Preview
FILED: NASSAU COUNTY CLERK 05/06/2024 01:48 PM INDEX NO. 607878/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024
NEW YORK STATE SUPREME COURT
NASSAU COUNTY
--------------------------------------------------------------X
RENEE WATSON, :
: SUMMONS
Plaintiff, :
: Plaintiff designates
v. : Nassau County
: as the place of trial
R & W LIVERY SERVICES, :
: The basis of venue is:
Defendant. : CPLR § 503(a)
--------------------------------------------------------------X
To the above-named Defendant:
YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve
a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of
appearance on counsel for Plaintiff within twenty (20) days after service of this summons,
exclusive of the day of service (or within thirty (30) days after the service is complete if this
summons is not personally delivered to you within the State of New York); and in case of your
failure to appear or answer, judgment will be taken against you by default for the relief
demanded in the complaint.
Dated: May 6, 2024
New York, New York MIZRAHI KROUB LLP
By:
Sagar K. Shah
225 Broadway, 39th Floor
New York, NY 10003
Telephone: (212) 595-6200
sshah@mizrahikroub.com
Counsel for Plaintiff
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NEW YORK STATE SUPREME COURT
NASSAU COUNTY
--------------------------------------------------------------X
RENEE WATSON, : Index No.:
:
Plaintiff, :
: VERIFIED COMPLAINT
v. :
:
R & W LIVERY SERVICES, : Jury Trial Demanded
:
Defendant. :
--------------------------------------------------------------X
Plaintiff Renee Watson (“Plaintiff” or “Watson”) by and through her attorneys, Mizrahi
Kroub, LLP, as and for her Complaint against Defendant R & W Livery Services (“R&W Livery”
or “Defendant”) alleges as follows:
PRELIMINARY STATEMENT
1. In the American workforce, there exist employers with iniquitous practices, which
often results in employees blowing the whistle. Unfortunately, Defendant R&W Livery has
treated its employees as nothing more than sub-human. Ms. Watson is one such employee who
experienced humiliating and degrading circumstances while working for Defendant.
2. R&W Livery’s work environment is hostile to women and is permeated by
unlawful conduct. Ms. Watson was left to fend for herself and was ultimately terminated in
retaliation for her opposition to Defendant’s fraudulent and unlawful treatment of her.
JURISDICTION AND VENUE
3. The Court has jurisdiction over this matter pursuant to Civil Practice Law and
Rules (“CPLR”) § 301 because Defendant resides in New York.
4. Venue is proper in this County pursuant to CPLR § 503(a) because Defendant
is located in Nassau County, New York.
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PARTIES
5. Plaintiff Watson is a former employee of R&W Livery.
6. Defendant R&W Livery is an employer formed under the law of the state of New
York with its principal place of business in West Hempstead, New York.
FACTUAL ALLEGATIONS
7. Beginning on January 10, 2023, R&W Livery employed Ms. Watson as a Personal
Assistant in New York.
8. R&W Livery provides accessible transportation for individuals. Ms. Watson’s
responsibilities included answering phones, scheduling patient pickups, and clerical work, among
other tasks.
9. She accomplished her job admirably and with dedication. Unfortunately, once
Ms. Watson objected to fraudulent billing practices and refused an order from Aline Frisch, R&W
Livery’s owner, Ms. Frisch terminated her employment.
10. Ms. Watson’s employment with R&W Livery was difficult from the outset. She
first spoke to Ms. Frisch during a phone call a few days after she started.
11. Ms. Frisch was extremely aggressive during this call and demanded that Ms.
Watson relocate from New York to Florida for training.
12. Ms. Frisch told Ms. Watson that she needed to come to Florida so that Ms. Frisch
could train her properly. Ms. Watson did as Ms. Frisch demanded and went to Florida as
instructed.
13. From February 3 through February 5, 2023, Ms. Watson was in Florida for work.
14. Although Ms. Watson was scheduled to return home on February 5, 2023, Ms.
Frisch extended Ms. Watson’s trip for an extra day.
15. During this trip, R&W Livery did not provide a hotel for Ms. Watson even though
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Ms. Watson was in Florida for work. Instead, Ms. Frisch forced Ms. Watson to stay with Ms.
Frisch at her home.
16. Although Ms. Watson had travelled from New York to receive training in
ambulatory services, she only received approximately one hour of training. The rest of Ms.
Watson’s time was spent running personal errands for Ms. Frisch.
17. Ms. Watson’s days in Florida were spent at Ms. Frisch’s beck and call until it was
bedtime and under duress because Ms. Frisch screamed and yelled at Ms. Watson regularly.
18. There were no set hours and Ms. Watson would regularly work 12-hour days.
R&W Livery, however, only paid Ms. Watson for 8 hours each day.
19. In addition, because of her kosher dietary restrictions, Ms. Frisch restricted what
Ms. Watson was allowed to eat because Ms. Watson could not bring non-kosher food into Ms.
Frisch’s home.
20. In mid-February 2023, Ms. Frisch travelled to Israel. Because Ms. Frisch needed
coverage during the time she was in Israel, Ms. Frisch forced Ms. Watson to come back to Florida
on February 10, 2023, where Ms. Watson was again forced to stay in Ms. Frisch’s home and
restricted from eating non-kosher food.
21. Once Ms. Watson arrived in Florida, Ms. Frisch told Ms. Watson that she would
need to cover the New York office from Florida and also take care of Ms. Frisch’s two dogs.
22. Ms. Watson was in Florida through February 21, 2023. During this time, she was
paid for only 45 hours — despite the fact that she worked 11 hours per day even on weekends
through her departure – answering calls, walking Ms. Frisch’s dog and other tasks Ms. Frisch
gave her.
23. Rather than paying overtime wages to Ms. Watson, Ms. Frisch improperly paid her
as a “reimbursement” for her overtime hours. Ms. Frisch regularly paid Ms. Watson’s overtime
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hours as “reimbursements” in order to avoid paying her time and a half for overtime hours.
24. In addition, Ms. Watson felt uncomfortable because Ms. Frisch told Ms. Watson to
bill an insurance provider for services that R&W Livery did not actually provide.
25. Ms. Frisch became angry that Ms. Watson was uncomfortable with this. In
addition, Ms. Frisch put the patients in personal cars and Ubers which cost $80 on occasion, yet
R&W Livery billed the patients $800 for ambulatory services.
26. One day while Ms. Frisch was in Israel, she demanded that Ms. Watson
impersonate Ms. Frisch during a call with the Department of Motor Vehicles (“DMV”) to reset
Ms. Frisch’s password because she needed to access her account.
27. Ms. Watson refused to do so because she felt it was improper.
28. Upon Ms. Watson’s refusal, Ms. Frisch immediately became infuriated and started
berating her. From that point forward, Ms. Frisch continued to mistreat Ms. Watson.
29. On February 21, 2023, Ms. Watson returned home to New York from Florida on a
flight that was scheduled to land at 11 p.m.
30. The next day, Ms. Watson notified Ms. Frisch via text message that she needed to
miss work that day because she had an appointment. Ms. Frisch seemed to understand and
allowed Ms. Watson to miss work that day.
31. On February 23, 2023, Ms. Watson was terminated.
32. Before she was terminated, Ms. Frisch lashed out and called Ms. Watson “a very
emotional female.”
33. Ms. Frisch also told Ms. Watson that she did not like the way she worked for her,
apparently in reference to Ms. Watson’s refusal to impersonate Ms. Frisch on the call with the
DMV.
34. Later, another employee told Ms. Watson, “You don’t have to come in tomorrow,
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you don’t work here no more. Not sure why you don’t work here anymore, whatever happened in
Florida, she doesn’t want you to come back.”
35. Ms. Watson is aware that Ms. Frisch instructed other staff members to make false
statements alleging that Ms. Watson stole documents.
36. Ms. Watson is also aware that R&W Livery’s initial reason for terminating her
employment was that Ms. Watson is a “a very emotional female,” but that R&W Livery has since
given a new reason – that Ms. Watson missed work from February 20 through February 22, 2023.
37. Ms. Watson notified Ms. Frisch about her February 22, 2023 appointment, and
Ms. Frisch approved and allowed the absence.
38. R&W Livery terminated Ms. Watson in retaliation for opposing R&W Livery’s
and Ms. Frisch’s fraudulent and unlawful conduct.
39. After Ms. Watson voiced her concerns about the unlawful conduct occurring
regularly at R&W Livery, she was terminated.
40. As a result of R&W Livery’s actions, Ms. Watson felt humiliated, degraded,
embarrassed, and emotionally distressed.
41. Ms. Watson continues to suffer emotional distress as a result of R&W Livery’s
treatment.
FIRST CAUSE OF ACTION
(Discrimination Under the NYSHRL)
Against Defendant
42. Plaintiff hereby repeats and realleges each and every allegation in the preceding
paragraphs as if set forth fully herein.
43. Defendant has discriminated against Plaintiff on the basis of her gender in
violation of the NYSHRL by subjecting Plaintiff to disparate treatment based upon her gender
including, but not limited to, discrimination, and a hostile work environment.
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44. As a direct and proximate result of Defendant’s unlawful discriminatory conduct
in violation of the NYSHRL, Plaintiff has suffered, and continues to suffer, monetary and/or
economic harm for which she is entitled to an award of monetary damages and other relief.
45. As a direct and proximate result of Defendant’s unlawful discriminatory conduct
in violation of the NYSHRL, Plaintiff has suffered, and continues to suffer, severe mental
anguish and emotional distress for which she is entitled to an award of monetary damages and
other relief.
SECOND CAUSE OF ACTION
(Retaliation in Violation of NYSHRL)
Against Defendant
46. Plaintiff hereby repeats, reiterates, and re-alleges the preceding as though set forth
fully herein.
47. By the actions described above, Defendant retaliated against Plaintiff in
violation of the NYSHRL after she complained of the discrimination perpetrated against her by
Defendant.
48. As a direct and proximate result of Defendant’s unlawful retaliatory conduct in
violation of the NYSHRL, Plaintiff has suffered, and continues to suffer, monetary and/or
other economic harm for which she is entitled to an award of monetary damages and other
relief.
49. As a direct and proximate result of Defendant’s unlawful retaliatory conduct in
violation of the NYSHRL, Plaintiff has suffered, and continues to suffer, severe mental
anguish and emotional distress for which she is entitled to an award of monetary damages and
other relief.
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THIRD CAUSE OF ACTION
(Violation of the NYLL § 740)
Against Defendant
50. Plaintiff repeats, reiterates and re-alleges each and every allegation in all of the
preceding paragraphs as if fully set forth herein.
51. New York Labor Law § 740 provides that “An employer shall not take any
retaliatory action against an employee . . . because such employee . . . discloses, or threatens
to disclose . . . an activity, policy or practice of the employer that the employee reasonably
believes is in violation of law, rule or regulation or that the employee reasonably believes
poses a substantial and specific danger to the public health or safety . . . or (c) objects to, or
refuses to participate in any such activity, policy or practice.
52. By the conduct described above, in response to Plaintiff’s protected complaints
and/or reports, Defendants subjected Plaintiff to a hostile work environment and the adverse
employment actions set forth above.
53. The Defendant actively participated in and/or aided and abetted the unlawful
conduct described herein.
54. Defendant’s retaliatory action was willful, malicious or wanton.
55. As a result of Defendant’s conduct, Plaintiff has suffered economic and
noneconomic injury for which she is entitled to monetary and other damages in an amount to
be determined at trial, together with an award of punitive damages in an amount to be
determined at trial, and any and all other available relief including attorneys’ fees and costs.
Plaintiff is entitled to any and all other available remedies and/or damages, including but not
limited to punitive damages and attorneys’ fees and expenses.
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FOURTH CAUSE OF ACTION
(Violation of the NYLL § 741)
Against Defendant
56. Plaintiff hereby repeats, reiterates and re-alleges each and every allegation as
contained in each of the preceding paragraphs as if fully set forth herein.
57. New York Labor Law § 741 provides that “no employer shall take retaliatory
action against any employee because the employee . . . discloses or threatens to disclose to a
supervisor . . . an activity, policy or practice of the employer or agent that the employee, in
good faith, reasonably believes constitutes improper quality of patient care or improper
quality of workplace safety . . . or objects to . . . any activity, policy or practice of the
employer or agent that the employee, in good faith, reasonably believes constitutes improper
quality of patient care or improper quality of workplace safety.”
58. By the conduct described above, in response to Plaintiff’s protected complaints
and/or reports, Defendant subjected Plaintiff to a hostile work environment and the adverse
employment actions set forth above.
59. The Defendant actively participated in and/or aided and abetted the unlawful
conduct described herein.
60. As a result of Defendant’s conduct, Plaintiff has suffered economic and
noneconomic injury for which she is entitled to monetary and other damages in an amount to
be determined at trial, together with an award of punitive damages in an amount to be
determined at trial, and any and all other available relief including attorneys’ fees and costs.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays that the Court enter judgment in her favor and against
Defendant, containing the following relief:
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A. A declaratory judgment that the actions, conduct and practices of Defendant
complained of herein violate the laws of the State of New York;
B. An injunction and order permanently restraining Defendant and their partners,
officers, owners, officials, agents, successors, employees and/or representatives, and any and all
persons acting in concert with and/or on behalf of them, from engaging in any such further
unlawful conduct, including the policies and practices complained of herein;
C. An award of damages against Defendant, or any jointly or severally liable entity
or person, in an amount to be determined at trial, plus prejudgment interest, to compensate
Plaintiff for all monetary and/or economic damages;
D. An award of damages against Defendant, or any jointly or severally liable entity
or person, in an amount to be determined at trial, plus prejudgment interest, to compensate
Plaintiff for all non-monetary and/or compensatory damages, including, but not limited to,
compensation for her physical injuries, mental anguish, psychological harm, and emotional
distress;
E. An award of punitive damages and any applicable penalties in an amount to be
determined at trial;
F. Prejudgment interest on all amounts due;
G. An award of fees and costs that Plaintiff has incurred in this action, as well
Plaintiff’s reasonable attorneys’ fees and costs to the fullest extent permitted by law; and,
H. Such other and further relief as the Court may deem just and proper.
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JURY DEMAND
Plaintiff hereby demands a trial by jury on all issues of fact and damages stated herein.
Dated: May 6, 2024
New York, New York Respectfully submitted,
MIZRAHI KROUB LLP
By:
Sagar K. Shah
225 Broadway, 39th Floor
New York, NY 10007
Telephone: (212) 595-6200
sshah@mizrahikroub.com
Counsel for Plaintiff
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VERIFICATION
RENEE WATSON, being duly sworn, deposes and says:
I am the plaintiff in the above-entitled action. I have read the foregoing complaint and know
the contents thereof. The same are true to my knowledge, except as to matters therein stated to be
alleged on information and belief and as to those matters I believe them to be true.
ReaceWahea
Renee Watson
Dated: May 06, 2024
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Document Ref: EUKH3-AZCHC-C9UKS-5MTSV Page 1 of 1
Preview
FILED: NASSAU COUNTY CLERK 05/06/2024 01:48 PM INDEX NO. 607878/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 NEW YORK STATE SUPREME COURT NASSAU COUNTY --------------------------------------------------------------X RENEE WATSON, : : SUMMONS Plaintiff, : : Plaintiff designates v. : Nassau County : as the place of trial R & W LIVERY SERVICES, : : The basis of venue is: Defendant. : CPLR § 503(a) --------------------------------------------------------------X To the above-named Defendant: YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of appearance on counsel for Plaintiff within twenty (20) days after service of this summons, exclusive of the day of service (or within thirty (30) days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated: May 6, 2024 New York, New York MIZRAHI KROUB LLP By: Sagar K. Shah 225 Broadway, 39th Floor New York, NY 10003 Telephone: (212) 595-6200 sshah@mizrahikroub.com Counsel for Plaintiff 1 of 12 FILED: NASSAU COUNTY CLERK 05/06/2024 01:48 PM INDEX NO. 607878/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 NEW YORK STATE SUPREME COURT NASSAU COUNTY --------------------------------------------------------------X RENEE WATSON, : Index No.: : Plaintiff, : : VERIFIED COMPLAINT v. : : R & W LIVERY SERVICES, : Jury Trial Demanded : Defendant. : --------------------------------------------------------------X Plaintiff Renee Watson (“Plaintiff” or “Watson”) by and through her attorneys, Mizrahi Kroub, LLP, as and for her Complaint against Defendant R & W Livery Services (“R&W Livery” or “Defendant”) alleges as follows: PRELIMINARY STATEMENT 1. In the American workforce, there exist employers with iniquitous practices, which often results in employees blowing the whistle. Unfortunately, Defendant R&W Livery has treated its employees as nothing more than sub-human. Ms. Watson is one such employee who experienced humiliating and degrading circumstances while working for Defendant. 2. R&W Livery’s work environment is hostile to women and is permeated by unlawful conduct. Ms. Watson was left to fend for herself and was ultimately terminated in retaliation for her opposition to Defendant’s fraudulent and unlawful treatment of her. JURISDICTION AND VENUE 3. The Court has jurisdiction over this matter pursuant to Civil Practice Law and Rules (“CPLR”) § 301 because Defendant resides in New York. 4. Venue is proper in this County pursuant to CPLR § 503(a) because Defendant is located in Nassau County, New York. 2 2 of 12 FILED: NASSAU COUNTY CLERK 05/06/2024 01:48 PM INDEX NO. 607878/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 PARTIES 5. Plaintiff Watson is a former employee of R&W Livery. 6. Defendant R&W Livery is an employer formed under the law of the state of New York with its principal place of business in West Hempstead, New York. FACTUAL ALLEGATIONS 7. Beginning on January 10, 2023, R&W Livery employed Ms. Watson as a Personal Assistant in New York. 8. R&W Livery provides accessible transportation for individuals. Ms. Watson’s responsibilities included answering phones, scheduling patient pickups, and clerical work, among other tasks. 9. She accomplished her job admirably and with dedication. Unfortunately, once Ms. Watson objected to fraudulent billing practices and refused an order from Aline Frisch, R&W Livery’s owner, Ms. Frisch terminated her employment. 10. Ms. Watson’s employment with R&W Livery was difficult from the outset. She first spoke to Ms. Frisch during a phone call a few days after she started. 11. Ms. Frisch was extremely aggressive during this call and demanded that Ms. Watson relocate from New York to Florida for training. 12. Ms. Frisch told Ms. Watson that she needed to come to Florida so that Ms. Frisch could train her properly. Ms. Watson did as Ms. Frisch demanded and went to Florida as instructed. 13. From February 3 through February 5, 2023, Ms. Watson was in Florida for work. 14. Although Ms. Watson was scheduled to return home on February 5, 2023, Ms. Frisch extended Ms. Watson’s trip for an extra day. 15. During this trip, R&W Livery did not provide a hotel for Ms. Watson even though 3 3 of 12 FILED: NASSAU COUNTY CLERK 05/06/2024 01:48 PM INDEX NO. 607878/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 Ms. Watson was in Florida for work. Instead, Ms. Frisch forced Ms. Watson to stay with Ms. Frisch at her home. 16. Although Ms. Watson had travelled from New York to receive training in ambulatory services, she only received approximately one hour of training. The rest of Ms. Watson’s time was spent running personal errands for Ms. Frisch. 17. Ms. Watson’s days in Florida were spent at Ms. Frisch’s beck and call until it was bedtime and under duress because Ms. Frisch screamed and yelled at Ms. Watson regularly. 18. There were no set hours and Ms. Watson would regularly work 12-hour days. R&W Livery, however, only paid Ms. Watson for 8 hours each day. 19. In addition, because of her kosher dietary restrictions, Ms. Frisch restricted what Ms. Watson was allowed to eat because Ms. Watson could not bring non-kosher food into Ms. Frisch’s home. 20. In mid-February 2023, Ms. Frisch travelled to Israel. Because Ms. Frisch needed coverage during the time she was in Israel, Ms. Frisch forced Ms. Watson to come back to Florida on February 10, 2023, where Ms. Watson was again forced to stay in Ms. Frisch’s home and restricted from eating non-kosher food. 21. Once Ms. Watson arrived in Florida, Ms. Frisch told Ms. Watson that she would need to cover the New York office from Florida and also take care of Ms. Frisch’s two dogs. 22. Ms. Watson was in Florida through February 21, 2023. During this time, she was paid for only 45 hours — despite the fact that she worked 11 hours per day even on weekends through her departure – answering calls, walking Ms. Frisch’s dog and other tasks Ms. Frisch gave her. 23. Rather than paying overtime wages to Ms. Watson, Ms. Frisch improperly paid her as a “reimbursement” for her overtime hours. Ms. Frisch regularly paid Ms. Watson’s overtime 4 4 of 12 FILED: NASSAU COUNTY CLERK 05/06/2024 01:48 PM INDEX NO. 607878/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 hours as “reimbursements” in order to avoid paying her time and a half for overtime hours. 24. In addition, Ms. Watson felt uncomfortable because Ms. Frisch told Ms. Watson to bill an insurance provider for services that R&W Livery did not actually provide. 25. Ms. Frisch became angry that Ms. Watson was uncomfortable with this. In addition, Ms. Frisch put the patients in personal cars and Ubers which cost $80 on occasion, yet R&W Livery billed the patients $800 for ambulatory services. 26. One day while Ms. Frisch was in Israel, she demanded that Ms. Watson impersonate Ms. Frisch during a call with the Department of Motor Vehicles (“DMV”) to reset Ms. Frisch’s password because she needed to access her account. 27. Ms. Watson refused to do so because she felt it was improper. 28. Upon Ms. Watson’s refusal, Ms. Frisch immediately became infuriated and started berating her. From that point forward, Ms. Frisch continued to mistreat Ms. Watson. 29. On February 21, 2023, Ms. Watson returned home to New York from Florida on a flight that was scheduled to land at 11 p.m. 30. The next day, Ms. Watson notified Ms. Frisch via text message that she needed to miss work that day because she had an appointment. Ms. Frisch seemed to understand and allowed Ms. Watson to miss work that day. 31. On February 23, 2023, Ms. Watson was terminated. 32. Before she was terminated, Ms. Frisch lashed out and called Ms. Watson “a very emotional female.” 33. Ms. Frisch also told Ms. Watson that she did not like the way she worked for her, apparently in reference to Ms. Watson’s refusal to impersonate Ms. Frisch on the call with the DMV. 34. Later, another employee told Ms. Watson, “You don’t have to come in tomorrow, 5 5 of 12 FILED: NASSAU COUNTY CLERK 05/06/2024 01:48 PM INDEX NO. 607878/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 you don’t work here no more. Not sure why you don’t work here anymore, whatever happened in Florida, she doesn’t want you to come back.” 35. Ms. Watson is aware that Ms. Frisch instructed other staff members to make false statements alleging that Ms. Watson stole documents. 36. Ms. Watson is also aware that R&W Livery’s initial reason for terminating her employment was that Ms. Watson is a “a very emotional female,” but that R&W Livery has since given a new reason – that Ms. Watson missed work from February 20 through February 22, 2023. 37. Ms. Watson notified Ms. Frisch about her February 22, 2023 appointment, and Ms. Frisch approved and allowed the absence. 38. R&W Livery terminated Ms. Watson in retaliation for opposing R&W Livery’s and Ms. Frisch’s fraudulent and unlawful conduct. 39. After Ms. Watson voiced her concerns about the unlawful conduct occurring regularly at R&W Livery, she was terminated. 40. As a result of R&W Livery’s actions, Ms. Watson felt humiliated, degraded, embarrassed, and emotionally distressed. 41. Ms. Watson continues to suffer emotional distress as a result of R&W Livery’s treatment. FIRST CAUSE OF ACTION (Discrimination Under the NYSHRL) Against Defendant 42. Plaintiff hereby repeats and realleges each and every allegation in the preceding paragraphs as if set forth fully herein. 43. Defendant has discriminated against Plaintiff on the basis of her gender in violation of the NYSHRL by subjecting Plaintiff to disparate treatment based upon her gender including, but not limited to, discrimination, and a hostile work environment. 6 6 of 12 FILED: NASSAU COUNTY CLERK 05/06/2024 01:48 PM INDEX NO. 607878/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 44. As a direct and proximate result of Defendant’s unlawful discriminatory conduct in violation of the NYSHRL, Plaintiff has suffered, and continues to suffer, monetary and/or economic harm for which she is entitled to an award of monetary damages and other relief. 45. As a direct and proximate result of Defendant’s unlawful discriminatory conduct in violation of the NYSHRL, Plaintiff has suffered, and continues to suffer, severe mental anguish and emotional distress for which she is entitled to an award of monetary damages and other relief. SECOND CAUSE OF ACTION (Retaliation in Violation of NYSHRL) Against Defendant 46. Plaintiff hereby repeats, reiterates, and re-alleges the preceding as though set forth fully herein. 47. By the actions described above, Defendant retaliated against Plaintiff in violation of the NYSHRL after she complained of the discrimination perpetrated against her by Defendant. 48. As a direct and proximate result of Defendant’s unlawful retaliatory conduct in violation of the NYSHRL, Plaintiff has suffered, and continues to suffer, monetary and/or other economic harm for which she is entitled to an award of monetary damages and other relief. 49. As a direct and proximate result of Defendant’s unlawful retaliatory conduct in violation of the NYSHRL, Plaintiff has suffered, and continues to suffer, severe mental anguish and emotional distress for which she is entitled to an award of monetary damages and other relief. 7 7 of 12 FILED: NASSAU COUNTY CLERK 05/06/2024 01:48 PM INDEX NO. 607878/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 THIRD CAUSE OF ACTION (Violation of the NYLL § 740) Against Defendant 50. Plaintiff repeats, reiterates and re-alleges each and every allegation in all of the preceding paragraphs as if fully set forth herein. 51. New York Labor Law § 740 provides that “An employer shall not take any retaliatory action against an employee . . . because such employee . . . discloses, or threatens to disclose . . . an activity, policy or practice of the employer that the employee reasonably believes is in violation of law, rule or regulation or that the employee reasonably believes poses a substantial and specific danger to the public health or safety . . . or (c) objects to, or refuses to participate in any such activity, policy or practice. 52. By the conduct described above, in response to Plaintiff’s protected complaints and/or reports, Defendants subjected Plaintiff to a hostile work environment and the adverse employment actions set forth above. 53. The Defendant actively participated in and/or aided and abetted the unlawful conduct described herein. 54. Defendant’s retaliatory action was willful, malicious or wanton. 55. As a result of Defendant’s conduct, Plaintiff has suffered economic and noneconomic injury for which she is entitled to monetary and other damages in an amount to be determined at trial, together with an award of punitive damages in an amount to be determined at trial, and any and all other available relief including attorneys’ fees and costs. Plaintiff is entitled to any and all other available remedies and/or damages, including but not limited to punitive damages and attorneys’ fees and expenses. 8 8 of 12 FILED: NASSAU COUNTY CLERK 05/06/2024 01:48 PM INDEX NO. 607878/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 FOURTH CAUSE OF ACTION (Violation of the NYLL § 741) Against Defendant 56. Plaintiff hereby repeats, reiterates and re-alleges each and every allegation as contained in each of the preceding paragraphs as if fully set forth herein. 57. New York Labor Law § 741 provides that “no employer shall take retaliatory action against any employee because the employee . . . discloses or threatens to disclose to a supervisor . . . an activity, policy or practice of the employer or agent that the employee, in good faith, reasonably believes constitutes improper quality of patient care or improper quality of workplace safety . . . or objects to . . . any activity, policy or practice of the employer or agent that the employee, in good faith, reasonably believes constitutes improper quality of patient care or improper quality of workplace safety.” 58. By the conduct described above, in response to Plaintiff’s protected complaints and/or reports, Defendant subjected Plaintiff to a hostile work environment and the adverse employment actions set forth above. 59. The Defendant actively participated in and/or aided and abetted the unlawful conduct described herein. 60. As a result of Defendant’s conduct, Plaintiff has suffered economic and noneconomic injury for which she is entitled to monetary and other damages in an amount to be determined at trial, together with an award of punitive damages in an amount to be determined at trial, and any and all other available relief including attorneys’ fees and costs. PRAYER FOR RELIEF WHEREFORE, Plaintiff prays that the Court enter judgment in her favor and against Defendant, containing the following relief: 9 9 of 12 FILED: NASSAU COUNTY CLERK 05/06/2024 01:48 PM INDEX NO. 607878/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 A. A declaratory judgment that the actions, conduct and practices of Defendant complained of herein violate the laws of the State of New York; B. An injunction and order permanently restraining Defendant and their partners, officers, owners, officials, agents, successors, employees and/or representatives, and any and all persons acting in concert with and/or on behalf of them, from engaging in any such further unlawful conduct, including the policies and practices complained of herein; C. An award of damages against Defendant, or any jointly or severally liable entity or person, in an amount to be determined at trial, plus prejudgment interest, to compensate Plaintiff for all monetary and/or economic damages; D. An award of damages against Defendant, or any jointly or severally liable entity or person, in an amount to be determined at trial, plus prejudgment interest, to compensate Plaintiff for all non-monetary and/or compensatory damages, including, but not limited to, compensation for her physical injuries, mental anguish, psychological harm, and emotional distress; E. An award of punitive damages and any applicable penalties in an amount to be determined at trial; F. Prejudgment interest on all amounts due; G. An award of fees and costs that Plaintiff has incurred in this action, as well Plaintiff’s reasonable attorneys’ fees and costs to the fullest extent permitted by law; and, H. Such other and further relief as the Court may deem just and proper. 10 10 of 12 FILED: NASSAU COUNTY CLERK 05/06/2024 01:48 PM INDEX NO. 607878/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 JURY DEMAND Plaintiff hereby demands a trial by jury on all issues of fact and damages stated herein. Dated: May 6, 2024 New York, New York Respectfully submitted, MIZRAHI KROUB LLP By: Sagar K. Shah 225 Broadway, 39th Floor New York, NY 10007 Telephone: (212) 595-6200 sshah@mizrahikroub.com Counsel for Plaintiff 11 11 of 12 FILED: NASSAU COUNTY CLERK 05/06/2024 01:48 PM INDEX NO. 607878/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/06/2024 VERIFICATION RENEE WATSON, being duly sworn, deposes and says: I am the plaintiff in the above-entitled action. I have read the foregoing complaint and know the contents thereof. The same are true to my knowledge, except as to matters therein stated to be alleged on information and belief and as to those matters I believe them to be true. ReaceWahea Renee Watson Dated: May 06, 2024 12 12 of 12 Document Ref: EUKH3-AZCHC-C9UKS-5MTSV Page 1 of 1