Paray v. VHF Inc.

Background

Vena Paray, proceeding without a lawyer, brought claims against her former employer, VHF Inc., and two former supervisors, Nicolas Rohde and Mohamed Soliman. She alleged discrimination based on marital status, race, religion, and sex, and retaliation under Title VII of the Civil Rights Act of 1964 and the New York State Human Rights Law.

Defendants moved to dismiss under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). The opinion does not describe the specific grounds on which the magistrate judge recommended dismissal; it incorporates the Report and Recommendation’s factual summary instead.

Report and Recommendation

Magistrate Judge Ona T. Wang issued a Report and Recommendation on August 22, 2025. It recommended that Defendants’ motion to dismiss be granted and that the complaint be dismissed with prejudice. The recommendation informed the parties that they had fourteen days to file written objections and warned that failing to object would waive objections and prevent appellate review.

Paray filed no objections and did not request more time to object. Because no timely objections were filed, the district court reviewed the recommendation for clear error rather than conducting a new review of disputed portions. Clear-error review asks whether the record leaves the court with a firm conviction that a mistake was made.

Ruling

Judge Rearden found that Paray waived judicial review by failing to object after receiving the stated warning. The court nevertheless reviewed the Report and Recommendation and found no clear error. It described the recommendation as well reasoned and supported by the facts and law.

The court adopted the Report and Recommendation in its entirety, granted Defendants’ motion to dismiss, and dismissed the complaint with prejudice. The Clerk of Court was directed to close the case.