Crage v. The Scwartzman Animal Medical Center

Background

The provided document is a letter-motion filed by counsel for Kristin Crage in an age-discrimination and retaliation case. The letter identifies claims under the federal Age Discrimination in Employment Act, the New York State Human Rights Law, and the New York City Human Rights Law.

Crage stated that the parties had completed three depositions and that the court had previously denied, without prejudice, two requests to take additional depositions. She asked to depose two nonparty witnesses: Emily Brill and Nicole Trinler.

Requested Discovery

Crage argued that Brill could provide information about alleged confidential information that defendants said Crage shared with Brill and that defendants identified as a reason for terminating Crage on September 26, 2024. The letter referred to text messages between Brill and individual defendant Paul Greene and to an email Brill sent to Crage after the termination. Crage argued that Brill’s knowledge and involvement could be relevant to her retaliation claim.

Crage described Trinler as a younger employee who served as an executive assistant and program manager to the medical center’s chief executive officer. Crage asserted that Trinler received a title change and a raise and that her work performance and workplace conduct could provide comparison evidence relevant to Crage’s age-discrimination and retaliation claims. Crage also stated that Greene and individual defendant Neil McCarthy did not know whether Trinler had work-performance problems, a history of misconduct, or violations of the medical center’s policies.

Arguments and Requested Extension

Crage relied on the federal discovery rule allowing discovery of nonprivileged information relevant to a claim or defense and proportional to the case’s needs. She argued that the trial was not imminent, that defendants would not be prejudiced, that she had been diligent, and that the requested depositions were likely to produce relevant evidence. If the depositions were allowed, she requested an extension until July 28, 2025, to complete fact discovery. The letter states that defendants opposed the deposition request but consented to an additional 30 days to complete discovery if the request was granted.

Disposition

The provided text does not contain a clear, legible ruling on the letter-motion. It therefore does not establish whether Judge Preska granted, denied, or otherwise resolved the requests to depose Brill and Trinler or the request to extend discovery.