2325 COM Cover Letter re Zinnia Health Objection w Exs

-9- 1.7(c)(18); 2014 ACA Code of Ethics, A.5.a; NAADAC/NCC AP Code of Ethics I- 23.; (ii) constituted improper quality of patient care; and/or (iii) were incompatible with clear mandates of public policy concerning the public health, safety or welfare. 49. Plaintiff reported, objected to and opposed such conduct, including by complaining to Rahman, Scher, Riofrio, and other senior management and human resources personnel. 50. As a result of Plaintiff’s reporting of and objections to such conduct, Defendants undertook adverse employment action and otherwise retaliated against Plaintiff, including by terminating her on pretextual grounds. 51. Defendants’ adverse employment action against and termination of Plaintiff was egregious, willful, wanton and in reckless disregard of Plaintiff’s rights. 52. Defendants’ senior management, upon information and belief including but not limited to Cincotta, Scher, and other senior managerial and human resources/legal personnel, directly participated in the relevant unlawful conduct. 53. Defendants’ retaliatory conduct has inflicted, and will continue to inflict, substantial injury upon Plaintiff, including without limitation economic damages including loss of income and benefits as well as emotional distress damages. WHEREFORE, Plaintiff demands judgment against all Defendants awarding her compensatory damages, including but not limited to front pay; back pay; the value of health insurance and other benefits, commissions, bonuses and vacation; damages for emotional distress; punitive damages; pre- and post-judgment interest; counsel fees and costs ofESX-L-004622-23 07/19/2023 2:53:48 PM Pg 9 of 13 Trans ID: LCV20232124530