Kathleen Cody worked for Copley Square Associates (“CSA”) for approximately seven months as an independent contractor, primarily as a real estate salesperson, before she was terminated. Despite the fact that she was not an employee, Cody filed an action, Cody v. Sutar , against CSA and four individual employees alleging that their gender- and age-based comments had created a hostile work environment. Cody claimed, in part, that the behavior violated ch. 214, § 1C. tht

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