In it, she says "upon information and belief" former CEO Neil Portnow's contract was not renewed because a recording artist claimed he raped her.

Recording Academy president/CEO Deborah Dugan filed a discrimination complaint with the Equal Employment Opportunity Commission (EEOC) on Tuesday (Jan. 21), after she was placed on administrative leave on Jan. 16 amid allegations of workplace bullying.

According to her complaint, Dugan sent an email to the Academy’s managing director Shonda Grant on Dec. 22 detailing sexual harassment, “egregious conflicts of interest, improper self-dealing by Board members and voting irregularities with respect to nominations for Grammy Awards.” She said the behavior was made possible by the organization's "boys’ club mentality and approach."

In that memo, Dugan claims that she has been subjected to sexual harassment by Joel Katz, the Academy’s outside general counsel and a former member and chair (1995-97) of the Academy’s board of trustees. She says she was also asked by current chair of the board John Poppo to rehire former Academy CEO Neil Portnow as a consultant at a $750,000 annual salary and that although she has been asked to take over Portnow’s position, she was being paid substantially less than her two male predecessors.

“The complaint that we filed today against the National Academy of Recording Arts and Sciences (the Grammys) highlights tactics reminiscent of those deployed by individuals defending Harvey Weinstein," said attorneys Douglas H. Wigdor and Michael J. Willemin, in a statement. "As we allege, the attempt by the Recording Academy to impugn the character of Deborah Dugan is a transparent effort to shift the focus away from its own unlawful activity. This blatant form of retaliation in corporate America is all too common, even post #MeToo, and we will utilize all lawful means necessary to ensure that those responsible are held accountable for their actions.”

Wigdor is currently representing a Jane Doe who will testify in the criminal trial against Harvey Weinstein. According to Wigdor, his client will testify that she was raped by Weinstein in 2005.

Dugan also claims "upon information and belief" the real reason Portnow's contract was not renewed was because a foreign female recording artist (and a member of the Academy) claimed he had raped her following a performance that she gave at Carnegie Hall. This information, the complaint states, had been withheld from Dugan by the Recording Academy Board until after Dugan agreed to take on the CEO position.

Regarding Katz, Dugan says in May 2019 she discovered “exorbitant improper expenditures” and was “sexually harassed” by Joel Katz. Among the fees the nonprofit pays out to Katz is $250,000 annually solely for travel and expenses to be on-call in the event the board needs any legal advice. In addition, Dugan says Katz’s firm billed the board more than $15 million for legal work for a period of a few years. Katz and his firm are also paid “hefty sums on a transactional basis,” according to her complaint.

Dugan also cites millions of dollars were paid to Proskauer Rose firm and its former partner Chuck Ortner for legal fees. Both Katz and Ortner are currently on the Grammy Museum board. The involvement of Katz and Ortner represent conflicts of interests, Dugan claims, noting the two attorneys also represent individual board members. Dugan’s complaint states that Katz represents interim CEO Mason, but believes he does it for free.

“As a result, Mr. Katz and Mr. Ortner are in unique and conflicted positions to curry unwarranted favor from the Board (in exchange for personal legal services),” says Dugan’s complaint. “They also are in unique and conflicted positions to influence Academy decision making (including award nominations) to favor their clients outside of the Academy.”

Dugan complaint also alleges that Katz sexually harassed her before she even began her work at the Academy. The alleged incident occurred in May 2019 when she was invited to attend the first day of the three-day meeting of the Academy’s Board at the Ritz Carlton in Laguna Niguel, according to her complaint.

On May 18, 2019, she says he contacted her and requested that she have dinner with him alone. This confused her but she agreed to “not upset the applecart.” At the dinner, Dugan claims, Katz ordered a very expensive bottle of wine and called her “baby” and told her multiple times that she was “very pretty.” He also told her about his failed marriage and that he was “lonely” and had “no one to spend time with.”

Katz continued, the complaint alleges, to tell Dugan that he was “very very rich,” had many homes around the world and even had a private plane. He allegedly suggested the two of them should “spend time together” and said that “traveling to my many homes could be something nice for us to share.” Dugan says that even though she made it clear she was not interested and was in a committed relationship, that Katz “leaned in and attempted to kiss” her at the end of the night.

“Ms. Dugan quickly turned away, repulsed,” the complaint states.

According to Dugan’s complaint, Katz continued to act inappropriately towards her following, calling her pretty and referring to her as “baby.”

Portnow has not responded to Billboard's request for comment.

Late Tuesday, Katz's lawyer, Howard Weitzman, issued a statement "categorically and emphatically" denying Dugan's version of events.

"This dinner meeting was 2½ months before Ms. Dugan started her job," Weitzman said in a written statement. "Mr. Katz believed they had a productive and professional meeting in a restaurant where a number of members of the Board of Trustees of the Academy, and others, were dining."

Katz's lawyer added, "Ms. Dugan's claims are made, for the first time, 7 months after this dinner took place. Mr. Katz will cooperate in any and all investigations or lawsuits by telling the absolute and whole truth. Hopefully Ms. Dugan will do the same."

Three weeks after Dugan says she sent her complaint to HR, on Jan. 16, 2020, she was placed on administrative leave. “The decision to put Ms. Dugan on leave was clearly made in retaliation for her complaint, and come with thinly veiled threats of termination in the event that Ms. Dugan persisted in pursuing claims against the Academy,” reads Dugan’s EEOC complaint.

Dugan claims when she was placed on leave that Harry Mason Jr., chair of the board and current interim president/CEO, told her he would tell people that she had “taken a leave of absence.” However, subsequently, she says, the board leaked to the press another story -- that she had been placed on administrative leave “in light of concerns raised by the Recording Academy board of trustees, including a formal allegation of misconduct by a senior female member of the Recording Academy team,” as public statement from the organization read on Jan. 16.

According to Dugan that statement was “false and defamatory” and made in retaliation for her HR complaint, accusing Mason of leaking a “false, retaliatory and defamatory letter designed to get out in front” to destroy her reputation.

Dugan says when she left the Academy on Jan. 16 she had reached an agreement “in principle” to resolve her legal claims. Subsequently, she says the Academy “backed out” and instead made her a “unacceptable offer of settlement,” giving her only one hour to decide whether to accept the Academy’s proposal.

According to her complaint, Dugan was only put on leave after she raised her complaints of sexual harassment and improprieties and indicated her intent to bring legal action. Dugan says the concerns against her made by Portnow’s executive assistant -- understood to be director of administration Claudine Little -- had been raised a month before she was actually put on leave.

In response, the Recording Academy said in a statement to Billboard: “It is curious that Ms. Dugan never raised these grave allegations until a week after legal claims were made against her personally by a female employee who alleged Ms. Dugan had created a ‘toxic and intolerable’ work environment and engaged in ‘abusive and bullying conduct’. When Ms. Dugan did raise her “concerns” to HR, she specifically instructed HR “not to take any action” in response.

“Nonetheless, we immediately launched independent investigations to review both Ms. Dugan’s potential misconduct and her subsequent allegations. Both of these investigations remain ongoing. Ms. Dugan was placed on administrative leave only after offering to step down and demanding $22 million from the Academy, which is a not-for-profit organization. Our loyalty will always be to the 25,000 members of the recording industry. We regret that Music’s Biggest Night is being stolen from them by Ms. Dugan's actions and we are working to resolve the matter as quickly as possible.”

Wigdor and Willemin responded to the Academy’s statement, calling the assertion that Dugan only raised concerns after complaints were made against her “completely false.”

“Ms. Dugan repeatedly raised concerns throughout her entire tenure at the Academy, and even gave large presentations focused on diversity and inclusion at Board meetings,” the statement continued. “In addition, it is not just Ms. Dugan who has raised concerns. As alleged in the charge, artists, other board members and employees have all raised virtually all of the concerns raised by Ms. Dugan. As alleged, the Academy has lost its way and abandoned the recording industry, instead focusing on self-dealing and turning blind eye to the “boys’ club” environment, obvious improprieties and conflicts of interest.

“It was never Ms. Dugan’s intention to turn this into a public fight precisely because of her love for music and the members of the recording industry. Unfortunately, staying silent was made impossible by the Board’s repeated leaks and disclosures of false and misleading information to the press.

“Finally, as alleged in the charge, on the morning of the day she was put on leave, the Academy offered Ms. Dugan millions of dollars to drop all of this and leave the Academy. The Board Chair demanded an answer within the hour. When Ms. Dugan refused to accept and walk away, she was put on leave. The Academy claimed that Ms. Dugan was put on leave based on accusations made against her over a month prior that the Board knows very well are meritless. That is not a credible story.”

In her complaint, Dugan says the Academy -- and Mason specifically -- is continuing to defame her by telling people, including John Legend’s manager Ty Stiklorius, that she attempted to extort $22 million from the Academy.

“This is flat out false, but Mr. Mason is intent on fully destroying Ms. Dugan, a strong woman who was willing to ‘step up’ to combat rampant discrimination and improprieties at the Academy,” reads Dugan’s complaint.

“The damage that the Academy has done to Ms. Dugan is immeasurable and can never be remedied,” it continues. “However, Ms. Dugan will do everything in her power to hold the Academy and the Board responsible for the unlawful conduct.”

1/22: This article has been updated to include a statement from Katz's attorney.