Instead, the Fair Work complaint says Paterson was told there were three alleged workplace breaches that amounted to serious misconduct, including the failure to complete training modules, the handling of a contract extension of one of her direct reports, and an inappropriate remark made at a ratings party about Nine getting “rid of all the dickheads”, according to her lawyers.

“It’s the lamest excuse to terminate a senior manager I’ve ever seen, and it doesn’t come within a bull’s roar of serious misconduct,” Laxon said.

Nine is aware of the complaint and has chosen not to comment, a spokesperson told this masthead, and the matter is scheduled for mediation initially. Nine and Walsh’s lawyers at Maurice Blackburn also declined to comment on the separate case.

Laxon has represented several high-profile media figures and executives who have left commercial networks this year, including Seven’s Robert Ovadia and former Spotlight executive producer Mark Llewellyn.

Nine and Dear are listed as respondents to Paterson’s claim, this masthead was told.

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Dear gave no explanation for Paterson’s departure in an email to staff. She was one of the first major exits after the publication of the workplace culture review in October, sparked by the departure of Dear’s predecessor, Darren Wick, earlier this year.

Wick was subject to historical complaints relating to his drunken lecherous behaviour towards colleagues.

The extensive report from independent firm Intersection, while not featuring any names, revealed a culture of widespread bullying, abuses of power and sexual harassment across the 4000-person company, with a particular focus on the broadcast division.

Nine was subsequently criticised by staff for anonymising the report and initially for failing to take action to remove perceived bad actors. The company later said it was investigating a number of separate complaints made by staff in conjunction with the report.