Preview
FILED: BRONX COUNTY CLERK 04/22/2024 03:42 PM INDEX NO. 807857/2023E
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 04/22/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX
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STACY ROUDABUSH, Index No. 807857/2023
Plaintiff, PLAINTIFF’S FIRST SET OF
-against- DOCUMENT DEMANDS TO
DEFENDANTS
ALBERT EINSTEIN COLLEGE OF MEDICINE OF
YESHIVA UNIVERSITY and KAMRAN
KHODAKHAH, Individually,
Defendants.
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TO DEFENDANTS AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that pursuant to CPLR § 3120, Plaintiff requests that
Defendant produce to Plaintiff, the documents and tangible things described below, within twenty
(20) days of service upon you, at the offices of PHILLIPS & ASSOCIATES, Attorneys at Law,
PLLC, 45 Broadway, Suite 430, New York, New York 10006.
INSTRUCTIONS
The following instructions are to be considered applicable to this request with respect
to each document sought herein:
1. ORIGINAL DOCUMENTS
In producing these documents, you are requested to produce originals, not copies, of the
documents requested. You are also requested to furnish all documents known or available to you,
regardless of whether these documents are held or produced directly by you or your agent,
employees, representatives, investigators, partners, or by your attorneys or their agents, employees,
representatives or investigators. The documents which are sought by this request for production
shall include not only those documents which are in the dominion or control of yourself, or your
representatives or agents, but also those which are held by anyone on your behalf, and not merely
such documents as are known to you of your own personal knowledge.
2. COPIES
If a document was prepared in several copies, or if additional copies were thereafter made,
and if such copies are not identical or are no longer identical by reason of subsequent notations or
modifications of any kind whatsoever, including without limitation, notations on the front and the
back of the pages thereof, then each such non-identical copy is a separate document and must be
produced.
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3. PRIVILEGES
In the event that you seek to withhold any documents on the basis that it is properly entitled
to limitation of discovery, or is subject to a privilege, please identify each such document withheld
by providing the following information:
A. The date of the document;
B. The subject to which the document relates;
C. The author of the document, and the author’s address;
D. The name of the recipient, addressee, or party for whom such document was
intended, and the name of all other persons to whom the document or copies thereof
were furnished, as well as those to whom it, or copies thereof, became available at
any time, together with the job title and address of each person so identified; and,
E. The basis for the privilege. If you assert a privilege as to any portion of any
categories of materials described herein, please produce the remainder of that
category as to which you do not assert a privilege.
4. LOST DOCUMENTS OR THINGS
If any document to be produced was, but is no longer in your possession and control, or is
no longer in existence, state whether it is:
(1) Missing or lost, destroyed or transferred voluntarily or involuntarily to others, and
if so, to whom; or how otherwise disposed of; and,
(2) For each such instance, explain the circumstances surrounding the authorization for
such disposition; the person authorizing such disposition; and the date of such
disposition.
5. DEFINITIONS
A. As used in this Request, the term “document” means, without limitation, the
following items: printed, recorded or produced by mechanical or computer-
generated process, or written or produced by hand, and includes without limitation,
handwritings, typewriting, printing, photo stating, photographing and every other
means of recording or preserving a verbatim summary or record of any form of
communication or representation, including letters, words, pictures, sounds,
symbols or any combination thereof and/or all transcript copies thereof; all records,
reports, papers, documents, books, logs, diaries, calendars letters, notes,
memoranda, agreements, communications, brochures, correspondence, telegrams,
computer diskettes, copies of computer diskettes, computer print-outs in any form,
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summaries of records of telephone conversations, summaries of records of
meetings or conferences, summaries of reports of investigations, paste-ups, layouts,
mock-ups statements, receipts, invoices, records of account and other writings.
B. The terms “refer or relating to” mean connected with, reflecting, having an
association with, depicting, illustrating, discussing, mentioning or otherwise having
some direct or indirect relation to the allegations contained in Plaintiff’s Complaint
in this matter.
C. “Defendant,” shall mean Defendants, servants, agents, employees,
representatives, divisions, attorneys, and anyone else acting on its behalf.
D. “You” shall mean and include Defendants, their agents, representatives, and
employees.
E. “Plaintiff” shall mean Plaintiff in the herein action.
F. “Communications” shall mean any oral or written statement, dialogue, colloquy,
discussion, conversation, or direct or indirect representation and, also, means any
transfer of thoughts or ideas between persons by means of documents and includes
any transfer of data from one location to another by electronic or similar means.
G. “Concerning” shall mean relating to, referring to, describing, evidencing, or
constituting.
H. “And/Or” The connectives “and” and “or” shall be construed either disjunctively
or conjunctively as necessary to bring within the scope of the discovery request all
responses.
I. “All/Each.” The terms “all” and “each” shall be construed as all and each.
DOCUMENT REQUESTS
1. Any and all Documents identifying the nature of Defendants’ operations, the physical
locations, and the corporate organizational structure, including the owners, shareholders,
directors, and all others who have any responsibility for the development of policy.
2. Any and all organizational charts for Defendants’ Biomedical Sciences PhD Program
(“PhD Program”), personnel charts, descriptions, lists, tables, flow charts or other similar
documents in the possession of Defendants that show the identities, titles or responsibilities
of each person responsible in any manner for personnel, recruitment, hiring, selection,
training, disciplining, demoting, terminating.
3. The complete personnel file of Plaintiff, as a student employee, including jacket of the file,
employment application, resume, completed job application, acknowledgments of receipt
of employment handbook and other documents, performance evaluations, written
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warnings, complaints, reprimands, and salary and benefit information.
4. Any and all documents which relate, pertain, or illustrate Plaintiff’s performance reviews
as both an employee and a student, while in the PhD Program.
5. Any and all written and/or oral contracts or agreements entered into between Defendants
and Plaintiff.
6. Any and all documents including, but not limited to, any employee handbooks that relate
or pertain to any of Defendants’ policies regarding gender discrimination, sexual
harassment, and/or retaliation, Defendants’ Human Resources policies, and any other
relevant policies which were in effect during Plaintiff’s employment with Defendants.
7. Any and all documents that relate or pertain to any of the Defendants’ code of conduct
policies, including but not limited to, discrimination, sexual harassment and retaliation.
8. Any and all documents that relate or pertain to any written statements or declarations
(signed or unsigned), made by any person which mentions, discusses or refers to Plaintiff.
9. The complete personnel file of Defendant KAMRAN KHODAKHAH, including jacket of
the file, employment application, resume, completed job application, acknowledgments of
receipt of employment handbook and other documents, performance evaluations, written
warnings, complaints, reprimands, and salary and benefit information.
10. Any and all documents that relate, pertain, or describe the process for assigning a mentor
to a student in Plaintiff’s position during the time Plaintiff was enrolled in the PhD
Program.
11. Any and all documents Defendants relied on to determine that Plaintiff could not continue
her course of study in the PhD Program.
12. Any and all documents which describe or pertain to Plaintiff’s job description, work duties,
and/or responsibilities of the position held by Plaintiff during her employment with
Defendants.
13. Any and all Documents that indicate the number of mentors in the PhD Program each year
from 2015 to the present.
14. Any and all documents which illustrate, relate, or pertain to the number of students in the
PhD program each year from 2015 to the present.
15. Any and all documents which illustrate, relate, or pertain to the students who were
supposed to graduate or receive a PhD but did not within the PhD Program each year from
2015 to the present.
16. Any and all documents that relate or pertain to any conversations or communications by,
among, or between Defendant KAMRAN KHODAKHAH and any past or present
employees, officers, agents or directors of Defendants relating to Plaintiff’s employment
with Defendants, or Plaintiff’s enrollment in the PhD Program, including but not limited
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to, text messages, emails, private social media messages, or other electronic
communications.
17. Any and all documents that relate or pertain to any conversations or communications by,
among, or between Bryen Jordan and any past or present employees, officers, agents or
directors of Defendants relating to Plaintiff’s employment with Defendants, or Plaintiff’s
enrollment in the PhD Program, including but not limited to, text messages, emails, private
social media messages, or other electronic communications.
18. Any and all documents that relate or pertain to any conversations or communications by,
among, or between Victoria Freedman and any past or present employees, officers, agents
or directors of Defendants relating to Plaintiff’s employment with Defendants, or
Plaintiff’s enrollment in the PhD Program, including but not limited to, text messages,
emails, private social media messages, or other electronic communications.
19. Any and all documents that relate or pertain to any conversations or communications by,
among, or between Defendants’ former and/or current employees, and any past or present
employees, officers, agents or directors of Defendants relating to Plaintiff’s employment
with Defendants, or Plaintiff’s enrollment in the PhD Program, including but not limited
to, text messages, emails, private social media messages, or other electronic
communications.
20. Any and all documents in Defendants’ possession which in any way relate or pertain to the
reason Plaintiff was removed from the PhD Program, including but not limited to e-mails
or other electronic documentation.
21. Any and all documents which relate or pertain to Plaintiff’s anonymous complaint
submitted in November 2015.
22. Any and all documents which relate or pertain to Plaintiff’s complaint to Defendants’
Human Resources Department submitted in November 2015.
23. Any and all documents which relate or pertain to the reason that Plaintiff was allegedly
prevented from joining Dr. Costa Dobrenis’s laboratory in Spring 2016.
24. Any and all documents which relate or pertain to the reason that Plaintiff was allegedly
prevented from joining Dr. Costa Dobrenis’s laboratory in September 2016.
25. Any and all documents which relate or pertain to the reason Plaintiff was placed on
academic probation in February 2021.
26. Any and all documents which relate, describe, or memorialize the meeting held by the
Student Advisory Committee in March 2021 to discuss Plaintiff’s academic probation.
27. Any and all emails sent by Victoria Freedman to Plaintiff on or about March 24, 2021,
concerning Plaintiff’s removal from the PhD program.
28. Any and all documents which relate or pertain to the reasons Plaintiff was removed from
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the PhD Program.
29. Any and all photographs, negatives, recordings and/or videotapes, edited and unedited,
which relate or pertain to the allegations in the Complaint, Defendants’ defenses, and/or of
Plaintiff.
30. Any and all documents, including electronic communications (i.e. texts or emails) in
Defendants’ possession, which discuss or reference in any way Plaintiff’s academic
probation.
31. Any and all documents that relate or pertain to any complaints, charges, reports or
allegations, whether oral or written, formal or informal, of gender discrimination, sexual
harassment, and/or retaliation which were made by any person, including but not limited
to employees, residents, volunteers, students, and/or customers of Defendants between
2015 and the present.
32. Any and all documents that relate or pertain to complaints, formal or informal, filed or
grieved against Defendant KAMRAN KHODAKHAH at any time between 2015 and the
present, including but not limited to any and all investigations that occurred as a result.
33. Any and all social media posts made by Defendants, including but not limited to Facebook,
Instagram, Twitter, Snapchat, MySpace and/or Tik Tok relating to Plaintiff.
34. Any and all documents that relate or pertain to any non-privileged investigations performed
by Defendants following Plaintiff’s claims of discrimination or retaliation.
35. Any and all documents that relate or pertain to any and all complaints, filed against
Defendants by any person, including but not limited to current and former employees,
applicants for employments, and customers of Defendants, with the Equal Employment
Opportunity Commission, the New York State Division of Human Rights, the New York
City Human Rights Commission, or any other Court, tribunal or administrative agency,
alleging gender discrimination, sexual harassment and/or retaliation within the last five (5)
years. This request includes any and all documents submitted to and/or obtained from any
of the above listed entities concerning Plaintiff.
36. Any and all documents that relate or pertain to any anti-gender-discrimination training
conducted by Defendants for employees within the last five (5) years.
37. Any and all documents that relate or pertain to any anti-sexual harassment training
conducted by Defendants for employees within the last five (5) years.
38. Any and all documents or correspondence concerning any expert witness Defendant
engaged with respect to this action, including any reports setting forth the expert’s opinions
and the basis for said opinions, as well as full and complete disclosure as required by
statute.
39. Any and all documents which reflect the yearly gross revenue for Defendant ALBERT
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EINSTEIN COLLEGE OF MEDICINE OF YESHIVA UNIVERSITY s from 2019 to the
present (including, but not limited to, tax filings and income statements).
40. Any insurance policies that may provide coverage for this action.
41. Any and all documents describing, constituting, summarizing, supporting and/or referring
to Defendants’ affirmative defenses to Plaintiff’s Complaint as set forth in Defendants’
Answer.
42. Any and all documents identified in Defendants’ Responses to Plaintiff’s First Set of
Interrogatories.
43. Any and all documents that Defendants deem unresponsive to the foregoing requests but
that are nonetheless somehow relevant to Plaintiff’s employment with Defendants,
including but not limited to her training, compensation, discipline, counseling, leave,
transfer, assignment, definition of position, investigations, evaluations, hiring or firing.
44. Any and all documents in Defendants’ possession that are relevant to this action but have
not been produced from the above document requests.
PLEASE TAKE NOTICE: This is a continuing request and Plaintiff reserves the right to
renew or make additional requests prior to the close of discovery.
Dated: April 3, 2024
New York, NY
PHILLIPS & ASSOCIATES,
ATTORNEYS AT LAW, PLLC
By: ___________________________
Zachary Randall
Sara R. Callow
Attorneys for Plaintiff
45 Broadway, Suite 430
New York, New York 10006
T: (212) 248-7431
F: (212) 901-2107
zrandall@tpglaws.com
scallow@tpglaws.com
TO: James Bryton
William Anthony
Littler Mendelson P.C.
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Attorneys for Defendant
Albert Einstein College Of Medicine Of
Yeshiva University
900 3rd Ave, New York
New York 10022
Nicole Callahan
Attorneys for Defendant
Kamran Khodakhah
445 Hamilton Avenue
Suite 1102
White Plains, NY 10601
(718) 889-3761
Page 8 of 8
Preview
FILED: BRONX COUNTY CLERK 04/22/2024 03:42 PM INDEX NO. 807857/2023E NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 04/22/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX -----------------------------------------------------------------X STACY ROUDABUSH, Index No. 807857/2023 Plaintiff, PLAINTIFF’S FIRST SET OF -against- DOCUMENT DEMANDS TO DEFENDANTS ALBERT EINSTEIN COLLEGE OF MEDICINE OF YESHIVA UNIVERSITY and KAMRAN KHODAKHAH, Individually, Defendants. -----------------------------------------------------------------X TO DEFENDANTS AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that pursuant to CPLR § 3120, Plaintiff requests that Defendant produce to Plaintiff, the documents and tangible things described below, within twenty (20) days of service upon you, at the offices of PHILLIPS & ASSOCIATES, Attorneys at Law, PLLC, 45 Broadway, Suite 430, New York, New York 10006. INSTRUCTIONS The following instructions are to be considered applicable to this request with respect to each document sought herein: 1. ORIGINAL DOCUMENTS In producing these documents, you are requested to produce originals, not copies, of the documents requested. You are also requested to furnish all documents known or available to you, regardless of whether these documents are held or produced directly by you or your agent, employees, representatives, investigators, partners, or by your attorneys or their agents, employees, representatives or investigators. The documents which are sought by this request for production shall include not only those documents which are in the dominion or control of yourself, or your representatives or agents, but also those which are held by anyone on your behalf, and not merely such documents as are known to you of your own personal knowledge. 2. COPIES If a document was prepared in several copies, or if additional copies were thereafter made, and if such copies are not identical or are no longer identical by reason of subsequent notations or modifications of any kind whatsoever, including without limitation, notations on the front and the back of the pages thereof, then each such non-identical copy is a separate document and must be produced. Page 1 of 8 FILED: BRONX COUNTY CLERK 04/22/2024 03:42 PM INDEX NO. 807857/2023E NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 04/22/2024 3. PRIVILEGES In the event that you seek to withhold any documents on the basis that it is properly entitled to limitation of discovery, or is subject to a privilege, please identify each such document withheld by providing the following information: A. The date of the document; B. The subject to which the document relates; C. The author of the document, and the author’s address; D. The name of the recipient, addressee, or party for whom such document was intended, and the name of all other persons to whom the document or copies thereof were furnished, as well as those to whom it, or copies thereof, became available at any time, together with the job title and address of each person so identified; and, E. The basis for the privilege. If you assert a privilege as to any portion of any categories of materials described herein, please produce the remainder of that category as to which you do not assert a privilege. 4. LOST DOCUMENTS OR THINGS If any document to be produced was, but is no longer in your possession and control, or is no longer in existence, state whether it is: (1) Missing or lost, destroyed or transferred voluntarily or involuntarily to others, and if so, to whom; or how otherwise disposed of; and, (2) For each such instance, explain the circumstances surrounding the authorization for such disposition; the person authorizing such disposition; and the date of such disposition. 5. DEFINITIONS A. As used in this Request, the term “document” means, without limitation, the following items: printed, recorded or produced by mechanical or computer- generated process, or written or produced by hand, and includes without limitation, handwritings, typewriting, printing, photo stating, photographing and every other means of recording or preserving a verbatim summary or record of any form of communication or representation, including letters, words, pictures, sounds, symbols or any combination thereof and/or all transcript copies thereof; all records, reports, papers, documents, books, logs, diaries, calendars letters, notes, memoranda, agreements, communications, brochures, correspondence, telegrams, computer diskettes, copies of computer diskettes, computer print-outs in any form, Page 2 of 8 FILED: BRONX COUNTY CLERK 04/22/2024 03:42 PM INDEX NO. 807857/2023E NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 04/22/2024 summaries of records of telephone conversations, summaries of records of meetings or conferences, summaries of reports of investigations, paste-ups, layouts, mock-ups statements, receipts, invoices, records of account and other writings. B. The terms “refer or relating to” mean connected with, reflecting, having an association with, depicting, illustrating, discussing, mentioning or otherwise having some direct or indirect relation to the allegations contained in Plaintiff’s Complaint in this matter. C. “Defendant,” shall mean Defendants, servants, agents, employees, representatives, divisions, attorneys, and anyone else acting on its behalf. D. “You” shall mean and include Defendants, their agents, representatives, and employees. E. “Plaintiff” shall mean Plaintiff in the herein action. F. “Communications” shall mean any oral or written statement, dialogue, colloquy, discussion, conversation, or direct or indirect representation and, also, means any transfer of thoughts or ideas between persons by means of documents and includes any transfer of data from one location to another by electronic or similar means. G. “Concerning” shall mean relating to, referring to, describing, evidencing, or constituting. H. “And/Or” The connectives “and” and “or” shall be construed either disjunctively or conjunctively as necessary to bring within the scope of the discovery request all responses. I. “All/Each.” The terms “all” and “each” shall be construed as all and each. DOCUMENT REQUESTS 1. Any and all Documents identifying the nature of Defendants’ operations, the physical locations, and the corporate organizational structure, including the owners, shareholders, directors, and all others who have any responsibility for the development of policy. 2. Any and all organizational charts for Defendants’ Biomedical Sciences PhD Program (“PhD Program”), personnel charts, descriptions, lists, tables, flow charts or other similar documents in the possession of Defendants that show the identities, titles or responsibilities of each person responsible in any manner for personnel, recruitment, hiring, selection, training, disciplining, demoting, terminating. 3. The complete personnel file of Plaintiff, as a student employee, including jacket of the file, employment application, resume, completed job application, acknowledgments of receipt of employment handbook and other documents, performance evaluations, written Page 3 of 8 FILED: BRONX COUNTY CLERK 04/22/2024 03:42 PM INDEX NO. 807857/2023E NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 04/22/2024 warnings, complaints, reprimands, and salary and benefit information. 4. Any and all documents which relate, pertain, or illustrate Plaintiff’s performance reviews as both an employee and a student, while in the PhD Program. 5. Any and all written and/or oral contracts or agreements entered into between Defendants and Plaintiff. 6. Any and all documents including, but not limited to, any employee handbooks that relate or pertain to any of Defendants’ policies regarding gender discrimination, sexual harassment, and/or retaliation, Defendants’ Human Resources policies, and any other relevant policies which were in effect during Plaintiff’s employment with Defendants. 7. Any and all documents that relate or pertain to any of the Defendants’ code of conduct policies, including but not limited to, discrimination, sexual harassment and retaliation. 8. Any and all documents that relate or pertain to any written statements or declarations (signed or unsigned), made by any person which mentions, discusses or refers to Plaintiff. 9. The complete personnel file of Defendant KAMRAN KHODAKHAH, including jacket of the file, employment application, resume, completed job application, acknowledgments of receipt of employment handbook and other documents, performance evaluations, written warnings, complaints, reprimands, and salary and benefit information. 10. Any and all documents that relate, pertain, or describe the process for assigning a mentor to a student in Plaintiff’s position during the time Plaintiff was enrolled in the PhD Program. 11. Any and all documents Defendants relied on to determine that Plaintiff could not continue her course of study in the PhD Program. 12. Any and all documents which describe or pertain to Plaintiff’s job description, work duties, and/or responsibilities of the position held by Plaintiff during her employment with Defendants. 13. Any and all Documents that indicate the number of mentors in the PhD Program each year from 2015 to the present. 14. Any and all documents which illustrate, relate, or pertain to the number of students in the PhD program each year from 2015 to the present. 15. Any and all documents which illustrate, relate, or pertain to the students who were supposed to graduate or receive a PhD but did not within the PhD Program each year from 2015 to the present. 16. Any and all documents that relate or pertain to any conversations or communications by, among, or between Defendant KAMRAN KHODAKHAH and any past or present employees, officers, agents or directors of Defendants relating to Plaintiff’s employment with Defendants, or Plaintiff’s enrollment in the PhD Program, including but not limited Page 4 of 8 FILED: BRONX COUNTY CLERK 04/22/2024 03:42 PM INDEX NO. 807857/2023E NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 04/22/2024 to, text messages, emails, private social media messages, or other electronic communications. 17. Any and all documents that relate or pertain to any conversations or communications by, among, or between Bryen Jordan and any past or present employees, officers, agents or directors of Defendants relating to Plaintiff’s employment with Defendants, or Plaintiff’s enrollment in the PhD Program, including but not limited to, text messages, emails, private social media messages, or other electronic communications. 18. Any and all documents that relate or pertain to any conversations or communications by, among, or between Victoria Freedman and any past or present employees, officers, agents or directors of Defendants relating to Plaintiff’s employment with Defendants, or Plaintiff’s enrollment in the PhD Program, including but not limited to, text messages, emails, private social media messages, or other electronic communications. 19. Any and all documents that relate or pertain to any conversations or communications by, among, or between Defendants’ former and/or current employees, and any past or present employees, officers, agents or directors of Defendants relating to Plaintiff’s employment with Defendants, or Plaintiff’s enrollment in the PhD Program, including but not limited to, text messages, emails, private social media messages, or other electronic communications. 20. Any and all documents in Defendants’ possession which in any way relate or pertain to the reason Plaintiff was removed from the PhD Program, including but not limited to e-mails or other electronic documentation. 21. Any and all documents which relate or pertain to Plaintiff’s anonymous complaint submitted in November 2015. 22. Any and all documents which relate or pertain to Plaintiff’s complaint to Defendants’ Human Resources Department submitted in November 2015. 23. Any and all documents which relate or pertain to the reason that Plaintiff was allegedly prevented from joining Dr. Costa Dobrenis’s laboratory in Spring 2016. 24. Any and all documents which relate or pertain to the reason that Plaintiff was allegedly prevented from joining Dr. Costa Dobrenis’s laboratory in September 2016. 25. Any and all documents which relate or pertain to the reason Plaintiff was placed on academic probation in February 2021. 26. Any and all documents which relate, describe, or memorialize the meeting held by the Student Advisory Committee in March 2021 to discuss Plaintiff’s academic probation. 27. Any and all emails sent by Victoria Freedman to Plaintiff on or about March 24, 2021, concerning Plaintiff’s removal from the PhD program. 28. Any and all documents which relate or pertain to the reasons Plaintiff was removed from Page 5 of 8 FILED: BRONX COUNTY CLERK 04/22/2024 03:42 PM INDEX NO. 807857/2023E NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 04/22/2024 the PhD Program. 29. Any and all photographs, negatives, recordings and/or videotapes, edited and unedited, which relate or pertain to the allegations in the Complaint, Defendants’ defenses, and/or of Plaintiff. 30. Any and all documents, including electronic communications (i.e. texts or emails) in Defendants’ possession, which discuss or reference in any way Plaintiff’s academic probation. 31. Any and all documents that relate or pertain to any complaints, charges, reports or allegations, whether oral or written, formal or informal, of gender discrimination, sexual harassment, and/or retaliation which were made by any person, including but not limited to employees, residents, volunteers, students, and/or customers of Defendants between 2015 and the present. 32. Any and all documents that relate or pertain to complaints, formal or informal, filed or grieved against Defendant KAMRAN KHODAKHAH at any time between 2015 and the present, including but not limited to any and all investigations that occurred as a result. 33. Any and all social media posts made by Defendants, including but not limited to Facebook, Instagram, Twitter, Snapchat, MySpace and/or Tik Tok relating to Plaintiff. 34. Any and all documents that relate or pertain to any non-privileged investigations performed by Defendants following Plaintiff’s claims of discrimination or retaliation. 35. Any and all documents that relate or pertain to any and all complaints, filed against Defendants by any person, including but not limited to current and former employees, applicants for employments, and customers of Defendants, with the Equal Employment Opportunity Commission, the New York State Division of Human Rights, the New York City Human Rights Commission, or any other Court, tribunal or administrative agency, alleging gender discrimination, sexual harassment and/or retaliation within the last five (5) years. This request includes any and all documents submitted to and/or obtained from any of the above listed entities concerning Plaintiff. 36. Any and all documents that relate or pertain to any anti-gender-discrimination training conducted by Defendants for employees within the last five (5) years. 37. Any and all documents that relate or pertain to any anti-sexual harassment training conducted by Defendants for employees within the last five (5) years. 38. Any and all documents or correspondence concerning any expert witness Defendant engaged with respect to this action, including any reports setting forth the expert’s opinions and the basis for said opinions, as well as full and complete disclosure as required by statute. 39. Any and all documents which reflect the yearly gross revenue for Defendant ALBERT Page 6 of 8 FILED: BRONX COUNTY CLERK 04/22/2024 03:42 PM INDEX NO. 807857/2023E NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 04/22/2024 EINSTEIN COLLEGE OF MEDICINE OF YESHIVA UNIVERSITY s from 2019 to the present (including, but not limited to, tax filings and income statements). 40. Any insurance policies that may provide coverage for this action. 41. Any and all documents describing, constituting, summarizing, supporting and/or referring to Defendants’ affirmative defenses to Plaintiff’s Complaint as set forth in Defendants’ Answer. 42. Any and all documents identified in Defendants’ Responses to Plaintiff’s First Set of Interrogatories. 43. Any and all documents that Defendants deem unresponsive to the foregoing requests but that are nonetheless somehow relevant to Plaintiff’s employment with Defendants, including but not limited to her training, compensation, discipline, counseling, leave, transfer, assignment, definition of position, investigations, evaluations, hiring or firing. 44. Any and all documents in Defendants’ possession that are relevant to this action but have not been produced from the above document requests. PLEASE TAKE NOTICE: This is a continuing request and Plaintiff reserves the right to renew or make additional requests prior to the close of discovery. Dated: April 3, 2024 New York, NY PHILLIPS & ASSOCIATES, ATTORNEYS AT LAW, PLLC By: ___________________________ Zachary Randall Sara R. Callow Attorneys for Plaintiff 45 Broadway, Suite 430 New York, New York 10006 T: (212) 248-7431 F: (212) 901-2107 zrandall@tpglaws.com scallow@tpglaws.com TO: James Bryton William Anthony Littler Mendelson P.C. Page 7 of 8 FILED: BRONX COUNTY CLERK 04/22/2024 03:42 PM INDEX NO. 807857/2023E NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 04/22/2024 Attorneys for Defendant Albert Einstein College Of Medicine Of Yeshiva University 900 3rd Ave, New York New York 10022 Nicole Callahan Attorneys for Defendant Kamran Khodakhah 445 Hamilton Avenue Suite 1102 White Plains, NY 10601 (718) 889-3761 Page 8 of 8