throbber
Case 2:22-cv-00690 Document 1 Filed 02/07/22 Page 1 of 17 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF NEW YORK
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`MONIQUE GREENIDGE,
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`Plaintiff,
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`Civil Action: ____________________
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`COMPLAINT
`AND JURY DEMAND
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`MOUNT SINAI HOSPITAL SOUTH
`NASSAU, SUHAS KAVTHEKAR,
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`JINCY THOMAS, and
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`WILSON DAVILA,
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`Defendants.
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`I.
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`JURISDICTION AND VENUE
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`
`Monique Greenidge, by her attorneys, The Cochran Firm, as and for her
`Complaint and Jury Demand, brings this cause of action against Mount Sinai South
`Nassau (Mt Sinai), Plaintiff’s current employer, Suhas Kavthekar, Jincy Thomas, and
`Wilson Davila (collectively, “Defendants”), alleging discrimination on the basis of her
`race in violation of Title VII of the Civil Rights Act of 1964 as amended by the Civil
`Rights Act of 1991 and in violation of New York State law and the Administrative Code
`of the City of New York. Plaintiff further seeks redress for injuries suffered as a result
`of Defendants’ retaliation against her for complaining about the unlawful
`discriminatory practices of Defendants.
`
`

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`II.
`
`PARTIES
`
`This Court has jurisdiction over the subject matter of the instant
`1.
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`Complaint pursuant to 28 U.S.C. § 1331 because the Plaintiff brings an action arising
`under the laws of the United States. The Court has jurisdiction over Plaintiff’s claims
`arising under State and local laws because they arise from the same set of facts
`forming the basis of Plaintiff’s federal claims.
`
`2.
`Venue is proper in this District pursuant to 42 U.S.C. § 2000e-5(f)(3)
`and 28 U.S.C. § 1391 because the unlawful discriminatory practices were committed
`and the employment records were maintained, in whole or in part, at Mt Sinai South,
`located at One Healthy Way, Oceanside, New York, which is in this District.
`3.
`At all times relevant hereto, Plaintiff, Monique Greenidge (“Plaintiff” or
`“Ms. Greenidge’) resided at 671 Leonard Avenue, Uniondale NY 11553.
`4.
`At all times relevant hereto, Defendant Mt Sinai Hospital South Nassau
`is a hospital in Nassau County, New York.
`5.
`At all times relevant hereto, Defendant Suhas Kavethekar was and
`continues to be employed by Mt. Sinai South as the Chief Technologist at Mt. Sinai
`South. 6. At all times relevant hereto, Defendant Jincy Thomas was and continues to
`be employed by Mt. Sinai South as the Lead Nuclear Medicine Technician.
`7. At all times relevant hereto, Defendant Wilson Davila was and continues to
`be employed by Mt. Sinai South as the Director of Radiology.
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`2
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`III.
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`PROCEDURAL REQUIREMENTS
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`FACTUAL ALLEGATIONS
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`Plaintiff has exhausted all administrative remedies. Plaintiff timely
`8.
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`filed a formal complaint with the EEOC on March 23, 2021. The EEOC issued a right
`to sue letter, dated November 9, 2021.
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`9.
`The Plaintiff is an African American woman.
`10.
`Plaintiff has worked for over twenty years at Mt Sinai South Nassau.
`She began work as a Nuclear Medicine Technician in 2001 after she was hired by
`Clough Murray, Chief Technologist at the time.
`11. While working under Ms. Murray’s supervision, Ms. Greenidge thrived in
`her role and received all the resources and support necessary to succeed in her
`position. 12. With Ms. Murray as her supervisor, Ms. Greenidge consistently received
`stellar yearly evaluations. Her duties as a Nuclear Medicine Technician included, but
`were not limited to, coordinating, facilitating, and overseeing patient scanning,
`ensuring all the necessary supplies were timely ordered and in stock to provide
`optimal patient care, and maintaining all equipment.
`13. Ms. Greenidge’s work environment drastically changed in 2006 when Mt
`Sinai hired a new Chief Technologist, Defendant Kavthekar, an Indian American man.
`Immediately upon assuming this role, Mr. Kavthekar targeted Ms. Greenidge on
`account of her race, completely ignoring her proven track record of success and
`commitment to the patients of Mt. Sinai.
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`IV.
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`3
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`14. Mr. Kavthekar frequently berated Ms. Greenidge in front of her colleagues
`and patients, falsely accused her of wrongdoing and allowed her non-African
`American colleagues to harass her without reprimand or consequence.
`15. In September 2007 Mr. Kavthekar hired Bayhun Erpanir to join the team
`as a Nuclear Medicine Technologist and allowed him to join in on the public
`harassment and berating of Ms. Greenidge. Mr. Erpanir frequently slammed doors in
`Ms. Greenidge’s face, followed her around the office despite being her peer and not
`her supervisor, and spoke to her in a demeaning manner in front of colleagues and
`patients. Mr. Erpanir did not treat his non-African American peers this way.
`16. Unable to withstand Mr. Erpanir’ s hostile and discriminatory treatment,
`Ms. Greenidge lodged multiple complaints to Defendant Kavthekar regarding the
`discriminatory treatment. Defendant Kavthekar failed to take action. Non-African
`Americans were not treated in this manner.
`17. The hostile work environment Ms. Greenidge was subjected to heightened
`when Mr. Erpanir was discriminatorily promoted to Lead Nuclear Medicine
`Technician over a more qualified African American candidate. Fay Hamilton, an
`African American woman, and the most senior technician on the team, was denied
`this promotion due to her race. Ms. Hamilton was objectively more qualified for the
`position than Mr. Erpanir but was not promoted because of her race and the glass-
`ceiling at Mt Sinai which hinders African American employees from promotional
`growth. 18. In his new role, Mr. Erpanir continued to discriminate against Ms.
`Greenidge. For example, on or about October 21, 2016, while meeting with a patient,
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`4
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`Mr. Erpanir yelled at Ms. Greenidge in front of the patient, that she needed to stop
`speaking with the patient and instead work on analyzing the scan as she is unable to
`do both. This humiliated and embarrassed Ms. Greenidge in front of the patient. Mr.
`Erpanir did not publicly scold his non-African American direct reports.
`19. When Ms. Greenidge again complained to Defendant Kavthekar about the
`situation, Mr. Erpanir lied and denied making the remarks. Defendant Kavthekar
`failed to take any further action. The lack of action provided Mr. Erpanir with the
`greenlight to continue his discriminatory and retaliatory treatment of Ms. Greenidge.
`20. Immediately following Ms. Greenidge’s complaint to Defendant Kavthekar,
`Mr. Erpanir began to lodge bogus complaints regarding Ms. Greenidge’s work
`performance. For example, on December 18, 2017, Mr. Erpanir complained that Ms.
`Greenidge did not stay late to assist with a last-minute patient request. Ms. Greenidge
`on that occasion, was unable to stay beyond her scheduled time due to a previously
`scheduled appointment for her daughter. Nonetheless, Mr. Erpanir still lodged a
`complaint to Defendant Kavthekar.
`21. It became clear to Ms. Greenidge that Mr. Erpanir and Defendant Kavthekar
`were acting in concert to set Ms. Greenidge up for failure. As a result, on December
`20, 2017, Ms. Greenidge escalated her complaints to Defendant Wilson Davila,
`Director of Radiology. Defendant Davila immediately dismissed Ms. Greenidge’s
`complaint and stated that he did not want to hear any complaints of past conduct.
`Rather than properly investigate her complaints, Defendant Davila suggested that Mr.
`Erpanir and Ms. Greenidge strengthen their teamwork by working together to put
`away supplies. Defendant Davila assured Ms. Greenidge that he would set up a
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`5
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`meeting within the department to discuss teamwork but failed to follow through on
`this promise.
`23. On September 28, 2018, Ms. Greenidge complained to Defendant Davila
`after she heard Mr. Erpanir speaking negatively of her to doctors and other member
`of Mt. Sinai staff. Defendant Davila did not follow-up on this complaint
`24. The discrimination and retaliation against Ms. Greenidge by the
`Defendants continued into October 2018 when Ms. Greenidge applied and
`interviewed for a promotion to Senior Nuclear Technologist at Ms. Sinai. Despite
`being fully qualified for the position, Ms. Greenidge was discriminatorily denied the
`promotion. The position was initially posted internally, instead, the role was given to
`an outside candidate, Defendant Jincy Thomas, an Indian American woman. It was
`clear that Defendant Kavthekar had no intention of hiring an African American
`woman, similar to the previous discriminatory treatment of Ms. Hamilton.
`25. Ms. Greenidge was more qualified than Defendant Thomas for the role and
`had the requisite experience, including PET CT experience, as Ms. Greenidge had
`specialized training in cardiology and nuclear medicine, whereas Defendant Thomas
`did not. On December 8, 2018, when Defendant Davila informed Ms. Greenidge that
`she would not be promoted, Ms. Greenidge immediately complained that the decision
`was on account of her race. Ms. Greenidge further pointed out Mt. Sinai’s history of
`passing overqualified African American employees such as Ms. Hamilton. Defendant
`Davila again ignored these complaints.
`26. As a result of Defendant Thomas’ lack of experience, Ms. Greenidge spent
`a significant amount of time training Ms. Thomas on how to perform the testing
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`6
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`involved with General Nuclear Medicine. Defendant Mt. Sinai claimed that Defendant
`Thomas was selected over Ms. Greenidge due to her experience with PET CT although
`the Mt. Sinai South location did not have the ability to conduct PET CTs on site. As a
`result, Defendant Thomas frequently performed testing off site which left the
`department severely short staff, requiring Ms. Greenidge to cover for Defendant
`Thomas. 27. In December of 2018, upon Defendant Thomas assuming her role as Senior
`Nuclear Technologist, Defendant Thomas began to target Ms. Greenidge on account
`of her race. Defendant Thomas routinely yelled at Ms. Greenidge and spoke to her in
`a disparaging fashion whenever Ms. Greenidge engaged her on issues related to
`patient care. Defendant Thomas did not speak to non-African American team
`members in this manner.
`28. The discriminatory treatment of Ms. Greenidge by Defendants Kavthekar
`and Thomas continued into the following year. Ms. Greenidge attempted to focus
`solely on providing exceptional care to the patients at Mt. Sinai but was constantly
`criticized and berated by her supervisors. On May 24, 2019, Ms. Greenidge again went
`to Defendant Davila’s office to lodge a complaint against Defendant Thomas for
`berating her for calling the rapid response team on a patient with chest pain, a
`customary action for treating patients experiencing chest pain at Mt. Sinai. Rather
`than investigate her complaint, Defendant Davila dismissively suggested that
`Defendant Thomas and Ms. Greenidge go to lunch together. Non-African American
`employees were not constantly berated in front of patients or forced to go to lunch
`with their tormentors.
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`7
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`29. On October 4, 2019, Ms. Greenidge approached Defendant Thomas with a
`suggestion to improve their job function by proposing placing a sign on radioactive
`bags. Defendant Thomas offensively moved closer to Ms. Greenidge’s face and asked,
`“what did you say to me?” in a menacing and threatening tone.
`30. On October 17, 2019, Ms. Greenidge met with the Human Resources to
`discuss her interactions with Defendant Thomas. Ms. Greenidge complained about
`Defendant Thomas’ menacing behavior during the October 4th encounter. Rather than
`addressing her complaint during this meeting, Ms. Greenidge was gaslighted and
`asked if she greets Defendant Thomas by saying good morning when she arrives,
`again ignoring her complaints of discrimination and hostile work environment.
`31. On January 7, 2020, following her numerous complaints to Defendant
`Davila and Human Resources, Ms. Greenidge was given a retaliatory write up for
`working on two patients simultaneously. Working on two patients was a common
`custom among lab technicians at Mt. Sinai. Non-African American employees were
`not written up for this practice, including Defendant Thomas.
`32. Because of Mt. Sinai’s failure to act, Ms. Greenidge continued to be
`subjected to discrimination and a hostile work environment. On January 10, 2020,
`and again on January 28,2020 Ms. Greenidge complained to Mary Golden in the
`Human Resources department that she endured discriminatory treatment and
`retaliation on a daily basis because of her race and reiterated her prior complaints.
`Again, her complaints were ignored in direct violation of Mt. Sinai’s Anti-
`Discrimination Policy.
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`8
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`33. Over the next several months the Defendants’ discriminatory treatment of
`Ms. Greenidge continued unabated. For example, On May 26, 2020, Defendant
`Kavthekar demanded that Ms. Greenidge cover a late shift assigned to Defendant
`Thomas. 34. On June 21, 2020, Defendant Kavthekar summoned Ms. Greenidge into his
`office and reprimanded her for her purported handling of the motion correction
`mechanism on a scan. During this meeting Defendant Kavthekar repeatedly and
`aggressively pointed his finger at Ms. Greenidge and questioned her skills.
`35. On June 24, 2020, Ms. Greenidge complained to Ms. Golden with Human
`Resources that she could no longer tolerate the discrimination and harassment by the
`Defendants. In retaliation for her complaint, within a few days, Ms. Greenidge was
`again berated and reprimanded by Defendant Kavthekar for purportedly failing to
`inform Defendant Thomas that a patient was waiting to be seen. When Ms. Greenidge
`proved that she took the necessary steps to notify Defendant Thomas of the patient,
`Defendant Kavthekar did not apologize but instead cavalierly stated “it happens.”
`36. Ms. Greenidge continued to endure the hostile work environment created
`by the Defendants. Defendant Thomas frequently tasked Ms. Greenidge with items
`that were outside of her job description, such as, on July 2, 2020, when Defendant
`Thomas questioned why Ms. Greenidge would not bring a patient down from the
`waiting area. Ms. Greenidge responded that she is a cardiac technician and would not
`be in the department at the time, to which Defendant Thomas questioned her
`dedication and work ethic. Ms. Greenidge immediately reported the interaction to
`
`9
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`Ms. Golden, stating that she felt the Defendants were mistreating her because she is
`African American.
`37. On July 9, 2020, Ms. Greenidge brought her father to the facility for an MRI
`and overheard Defendant Kavthekar and Defendant Wilson state that Ms. Greenidge
`was “acting like an ass”
`38. In late October of 2020, Ms. Greenidge reached out to Kathy Boyle in the
`Human Resources department to complain about the discriminatory treatment that
`at this point was allowed to continue for several years. Ms. Greenidge stated that she
`was being discriminated and retaliated against. As a direct result of this complaint,
`Ms. Greenidge was written up by Defendant Wilson on November 9, 2020, and placed
`on a discriminatory and retaliatory action plan. On the same day, Ms. Greenidge
`complained of this direct retaliation to Ms. Golden in Human Resources.
`39. Once Ms. Greenidge was placed on the action plan, she was falsely told by
`Ms. Boyle that Human resources would not take any action, nor investigate her claims
`until she submitted a written report of her grievances. This was not an actual
`requirement. In addition, Ms. Greenidge had lodged numerous complaints of
`discrimination against the Defendants but had never previously been told that only
`written reports would be investigated.
`40. Ms. Greenidge continued to work diligently to successfully complete the
`unwarranted, retaliatory and pretextual action plan during the following months.
`41. Following the action, plan the discriminatory treatment continued. On
`March 3, 2021, during a daily huddle, Ms. Greenidge asked that the radioactive bags
`be placed in another area to allow for easier pick-up. Defendant Thomas proceeded
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`to point her pen at Ms. Greenidge and publicly argue with her about the suggestion.
`Non-African American employees were not publicly chastised in this manner.
`42. The following day on March 4, 2021, Ms. Greenidge notified Defendant
`Kavthekar that she had a family emergency and would not be able to come in to work.
`In response, Defendant Kavthekar sent multiple harassing text messages to Ms.
`Greenidge’s personal cell phone demanding to know the nature of her emergency,
`therefore violating Mt. Sinai’s leave policy and invading Ms. Greenidge’s rights.
`43. On March 16, 2021, Ms. Greenidge sent an email complaint to Kathy Boyle
`and Ms. Golden describing the most recent incidents of the ongoing racial
`discrimination and retaliation she was enduring from the Defendants.
`44. On March 18, 2021, following her complaint, Defendant Thomas again
`yelled at Ms. Greenidge in front of a patient regarding a task to complete before taking
`a lunch break. This left Ms. Greenidge embarrassed and humiliated. MS. Greenidge
`notified Ms. Golden of Human Resources of the retaliatory treatment via email on
`March 22, 2021.
`45. On March 31, 2021, Ms. Greenidge met with Defendants Kavthekar and
`Wilson regarding the action plan, which was set to expire. At the meeting, Defendants
`Kavthekar and Wilson reprimanded Ms. Greenidge regarding the verification of one
`study and extended the performance plan for an additional two weeks. Non-African
`American employees were not reprimanded and/or subjected to such overhanded
`criticism and discipline. Ms. Greenidge successfully completed the items on the
`retaliatory action plan by April 21,2021.
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`11
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`46. On July 1, 2021, Defendant Thomas again yelled at Ms. Greenidge in front
`of a patient, leaving her embarrassed and humiliated. Ms. Greenidge again
`complained to Defendant Kavthekar about the hostile work environment she was
`enduring at the hands of Defendant Thomas.
`47. In retaliation for Ms. Greenidge’s ongoing complaints of racial
`discrimination and retaliation, Defendant Thomas began
`lodging false and
`outrageous accusations against Ms. Greenidge to Defendants Kavthekar and Wilson.
`On August 17, 2021, Defendant Thomas falsely accused Ms. Greenidge of purposely
`striking her with a wheelchair. Ms. Greenidge immediately denied the false allegation,
`but instead of investigating the clearly retaliatory motive for the obviously false
`allegation, Defendant Wilson asked Ms. Greenidge if she apologized to her tormentor,
`Defendant Thomas.
`48. Defendant Thomas continued her attempts to push Ms. Greenidge out of
`her position during the following months by failing to relay important messages,
`refusing to perform tasks, and misreporting interactions with Ms. Greenidge. On
`December 3, 2021, during the daily huddle, Ms. Greenidge complained openly about
`Defendant Thomas’ discriminatory treatment of her. In the presence of Faye
`Hamilton, Defendant Kavthekar, Defendant Thomas, and the team secretary, Diane
`Kane, Ms. Greenidge complained that Defendant Thomas frequently spoke to her in a
`derogatory and condescending tone. Ms. Hamilton spoke up in support of Ms.
`Greenidge’s complaints during the meeting, and stated that she often observed
`Defendant Thomas’ disparate treatment of Ms. Greenidge. The discriminatory and
`retaliatory treatment of Ms. Greenidge continues unabated.
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`12
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`COUNT I – IN VIOLATION OF TITLE VII OF THE CIVIL RIGHTS ACT OF 1964 AS
`AMENDED BY THE CIVIL RIGHTS ACT OF 1991 AND 42 U.S.C. § 1981 FOR RACE
`DISCRIMINATION
`(AS AGAINST ALL DEFENDANTS)
`
`
`
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`Plaintiff incorporates and re-alleges all preceding paragraphs as if fully
`49.
`set forth herein and further alleges as follows:
`50.
`Defendants treated Plaintiff less favorably than similarly situated non-
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`African American employees in the terms and conditions of Plaintiff’s employment.
`Defendants’ treatment of Plaintiff negatively and adversely
`impacted her
`employment.
`
`51.
`As a direct and proximate result of Defendants’ discriminatory conduct,
`Plaintiff suffered and will continue to suffer irreparable harm, pecuniary losses and
`other damages. Plaintiff is entitled to declaratory relief, injunctive relief, and
`compensatory and punitive damages to make her whole.
`
`
`52.
`Plaintiff incorporates and re-alleges all preceding paragraphs as if fully
`set forth herein and further alleges as follows:
`Defendants subjected Plaintiff to a hostile work environment based on
`
`53.
`her race. The conditions and conduct that Plaintiff was subjected to were objectively
`and subjectively hostile and substantially and adversely impacted the terms and
`condition of Plaintiff’s employment.
` Plaintiff complained about the hostile
`environment to Human Resources and Defendants/Human Resources failed to
`promptly prevent and correct the hostile, racially discriminatory conduct.
`
`13
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`COUNT II – IN VIOLATION OF TITLE VII OF THE CIVIL RIGHTS ACT OF 1964 AS
`AMENDED BY THE CIVIL RIGHTS ACT OF 1991 AND 42 U.S.C. § 1981 FOR
`HOSTILE WORK ENVIRONMENT
`(AS AGAINST ALL DEFENDANTS)
`
`

`

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`COUNT III – IN VIOLATION OF TITLE VII OF THE CIVIL RIGHTS ACT OF 1964 AS
`AMENDED BY THE CIVIL RIGHTS ACT OF 1991 AND 42 U.S.C. § 1981 FOR
`RETALIATION
`(AS AGAINST ALL DEFENDANTS)
`
`
`As a direct and proximate result of Defendants’ discriminatory conduct,
`54.
`
`Plaintiff suffered and will continue to suffer irreparable harm, pecuniary losses and
`other damages. Plaintiff is entitled to declaratory relief, injunctive relief, and
`compensatory and punitive damages to make her whole.
`
`55.
`Plaintiff incorporates and re-alleges all preceding paragraphs as if
`fully set forth herein and further alleges as follows:
`
`56.
`Defendants were aware that Plaintiff engaged in a protected activity by
`filing complaints of discrimination based on race against the Defendants. In
`retaliation, Defendants constantly harassed and retaliated against Ms. Greenidge
`because of her complaints of discrimination and retaliatory made false accusations
`regarding her work performance.
`
`57.
`As a direct and proximate result of Defendants’ discriminatory conduct,
`Plaintiff suffered and will continue to suffer irreparable harm, pecuniary losses and
`other damages. Plaintiff is entitled to declaratory relief, injunctive relief, and
`compensatory and punitive damages to make her whole.
`58.
`Plaintiff incorporates and re-alleges all preceding paragraphs as if fully
`set forth herein and further alleges as follows:
`
`14
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`COUNT IV – VIOLATION OF THE NEW YORK STATE EXECUTIVE LAW § 296 (6),
`FOR AIDING AND ABETTING DISCRIMINATION
`(AS AGAINST ALL DEFENDANTS)
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`
`
`
`

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`New York State Executive Law § 296 (6) provides that it shall be an
`59.
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`unlawful discriminatory practice: “For any person to aid, abet, incite, compel or
`coerce the doing of any acts forbidden under this article, or attempt to do so.”
`
`60.
`Each of the Defendants engaged in an unlawful discriminatory practice
`in violation of New York State Executive Law § 296 (6) by aiding, abetting, inciting,
`compelling and coercing the discriminatory conduct.
`
`61.
`As a direct and proximate result of Defendants’ discriminatory conduct,
`Plaintiff suffered and will continue to suffer irreparable harm, pecuniary losses and
`other damages. Plaintiff is entitled to declaratory relief, injunctive relief, and
`compensatory and punitive damages to make her whole.
` COUNT V – VIOLATION OF THE NEW YORK STATE EXECUTIVE LAW § 296 (7),
`62.
`Plaintiff incorporates and re-alleges all preceding paragraphs as if fully
`set forth herein and further alleges as follows:
`63.
`New York State Executive Law § 296 (7) provides that “[i]t shall be an
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`unlawful discriminatory practice for any person engaged in any activity to which this
`section applies to retaliate or discriminate against any person because he or she has
`opposed any practices forbidden under this article or because he or she has filed a
`complaint, testified or assisted in any proceeding under this article.”
`Plaintiff filed a complaint within the meaning of New York State
`
`64.
`Executive Law. Defendants engaged in an unlawful discriminatory practice by
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`15
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`FOR RETALIATION
`(AS AGAINST ALL DEFENDANTS)
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`

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`COUNT VI - HIRING, TRAINING, RETENTION AND SUPERVISION
`(AS AGAINST DEFENDANTS MT SINAI, WILSON and KAVETHKAVAR )
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`retaliating, and otherwise discriminating against Plaintiff because of her opposition
`to the unlawful employment practices of Defendants.
`65.
`The practices complained of were intentional and were done with
`malice or reckless indifference to Plaintiff’s protected rights.
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`66.
`As a direct and proximate result of Defendants’ conduct, Plaintiff
`suffered and will continue to suffer irreparable harm, pecuniary losses, and other
`damages. Plaintiff is entitled to declaratory relief and compensatory damages to
`make her whole in addition to attorney fees and costs.
`
`
`67.
`Plaintiff incorporates and re-alleges all preceding paragraphs as if fully
`set forth herein and further alleges as follows:
`As a result of Plaintiff’s complaints, Defendant knew or should have
`
`68.
`known by the exercise of diligence and reasonable care of the racially based hostile
`work environment and discrimination perpetuated by Defendants’ management
`employees. Defendant failed to properly hire, train, retain and supervise its managers
`such that incidents of harassment are properly investigated and promptly prevented
`and/or corrected.
`
`69.
`As a direct and proximate result of Defendants’ discriminatory conduct,
`Plaintiff suffered and will continue to suffer irreparable harm, pecuniary losses, and
`other damages. Plaintiff is entitled to declaratory relief, injunctive relief, and
`compensatory and punitive damages to make her whole.
`The Plaintiff demands a jury trial in this action.
`70.
`
`16
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`JURY DEMAND
`
`V.
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`
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`

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`WHEREFORE, the Plaintiff demands judgment as follows:
`
`a)
`Declaring that the actions, patterns and practices of Defendants, their
`agents, servants and all those acting in concert with them, constituted, and does
`constitute, a violation of Title VII of the Civil Rights Act of 1964 as amended by the
`Civil Rights Act of 1991; and all applicable rules and regulations, and common law
`principals.
`
`b)
`Awarding damages for economic and emotional injuries as well as
`interest, costs, disbursements, common law, statutory, compensatory, exemplary,
`and punitive damages, pre-judgment interest, pecuniary and non-pecuniary damages
`and such other and further relief as to this Court deems just and proper; and
`
`c)
`Awarding counsel fees, costs, and disbursements of this action.
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`Together with such other and further equitable relief which as to this Court
`may deem just and proper.
`Dated:
`February 7, 2021
`
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`New York, New York
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`Tracey L. Brown, Esq. (TB-4094)
`Monique D. Milner
`THE COCHRAN FIRM
`Attorneys for Plaintiff
`55 Broadway, 23rd Floor
`New York, New York 10006
`(212) 553-9215
`
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`_______________________________
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`17
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