2325 COM Cover Letter re Zinnia Health Objection w Exs

-3- FACTS COMMON TO ALL CAUSES OF ACTION 9. Rodgers is a 63-year-old African American woman. 10. At all relevant times, Rodgers was and is a licensed Marriage and Family Therapist/Licensed Clinical Alcohol & Drug Counselor in good standing with the New Jersey Division of Consumer Affairs and the New Jersey Board of Marriage and Family Therapy Examiners (the “Board”). See N.J.S.A. 45:8B-34 et seq. 11. On or about January 17, 2022, Zinnia hired Rodgers as an Outpatient License Clinician earning $70,000 a year. 12. In this role, Rodgers provided group and individual therapy to residents and outpatients of the Endeavor House. 13. Rodgers reported directly to Idris Rahman, also a licensed therapist and the Endeavor House’s Assistant Clinical Director, and was indirectly supervised/managed by Cincotta, Zinnia’s New Jersey-based Vice President of Operations, and Estefania Riofrio, the Endeavor House’s Clinical Director. 14. On Monday, December 26, 2022, the day after Christmas, one of Rodger’s clients, a vulnerable inpatient substance abuse patient, reported to Rodgers that she was sleeping with Steven Costa, Operational Manager, a Zinnia and Endeavor House staff member. 15. Upon information and belief, Costa reported directly to Cincotta, was a resident overseer in Zinnia’s Bloomfield House, an all-male sober facility, and supervised operational staff for Zinnia’s male and female sober houses. 16. As the patient was in recovery and being actively treated by Zinnia for substance abuse, for Costa to be engaging in a romantic/sexual relationship with Rodger’sESX-L-004622-23 07/19/2023 2:53:48 PM Pg 3 of 13 Trans ID: LCV20232124530