SneerClub

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Between the end of 2002 and beginning of 2003, Dawn distanced herself from Singer. (Complaint, ¶ 44.) In May 2003, Singer asked Dawn to work with him on a piece he had been asked to write for the Los Angeles Times, for which she would receive co-writing credit. (Id. at ¶ 45.) From 2002 through 2020, all of Singer's female co-authors were women with whom Singer had been sexually involved, or to whom he had made clear his sexual interest. (Id. at ¶¶ 46, 47.) Despite a pattern of professional reward for sexual affection, Singer wrote to Dawn that he believed he could only be accused of anything if an angry ex "made something up" or "had a false memory." (Id. at ¶ 49.) Dawn came to understand that she too would be rewarded for maintaining an affectionate relationship with Singer, with offers of prestigious work, and would lose those offers without such expressions of warmth. (Id. at ¶ 50.)

Dawn and Singer became sexually involved again when working on the Los Angeles Times op-ed together, with Dawn agreeing to be part of Singer's "harem" as long as "she was his favorite, the lead in his orchestra, as he called it." (Complaint, ¶ 52.) Dawn wondered if she should be trying to have a child with her partner and was reminded by Singer that if she did, it would negatively affect her figure and would interfere with their affair. (Id. at ¶ 53.) In 2003, Singer told Dawn that while he still wished to be sexually involved with her, she had been replaced as the main recipient of his affections by a woman he had met at a conference in Europe and who was 10 years younger than Dawn and who was married. (Id. at ¶¶ 54-56.) Singer acknowledged the "high risk" that the affair would destroy the woman's marriage. (Id. at ¶ 57.) Dawn wrote numerous emails to Singer making it clear that she was emotionally shattered by the turn of events. (Id. at ¶ 59.)

Feeling old compared to her younger replacement, Dawn had a facelift in 2004, at the age of 41. (Complaint, ¶ 70.) Her face became infected, and she was ill for weeks. (Id. at ¶ 71.) Dawn shared news of the long-term affair with her partner, now a partner of four years. (Id. at ¶ 74.) The relationship was strained beyond repair and plans for marriage between Dawn and her partner were put on hold. (Id. at ¶¶ 75, 76.) Before learning about the affair between

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