The 38-page complaint, available at The Huffington Post, catalogues a vast array of racist, sexist, and generally bad behavior by Post staff--far beyond the cartoon originally connected with Guzman's dismissal.

For example:

"On one occasion when Ms. Guzman and three female employees of the Post were sharing drinks at an after-work function. Defendant [editor in chief Col] Allan approached the group of women, pulled out his blackberry and asked them 'What do you think of this?' On his blackberry was a picture of a naked man lewdly and openly displaying his penis."

And:

When she would walk by certain offices at the paper, Guzman alleges, editors would routinely sing songs from West Side Story -- a nod to her Hispanic heritage -- including the tune: "I want to live in America."

And:

"A White male senior editor sexually propositioned a young female Copy Assistant, telling her that 'If you give me a blowjob, I will give you a permanent reporter job.'"

And, for what it's worth:

"Charles Hurt, the Post's Washington D.C. Bureau Chief and a high ranking journalist at the newspaper, [told Guzman] that the Post's 'goal is to destroy Barack Obama. We don't want him to succeed.'"