Kevin Flanigan II of Avon, Ohio, an employee at 19 Action News, is the plaintiff and WOIO, Raycom Media, William Applegate, Deborah Pando are the defendants in a complaint filed in the Cuyahoga County Court of Common Pleas.
The complaint alleges that Deborah Pando (Ms. Pando) and other WOIO employees have provided sexual favors to clients in furtherance of attempting to secure their advertizement commitment with WOIO.
The complaint alleges that Deborah Pando (Ms. Pando) and others purchase, and consume cocaine during work hours, on the business premises and/or at corporate events.
The complaint by submitted by Andrew Kabat and Daniel Connell of Haber Polk, Kabat, LLP of Cleveland.
A copy of the complaint is available, for viewing and download, via an article by Eric Sandy of Cleveland Scene at http://www.scribd.com/doc/199425066/Lawsuit-Against-WOIO
Rachel Dissell of The Plain Dealer quotes William Applegate as saying that,
"the numerous offensive and erroneous allegations contained in this suit compels us to strongly deny them on behalf of the station and particularly our employees, viewers and clients. And yes, we certainly do intend to defend ourselves vigorously,"