Exhibit,Appendix: Robert Harris v. Intimo, Inc., Nathan Nathan, Tommy Nathan, Moris Zilkha, Prestige Employee Administrators, Inc. A/K/A Prestige Employee Administrators, Prestige Employee Administrators Ii, Inc. A/K/A Prestige Employee Administrators, John Does 1 - 10, Abc Corps. 1 - 8

On January 10, 2017 a Exhibit,Appendix was filed involving a dispute between Robert Harris, and Abc Corps. 1 - 8, Intimo, Inc., John Does 1 - 10, Moris Zilkha, Nathan Nathan, Prestige Employee Administrators Ii, Inc. A K A Prestige Employee Administrators, Prestige Employee Administrators, Inc. A K A Prestige Employee Administrators, Tommy Nathan, for Commercial - Contract in the District Court of New York County.

Preview
FILED: NEW YORK COUNTY CLERK 12/30/2019 05:37 PM INDEX NO. 650175/2017
NYSCEF DOC. NO. 147 RECEIVED NYSCEF: 12/30/2019

MEYERS FRIED-GRODIN, LLP
Empire State Building
350 Fifth Avenue, 59th Floor
New York, NY 10118
Phone: (646) 596-1292
E-mail: JMeyers@MfgLegal.com
Attorneys for Plaintiff Robert Harris

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------------------------------------------X
ROBERT HARRIS,
Plaintiff,
Index No. 650175/2017
vs.

INTIMO, INC., NATHAN NATHAN PLAINTIFF’S FIRST REQUEST
individually, TOMMY NATHAN, individually, FOR THE PRODUCTION OF
MORIS ZILKHA, individually, PRESTIGE DOCUMENTS DIRECTED TO
EMPLOYEE ADMINISTRATORS, INC. PRESTIGE EMPLOYEE
a/k/a PRESTIGE EMPLOYEE ADMINISTRATORS, INC. AND
ADMINISTRATORS, PRESTIGE EMPLOYEE PRESTIGE EMPLOYEE
ADMINISTRATORS II, INC. a/k/a PRESTIGE ADMINISTRATORS, INC. II
EMPLOYEE ADMINISTRATORS and JOHN
DOES 1-10, and ABC CORPS. 1-8,
fictitious names for persons or entities whose
present roles and identities are unknown,

Defendants.
--------------------------------------------------------------------------X
TO:
David B. Lichtenberg, Esq.
Eric T. Baginski, Esq.
Fisher & Phillips LLP
430 Mountain Avenue, Suite 303
Murray Hill, NJ 07974
(dlichtenberg@fisherphillips.com)
(ebaginski@fisherphillips.com)
Attorneys for the Prestige Defendants

COUNSEL:

PLEASE TAKE NOTICE that Plaintiff Robert Harris (“Mr. Harris” or “Plaintiff”),

pursuant to CPLR § 3102(a) and R 3120, hereby requests that Defendants produce for inspection

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and copying, by Plaintiff, at the offices of Meyers Fried-Grodin LLP, located at Empire State

Building 350 Fifth Avenue, 59th Floor New York, NY 10118, twenty (20) days of the service of

this Request, the documents and/or things that are set forth in the attached Schedule of

Documents.

This Request for Production shall be deemed to be continuing so as to require

supplemental production should Plaintiff or its counsel obtain further or supplemental documents

between the time that the documents are presented and the time of trial.

The Definitions section of Plaintiff’s First Set of Interrogatories is incorporated herein by

reference.

If any request for documents is deemed to call for the production of privileged materials

and such privilege is asserted, a list is to be furnished identifying each document so withheld

together with the following information:

(a) the privilege or other ground of nondisclosure asserted;

(b) a statement of facts constituting the basis for the claim of privilege or other

ground of nondisclosure;

(i) the date of the document;

(ii) the names of its author(s) or preparer(s) and an identification by

employment and title of each such person;

(iii) the names of each person who was sent or had access to or custody of the

document, together with an identification by employment of each such

person; and

(iv) the paragraph of this request to which the document relates.

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In lieu of appearing at the time and place specified above, Defendants may comply with

this Request by mailing legible copies of the documents described herein to the undersigned so

that they arrive at the offices of the undersigned on or before within twenty (20) days of the

service of this Request.

MEYERS FRIED-GRODIN LLP
Attorneys for Plaintiff Robert Harris

By: ______________________________
Jonathan Meyers, Esq.

Dated: October 30, 2019

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FILED: NEW YORK COUNTY CLERK 12/30/2019 05:37 PM INDEX NO. 650175/2017
NYSCEF DOC. NO. 147 RECEIVED NYSCEF: 12/30/2019

DEFINITIONS

The definitions of terms set forth herein shall apply to Plaintiff’s First Request for

Production of Documents directed to Defendants and to any other discovery requests that

Plaintiff serves on Defendants.

1. The term “communication” is defined as the transmittal of information, whether

written or verbal, in the form of facts, ideas, inquiries or otherwise.

2. The term “document” includes all written, typed, printed, recorded or graphic

statements, communications or other matters, however produced or reproduced, including, but

not limited to, all letters, memoranda, notes, e-mails, computer records, telegrams, telexes, faxes,

cables, telephone records, records, bills, invoices, ledgers, journals, bulletins, directives,

instructions, reports, memoranda of conversations, diaries, affidavits, briefs, pleadings, decrees,

transcriptions, summaries, computer records, recordings, diagrams, charts, drawings, graphs and

other writings. All originals, copies, drafts and non-identical copies in the possession, custody or

control of defendants or defendants’ representatives shall be treated as separate documents.

3. A document is within the “possession, custody or control” of defendants or

defendants’ representatives, if defendants or defendants’ representative has the right to secure the

document or a copy thereof from another person or entity having actual physical possession

thereof.

4. The term “person” is defined as any natural person or any business, corporation,

firm, partnership, proprietorship, joint venture, board, authority, commission, legal or

government entity or other association.

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5. The term “personnel file” or “personnel files” refers to any files designated as

being a personnel file and/or any documents or collection of documents regarding the hiring,

employment, and/or termination employees of either or bother of the defendants (including but

not limited to information regarding each such employee’s job application, resume, performance

history, evaluations, disciplinary history, attendance, history of promotions, history of

compensation, and the like).

6. “Identify”, “identification” and “identity” as used herein mean:

(a) with respect to a document:

(i) the type of document, whether a letter memorandum,

report, agreement, recording, notation, etc.;

(ii) any caption, heading and/or date shown on the face of the

document;

(iii) the identity of each individual who originated, initialed,

signed, authorized, prepared or received (and if the same

was done on behalf of any person, the identity of each such

person), or is in any way referred to in the document;

(iv) the number of pages if written or the approximate size or

length if recorded; and

(v) the general subject matter of the document.

(b) with respect to a natural person, his or her:

(i) full name;

(ii) occupation and employer, if any;

(iii) gender

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(iv) business and home address; and

(v) business and home telephone number and e-mail address.

(i) its full name;

(ii) the jurisdiction under whose laws it was organized;

(iii) its principal office address and telephone number; and

(iv) its principal officer or member known to you.

(d) with respect to an oral communication:

(i) the date and time it occurred;

(ii) the place where it occurred;

(iii) the complete substance of the communication;

(iv) the identity of each person:

(1) to whom such communication was made;

(2) by whom such communication was made;

(3) who was present when such communication was

made.

(v) if by telephone:

(1) the identity of each person:

(a) who made each telephone call;

(b) who participated in each call;

(2) the place where each person participating in each

call was located.

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(vi) the identity of all documents memorializing referring,

pertaining or relating in any way to the subject of the

communication.

7. The term “concerning” is defined as relating to, referring to, pertaining to,

alluding to, describing, detailing, embodying, evidencing, reflecting, comprising or constituting,

whether directly or indirectly, the subject matter identified in a specific interrogatory or

document request.

8. The terms “all” and “each” should be construed as all and each.

9. The terms “and” and “or” should be construed either disjunctively or

consecutively, as necessary to bring within the scope of each discovery request all responses or

documents which might otherwise be construed to be outside of its scope.

10. The use of the singular form of a word should be construed to include the plural

form and vice versa.

11. The use of the past tense form of a word should be construed to include the

present tense form and vice versa.

12. The term “Defendant,” “Defendants” or “you” refers to the party to whom these

discovery demands are directed, as well as that party’s employees, owners, agents, counsel,

contractors or servants of any kind, and any consultants, experts, investigators, agents,

representatives, or other persons acting on that party’s behalf.

13. The term “Prestige” refers collectively to defendants Prestige Employee

Administrators, Inc. and Prestige Employee Administrators II, Inc. and their subsidiaries,

affiliates, predecessor entities; their employees, owners, agents, counsel, contractors or servants

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of any kind; and any consultants, experts, investigators, agents, representatives, or other persons

acting on their behalf.

14. The term “you” refers to party responding to this discovery demand and any

consultants, experts, investigators, counsel, agents, representatives, or other persons acting on

their behalf.

15. The term “Plaintiff” refers to Robert Harris.

16. The term “Complaint” refers to the Complaint (and any subsequently-filed

complaint) that Plaintiff filed in this action, bearing Index No. 650175/2017.

17. The term “Answer” refers to the answer (and any other pleadings, e.g.

counterclaims) filed by Defendants in this action. The term “Answer” also refers to any Answers

that any of the Defendants may file at any point in the future.

18. The term “lawsuit” refers to the instant litigation between Plaintiff and

Defendants, bearing Index No. 650175/2017.

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NYSCEF DOC. NO. 147 RECEIVED NYSCEF: 12/30/2019

SCHEDULE OF DOCUMENTS

1. All documents that refer or relate in any way to the terms and conditions of

Plaintiff’s employment and/or application for employment, with any of the Defendants in this

case, including, but not limited to, offers of employment, job descriptions, contracts of

employment, non-disclosure agreements, and restrictive covenants;

2. All documents relating to Plaintiff’s i) job performance; ii) compensation; and iii)

benefits (including, without limitation, health insurance and any pension benefits/401(k)); and

iv) attendance.

3. All documents that refer or relate in any way to the evaluation, formal or

informal, of Plaintiff’s work as an employee of any of the Defendants in this case;

4. All documents that refer or relate in any way to the duties, obligations, and

requirements of Plaintiff’s employment or prospective employment with any of the Defendants

in this case;

5. All documents that refer or relate to any adverse employment decisions or actions

of any nature taken with respect to Plaintiff by any of the Defendants including, but not limited

to, any counseling and/or disciplinary actions, reprimands, warnings, termination of

employment, withdrawal of an offer of employment, and/or a refusal to hire Plaintiff;

6. With respect to the time period during which Plaintiff was employed by any of the

Defendants in this case, all documents that refer or relate to the Defendants’ employee policies,

including but not limited to, employee handbooks and personnel or human resource policies and

procedures;

7. All documents constituting, containing, describing, or relevant to communications

(whether written or oral or electronic) between any owner, officer, employee, or agent of any of

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Defendants and any person (including but not limited to Plaintiff, third parties, or others

employed by one or more of the Defendants) that refer or relate in any way to the allegations

contained in Plaintiff's Complaint and/or to the defenses raised by Defendants in their Answer;

8. All documents constituting, containing, describing, or relevant to communications

(whether written or oral or electronic) between any owner, officer, employee, or agent of any of

Defendants and any person (including but not limited to Plaintiff, third parties, or others

employed by one or more of the Defendants) that refer or relate in any way to the Plaintiff;

9. Any and all calendars, diaries, or notes of events maintained by any of the

Defendants that relate to the allegations contained in Plaintiff’s Complaint and/or to the defenses

raised in Defendants’ Answer;

10. All documents that support or refute the allegations set forth in the Plaintiff’s

Complaint and/or the defenses raised in Defendants’ Answer.

11. All documents that constitute or, refer to, or relate to reports provided to you by

any and all experts whom any of the Defendants have engaged, consulted with, or plan to use in

this case;

12. All documents any of the Defendants intend to introduce as exhibits at trial;

13. All documents constituting or relating to the training of Defendants’ employees

regarding how to identify employment discrimination and/or harassment (or hostile work

environment) and what an employee’s legal rights are in connection with anti-discrimination and

anti-harassment laws.

14. All documents constituting or relating to the training of Defendants’ employees,

supervisors, managers, owners, principals or others, with respect to how to respond to

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individuals who complain to management about what those individuals believe that they were

subjected to employment discrimination and/or harassment (or hostile work environment).

15. Any and all policies of Defendants regarding employment discrimination,

harassment, hostile work environment, and/or retaliation.

16. Any and all policies of Defendants regarding investigating allegations of

discrimination, harassment, a hostile work environment, and/or retaliation.

17. All documents constituting or relating to any investigation that was conducted

into the allegations set forth in Plaintiff’s Complaint (even if you learned about those allegations,

or substantially similar allegations, before receiving a copy of Plaintiff’s Complaint).

18. All Documents showing the organizational structure of Plaintiff’s job position(s) or

anticipated position(s) in relation to other job positions with any of the Defendants in this case.

19. Any and all Documents that evidence, refer, or relate to any internal complaints,

made to any of the Defendants, between January 1, 2009 and the present, in which any of the

Defendants’ employees, former employees, or job applicants alleged that they were subjected to

discrimination, harassment, a hostile work environment, retaliation and/or were not paid all

compensation they contended was owed to them.

20. Any and all Documents that evidence, refer, or relate to any complaints

(regardless of whether or not any formal complaints or charges were filed) with any court,

arbitrator, or alternative dispute resolution organization, between January 1, 2009 and the

present, in which any of the Defendants’ employees, former employees, or job applicants alleged

that they were subject to discrimination, harassment, a hostile work environment, retaliation

and/or were not paid all compensation they contended was owed to them.

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21. Any and all Documents that evidence, refer, or relate to any formal or informal

complaints and/or charges filed by or with the Equal Employment Opportunity Commission

(“EEOC”), New York City Commission on Human Rights (“NYCCHR”), New York State

Division on Human Rights (“NYSDHR”), New York Department of Labor (“NYDOL”), United

States Department of Labor (“USDOL”), the Occupational Safety and Health Commission

(“OSHA”), or any government agencies (in any state or locality), between January 1, 2009 and

the present, in which any of the Defendants’ employees, former employees, or job applicants

alleged that they were subjected to discrimination, harassment, a hostile work environment,

retaliation, and/or were not paid all compensation they contended was owed to them.

22. Any and all Documents that evidence, refer, or relate to any complaints

(regardless of whether or not any formal complaints or charges were filed) with any court,

arbitrator, or alternative dispute resolution organization, between January 1, 2009 and the

present, in which any of the Defendants’ employees, former employees, or others alleged that

they did not receive wages due, were not paid prevailing wage, were not properly paid overtime

and/or were not properly paid minimum wage.

23. Any and all Documents that evidence, refer, or relate to any formal or informal

complaints and/or charges filed by or with the NYDOL, USDOL or any government agencies (in

any state or locality), between January 1, 2009 and the present, in which any of the Defendants’

employees, former employees, or others alleged that they did not receive wages due, were not

paid prevailing wage, were not properly paid overtime and/or were not properly paid minimum

wage and/or were not paid any form of compensation they contended was owed to them.

24. Any and all documents that any of the Defendants submitted to, or received from,

the NYDOL in connection with any claim(s) for unemployment benefits made by Plaintiff.

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25. Any and all document retention policies that any of the Defendants have used

between January 1, 2009 and the present.

26. With respect to all persons whom Defendants expect to call as an expert witness,

a copy of i) all documents and things provided to and/or relied upon by these persons in

developing their opinions; ii) all reports, correspondence, notes and other things generated by

each person which relate to the subject matter of his/her testimony.

27. The complete personnel file of Nathan Nathan.

28. The complete personnel file of Tommy Nathan.

29. The complete personnel file of Moris Zilkha.

30. The complete personnel files of all employees of any of the Defendants in this

case who performed the same or similar job duties as Plaintiff between January 1, 2009 and the

present.

31. With respect to the time period of January 1, 2005 through the present, the

personnel files of all employees whose employment ended for the same reason that Plaintiff’s

ended.

32. The complete personnel file of Plaintiff.

33. The complete personnel file of the individual(s) who replaced Plaintiff or

assumed Plaintiff’s job responsibilities, after Plaintiff’s employment ended.

34. The complete personnel file of all of Plaintiff’s supervisors and/or of anyone with

authority to hire Plaintiff, fire Plaintiff, discipline Plaintiff, or affect the terms and conditions of

Plaintiff’s employment.

35. All documents memorializing or reflecting the reason why Plaintiff and/or any

other employees of any of the Defendants in this case who performed the same or similar job

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duties as Plaintiff between January 1, 2009 and the present were terminated, laid off, asked to

resign, or were otherwise involuntarily separated from their employment.

36. All documents memorializing or reflecting the reason why Plaintiff and/or any

other employees of any of the Defendants in this case who performed the same or similar job

duties as Plaintiff between January 1, 2009 and the present quit or otherwise voluntarily

separated from their employment, including but not limited to Exit Interviews.

37. All documents memorializing or reflecting the reason why Plaintiff and/or any

other employees of any of the Defendants in this case who performed the same or similar job

duties as Plaintiff between January 1, 2009 and the present were not terminated, laid off, asked to

resign, or be otherwise involuntarily separated from their employment.

38. All documents that relate in any manner to Plaintiff or the allegations in

Plaintiff’s Complaint or the defenses in Defendant’s Answer.

39. All documents you received from, or gave to Plaintiff regarding work Plaintiff

performed for any of the Defendants.

40. All statements, affidavits, certifications, and/or declarations obtained from any of

the Defendants’ employees, officers, and/or directors, or from any person or individual,

concerning the allegations set forth in Plaintiff’s Complaint or the defenses raised in Defendants’

Answer.

41. All of the Defendants’ financial records for the time period of January 1, 2016

through the present

42. With respect to the time period of January 1, 2016 through the present, all

documents concerning the financial condition, financial performance profitability or lack or

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profitability of Defendants, including, but not limited to, financial statements, compilations,

auditor reports, profit and loss statements, annual reports, 10-K statements, and balance sheets.

43. All documents that reflect policies or procedures that Plaintiff allegedly violated.

44. All documents that reflect the reason Plaintiff was suspended, terminated or had a

job offer withdrawn, or was not hired, or was not considered for a transfer or for employment in

a different position.

45. All documents showing the compensation that any of the Defendants in this case

paid to Plaintiff, including but not limited to all payroll records, payroll registers, paystubs,

paychecks, receipts, and ledgers and W-2 or 1099 forms.

46. Plaintiff’s job description or job descriptions.

47. All documents that show, state, or reflect the ownership or control relationships

between each of the Defendants and: (i) one another; and (ii) any other person(s), entity(ies),

and/or individual(s).

48. All documents that show, state, or reflect any change in ownership or control over

Prestige Employee Administrators, Inc. between January 1, 2009 and the present.

49. All documents that show, state, or reflect any change in ownership or control over

Prestige Employee Administrators II, Inc. between January 1, 2009 and the present

50. All documents that show, state, or reflect communications between any of the

Defendants and Plaintiff.

51. Any insurance agreements which would indemnify or reimburse any of the

Defendants for payments made to satisfy any judgment or settlement obtained in this matter.

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52. Any and all Documents that any of the Defendants, or anyone acting on any of the

Defendants’ behalf, submitted to, or received from, any insurance carrier(s) relating to Plaintiff

and/or Plaintiff’s allegations in this lawsuit.

53. All documents (including but not limited to meeting minutes, e-mails, notices,

video recordings, and/or anything else) relating to any and all meetings in which management

discussed Plaintiff’s allegations of discrimination with anyone at all.

54. All communications (including but not limited to e-mails, text messages, Outlook

calendar notices, letters, memoranda and/or anything else) to or from Plaintiff.

55. All communications (including but not limited to e-mails, text messages, Outlook

calendar notices, letters, memoranda and/or anything else) regarding Plaintiff.

56. All communications (including but not limited to e-mails, text messages, Outlook

calendar notices, letters, memoranda and/or anything else) regarding the allegations in Plaintiff’s

Complaint.

57. All communications (including but not limited to e-mails, text messages, Outlook

calendar notices, letters, memoranda and/or anything else) regarding the defenses in Defendants’

Answer.

58. All agreements between Prestige Employee Administrators, Inc. and Intimo, Inc.

(or any other person or entity named as a defendant in this lawsuit).

59. All agreements between Prestige Employee Administrators II, Inc. and Intimo,

Inc. (or any other person or entity named as a defendant in this lawsuit).

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60. All posters, signs, handouts and/or other documents concerning the New York

Labor Law, the Fair Labor Standards Act and/or any other wage and hour laws that were made

available to and/or provided to employees from January 1, 2009 through the present.

61. All company credit card statements for Plaintiff’s company credit card (believed

to be an American Express card), between January 1, 2010 through the present.

62. All documents identifying each and every individual who had authority and/or

control over the payment of compensation to Plaintiff.

63. All documents identifying each and every individual who had authority and/or

control over setting or agreeing to the compensation arrangements with Plaintiff.

64. The complete personnel file of Lynette Dunsworth.

65. The complete personnel file of Sarah Daitzman.

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AFFIRMATION OF SERVICE

Jonathan Meyers, an attorney of full age and duly admitted to practice before the courts

of this State, hereby affirms under the penalties of perjury:

1. I am an attorney-at-law admitted to practice before this Court and am a partner in

Meyers Fried-Grodin, LLP, attorneys for Plaintiff Robert Harris.

2. I am not a party to this action, am over 18 years of age, and my business address

is Meyers Fried-Grodin, LLP, Empire State Building, 350 Fifth Avenue, 59 th Floor, New York,

NY 10118.

3. On October 30, 2019, I served the attached PLAINTIFF’S FIRST REQUEST

FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS PRESTIGE

EMPLOYEE ADMINISTRATORS, INC. AND PRESTIGE EMPLOYEE

ADMINISTRATORS II, INC. on the parties listed below by sending a copy to their counsel

via prepaid by electronic mail and first class mail, in a sealed envelope addressed as follows,

which addresses were designated by the attorneys for such purpose:

David B. Lichtenberg, Esq.
Eric T. Baginski, Esq.
Fisher & Phillips LLP
430 Mountain Avenue, Suite 303
Murray Hill, NJ 07974
(dlichtenberg@fisherphillips.com)
(ebaginski@fisherphillips.com)
Attorneys for the Prestige Defendants

October 30, 2019

______________________________
JONATHAN MEYERS

Case Info

Judge

Nancy M. Bannon Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

December 30, 2019

Case Filing Date

January 10, 2017

County

Parties

ABC Corps. 1 - 8 Defendant
BAGINSKI, ERIC TADEUSZ Attorney for the Defendants
Intimo, Inc. Defendant
John Does 1 - 10 Defendant
LICHTENBERG, DAVID B. Attorney for the Defendant
LICHTENBERG, DAVID B. Attorney for the Defendants
MARCUS, SETH L Attorney for the Defendant
MARCUS, SETH L Attorney for the Defendants
MEYERS, JONATHAN Attorney for the Plaintiff
Moris Zilkha Defendant
Nathan Nathan Defendant
Prestige Employee Administrators II, Inc. a/k/a Prestige Employee Administrators Defendant
Prestige Employee Administrators, Inc. a/k/a Prestige Employee Administrators Defendant
Robert Harris Plaintiff
Tommy Nathan Defendant
JONATHAN MEYER Attorneys for Plaintiffs
Jessica Meyers Attorneys for Plaintiffs
ERIC TANT Attorneys for Defendants

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