Bloise v. Q4 Generational Wealth
- Stewart Aaron
- 1:22-cv-10488
- U.S. District Court · Southern District of New York
- 2
In Alicia Bloise v. Q4 Generational Wealth, Judge Aaron ordered mental-health records produced if Bloise seeks more than garden-variety emotional-distress damages.
Alicia Bloise, Q4 Generational Wealth, Inc. doing business as Calientes Restaurant & Bar, and Melanie Burgos.
What happened
Alicia Bloise filed a motion for default judgment against Q4 Generational Wealth, Inc., and other defendants. In supporting materials, she referred to a diagnosis of severe anxiety and depression and treatment by a social worker or therapist, but she did not provide related medical records.
The court explained that without medical evidence, an emotional-distress claim is generally treated as "garden variety," which limits the damages available. Evidence for such a claim is typically limited to the plaintiff's own testimony and does not require expert opinions or mental-health records.
Judge Stewart D. Aaron ordered that Bloise must file and serve records from her doctor, social worker, and therapist if she wants to place her mental health in controversy and seek greater-than-garden-variety emotional-distress damages. The order did not rule on her motion for default judgment. If the records are filed and served, Q4/Calientes and Melanie Burgos must keep them confidential.
The detailed version
- Bloise v. Q4 Generational Wealth · No. 1:22-cv-10488
- Stewart Aaron
- Dec. 2, 2025
Background
On September 3, 2025, Alicia Bloise filed a motion for default judgment, an accompanying affirmation, and exhibits. Her supporting materials referred to a doctor's diagnosis of "severe anxiety and depression" and treatment by a social worker and/or therapist. Bloise did not submit records from those providers with the motion.
Court's analysis
The court stated that when a plaintiff does not submit medical evidence supporting an emotional-distress claim, the claim is treated as "garden variety." That classification limits the range of damages that may be recovered. The court also stated that evidence for garden-variety emotional-distress claims typically is limited to the plaintiff's testimony and does not require expert opinions or mental-health records.
Order
The court ordered Bloise, if she wishes to place her mental health in controversy and seek more than garden-variety emotional-distress damages, to file records from her doctor, social worker, and therapist concerning her mental health during and after her employment at Q4 Generational Wealth, Inc., doing business as Calientes Restaurant & Bar. The deadline to file the records was December 16, 2025. She also had to serve the records on Q4/Calientes and file proof of service by December 18, 2025. The order noted that the records could be filed under seal.
If Bloise files and serves the records, Q4/Calientes and its principal, Melanie Burgos, must treat them as confidential and must not disclose them to anyone in any manner. The opinion does not state a ruling on Bloise's motion for default judgment.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.