Case 1:24-cv-10840-LTS Document 6 Filed 04/09/24 Page 1 of 16
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`
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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MASSACHUSETTS
`
`MARGARET CURTIN,
`
`Plaintiff,
`
`v.
`
`CAMBRIDGE HEALTH ALLIANCE,
`
`Defendant.
`
`Civil Action No. 1:24-cv-10840-LTS
`
`DEFENDANT CAMBRIDGE HEALTH ALLIANCE’S ANSWER TO PLAINTIFF
`MARGARET CURTIN’S FIRST AMENDED COMPLAINT
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`For its answers and defenses to the Complaint and Jury Demand of plaintiff Margaret
`
`Curtin (“Plaintiff”), defendant Cambridge Health Alliance (“Defendant” or “CHA”) states as set
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`forth herein. Answers to each paragraph of the Complaint are made without waiving, but expressly
`
`reserving, all rights that CHA may have to seek relief by appropriate motions directed to the
`
`allegations of the Complaint.
`
`INTRODUCTION
`
`1.
`
`Defendant is without sufficient information or knowledge to confirm or deny whether
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`Plaintiff is a “practicing Christian” and whether she is a “Board Certified Family Medicine Nurse
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`Practitioner.” Defendant admits that Plaintiff is seeking damages against CHA but denies that
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`Plaintiff is entitled to any such relief.
`
`I. PARTIES
`
`2.
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`Defendant is without sufficient information or knowledge to confirm or deny Plaintiff’s
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`age at the time her employment with CHA ended. Defendant admits that Plaintiff was employed
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`by CHA as a Family Nurse Practitioner for a little over twenty eight years. CHA is without
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`
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`
`
`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MASSACHUSETTS
`
`MARGARET CURTIN,
`
`Plaintiff,
`
`v.
`
`CAMBRIDGE HEALTH ALLIANCE,
`
`Defendant.
`
`Civil Action No. 1:24-cv-10840-LTS
`
`DEFENDANT CAMBRIDGE HEALTH ALLIANCE’S ANSWER TO PLAINTIFF
`MARGARET CURTIN’S FIRST AMENDED COMPLAINT
`
`For its answers and defenses to the Complaint and Jury Demand of plaintiff Margaret
`
`Curtin (“Plaintiff”), defendant Cambridge Health Alliance (“Defendant” or “CHA”) states as set
`
`forth herein. Answers to each paragraph of the Complaint are made without waiving, but expressly
`
`reserving, all rights that CHA may have to seek relief by appropriate motions directed to the
`
`allegations of the Complaint.
`
`INTRODUCTION
`
`1.
`
`Defendant is without sufficient information or knowledge to confirm or deny whether
`
`Plaintiff is a “practicing Christian” and whether she is a “Board Certified Family Medicine Nurse
`
`Practitioner.” Defendant admits that Plaintiff is seeking damages against CHA but denies that
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`Plaintiff is entitled to any such relief.
`
`I. PARTIES
`
`2.
`
`Defendant is without sufficient information or knowledge to confirm or deny Plaintiff’s
`
`age at the time her employment with CHA ended. Defendant admits that Plaintiff was employed
`
`by CHA as a Family Nurse Practitioner for a little over twenty eight years. CHA is without
`
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`
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`Case 1:24-cv-10840-LTS Document 6 Filed 04/09/24 Page 2 of 16
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`sufficient information or knowledge to confirm or deny whether Plaintiff is “board certified.”
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`Defendant denies the remaining allegations in Paragraph 2.
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`3.
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`Defendant admits that Plaintiff was employed by Cambridge Health Alliance and worked
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`at CHA’s East Cambridge Health Center.
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`4.
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`Defendant admits that one of CHA’s hospital campuses is located at 1493 Cambridge
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`Street, Cambridge, MA 02139.
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`5.
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`6.
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`Admitted.
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`Defendant states that the allegations in Paragraph 6 are vague and ambiguous and are
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`therefore not susceptible to a response. To the extent a response is required, Defendant denies the
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`allegations in Paragraph 6 to the extent it characterizes a written document, the contents of which
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`speak for itself.
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`7.
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`Defendant states that the allegations in Paragraph 7 are vague and ambiguous and are
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`therefore not susceptible to a response. To the extent a response is required, Defendant denies the
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`allegations in Paragraph 7 to the extent it characterizes a written document, the contents of which
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`speak for itself.
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`8.
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`9.
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`Denied.
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`Defendant states that Paragraph 9 states a legal conclusion to which no response is required.
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`To the extent that a response is required, Defendant denies Plaintiff’s characterization of its
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`corporate structure, but admits that CHA is an employer with more than 15 employees.
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`10.
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`Denied.
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`- 2 -
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`Case 1:24-cv-10840-LTS Document 6 Filed 04/09/24 Page 3 of 16
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`11.
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`Denied.
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`II. MASSACHUSSETTS COMMISSION AGAINST DISCRIMINATION
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`(“MCAD”) CHARGE
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`12.
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`Defendant admits that Plaintiff filed a charge with the MCAD. Defendant is without
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`sufficient information or knowledge to confirm or deny whether the MCAD “then notified” the
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`EEOC.
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`13.
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`Defendant is without sufficient information or knowledge to confirm or deny whether the
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`EEOC issued Plaintiff with a “Right-to-Sue” notice.
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`14.
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`Defendant states that Paragraph 14 states a legal conclusion to which no response is
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`required. To the extent a response is required, Defendant is without sufficient information or
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`knowledge to confirm or deny the precise timeframe in which Plaintiff brought her lawsuit or
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`whether “all preconditions for filing this lawsuit have been performed or occurred.”
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`III. FACTS
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`15.
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` Defendant is without sufficient information or knowledge to confirm or deny Plaintiff’s
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`age at the time her employment with CHA ended. Defendant admits that Plaintiff was employed
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`by CHA for approximately twenty-eight years. Defendant denies the remaining allegations in
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`Paragraph 15.
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`16.
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`Denied.
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`17.
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`Defendant states that Paragraph 17 states a legal conclusion to which no response is
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`required. To the extent a response is required, Defendant denies Plaintiff’s characterization of
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`federal and Massachusetts law, the contents of which speak for itself.
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`- 3 -
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`Case 1:24-cv-10840-LTS Document 6 Filed 04/09/24 Page 4 of 16
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`18.
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`Defendant denies Plaintiff’s characterization of former Massachusetts Governor Charles
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`Baker’s decisions regarding the COVID-19 pandemic, and the results of such decisions.
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`19.
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`Defendant admits that it implemented a COVID-19 vaccination policy that required
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`employees to receive a COVID-19 vaccine. Defendant denies Plaintiff’s characterization of this
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`policy, the contents of which speak for itself.
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`20.
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`Defendant states that the allegations in Paragraph 20 are not susceptible to admission or
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`denial because they are vague and ambiguous as written. To the extent a response is required,
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`Defendant denies Plaintiff’s characterization of former Governor Baker’s decisions regarding the
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`COVID-19 pandemic and CHA’s COVID-19 vaccination policy.
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`21.
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`Defendant states that the allegations in Paragraph 21 are not susceptible to admission or
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`denial because they are vague and ambiguous as to the meaning of “Religious Exemption and
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`Accommodation.” To the extent a response is required, Defendant admits that Plaintiff applied
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`for a religious accommodation on September 20, 2021.
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`22.
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`Defendant states that the allegations in Paragraph 22 are not susceptible to admission or
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`denial because they are vague and ambiguous as to the meaning of “protocol” and “Religious
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`Exemption and Accommodation.” To the extent a response is required, Defendant admits that
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`Plaintiff applied for a religious accommodation.
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`23.
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`Defendant states that the allegations in Paragraph 23 are not susceptible to admission or
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`denial because they are vague and ambiguous as to the meaning of “her request” and “Religious
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`Exemption and Accommodation.” To the extent a response is required, Defendant denies
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`- 4 -
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`Case 1:24-cv-10840-LTS Document 6 Filed 04/09/24 Page 5 of 16
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`Plaintiff’s characterization of her religious accommodation request, the contents of which speaks
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`for itself.
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`24.
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`Defendant states that the allegations in Paragraph 24 are not susceptible to admission or
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`denial because they are based on a quotation from an unidentified document that has not been
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`made available by Plaintiff as an attachment to the First Amended Complaint. To the extent a
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`response is required, Defendant denies Plaintiff’s characterization of her religious accommodation
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`request, the contents of which speaks for itself.
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`25.
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`Defendant states that the allegations in Paragraph 25 are not susceptible to admission or
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`denial because they are based on a quotation from an unidentified document that has not been
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`made available by Plaintiff as an attachment to the First Amended Complaint. To the extent a
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`response is required, Defendant denies Plaintiff’s characterization of her religious accommodation
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`request, the contents of which speaks for itself.
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`26.
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`Defendant states that the allegations in Paragraph 26 are not susceptible to admission or
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`denial because they are based on a quotation from an unidentified document that has not been
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`made available by Plaintiff as an attachment to the First Amended Complaint. To the extent a
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`response is required, Defendant denies Plaintiff’s characterization of her religious accommodation
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`request, the contents of which speaks for itself.
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`27.
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`Defendant states that the allegations in Paragraph 27 are not susceptible to admission or
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`denial because they are vague and ambiguous as to the meaning of “Religious Exemption and
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`Accommodation” and are based on a quotation from an unidentified document that has not been
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`made available by Plaintiff as an attachment to the First Amended Complaint. To the extent a
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`- 5 -
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`Case 1:24-cv-10840-LTS Document 6 Filed 04/09/24 Page 6 of 16
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`response is required, Defendant denies Plaintiff’s characterization of her religious accommodation
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`request, the contents of which speaks for itself.
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`28.
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`Defendant admits that Plaintiff submitted a letter from a priest but is without sufficient
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`information or knowledge to admit or deny whether the letter was from her “Parish Priest.”
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`Defendant denies the remaining allegations in Paragraph 28.
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`29.
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`Defendant states that the allegations in Paragraph 29 are not susceptible to admission or
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`denial because they are vague and ambiguous as to the meaning of “Administrators” and “hearing.”
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`To the extent a response is required, Defendant is without sufficient information or knowledge to
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`confirm or deny the allegations in Paragraph 29.
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`30.
`
`Denied.
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`31.
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`Defendant is without sufficient information or knowledge to confirm or deny Plaintiff’s
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`beliefs. Defendant denies the remaining allegations in Paragraph 31.
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`32.
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`Defendant states that the allegations in Paragraph 32 are not susceptible to admission or
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`denial because they are vague and ambiguous as to the meaning of “Religious Exemption and
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`Accommodation.” To the extent a response is required, Defendant admits that CHA sent Plaintiff
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`a letter to inform her that her religious accommodation request was denied, but denies Plaintiff’s
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`characterization of this letter, the contents of which speaks for itself.
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`33.
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`Defendant is without sufficient information or knowledge to confirm or deny Plaintiff’s
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`feelings and denies the remainder of Paragraph 33.
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`- 6 -
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`Case 1:24-cv-10840-LTS Document 6 Filed 04/09/24 Page 7 of 16
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`34.
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`Defendant states that the allegations in Paragraph 34 are not susceptible to admission or
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`denial because they are vague and ambiguous as to the identity of the “Medical Director”
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`referenced therein. To the extent a response is required, Defendant denies that CHA
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`“premature[ly] post[ed] […] her job online.” Defendant is without sufficient information or
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`knowledge to confirm or deny the remaining allegations in Paragraph 34.
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`35.
`
`Denied.
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`36.
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`Defendant is without sufficient information or knowledge to confirm or deny whether
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`Plaintiff was “one month shy of being able to secure another five percent increase in her retirement
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`benefits in perpetuity.” Defendant denies the remaining allegations in Paragraph 36.
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`37.
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`Defendant is without sufficient information or knowledge to confirm or deny whether
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`Plaintiff “was the family’s primary wage earner.” Defendant denies the remaining allegations in
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`Paragraph 37.
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`38.
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`Defendant states that the allegations in Paragraph 34 are not susceptible to admission or
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`denial because they are vague and ambiguous as to the meaning of “Hobson’s Choice” and as to
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`the source of the text quoted therein. To the extent a response is required, Defendant denies the
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`allegations in Paragraph 38.
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`39.
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`Defendant is without sufficient information or knowledge to confirm or deny what Plaintiff
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`believed and whether Plaintiff was “traumatized.”
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`40.
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`Denied.
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`- 7 -
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`Case 1:24-cv-10840-LTS Document 6 Filed 04/09/24 Page 8 of 16
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`41.
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`Defendant states that the allegations in Paragraph 41 are not susceptible to admission or
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`denial because they are vague and ambiguous as to the meaning of “service,” “greatly benefited,”
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`“keep its doors open” and “serving . . . as it was tasked to do.” To the extent a response is required,
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`Defendant is without sufficient information or knowledge to confirm or deny whether, how or to
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`what magnitude Plaintiff’s “service . . . benefitted” CHA.
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`42.
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`Denied.
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`43.
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`Defendant is without sufficient information or knowledge to confirm or deny what Plaintiff
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`did with her “retirement monies” and whether Plaintiff was “one month short of receiving a full-
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`year’s credit in perpetuity for her retirement.” Defendant denies the remaining allegations in
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`Paragraph 43.
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`44.
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`Defendant is without sufficient information or knowledge to confirm or deny whether
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`Plaintiff was “unable to secure a job for over fourteen (14) months” and whether she experienced
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`harm and stress. Defendant denies the remaining allegations in Paragraph 44.
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`45.
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`Defendant is without sufficient information or knowledge to confirm or deny whether
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`Plaintiff “volunteered to continue working with accommodations” but admits Plaintiff discussed
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`her religious accommodation request with Defendant. Defendant denies the remaining allegations
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`in Paragraph 45.
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`46.
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`Defendant states that the allegations in Paragraph 46 are not susceptible to admission or
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`denial because they are vague and ambiguous as to when the alleged “offe[r]” was made and the
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`source of the text quoted therein and as to the meaning of “the same means.” Further, Defendant
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`is without sufficient information or knowledge to form a belief as to whether the allegations are
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`- 8 -
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`Case 1:24-cv-10840-LTS Document 6 Filed 04/09/24 Page 9 of 16
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`“ironic” and whether Plaintiff “worked successfully.” Defendant denies the remaining allegations
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`in Paragraph 46.
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`47.
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`Defendant states that the allegations in Paragraph 46 are not susceptible to admission or
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`denial because they are vague and ambiguous as to the meaning of “older,” “seasoned,”
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`“dedicated,” “higher-paid,” “long-term,” and “loyal.” To the extent a response is required,
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`Defendant is without sufficient information or knowledge to confirm or deny Plaintiff’s “plans”
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`and whether Plaintiff was an “older, seasoned, dedicated, higher-paid, long-term, and loyal
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`employee.”
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`48.
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`Denied.
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`49.
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`Defendant is without sufficient information or knowledge to confirm or deny Plaintiff’s
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`personal feelings about her “work at CHA” that are described in Paragraph 49.
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`50.
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`Denied.
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`51.
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`Defendant is without sufficient information or knowledge to confirm or deny whether
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`Plaintiff was or is “devastated” And the extent to which she “suffered damages.” Defendant
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`denies the remaining allegations in Paragraph 51.
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`Defendant denies the allegations contained in unnumbered paragraph: THE COVID-19
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`VACCINES ARE NOT EFFECTIVE AT STOPPING THE SPREAD OF THE DISEASE
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`52.
`
`Defendant states that the allegations in Paragraph 52 are not susceptible to admission or
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`denial because they are vague and ambiguous as to the “announcement” referenced and what
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`became “immediately clear.” To the extent a response is required, Defendant denies the
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`allegations in Paragraph 52.
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`- 9 -
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`Case 1:24-cv-10840-LTS Document 6 Filed 04/09/24 Page 10 of 16
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`53.
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`Defendant is without sufficient information or knowledge to confirm or deny the precise
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`dates on which various “visible persons” announced that they became “infected by COVID-19,”
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`and whether this was “despite having been injected with a COVID-19 vaccine.” Defendant denies
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`that the allegations in Paragraph 53 “illustrat[e] by example” the allegations in Paragraph 53.
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`54.
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`Defendant is without sufficient information or knowledge to confirm or deny the quoted
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`statements Plaintiff alleges were made by the “Public Health Officials” at unidentified places and
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`times stated in subparagraphs a. and b. of Paragraph 54. Defendant denies the remaining
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`allegations in Paragraph 54.
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`55.
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`Defendant denies Plaintiff’s characterization of the CDC’s guidance “as of August 2020,”
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`the contents of which speak for itself.
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`56.
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`Defendant is without sufficient information or knowledge to confirm or deny Plaintiff’s
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`representations about the “majority of people now hospitalized for COVID-19.”
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`57.
`
`Denied.
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`58.
`
`Denied.
`
`59.
`
`Denied.
`
`60.
`
`Denied.
`
`61.
`
`Denied.
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`- 10 -
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`Case 1:24-cv-10840-LTS Document 6 Filed 04/09/24 Page 11 of 16
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`CLAIM FOR RELIEF
`
`COUNT I
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`VIOLATION OF M.G.L. 151B, AGE AND RELIGIOUS DISCRIMINATION AND
`VIOLATIONS OF TITLE VII
`
`62.
`
`Defendant restates its responses to Paragraphs 1 through 61 as if fully stated herein.
`
`63.
`
`Defendant is without sufficient information or knowledge to confirm or deny whether
`
`Plaintiff was “specific” or “honest” and whether she conveyed her “sincerely held religious
`
`beliefs” to Defendant.
`
`64.
`
`Defendant states that Paragraph 64 states a legal conclusion to which no response is
`
`required. To the extent a response is required, Defendant denies the allegations in Paragraph 64.
`
`65.
`
`Defendant states that Paragraph 65 states a legal conclusion to which no response is
`
`required. To the extent a response is required, Defendant denies the allegations in Paragraph 65.
`
`66.
`
`Defendant states that Paragraph 66 states a legal conclusion to which no response is
`
`required. To the extent a response is required, Defendant is without sufficient information or
`
`knowledge to confirm or deny whether “at all relevant times” Plaintiff was “protected against
`
`discrimination due to her age and religious beliefs.”
`
`67.
`
`Defendant denies Plaintiff’s characterization of the definition of “discrimination,” the
`
`meaning of which is defined by state and federal law.
`
`68.
`
`Defendant denies Plaintiff’s characterization of the description of age discrimination, a
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`concept which is defined by state and federal law.
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`- 11 -
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`Case 1:24-cv-10840-LTS Document 6 Filed 04/09/24 Page 12 of 16
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`69.
`
`Defendant is without sufficient information or knowledge to confirm or deny Plaintiff’s
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`age at the time her employment at CHA ended. Defendant denies the remaining allegations in
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`Paragraph 69.
`
`70.
`
`Denied.
`
`71.
`
`Denied.
`
`72.
`
`Denied.
`
`73.
`
`Denied.
`
`74.
`
`Denied.
`
`Defendant denies that Plaintiff is entitled to the relief requested in the unnumbered
`
`paragraph following Paragraph 74 that introduces Plaintiff’s specific prayers for damages, and
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`denies that Plaintiff is entitled to any of the relief in Paragraphs A through F.
`
`
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`
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`AFFIRMATIVE DEFENSES
`
`FIRST AFFIRMATIVE DEFENSE
`
`Plaintiff fails to state a claim upon which relief can be granted.
`
`SECOND AFFIRMATIVE DEFENSE
`
`To the extent the claims of the Plaintiff are based on alleged actions that occurred outside
`
`the applicable statutes of limitations, such claims are barred.
`
`THIRD AFFIRMATIVE DEFENSE
`
`To the extent that Plaintiff mitigated, minimized or avoided any damages allegedly
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`- 12 -
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`Case 1:24-cv-10840-LTS Document 6 Filed 04/09/24 Page 13 of 16
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`sustained, any damages against Defendant must be reduced by that amount. In addition, to the
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`extent that Plaintiff failed to make reasonable efforts to mitigate, minimize or avoid any damages
`
`allegedly sustained, any damages against Defendant must be barred.
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`FOURTH AFFIRMATIVE DEFENSE
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`Plaintiff’s claims, in whole or in part, are barred because she failed to exercise reasonable
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`diligence in mitigating her alleged damages.
`
`FIFTH AFFIRMATIVE DEFENSE
`
`Defendant, at all times relevant to this action, acted in good faith and in full compliance
`
`with all applicable laws and duties.
`
`SIXTH AFFIRMATIVE DEFENSE
`
`Defendant, at all times relevant to this action, acted with proper motives and means, and in
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`accordance with business necessity.
`
`SEVENTH AFFIRMATIVE DEFENSE
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`Defendant has not engaged in any discriminatory activity or employment practice.
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`EIGHTH AFFIRMATIVE DEFENSE
`
`Defendant has not engaged in any conduct justifying damages under Title VII of the Civil
`
`Rights Act of 1964, 42 U.S.C. § 2000e, et seq.
`
`NINTH AFFIRMATIVE DEFENSE
`
`Defendant has not engaged in any conduct justifying damages under The Age
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`Discrimination Act of 1975, 42 U.S.C. Sections 6101-6107, and is subject to Defendant’s Partial
`
`Motion to Dismiss.
`
`TENTH AFFIRMATIVE DEFENSE
`
`Defendant has not engaged in any conduct justifying damages under Mass. Gen. Laws Ch.
`
`151B §4.
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`- 13 -
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`Case 1:24-cv-10840-LTS Document 6 Filed 04/09/24 Page 14 of 16
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`ELEVENTH AFFIRMATIVE DEFENSE
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`Defendant has not engaged in any willful or wanton activity or conduct justifying an award
`
`of punitive damages.
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`TWELFTH AFFIRMATIVE DEFENSE
`
`Plaintiff’s claims are barred by the doctrine of unclean hands and equitable estoppel.
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`THIRTEENTH AFFIRMATIVE DEFENSE
`
`Plaintiff’s claims, in whole or in part, are barred because she has failed to exhaust her
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`administrative remedies.
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`FOURTEENTH AFFIRMATIVE DEFENSE
`
`Plaintiff has not suffered any monetary or equitable damages.
`
`FIFTEENTH AFFIRMATIVE DEFENSE
`
`Plaintiff has failed to quantify any damages allegedly suffered as a result of any conduct
`
`by Defendant.
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`SIXTEENTH AFFIRMATIVE DEFENSE
`
`
`Plaintiff is not entitled to attorneys’ fees, costs and/or interest.
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`- 14 -
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`Case 1:24-cv-10840-LTS Document 6 Filed 04/09/24 Page 15 of 16
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`Dated: April 9, 2024
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`
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`Respectfully submitted,
`
`CAMBRIDGE HEALTH ALLIANCE
`
`By Its Attorneys,
`
`/s/ Alexa M. Esposito
`Asha A. Santos, Bar No. 670861
`asantos@littler.com
`Alexa M. Esposito, Bar No. 698378
`aesposito@littler.com
`
`LITTLER MENDELSON, P.C.
`One International Place
`Suite 2700
`Boston, MA 02110
`Telephone: 617.378.6000
`Facsimile:
`617.737.0052
`
`
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`- 15 -
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`Case 1:24-cv-10840-LTS Document 6 Filed 04/09/24 Page 16 of 16
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`CERTIFICATE OF SERVICE
`
`I, Alexa M. Esposito, hereby certify that on this 9th day of April 2024, the foregoing
`document was filed electronically through the ECF system, is available for viewing and
`downloading from the ECF system, will be sent electronically to counsel of record as registered
`participants identified on the Notice of Electronic Filing and via first class mail upon those non-
`registered participants.
`
`
`
`/s/ Alexa M. Esposito
`Alexa M. Esposito
`
`
`
`- 16 -
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`
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