(Aiding and Abetting in Violation of the NYSHRL)  (Individual and Class Action Claims)  (Against Defendants Thompson and Levien)  304.  Plaintiffs and the members of the Race Class, Age Class, and/or Gender Class  hereby repeat and re-allege each and every allegation in all of the preceding paragraphs as if  fully set forth herein.  305.  Defendants Thompson and Levien knowingly or recklessly aided and abetted the  unlawful employment practices, discrimination and retaliation against Plaintiffs and the members  of the Race Class, Age Class, and/or Gender Class in violation of the NYSHRL.  306.  As a direct and proximate result, Plaintiffs and the members of the Race Class,  Age Class, and/or Gender Class have suffered and continue to suffer monetary and/or economic  harm, including, but not limited to, loss of past income, future income, compensation and  benefits, for which they are entitled to an award of monetary damages and other relief.  307.  As a direct and proximate result, Plaintiffs and the members of the Race Class,  Age Class, and/or Gender Class have suffered, and continue to suffer, emotional distress for  which they are entitled to an award of monetary damages and other relief.  37.  The Times, on its website, states a goal of “having a staff as wide as it is deep,  broad in perspective, backgrounds and experiences . . . to capture the multitude of voices of  America and the world, with true fidelity.”     38.  Recently, diversity has been subverted at every turn throughout the organization,  and in particular on the business side in the Advertising division.     39.  In 2011, the Times terminated Janet Robinson as CEO.  She was replaced with  Defendant Mark Thompson, a candidate riddled with problems involving ethics scandals, poor  decision-making and a record of gender and age discrimination at the BBC.    40.  At the time, Mr. Thompson was Director-General of the BBC, where he was  embroiled in a scandal that saw the media organization squash an important piece of  investigative journalism.  That piece would have revealed one of the network’s most well-known  former personalities, Jimmy Savile, to be a serial pedophile.   41.  In or around December 2011, the BBC’s show “Newsnight” was going to run the  story when the piece was suddenly cancelled.  Incredibly, around the same time, the BBC ran  numerous tributes to Mr. Savile and his contributions to the network.   42.  When the cancellation of the program became known, in or around October 2012,  all eyes looked to Mr. Thompson to determine whether he had played a role.     44.  As a result, Mr. Thompson changed his story, acknowledging that he was told  about an investigation, but maintained his lack of awareness of any details involving sexual  abuse.  However, this version of events was then undone by the surfacing of an audio recording  in which he admitted awareness that the investigation involved “sexual abuse of some kind.”   45.  In fact, it became known that Mr. Thompson was so sensitive to his alleged  involvement becoming public that he had his lawyers send a letter to the BBC threatening to sue  the network if any stories regarding his involvement in the suppression were released.   46.  Mr. Thompson’s inconsistent statements led the then-New York Times’s Public  Editor, Margaret Sullivan, to question his appointment to the CEO helm. Ms. Sullivan stated that  Defendant Thompson’s:   “integrity and decision-making are bound to affect the Times  and its journalism – profoundly.  It’s worth considering now  whether he is the right person for the job, given this turn of  events.”    47.  New York Times columnist Joe Nocera questioned the Mr. Thompson hire in his  own column, saying:   “Thompson winds up appearing willfully ignorant, and it makes  you wonder . . . what kind of leader he was. It also makes you  wonder what kind of chief executive he’d be at The Times.”    48.  In hiring Mr. Thompson, the New York Times either willfully ignored or  completely dismissed that he had significant problems with gender and age discrimination while  at the BBC.     50.  In addition, in November 2008, four female BBC presenters of the show  “Countryfile,” Michaela Strachan, Charlotte Smith, Miriam O’Reilly and Juliet Morris, were all  dismissed from the program while male hosts John Craven and Adam Henson were kept on.   51.  Miriam O'Reilly, one of the terminated “Countryfile” presenters, claimed she was  “warned about wrinkles,” and she filed an age discrimination suit and won a payout against the  98.  Ms. Grant began her employment at the Times as an Account Manager.     I.  Plaintiff Ernestine Grant  