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Edreweene Raymond v. City Of New York, Constantin Tasachas, Natalie Maldonado, Victoria Perry
A Torts - Other (Employment Discrimination) case was filed by (Subcribe to view) represented by (Subcribe to view) against (Subscribe to view) represented by (Subscribe to view) in the jurisdiction of Kings County. Judge Kings Cdp7 presiding.
Case Details
Case Number
Filing Date
July 18, 2022
Last Refreshed
October 12, 2023
Filing Location
Kings County, NY
Judge
Hon. Kings Cdp7
Category
Torts - Other (Employment Discrimination)
Practice Area
Labor and Employment
Matter Type
Discrimination
Status
Appealed
Overview
This is a civil rights action on behalf of the plaintiff EDREWEENE RAYMOND
(hereinafter referred to as “plaintiff’) for injunctive relief and to vindicate his rights for denial
of civil rights and employment benefits with the New York City Police Department (hereinafter
referred to as “NYPD” by Defendants THE CITY OF NEW YORK, TSACHAS,
MALDONADO and PERRY as a result of their unlawful conduct. More specifically, plaintiff
seeks damages related to the deprivation of his rights secured by New York State Executive §
296, and New York City Local Law §8-101 et al. Plaintiff was denied employment benefits on
the basis of his race, and in retaliation for protected complaints of unlawful discrimination.
Causes of Action
COUNT I RACE DISCRIMINATION IN VIOLATION OF NEW YORK STATE EXECUTIVE LAW § 296
COUNT III RETALIATION IN VIOLATION OF NEW YORK STATE EXECUTIVE LAW § 296
COUNT IV RACE DISCRIMINATION IN VIOLATION OF NEW YORK CITY ADMINISTRATIVE CODE § 8-107
COUNT VI RETALIATION IN VIOLATION OF NEW YORK CITY ADMINISTRATIVE CODE § 8-107
COUNT VII RACE DISRIMINATION STRICT LIABILITY IN VIOLATION OF NEW YORK CITY ADMINISTRATIVE CODE § 8-107(13)(b)
COUNT VIII RETALIATION STRICT LIABILITY IN VIOLATION OF NEW YORK CITY ADMINISTRATIVE CODE § 8-107(13)(b)
COUNT IX
Parties
Plaintiffs
Edreweene Raymond
Attorneys for Plaintiffs
Scola, John Andrew
Defendants
City Of New York
Constantin Tasachas
Natalie Maldonado
Victoria Perry
Attorneys for Defendants
Suhovsky, Stephen Matthew
Case Documents
STIPULATION - BRIEFING SCHEDULE
Date: Sep 29, 2023
EXHIBIT(S) - 17 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 18 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 16 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 30 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 27 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 26 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 20 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 9 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 23 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 24 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 31 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 1 (Motion 2)
Date: Sep 21, 2023
RESPONSE TO STATEMENT OF MATERIAL FACTS
Date: Sep 21, 2023
MEMORANDUM OF LAW IN OPPOSITION
Date: Sep 21, 2023
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION
Date: Sep 21, 2023
EXHIBIT(S) - 25 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 12 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 2 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 3 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 14 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 15 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 28 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 13 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 21 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 4 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 29 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 22 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 5 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 7 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 8 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 6 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 10 (Motion 2)
Date: Sep 21, 2023
EXHIBIT(S) - 11 (Motion 2)
Date: Sep 21, 2023
STIPULATION - ADJOURNMENT OF MOTION (Motion 2)
Date: Sep 08, 2023
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION
Date: Jul 10, 2023
STATEMENT OF MATERIAL FACTS
Date: Jul 10, 2023
EXHIBIT(S) - A (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - G (Motion 2)
Date: Jul 10, 2023
MEMORANDUM OF LAW
Date: Jul 10, 2023
EXHIBIT(S) - N (Motion 2)
Date: Jul 10, 2023
NOTICE OF MOTION
Date: Jul 10, 2023
EXHIBIT(S) - O-1 (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - K (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - Q (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - L (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - M (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - T (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - R (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - H (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - Y (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - S (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - AE (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - J (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - U (Motion 2)
Date: Jul 10, 2023
NO FEE AUTHORIZATION (LETTER/ORDER/AFFIRMATION)
Date: Jul 10, 2023
EXHIBIT(S) - X (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - W (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - Z (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - V (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - C (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - E (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - B (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - F (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - AC (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - AA (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - I (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - AB (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - D (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - AD (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - O-2 (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - P (Motion 2)
Date: Jul 10, 2023
EXHIBIT(S) - A (Motion 1)
Date: Jun 10, 2023
NOTICE OF APPEAL
Date: Jun 10, 2023
NOTICE OF ENTRY
Date: Jun 10, 2023
ORDER - INTERIM
Date: May 10, 2023
MEMORANDUM OF LAW IN REPLY
Date: Feb 07, 2023
EXHIBIT(S) - B (Motion 1)
Date: Jan 12, 2023
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION
Date: Jan 12, 2023
EXHIBIT(S) - A (Motion 1)
Date: Jan 12, 2023
MEMORANDUM OF LAW IN OPPOSITION
Date: Jan 12, 2023
STIPULATION - ADJOURNMENT OF MOTION
Date: Nov 22, 2022
AFFIDAVIT
Date: Oct 28, 2022
EXHIBIT(S) - 2 (Motion 1)
Date: Oct 28, 2022
EXHIBIT(S) - 1 (Motion 1)
Date: Oct 28, 2022
NO FEE AUTHORIZATION (LETTER/ORDER/AFFIRMATION)
Date: Oct 28, 2022
MEMORANDUM OF LAW
Date: Oct 28, 2022
RJI -RE: NOTICE OF MOTION
Date: Oct 28, 2022
NOTICE OF MOTION
Date: Oct 28, 2022
STIPULATION - OTHER
Date: Oct 21, 2022
STIPULATION - OTHER
Date: Oct 03, 2022
STIPULATION - OTHER
Date: Aug 29, 2022
STIPULATION - OTHER
Date: Aug 05, 2022
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Jul 26, 2022
SUMMONS COMPLAINT
Date: Jul 18, 2022Case Events
| Date | Type | Description | |
|---|---|---|---|
| September 29, 2023 | STIPULATION - BRIEFING SCHEDULE | ||
| September 21, 2023 |
EXHIBIT(S) - 17 (Motion #2) Aaron Diaz Affidavit |
||
| September 21, 2023 |
EXHIBIT(S) - 18 (Motion #2) Chief Fox Dep |
||
| September 21, 2023 |
EXHIBIT(S) - 16 (Motion #2) Raymond Monthly Reports |
||
| September 21, 2023 |
EXHIBIT(S) - 30 (Motion #2) Raymond Arrests |
||
| September 21, 2023 |
EXHIBIT(S) - 27 (Motion #2) Recording Transcript |
||
| September 21, 2023 |
EXHIBIT(S) - 26 (Motion #2) CD Adjudication Transcript |
||
| September 21, 2023 |
EXHIBIT(S) - 20 (Motion #2) TSachas Command Discipline |
||
| September 21, 2023 |
EXHIBIT(S) - 9 (Motion #2) NYPD Patrol Guide 205-48 |
||
| September 21, 2023 |
EXHIBIT(S) - 23 (Motion #2) Economic Expert Appraisal |
||
| September 21, 2023 |
EXHIBIT(S) - 24 (Motion #2) Sawyer Arrests and Summonses |
||
| September 21, 2023 |
EXHIBIT(S) - 31 (Motion #2) See Through NY |
||
| September 21, 2023 |
EXHIBIT(S) - 1 (Motion #2) Plaintiff Dep |
||
| September 21, 2023 | RESPONSE TO STATEMENT OF MATERIAL FACTS | ||
| September 21, 2023 | MEMORANDUM OF LAW IN OPPOSITION | ||
| September 21, 2023 | AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION | ||
| September 21, 2023 |
EXHIBIT(S) - 25 (Motion #2) Sawyer Evaluations |
||
| September 21, 2023 | EXHIBIT(S) - 12 (Motion #2) | ||
| September 21, 2023 |
EXHIBIT(S) - 2 (Motion #2) Raymond Affidavit |
||
| September 21, 2023 |
EXHIBIT(S) - 3 (Motion #2) Tsachas Dep |
||
| September 21, 2023 |
EXHIBIT(S) - 14 (Motion #2) Grable Dep |
||
| September 21, 2023 |
EXHIBIT(S) - 15 (Motion #2) Expert Liability Report |
||
| September 21, 2023 |
EXHIBIT(S) - 28 (Motion #2) Desroiers arrests |
||
| September 21, 2023 | EXHIBIT(S) - 13 (Motion #2) | ||
| September 21, 2023 |
EXHIBIT(S) - 21 (Motion #2) Tsachas Reccomendation to CARB |
||
| September 21, 2023 |
EXHIBIT(S) - 4 (Motion #2) Pu Folkes Dep |
||
| September 21, 2023 |
EXHIBIT(S) - 29 (Motion #2) Desroisers Evaluations |
||
| September 21, 2023 |
EXHIBIT(S) - 22 (Motion #2) Raymond Projected Score |
||
| September 21, 2023 |
EXHIBIT(S) - 5 (Motion #2) Transcript Recording |
||
| September 21, 2023 |
EXHIBIT(S) - 7 (Motion #2) Campbell Dep |
||
| September 21, 2023 |
EXHIBIT(S) - 8 (Motion #2) Smith Dep |
||
| September 21, 2023 |
EXHIBIT(S) - 6 (Motion #2) Raymond Evaluations |
||
| September 21, 2023 |
EXHIBIT(S) - 10 (Motion #2) CARB Transcript |
||
| September 21, 2023 | EXHIBIT(S) - 11 (Motion #2) | ||
| September 21, 2023 |
EXHIBIT(S) - 19 (Motion #2) Appeal Transcript |
||
| September 08, 2023 | STIPULATION - ADJOURNMENT OF MOTION (Motion #2) | ||
| July 10, 2023 | AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION | ||
| July 10, 2023 | STATEMENT OF MATERIAL FACTS | ||
| July 10, 2023 |
EXHIBIT(S) - A (Motion #2) A copy of Plaintiffs Deposition Transcript |
||
| July 10, 2023 |
EXHIBIT(S) - G (Motion #2) A copy of Oliver Pu-Folkess Deposition Transcript |
||
| July 10, 2023 | MEMORANDUM OF LAW | ||
| July 10, 2023 |
EXHIBIT(S) - N (Motion #2) A copy of Tsachass IAB Transcript and Resulting CD |
||
| July 10, 2023 | NOTICE OF MOTION | ||
| July 10, 2023 |
EXHIBIT(S) - O-1 (Motion #2) A copy Campbells IAB Transcript Part 1 |
||
| July 10, 2023 |
EXHIBIT(S) - K (Motion #2) A copy of Plaintiffs Monthly Evaluations |
||
| July 10, 2023 |
EXHIBIT(S) - Q (Motion #2) A copy of Plaintiffs May 2018 letter to Commissioner ONeil |
||
| July 10, 2023 |
EXHIBIT(S) - L (Motion #2) A copy of Tsachass Reports on Plaintiff |
||
| July 10, 2023 |
EXHIBIT(S) - M (Motion #2) A copy of the CARB Meeting Transcript |
||
| July 10, 2023 |
EXHIBIT(S) - T (Motion #2) A copy of Plaintiffs Federal Complaint, filed on August 31, 2015 |
||
| July 10, 2023 |
EXHIBIT(S) - R (Motion #2) A copy of Plaintiffs Command Discipline and Transcript |
||
| July 10, 2023 |
EXHIBIT(S) - H (Motion #2) A copy of Plaintiffs Appeal Transcript |
||
| July 10, 2023 |
EXHIBIT(S) - Y (Motion #2) A copy of December 17, 2015 NYPD Employee Management Division Letter |
||
| July 10, 2023 |
EXHIBIT(S) - S (Motion #2) A copy of Plaintiffs Complaint, filed on July 18, 2022 |
||
| July 10, 2023 |
EXHIBIT(S) - AE (Motion #2) A copy of Plaintiffs Notice of Appeal, filed on June 10, 2023 |
||
| July 10, 2023 |
EXHIBIT(S) - J (Motion #2) A copy of Plaintiffs Monthly Reports |
||
| July 10, 2023 |
EXHIBIT(S) - U (Motion #2) A copy of Defendants Motion to Dismiss the Complaint, filed on October 28, 2022 |
||
| July 10, 2023 | NO FEE AUTHORIZATION (LETTER/ORDER/AFFIRMATION) | ||
| July 10, 2023 |
EXHIBIT(S) - X (Motion #2) A copy of NYPD Patrol Guide Excerpts |
||
| July 10, 2023 |
EXHIBIT(S) - W (Motion #2) A copy of Excerpts from IAB Interview of Victoria Perry |
||
| July 10, 2023 |
EXHIBIT(S) - Z (Motion #2) A copy of the CARB Recommendation |
||
| July 10, 2023 |
EXHIBIT(S) - V (Motion #2) A copy of Decision and Order on Motion to Dismiss, filed on May 10, 2023 |
||
| July 10, 2023 |
EXHIBIT(S) - C (Motion #2) A copy of Constantin Tsachass Deposition Transcript |
||
| July 10, 2023 |
EXHIBIT(S) - E (Motion #2) A copy of Corey Grables Deposition Transcript |
||
| July 10, 2023 |
EXHIBIT(S) - B (Motion #2) A copy of Martin Campbells Deposition Transcript |
||
| July 10, 2023 |
EXHIBIT(S) - F (Motion #2) A copy of Joseph Foxs Deposition Transcript |
||
| July 10, 2023 |
EXHIBIT(S) - AC (Motion #2) A copy of Desrosierss Evaluation |
||
| July 10, 2023 |
EXHIBIT(S) - AA (Motion #2) A copy of the May 6, 2021 Declaration of Constantin Tsachas |
||
| July 10, 2023 |
EXHIBIT(S) - I (Motion #2) A copy of a transcript of Plaintiffs Recording of Campbell |
||
| July 10, 2023 |
EXHIBIT(S) - AB (Motion #2) A copy of Desrosiers and Raymond stats |
||
| July 10, 2023 |
EXHIBIT(S) - D (Motion #2) A copy of Gentry Smiths Deposition Transcript |
||
| July 10, 2023 |
EXHIBIT(S) - AD (Motion #2) A copy of Desrosierss Evaluation Memo |
||
| July 10, 2023 |
EXHIBIT(S) - O-2 (Motion #2) A copy Campbells IAB Transcript Part 2 |
||
| July 10, 2023 |
EXHIBIT(S) - P (Motion #2) A copy of Plaintiffs December 2015 letter |
||
| June 10, 2023 |
EXHIBIT(S) - A (Motion #1) Raymond Order |
||
| June 10, 2023 | NOTICE OF APPEAL | ||
| June 10, 2023 | NOTICE OF ENTRY | ||
| May 10, 2023 | ORDER - INTERIM | ||
| February 07, 2023 | MEMORANDUM OF LAW IN REPLY | ||
| January 12, 2023 |
EXHIBIT(S) - B (Motion #1) COMPLAINT |
||
| January 12, 2023 | AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION | ||
| January 12, 2023 |
EXHIBIT(S) - A (Motion #1) SWAIN ORDER |
||
| January 12, 2023 | MEMORANDUM OF LAW IN OPPOSITION | ||
| November 22, 2022 | STIPULATION - ADJOURNMENT OF MOTION | ||
| October 28, 2022 | AFFIDAVIT | ||
| October 28, 2022 |
EXHIBIT(S) - 2 (Motion #1) Summons and Complaint |
||
| October 28, 2022 |
EXHIBIT(S) - 1 (Motion #1) Federal Decision on MSJ |
||
| October 28, 2022 | NO FEE AUTHORIZATION (LETTER/ORDER/AFFIRMATION) | ||
| October 28, 2022 | MEMORANDUM OF LAW | ||
| October 28, 2022 | RJI -RE: NOTICE OF MOTION | ||
| October 28, 2022 | NOTICE OF MOTION | ||
| October 21, 2022 | STIPULATION - OTHER | ||
| October 03, 2022 |
STIPULATION - OTHER Respond |
||
| August 29, 2022 |
STIPULATION - OTHER Time to Respond |
||
| August 05, 2022 | STIPULATION - OTHER | ||
| July 26, 2022 |
AFFIRMATION/AFFIDAVIT OF SERVICE Constantin Tsachas |
||
| July 18, 2022 | SUMMONS + COMPLAINT |
