Corradino v. Liquidnet Holdings, Inc.

What the document is

This document is a letter from Corradino’s lawyer asking the court to intervene in four discovery disputes. Discovery is the pretrial exchange of information and documents between opposing parties. The court’s action was limited to ordering Defendant to file a letter response by June 29, 2020. The document does not state that the court granted or denied any of Corradino’s discovery requests.

Claims and background described in the letter

The letter says Corradino is a former Liquidnet Human Resources executive. It alleges that she experienced sexual harassment by Merrin, whom the letter identifies as Liquidnet’s former Chief Executive Officer, and other members of Liquidnet’s senior leadership. It also alleges that Liquidnet retaliated against her by giving her a choice between dismissing her lawsuit and submitting to a confidential arbitration process, or losing her job, and that Liquidnet then fired her.

According to the letter, Corradino asserts claims under the Trafficking Victims Protection Act, a federal law, as well as the New York State Human Rights Law and the New York City Human Rights Law. The court did not decide the merits of those claims in this document.

Discovery requests

1. Investigation materials. Corradino requested documents concerning Liquidnet’s investigation of her complaints. The letter argues that attorney-client privilege and work-product protection do not apply because the investigation was conducted for business rather than legal purposes. It also argues that, even if protection applied, the defendants waived it by relying on the investigation’s reported conclusion that the claims could not be corroborated and were described as “salacious” and “lacking merit.” These are arguments in Corradino’s letter, not findings by the court.

2. Other discrimination complaints. Corradino requested documents from January 1, 2008, onward concerning other complaints of discrimination or harassment against Merrin or Liquidnet. The letter argues that the request is relevant to her claims, including her allegation of a continuing pattern of conduct and her claims under the federal statute’s ten-year limitations period.

3. Merrin’s compensation. Corradino requested compensation information from Merrin’s personnel file. The letter argues that the information is relevant because she seeks punitive damages and a defendant’s financial circumstances may be considered when determining such damages.

4. Electronically stored information. Corradino also asked the defendants to continue searching for responsive electronically stored information. The letter says the defendants asserted that they had exceeded a presumptive 160-hour limit under the judge’s individual rules. It also says the defendants agreed to provide time records showing the time spent reviewing and producing responsive information, which Corradino would review before deciding whether to challenge that position.

Ruling

Judge Lorna G. Schofield ordered Defendant to file a letter response by June 29, 2020. The opinion text provided does not include a later ruling on the four discovery issues.