Pages 43-45. LOL.
234. During Ms. Dunphy’s work for Defendants, Giuliani often made outrageous comments that created and added to the hostile work environment that Ms. Dunphy was forced to endure. Ms. Dunphy found these comments revolting, but there was little she could do to stop them given the lack of any Human Resources personnel and the extraordinary degree of control that Giuliani had wielded over her as her boss and lawyer.
235. For example, Giuliani made the comments described below, many of which were recorded:
a. Giuliani made derogatory comments about Jewish men and implied that their penises were inferior due to “natural selection.”
b. Giuliani told Ms. Dunphy that “black guys hit women more than anybody else does... and so do Hispanic guys – it is in their culture.”
c. Giuliani said, “Jews want to go through their freaking Passover all the time, man oh man. Get over the Passover. It was like 3,000 years ago. The red sea parted, big deal. It’s not the first time that happened.”
d. Giuliani made comments about “freakin Arabs” and Jews.
e. Giuliani demeaned and sexualized Hillary Clinton and mocked her body.
f. Giuliani demeaned and sexualized Margaret Thatcher and wondered about the effect she would have on his penis.
g. Giuliani said, “If my life depended on it, if I had to make love to Nancy Pelosi, I couldn’t do it. I’d have to die.”
h. Giuliani referred to employee Vanessa Ryan, who is Maria Ryan’s daughter, as “fat” and said that he felt bad for her because she was fat. He further said he was “trying not to feed” her.
i. Giuliani disparaged a female lawyer because of her breast size.
j. Giuliani made a series of derogatory remarks about the LGBTQ community, including:
i. Giuliani claimed that Mayor Michael Bloomberg “became gay” because his wife left him.
ii. Giuliani named a prominent Republican as gay.
iii. Giuliani used the word “fag” to refer to actor Matt Damon.
iv. Giuliani mocked Senator Elizabeth Warren as “in search of a gender,” stating: “Pocahontas was a really hot babe, and Warren does not look like a babe. She looks like a person in search of a gender.” Giuliani later said he was “very hot” for Warren.
v. Giuliani named a prominent lawyer who he believed would require $10 million for gay sex. Giuliani then insisted that he was the only one of his male friends who would turn down any amount of money to have sex with a man.
k. Giuliani said to Ms. Dunphy, at various times, in statements that were recorded:
i. “I’m gonna make it a little painful.”
ii. “Stick it up your ass.”
iii. “You’re a fucking slut.”
iv. You’re my bitch.
v. “I’m gonna get my cock in there.”
vi. “Be a slut! Be Rudy’s slut!”
vii. Giuliani called Ms. Dunphy a “whore.”
viii. Giuliani said, “I want to own you officially. Legally. With a document.”
ix. “I can’t control myself. I lose control. I think of you all the time. I’m unable to control it. I’m addicted.”
x. “I can’t think about you without getting hard. Even when I think about how smart you are, I get hard.”
xi. Giuliani stated that he would “get in trouble with underage girls” if they were 16 but looked 20.
xii. “I think of you as my daughter. Is that weird?”—which Giuliani
said while engaging in sexual contact with Ms. Dunphy.
xiii. Giuliani told Ms. Dunphy that she was “his” and he had purportedly “been too easy on [her].”
236. These statements are just some examples of the inappropriate comments that Giuliani made to Ms. Dunphy while she worked for Defendants. There are many others. These types of comments made Ms. Dunphy extremely uncomfortable and contributed to a hostile work environment.
237. Giuliani’s constant fear of the FBI also contributed to inappropriate
