At Makarem & Associates, we represent employees in a lot of harassment cases. The ones that stay with us are usually the ones where the person had the least room to say no.
That’s the case our firm filed in Los Angeles County Superior Court against Modu Management Group, Inc. and its president. According to the complaint, our client was told — in plain terms — that she would be fired if she didn’t accept her boss’s “offer of companionship.” She was newly hired. He owned the company. And the company was sponsoring her work visa.
This is what lawyers call quid pro quo harassment. This is what it looks like from the inside.
It Started as “Work”
Our client was hired in late 2023 as a data analyst. She was qualified, she performed well, and she was building a career. As part of her hiring, the company agreed to sponsor her immigration visa.
Shortly after she started, the complaint alleges, the company’s president began asking her to dinners at Los Angeles restaurants — framed as part of a restaurant management project. She thought one-on-one dinners with the owner were unusual, but she was new, she was ambitious, and the meetings were presented as work.
After the first dinner, she noticed he seemed romantically interested in her. She told him directly that she was not interested in a relationship.
That should have been the end of it.
The Escalation
It wasn’t. He invited her to golf outings with personal friends. During one of them, our client alleges, she noticed him taking photos and video up her skirt. She was stunned — and said nothing, because she was new and he owned the company.
From spring into summer of 2024, the complaint describes an escalating pattern: sexual comments, unwanted touching, expensive gifts, and late-night messages. At one dinner he kissed her on the cheek and put his hands on her waist. He told her he really liked her and didn’t know what to do about it. In his car, he kissed her repeatedly, put his tongue in her mouth, and touched her thighs. She describes feeling scared and paralyzed.
The text messages continued: asking what she was doing after work, asking what she planned to wear, telling her to wear more perfume so he could smell it, telling her he couldn’t sleep because he missed her, asking her to send him pictures of herself.
Our client’s response tells you a great deal about the position she was in. She didn’t report him. She sent herself a bouquet of flowers at the office and told him they were from her boyfriend — hoping that the appearance of a relationship would accomplish what her own refusals hadn’t.
The Threat
When she began declining the dinner invitations, the complaint alleges, he reminded her that she was “replaceable.”
Then, according to the complaint, he stopped hinting. He allegedly told her he would fire her if she did not accept his offer of companionship — that he was uncomfortable knowing she was seeing other men and would have to terminate her if she didn’t agree to be with him. He then made it concrete: there would be a round of layoffs at the company, and she would be among those let go if she didn’t accept.
That is the legal definition of quid pro quo harassment in a single sentence. Under California’s Fair Employment and Housing Act, it is unlawful to condition a job — or continued employment, or a promotion, or a raise — on submitting to sexual or romantic advances. An employee does not have to be fired, and does not have to give in, for the conduct to be unlawful. Conditioning a job on a sexual or romantic relationship is itself actionable harassment under FEHA.
“We Won’t Be Investigating the Owner”
By July 2024, the complaint alleges, our client was experiencing severe anxiety attacks, fear, and depression. She reported the harassment to the company’s human resources department in a written complaint detailing the unwanted touching and the messages.
According to the complaint, HR told her the company would not be investigating its own president.
It went further than refusal. In later meetings, a managing officer allegedly tried to talk her out of taking legal action — telling her she shouldn’t trust her lawyer, that she was being immature, and that things wouldn’t turn out the way she wanted.
We want to be direct about this, because it is a moment a lot of employees find themselves in: an employer telling you not to trust your own attorney is not advice. It is an employer with an obvious conflict of interest attempting to manage its own liability, using your fear as the lever.
Where the Case Stands
The complaint further alleges that our client was ultimately terminated, and that her sex was a substantial motivating reason for that termination.
Filed in the Superior Court of California for the County of Los Angeles against Modu Management Group, Inc. and its president individually, the complaint alleges sexual harassment in violation of FEHA, sex
discrimination in violation of FEHA, and failure to prevent harassment and discrimination in violation of FEHA. It seeks compensatory and punitive damages, and demands a jury trial.
The case is proceeding through the California courts, and we’ll share updates as it moves forward.
What This Case Can Teach Other California Employees
• Quid pro quo doesn’t require the threat to be carried out. If your job, hours, promotion, or continued employment is conditioned on a romantic or sexual relationship, that conduct is itself actionable under FEHA — you do not have to be fired first, and you do not have to give in.
• The harasser being the owner doesn’t protect the company — it exposes it. When the harasser is a supervisor or owner, California employers are generally strictly liable for the harassment; “we didn’t know” is not a defense to liability, though an employee’s unreasonable failure to use an available complaint procedure can limit damages.
• “HR won’t investigate the owner” is not the end of the road. It’s a fact that strengthens a failure-to-prevent claim. Your rights under FEHA do not depend on your employer’s willingness to enforce them.
• Immigration sponsorship is leverage, and the law knows it. FEHA protects employees regardless of immigration status. An employer cannot lawfully use a visa, a sponsorship, or a threat about either to extract compliance.
• Saying no indirectly is still saying no. Declining invitations, deflecting with a boyfriend, going quiet — these are survival strategies, not consent, and they do not mean the conduct was welcome.
• Don’t let your employer talk you out of talking to a lawyer. A consultation costs you nothing and commits you to nothing.
If someone at your job has tied your employment to a personal relationship — or you’re being pressured and aren’t sure what to call it — Makarem & Associates offers free, confidential consultations. Reach out. We’re here to listen, and to help.
This article is based on allegations made in a publicly filed legal complaint. The allegations described are not yet proven in court, and defendants are entitled to respond and defend themselves. Our client’s name has been withheld out of respect for her privacy. This article is for informational purposes only and does not constitute legal advice.
