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Supporting Documentation · Feb 13, 2025

2325 COM Cover Letter re Zinnia Health Objection w Exs

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-5- 22. Rodgers heard nothing from Rahman, Zinnia’s Human Resources Department, or anyone else during her holiday, and she went back to work on Friday, December 30, 2022. 23. After facilitating a group therapy session in the morning, Rodgers went to Rahman's office again to follow-up on the Costa report. 24. To Rodgers’ shock, Rahman indicated at that time that Costa had filed a complaint against Rodgers accusing her of improperly "gossiping" about Costa and/or defaming him. 25. Given that the only person Rodgers had discussed the matter with was Rahman himself, a direct supervisor also bound by patient confidentiality to whom she had a legal and ethical obligation to report the misconduct, it became evident to Rodgers that Rahman had disclosed her report to Costa who had been using her three-day absence from Zinnia to “set her up,” potentially by encouraging other patients to make coerced and/or falsified claims about Rodgers. 26. That Rahman, Costa, and others in Zinnia’s management were collaborating appeared to be confirmed when Rahman received a call he indicated was from Costa who was “on his way” to Rahman’s office. 27. Rahman, visibly flustered, rushed Rodgers from the office and indicated that he would follow up with her after he had received Costa. 28. Shortly thereafter, Rahman called Rodgers back into his office where Scher, Zinnia's Regional Human Resources Manager, was on the phone. 29. Scher told Rodgers she was being sent home pending an investigation.ESX-L-004622-23 07/19/2023 2:53:48 PM Pg 5 of 13 Trans ID: LCV20232124530

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