Duncan Milner v. TBWA Worldwide, Inc.

I. FACTUAL BACKGROUND

Plaintiff has been employed by the Entity Defendants since 1987, with a one-year hiatus in 1988. Dkt. 1-1 (Compl.) ¶ 9. Plaintiff’s employment was terminated in 2019; he was 61. See id. In around April 2015, Milner contacted Ruhanen about his disappointing yearly performance bonus, the stagnation of his base salary, and “no new stock grants since 2012.” Id. ¶ 12(e). A week later, Ruhanen told Plaintiff that his decreasing bonus was due to the “economics of the network and the agency.” Id. In around late 2016, Plaintiff was informed that he was being replaced by Brent Anderson, who was significantly younger than Plaintiff. Id. ¶ 12(f). In around 2017, Plaintiff was demoted to the Media Arts Lab\For Good agency, where his total annual compensation was cut in half and the number of employees reporting to him decreased from 40 to 50 to only six. See id. ¶ 12(g). Plaintiff was also moved to a less desirable office space and was no longer invited to exclusive marketing events or quarterly global creative meetings. See id. ¶ 12(j). The creative directors who were invited to such meetings were substantially younger than Plaintiff. Id. Between…