2325 COM Cover Letter re Zinnia Health Objection w Exs

-2- 3. Zinnia holds itself out as a leader in the substance use and mental health treatment field and operates treatment facilities in Florida, California, Colorado, Indiana, Rhode Island and New Jersey. 4. Among the facilities owned and operated by Zinnia is the Endeavor House North treatment facility and sober house located at 206 Bergen Avenue, Kearny, New Jersey 07032 (“Endeavor House”). 5. Defendant Daniel Cincotta (“Cincotta”) is a resident of New Jersey who at all relevant times served as Zinnia’s Vice President of Operations and had oversight responsibilities for the Endeavor House. Upon information and belief, Cincotta maintains a principal residence at 16 Vermeer Drive, Apt 17, South Amboy, New Jersey 08879. 6. Defendant Deena Scher (“Scher”) is a resident of New Jersey who at all relevant times served as Zinnia’s Regional Human Resources Manager and had oversight responsibilities for the Endeavor House. Upon information and belief, Scher maintains a principal residence at 25 Ellen Heath Drive, Matawan, New Jersey 07747. 7. Upon information and belief, Defendants John and Jane Does 1-10 are managers, employees, agents, servants or workmen of and/or independent contractors retained or otherwise authorized by Zinnia that were involved in the discriminatory and retaliatory conduct identified herein. 8. Upon information and belief, Defendants ABC and XYZ Corporations 1-10 are employees, agents, servants or workmen of and/or independent contractors retained or otherwise authorized by Zinnia that were involved in the discriminatory and retaliatory conduct identified herein.ESX-L-004622-23 07/19/2023 2:53:48 PM Pg 2 of 13 Trans ID: LCV20232124530