went public with accusations against him of sexual harassment and misconduct at work
Of all my assignments for Charlie Rose, the one that came with the oddest sense of happiness
was when he asked that I unclog the toilet in the master bedroom of his Bellport home. It was
brimming with feces and had left the upstairs smelling like a factory farm. My yellow dish
gloves were flimsy and it was impossible to move the plunger without excrement slopping
from the bowl. But I confidently reassured myself, "No man would ask this of a woman with
sex."
whom he wanted to have
It was the summer of 2007, and as an intern at Rose's PBS show I was learning about the
man's narcissism, temper, and licentiousness. I was at his Bellport estate because he had hired
me to organize and alphabetize his library-two floors of an entire guesthouse cluttered with
books. The work left my arms sore and my neck stiff, but it paid well. Rose's executive
producer had also been encouraging after sensing that I found this opportunity, as initially
presented to me by Rose, dubiously incongruous with the work I was or wanted to be doing at
the show. One-on-one time with the boss was essential to becoming part of the team, she told
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me. She cannot have been innocent of what that involved.
From Catherine Deneuve to Andrew Sullivan, many have expressed concern that amid the
#MeToo movement's fervor we are not accurately accounting for how significantly the
actions and circumstances of accused men have varied. Clearly, they don't all deserve the
same predatory label? Or complete career banishment? I certainly don't believe so. Nor do I
know of any woman who thinks so. But I do believe that Charlie Rose's case falls toward the
worse end of the spectrum. His misdeeds were systematic and they were enabled at the
highest of levels.
The Washington Post's further revelations about Rose's behavior and the failure of CBS
managers to heed the warnings they received from women like me are of little surprise. (I was
among the women interviewed for The Post's earlier reporting on Rose's conduct, which
resulted in the cancelation of his PBS show and his being fired by CBS last year. Rose
apologized for his behavior in response to the original Post story; this week, he called the new
report "unfair and inaccurate.") I would expect CBS executives to have known. The man's
secret was as reliably open as a Waffle House. During my time working for Rose, there were
many who indicated knowledge of his treatment of women. I heard Upper East Side
salesclerks gossiping about it; professors in my graduate program discussed it more or less
explicitly; one of the show's regular guests gave two of my female colleagues a wink and a
thinly-veiled hint about his behavior by way of warning.
When you're young and ambitious, such open secrets can feel more like a helpful heads-up
than an insidious normalization of abuse. I was a minister's daughter from New Mexico
whose résumé most prominently featured Amnesty International and high-school forensics
coaching, so I came to the show naive about the inner workings of broadcast journalism.
When I first began witnessing questionable behavior from Rose (such as his call to the office
summoning a new intern, the one who was a Southern beauty pageant queen, to his apartment
to help him "pick out a tie"), my takeaway was as much about the industry as it was about
him. I wasn't entirely wrong.
Broadcast news was founded on the trust and veneration of male icons, and as the media
landscape changed, many of us held on to such men wistfully. I certainly did-though, in my

time at the show, I heard things about other notable men in the industry. These stories weren't
on the same level as what we now know of Rose, but they still disappointed someone like me
who had once counted myself an admirer. It was Peter Jennings who, while covering the
Anita Hill hearings, acknowledged to viewers that the men in his office were receiving an
education. Not enough of a lesson, in hindsight.
Despite my darkening view of the tangled web of sex and power at work, I forged ahead with
the unpaid internship, determined to secure a job by the time I finished the master's program I
was (and I was hired as an associate producer). I was an older-than-

taking subsequently
average intern and was given research and writing assignments similar to those of a producer.
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The work was enjoyable and I was good at it. I also learned a lot from Rose's staff:
and were at the show for its and guests-

intelligent, funny, resourceful, they format, topics,
not for its host. And they succeeded by separating the man from the work they did on his
behalf. I was aspiring to do the same when I found myself in Bellport, quite literally, willing
to put up with his shit.
I would soon endure a great deal more. Not long after he told me to unclog his brimming
toilet, he asked me to join him in looking at the moonlight, clutching me from behind as I did.
He would call me late at night to berate me over the phone for my benighted background
report on Bill Clinton or Sergei Lavrov or whichever upcoming interview was causing him
anxiety, and he would call me at sunrise to tell me that he, breathing heavily, was thinking
about me. The man who had enthusiastically interviewed Gloria Steinem some ten times
would introduce me to his airport driver, not as someone who had helped prepare him for the
lucrative speaking engagement from which he was returning, but as a table dancer he'd
picked up the night before. He would get on top of me in an airplane, grope me in cars, and
emerge naked in my presence.
Why did I even once put up with it? Or as Daphne Merkin bluntly asked in The New York
agency?"
Times of the #MeToo movement: "What happened to women's I've turned over this
question in my mind so constantly in the last six months, I feel I could write a book on the
subject. But perhaps most significant-even more significant than my career aspirations and
my dependence on a paycheck-was that Rose's advances occurred in a professional
environment of madness, anxiety, and utter exhaustion. One can function in such an
atmosphere for only so long before ceasing to operate at one's best, most lucid self.
I was a highly educated woman with a strong support network, and I had been privy to the
open secret. Rose's lechery didn't sideswipe me; it swallowed me, slowly, and despite my
best efforts. The more I struggled to manage the situation, the deeper I sank. The only option
was to leave my job, with an immense sense of shame. Were I a better woman, I told myself, I
would have found a way to fight back. Instead, I had exhausted myself with pleasantries and
smiled attentively while doing my best to avoid finding myself alone with him.
With a decade's perspective and a better understanding of what it means to engage with a
outsized I can forgive myself. Even Charlie Rose's CBS This co-
dangerously ego, Morning
host Norah O'Donnell acknowledged that she would have felt uncomfortable talking to him
me,"
about his treatment of women. "I think he would've screamed at she recently told The
Hollywood Reporter. I know this fear well. In the weeks after I went on the record against
Rose, I would return home cautiously from running errands, approaching slowly to make sure
that he wasn't wrathfully waiting for me outside my front door.
This was a preposterous fear. I live in Brussels. But if there's one thing I knew about Charlie
Rose, it was that he did as he pleased, regardless of the irrationalities involved. Who was I to
rule out the possibility that he might take a transatlantic flight as his career imploded, even if
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it was just to scream at an old employee whose name he probably still can't pronounce?
Rose used to drive between his Manhattan and Heliport residences with an awkwardly large
TV hooked up on the passenger-side floor of his Mercedes, so that he could spend the
commute watching his own program. He laughed when I asked him about the safety of such
multitasking. But he scowled when I later questioned him on the appropriateness of our late-
night work dinners. He said that if I couldn't handle the hours, I wasn't up for the job. Every
producer at the show had frequent dinners with him, he lied.
He himself appeared to believe his lies, despite obvious evidence to the contrary. Either that
or the truth simply didn t matter. Dinners, meanwhile, rarely incorporated work. He would
talk mostly about himself, his accomplishments, and his admirers, occasionally pausing to cue
my validation. Staff meetings were often no different.
In 2018, this should sound and feel familiar. I spoke out against Charlie Rose because the
Trump presidency and Trump's open secrets made me more uncomfortable than did the idea
of going public about what had been my life's most deeply buried moments of shame. For
those who carry the scars of having worked for the Charlie Roses of the world, it has become
too apparent how such misconduct can be even intelligent and well-
only normalized, among
intentioned people, and even in the highest offices and most esteemed institutions in the
country.
As the new 8'ashington Post report notes, the allegations against Charlie Rose date back to
1976. After an illustrious-seeming, decades-long career moving among the most influential
figures of our time, Rose was brought down by the tenacious reporting of two young women,
Amy Brittain and Irin Carmon. Armed with little more than cold calls, they cultivated among
those to whom they spoke a level of comfort and confidence that would have made Charlie
Rose in his heyday envious. They exposed his open secret and everything the open secrecy
had enabled.
This essay has been updated to clarify that the author worked for PBS first as an intern and
then as an associate producer.
May 4, 2018, 8:21 am
RELATED
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Secret of Charlie Rose | by Reah Bravo |NYR The Ne... https://www.nybanks
FILED: NEW YORK COUNTY CLERK Daily |01/06/2020 09:07 cam/daily/2018/05/04/the-open-secret-of-charlie-rose
PM INDEX NO. 154172/2018
The Unsexv Truth About Harassiüent Kick Against the Pricks

Melissa Gira Grant Laura Kipnis
Charlie'
'Being
Laura Marsh
© 1963-2018 NYREV, Inc. All rights reserved.
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EXHIBIT 14
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Re: Katherine et al. v. Charlie Rose Inc., et al. - Index No....
FILED:Brooks
NEWHarris,YORK COUNTY CLERK 01/06/2020 09:07 https://mail.aol.corn/webmail-std/en-us/PrintMessage
PM INDEX NO. 154172/2018
From: kgldbrg (kgldbrgoaol.corn)
To: jbach (jbachoshapiroarato.corn); carato (caratooshapiroarato.corn); jwolf (jwolfoshapiroarato.corn)
Subject: Re: Katherine Brooks Harris, et al. v. Charlie Rose Inc., et al. - Index No. 154172/2018
Date: Fri, Sep 20, 2019 11:15 am
Attachments: 2019 9 20 Draft Confidentiality-Stipulation Sent to Counsel.docx (30K)
Attached is a proposed confidentiality agreement for your review, based on the draft sent to you in mid July 2019.
Kenneth A. Goldberg, Esq.

Goldberg 8 Fliegel LLP
(212) 983-1077 telephone
(212) 973-9577 facsimile
www.goldbergfliegel.corn
www.employmentlaw.nyc
kgldbrg Naol.corn
Confidentiality Note: This email is confidential and is intendedsolely

for the use of the addressees. This communication may contain legally
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1 of 1 12/29/2019, 12:00 PM

COUNTY OF NEW YORK
--------------------------------------X
Katherine Brooks Harris, et al. Index No .
154172/ 2018
Plaintiffs'
STIPULATION AND
-against-
ORDER FOR THE
PRODUCTION AND
Charlie Rose Inc. et al., EXCHANGE OF

CONFIDENTIAL
Defendants. INFORMATION
-------------------------------------X
This matter having come before the Court by stipulation of
Plaintiffs and Defendants, for entry of a protective order
pursuant to CPLR 3103(a), limiting the review, copying,
dissemination and filing of confidential and/or proprietary
documents and information to be produced by either party and
their respective counsel or by any non-party in the course of
discovery in this matter to the extent set forth below; and the
parties, by, between and among their respective counsel, having
stipulated and agreed to the terms set forth herein, and good
cause having been shown;
IT IS hereby ORDERED that:
1. This Stipulation is being entered into to facilitate
the production, exchange and discovery of documents and
information that the parties agree merit confidential treatment
"Documents"
(hereinafter the or "Testimony").
2. Either party may designate Documents produced, or
Testimony given, in connection with this action as
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"confidential,"
either by notation on the document, statement on
the record of the deposition, written advice to the respective
undersigned counsel for the parties hereto, or by other
appropriate means.
3. As used herein:
Information"
(a) "Confidential shall mean all Documents
and Testimony, and all information contained therein, to the
extent such Documents or Testimony contain business trade
secrets, private financial information, private medical/mental
Plaintiffs'
health information, mitigation efforts, or
confidential proprietary business information.
party"
(b) "Producing shall mean the parties to this
action and any third-parties producing "Confidential
Information"
in connection with depositions, document production
or otherwise, or the party asserting the confidentiality
privilege, as the case may be.
party"
(c) "Receiving shall mean the party to this action
Information"
and/or any non-party receiving "Confidential in
connection with depositions, document production or otherwise.
4. The Receiving party may, at any time, notify the
Producing party that the Receiving party does not concur in the
designation of a document or other material as Confidential
Information. If the Producing party does not agree to
declassify such document or material, the Producing party may
214 of 226
seek a conference with the Court, pending which the documents or
materials shall continue to be treated as Confidential
Information. In the event that the Producing party does not
seek a conference with the Court within five (5) days of the
request to declassify, the documents or materials shall no
longer be treated as Confidential Information.
5. Except with the prior written consent of the Producing
party or by Order of the Court, Confidential Information shall
not be furnished, shown or disclosed to any person or entity
except to:
a. the parties and personnel of plaintiff or defendant
actually engaged in assisting in the preparation of this
action for trial or other proceeding herein and who have
been advised of their obligations hereunder;
b. counsel for the parties to this action and their
associated attorneys, paralegals and other professional
personnel (including support staff) who are directly assisting
such counsel in the preparation of this action for trial or
other proceeding herein, are under the supervision or control of
such counsel, and who have been advised by such counsel of their
obligations hereunder;
c. expert witnesses or consultants retained by the
parties or their counsel to furnish technical or expert services
in connection with this action or to give testimony with respect
215 of 226
to the subject matter of this action at the trial of this action
or other proceeding herein; provided, however, that such
Confidential Information is furnished, shown or disclosed in
accordance with paragraph 7 hereof;
d. the Court and court personnel;
e. an officer before whom a deposition is taken,
including stenographic reporters and any necessary secretarial,
clerical or other personnel of such officer;
f. trial and deposition witnesses; and
g. any other person agreed to by the parties.
6. Confidential Information shall be utilized by the
Receiving party and its counsel only for purposes of this
litigation and for no other purposes.
7. Before any disclosure of Confidential Information is
made to an expert witness or consultant pursuant to paragraph
5(c) hereof, counsel for the Receiving party shall obtain the
expert's written agreement, in the form of Exhibit A attached
hereto, to comply with and be bound by its terms. Counsel for
the party obtaining the certificate shall supply a copy to
counsel for the other party at the time of the disclosure of the
information required to be disclosed by CPLR 3101(d), except
that any certificate signed by an expert or consultant who is
not expected to be called as a witness at trial is not required
to be supplied.
8. This Stipulation shall not preclude any party from
216 of 226
using Confidential Information during any hearing or trial in
this matter. Should the need arise for any of the parties to
disclose Confidential Information during any hearing or trial,
including through argument or the presentation of evidence, and
the parties cannot resolve between themselves any disputes over
the disclosure of Confidential Information, the parties may seek
a conference with the Court.
9. This Stipulation shall not preclude counsel for the
parties from using during any deposition in this action any
documents or information which have been designated as
Information"
"Confidential under the terms hereof.
10. A party may designate as Confidential Information
subject to this Stipulation any document, information, or
deposition testimony produced or given by any non-party to this
case, or any portion thereof. In the case of Documents,
designation shall be made by notifying all counsel in writing of
those documents which are to be stamped and treated as such at
any time up to fifteen (15) days after actual receipt of copies
of those documents by counsel for the party asserting the
confidentiality privilege. In the case of deposition Testimony,
designation shall be made by notifying all counsel in writing of
those portions which are to be stamped or otherwise treated as
such at any time up to fifteen (15) days after the transcript is
received by counsel for the party asserting the confidentiality
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privilege. Prior to the expiration of such fifteen (15) day
period (or until a designation is made by counsel, if such a
designation is made in a shorter period of time), all such
documents shall be treated as Confidential Information.
11. A Receiving Party who seeks to file with the Court
any deposition transcripts, exhibits, answers to
interrogatories, and other documents which have previously been
designated as comprising or containing Confidential Information,
and any pleading, brief or memorandum which reproduces,
paraphrases or discloses Confidential Information, shall provide
all other parties with reasonable advance notice of its
intentions; in the event the parties cannot resolve the issues,
the parties may seek a conference with the Court.
12. Any person receiving Confidential Information shall
not reveal or discuss such information to or with any person not
entitled to receive such information under the terms hereof.
13. Any document or information that may contain
Confidential Information that has been inadvertently produced
"confidential"
without identification as to its nature may be so
designated by the party asserting the confidentiality privilege
by written notice to the undersigned counsel for the Receiving
"confidential"
party identifying the document or information as
within a reasonable time following the discovery that the
document or information has been produced without such
designation. A party's inadvertent disclosure of material
218 of 226
previously designated as Confidential Information shall not
waive such designation.
14. Extracts and summaries of Confidential Information
shall also be treated as confidential in accordance with the
provisions of this Stipulation.
15. The production or disclosure of Confidential
Information shall in no way constitute a waiver of each party's
right to object to the production or disclosure of other
information in this action or in any other action.
16. This Stipulation is entered into without prejudice to
the right of either party to seek relief from, or modification
of, this Stipulation or any provisions thereof by properly
noticed motion to the Court or to challenge any designation of
confidentiality as inappropriate under the Civil Practice Law
and Rules or other applicable law.
17. This Stipulation shall continue to be binding after
the conclusion of this litigation except
(a) that there shall be no restriction on documents that
are used as exhibits in Court (unless such exhibits were filed
under seal as allowed by order of the Court); and
(b) that a party may seek the written permission of the
Producing party or further order of the Court with respect to
dissolution or modification of any the Stipulation. The
provisions of this Stipulation shall, absent prior written
consent of both parties, continue to be binding after the
219 of 226
conclusion of this action.
18. Nothing herein shall be deemed to waive any privilege
recognized by law, or shall be deemed an admission as to the
admissibility in evidence of any facts or documents revealed in
the course of disclosure.
19. Within sixty (60) days after the final termination of
this litigation by settlement or exhaustion of all appeals, all
Confidential Information produced or designated and all
reproductions thereof, shall be returned to the Producing Party
or shall be destroyed, at the option of the Producing Party. In
the event that any party chooses to destroy physical objects and
documents, such party shall certify in writing within sixty (60)
days of the final termination of this litigation that it has
undertaken its best efforts to destroy such physical objects and
documents, and that such physical objects and documents have
been destroyed to the best of its knowledge. Notwithstanding
anything to the contrary, counsel of record for the parties may
retain one copy of documents constituting work product, a copy
of pleadings, motion papers, discovery responses, deposition
transcripts and deposition and trial exhibits. This Stipulation
shall not be interpreted in a manner that would violate any
applicable cannons of ethics or codes of professional
responsibility. Nothing in this Stipulation shall prohibit or
interfere with the ability of counsel for any party, or of
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experts specially retained for this case, to represent any
individual, corporation, or other entity adverse to any party or
its affiliate(s) in connection with any other matters.
20. This Stipulation may be changed by further order of
this Court, and is without prejudice to the rights of a party to
move for relief from any of its provisions, or to seek or agree
to different or additional protection for any particular
material or information.
Attorneys for Plaintiff Attorneys for Defendant

By: By:
New York, New York New York, New York

Tel.: Tel.:
Dated: Dated:
SO ORDERED J.S.C.
221 of 226
EXHIBIT “A”

COUNTY OF NEW YORK: COMMERCIAL DIVISION
-------------------------------------- X
Katherine Books Harris, et al.

Plaintiffs, Index No.
AGREEMENT REGARDING
-against-
Charlie Rose Inc. et al., CONFIDENTIAL INFO.
Defendants.
------------------------------------- X
I, , state that:
1. My address is
2. My present employer is
3. My present occupation or job description is
4. I have received a copy of the Stipulation for the
Production and Exchange of CONFIDENTIAL INFORMATION (the
“Stipulation”) entered in the above-entitled action on
5. I have carefully read and understand the provisions of the
Stipulation.
6. I will comply with all of the provisions of the
Stipulation.
222 of 226
7. I will hold in confidence, will not disclose to anyone not
qualified under the Stipulation, and will use only for purposes
of this action, any Confidential Information that is disclosed
to me.
8. I will return all Confidential Information that comes into
my possession, and documents or things that I have prepared
relating thereto, to counsel for the party by whom I am employed
or retained, or to counsel from whom I received the Confidential
Information.
9. I hereby submit to the jurisdiction of this court for the
purpose of enforcement of the Stipulation in this action.
Dated:
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EXHIBIT 15
224 of 226
DEPOSITION QUESTIONS LISTED IN THE STATEMENT OF FACTS (“SOF”)

RELATING TO QUESTIONS/LINES OF QUESTIONING RAISED IN THE MOTION
SOF G
1. “Did you review any documents to prepare for this deposition?” (Tr. 13:4-5).
2. “I'm asking Mr. Rose, did you review on your own any documents to prepare yourself for
today.” (Tr. 13:11-16).
3. “It is our position that the documents reviewed for preparation of the deposition, those are
not privileged; we're not asking for discussions with your client” (Tr. 14:10-14).
SOF H
4. “Were there any particular stories that you recall hearing that you felt, okay, that one was
true?" (Tr. 219:3-5).
5. “If any of the women from the Washington Post articles come to trial and say you touched
them, are they lying?” (Tr. 270:20-22).
SOF I
6. “After, Mr. Rose, after reading the Washington Post article of November 20th of 2017,
‘Eight Women Say Charlie Rose Sexually Harassed Them with Nudity, Groping and
Lewd Calls,’ did you feel any remorse towards the women that were identified in that
article?” (Tr. 224:19-25).
SOF J
7. “When you read the article in the Washington Post, did you feel that you had engaged in
any inappropriate conduct towards any of the women referenced in the Washington Post
article?” (Tr. 228:4-8).
8. “As to the allegations in the Washington Post, did you consider yourself to have
committed any act of sexual harassment?” (Tr. 227:9-12).
9. “Did Mr. Licht ever talk to you about a complaint he received about your conduct
towards a female employee?” (Tr. 230:2-4).
SOF K
10. “With whom did you have a romantic relationship?” (Tr. 75:13-14).
11. “Were any of the women in the Washington Post article, specifically Reah Bravo, Kyle
Godfrey-Ryan or Megan Creydt, women with whom you claim you had a romantic
relationship?” (Tr. 209:16-20).
12. “Mr. Rose, did you ever have a romantic relationship with any woman that worked for
you at the Bloomberg building, 731 Lexington?” (Tr. 77:14-17).
225 of 226
13. “Did you ever have a romantic relationship with any woman that worked with you at
CBS?” (Tr. 79:3-5).
14. “Who was that person?” (Tr. 81:24).
15. “Did you ever date her?” (Tr. 90:15).
SOF L
16. “Mr. Bach, if I want to ask these questions as to these individuals, will you let Mr. Rose
answer questions as to his conduct towards them” (Tr. 280:21-24).
SOF M
17. “One of those people is Reah Bravo, right?” (Tr. 107:17-18).
18. “She was an assistant, right?” (Tr. 259:15).
19. “Did you have her come to your apartment to watch the movie that she described in her
article?” (Tr. 233:21-23).
20. “Will you let him answer any questions about his conduct towards Sarah Gordon,
regarding Mr. Rose’s conduct towards Sarah Gordon?” (Tr. 234:2-5).
21. “Is Sarah Gordon a woman with whom you had a romantic relationship or intimate
relationship?” (Tr. 234:11-13).
22. “Mr. Bach, I want to ask questions about Chelsea Royal, will you allow your client to
answer those questions?” (Tr. 281:13-16).
23. “Did you know an Annmarie Parr?” (Tr. 284:4).
SOF N
24. “Mr. Rose, did you know a Joana Matthias?” (Tr. 282:22-23).
25. “Did you know a Molly Peter?” (Tr. 283:7).
26. “Mr. Rose, did you know a Beth Homan-Ross?” (Tr. 283:24-25).
SOF O
27. “Did you ever have any sort of intimate relationship with her?” (Tr. 130:6-7).
SOF P
28. “Did you find her to be attractive?” (Tr. 267:9-10).
SOF Q
29. “What did you say to Mr. Beattie and what did he say to you?” (Tr. 250:14-15).
226 of 226

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FILED: NEW YORK COUNTY CLERK 01/06/2020 09:07 PM INDEX NO.

SUPREME COURT OF THE STATE OF NEW YORK

Katherine Brooks Harris, Sydney McNeal and :

Yuqing ("Chelsea") Wei, Index No. 154172/2018

a/k/a Charlie Rose, :

I, KENNETH A. GOLDBERG, hereby affirm as follows:

1. I am counsel for Plaintiffs in the above-referenced matter. I make this affirmation

filed by Plaintiffs in this action (NYSCEF ## 63-65).

6. Attached hereto as Exhibit 5 is a true and correct copy of a Washington Post

7. Attached hereto as Exhibit 6 is a true and correct copy of a document produced by

8. Attached hereto as Exhibit 7 is a true and correct copy of a document produced by

transcript (unsigned) of the October 28, 2019 deposition of Kyle Godfrey-Ryan.

with Bates Numbers P0059-P0063.

16. Attached hereto as Exhibit 15 is a list of deposition questions identified in

knowledge, information and belief.

Dated: New York, New York

By: /s/ Kenneth A. Goldberg

New York, New York 10022

Telephone: (212) 983-1077

Facsimile: (212) 973-9577

Attorneys for Plaintiffs

SUPREME COURT OF THE STATE OF NEW YORK

Yuqing ("Chelsea") Wei,

To The Above Named Defendant(s):

CBS News Communications Inc.

Charlie Rose Inc.

The basis of venue location of incident/occurrence which is New York County.

Dated: New York, New York

/s/ Kenneth A. Goldberg

Goldberg & Fliegel, LLP

Attorneys for Plaintiffs

SUPREME COURT OF THE STATE OF NEW YORK

Yuqing ("Chelsea") Wei,

NATURE OF THE ACTION

OVERVIEW OF THE NEW YORK CITY HUMAN RIGHTS LAW

broadest and most protective laws against discrimination in the nation.

3. Under the NYCHRL, "discrimination shall play no role in decisions relating to

denied, 13 N.Y.3d 702 (2009) (emphasis supplied).

6. The NYCHRL "shall be construed liberally for the accomplishment of the

federal and state civil rights laws).

8. Plaintiff Katherine Brooks Harris is an adult female residing in New York.

9. Plaintiff Sydney McNeal is an adult female residing in Texas.

and/or address in New York, New York.

JURISDICTION AND VENUE

New York and the City of New York.

limitation Section 503 of the C.P.L.R.

Minutes, 48 Hours, Face The Nation and other programs.

NY 10019 ("CBS Studios").

own talk show Charlie Rose.

Minutes and its spinoff 60 Minutes H.

Associate for CBS This Morning, at the CBS Studios.

to work in the CBS Studios during the morning hours.

and had talked to Ryan Kadro (Executive Producer) about her.

offered to Ms. Harris, to lure Ms. Harris to work for Rose.

45. Ms. Harris advised Mr. Kadro of Rose's offer.

Associate Producer for Rose.

Assistant, a position based in Manhattan.

CBS This Morning, at the CBS Studios.

position for interns and recent college graduates.

55. Ms. Wei performed well and was promoted.