2325 COM Cover Letter re Zinnia Health Objection w Exs

-8- 43. Not only has Rodgers not been contacted by Zinnia at any point since her wrongful termination (including in connection with the investigations of Costa and or Cincotta that led to their terminations), in contravention of Scher’s and Riofrio’s assurances to her, Zinnia has in fact challenged Rodgers’ application for unemployment benefits. 44. Upon information and belief, Rodgers was replaced by Zinnia in her role as an Outpatient Licensed Clinician for the Endeavor House by one or more persons who were substantially younger than 63 years old. FIRST COUNT (Retaliation in Violation of the New Jersey Conscientious Employee Protection Act, N.J.S.A. 34:19-1 et. seq. – All Defendants) 45. Plaintiff repeats and realleges the allegations set forth above as if set forth at length herein. 46. At all relevant times, Defendants were each acting as an “employer” within the meaning of N.J.S.A., 34:19-2(a). 47. Plaintiff, a Marriage and Family Therapist and License Clinical Alcohol & Drug Counsel licensed by the New Jersey Division of Consumer of Affairs and the New Jersey Board of Marriage and Family Therapists, is a “licensed or certified health care professional” within the meaning of N.J.S.A., 34:19-2(a). 48. Plaintiff reasonably believed that Defendants’ conduct, activities, directives, practices and procedures, in particular in connection with Costa’s predatory and exploitive behaviors: (i) constituted violations of a law, or a rule or regulation promulgated pursuant to law, including without limitation N.J.A.C. 10:161A-17.2(a)(9) & 10:161A-ESX-L-004622-23 07/19/2023 2:53:48 PM Pg 8 of 13 Trans ID: LCV20232124530