On May 2, 2025, The Law Office of David H. Rosenberg, P.C. (“Firm”) filed a Verified Complaint of gender, familial status, marital status (“protected classes”) discrimination and retaliation case with the New York State Division of Human Rights against Respondents Northwell Health Inc. (“Northwell”) and Ramona Rajapakse, M.D. (“Dr. Rajapakse”).
As alleged in the Verified Complaint, Complainant, a married mother, started working for Northwell as a nurse practitioner on October 9, 2022.
According to the Verified Complaint, on around January 23, 2023, Complainant said to female manager Hannah Busuttil (“Busuttil”) generally, “I’m going to be out of the office today since my daughter is having a bad asthma attack again and my husband is unable to take off more days. He already took off so many days with her in the past while she was sick.” Busuttil said generally, “No problem, good luck with everything,” and approved the request.
As alleged in the Verified Complaint, on or around January 24, 2024, Complainant informed Busuttil in front of Dr. Rajapakse generally, “My husband takes off a lot when he can with my daughter when she is sick, so I do not have to. When her asthma is really bad, I stay home with her because I am the health care professional, and my husband does not know how to handle it, nor do I feel comfortable that he will know the signs that she will need to go to the hospital again.” Dr. Rajapakse said, “You need to let me know personally about all of your requested days off and sick days personally, not just Hannah anymore.”
According to the Verified Complaint, on or around February 1, 2023, Busuttil said to Complainant words to the effect of, “I don’t know why she is having you inform her your days off or sick days as well. No other office works that way. They just inform the manager, and they send out correspondence to everyone who needs to know. That is not right that you are the only person who needs to do that. She is not like that with anyone else.”
As alleged in the Verified Complaint, on or around April 14, 2023, Complainant said to Busuttil generally, “I want to take two weeks’ vacation in August. What will Dr. Rajapakse think?” To which Busuttil responded generally, “Take the two-week vacation since you are entitled to it. If Dr. Rajapakse gets two weeks, you get two weeks too. She is always on vacation and barely works; you are here working hard all the time.”
According to the Verified Complaint, on or around April 15, 2023, Dr. Rajapakse said generally, “Nurse Practitioners don’t get two weeks’ vacation,” in front of Busuttil who replied with words to the effect of, “Nurse Practitioners get two weeks’ vacation. Everyone does as long as it is approved by management and doesn’t interfere with the office and I asked administration and they said the same thing”.
As alleged in the Verified Complaint, on or around May 15, 2023, Complainant said to Dr. Rajapakse and Busuttil, “I am going to be out sick today with my daughter because she is having issues with her asthma again” to which Dr. Rajapakse responded generally, “Please send me a message in writing to that effect as well.” Other employees outside of the protected classes were not treated this way.
According to the Verified Complaint, on or around May 18, 2023, Dr. Rajapakse told Complainant in front of Busuttil, “You are taking too much time off. As a provider, we don’t take time off, and this looks bad. You should find a nanny for your sick child. I had a nanny, and I never took my time off with my twins.”
Complainant opposed the treatment by saying words to the effect of, “I do not feel comfortable leaving my sick child with a nanny. I do not abuse my time off, and I only take off once every couple of months for a sick child, as you know my circumstances with my daughter. Every time she is really sick, she ends up in the hospital. She is not a normal sick child.”
As alleged in the Verified Complaint, on or around May 19, 2023, Busuttil told Complainant, “That was not right that she told you to find a nanny for your sick child. Why does she care anyway? Even when you are off, you still work from home, and it is not like you call out all the time. If you were another staff member, I wouldn’t even blink an eye about your time requests. You even ask for your days off months in advance. She only cares because then she actually has to do work.”
According to the Verified Complaint, on or around June 24, 2023, Busuttil informed Complainant her request to attend the Gastroenterology conference was denied by Dr. Rajapakse, saying generally, “I don’t know why Dr. Rajapakse denied your conference. Usually, the manager is the one that gives the okay. I don’t know why she is denying your conference, you should talk to her.”
Complainant later asked Dr. Rajapakse, generally in front of Busuttil, “Why was my request to attend the conference denied?” Dr. Rajapakse replied generally, “I am going to this conference, I do not think you should go. This is more for doctors and not nurse practitioner. There is a better one in December that you should go to.”
As alleged in the Verified Complaint, on or around September 12, 2023, Complainant said to Dr. Rajapakse and Busuttil, “My daughter and I have COVID and will be out sick for a couple of days as my daughter is not doing well.” Dr. Rajapakse responded in front of Busuttil, “Do you just have a fever? You should go and see employee health.” Other employees outside of the protected classes and those who did not oppose discriminatory practices were not treated this way.
According to the Verified Complaint, on or around September 14, 2023, Dr. Rajapakse sent an email to Complainant and Busuttil that falsely accused Complainant generally of “not informing me of what is going on with her while she is out.” Other employees outside of the protected classes and those who did not oppose discriminatory practices were not treated this way.
As alleged in the Verified Complaint, on or around September 20, 2023, Dr. Rajapakse said to Complainant in front of Busuttil, “Why do your days on Friday end so early? Who gave you the okay to do this?” to which Complainant replied generally, “My schedule hasn’t changed since I started to work here. I don’t know.”
Busuttil said words to the effect of, “Yeah, [Complainant’s] schedule mimics the last NP and has always been like that,” to which Dr. Rajapakse replied generally, “No, [Complainant] can’t leave early on Fridays and needs to fill up her schedule. Any time off, I need to know. Any changes in the schedule has to go through me.” Other employees outside of the protected classes and those who did not oppose discriminatory practices were not treated this way.
According to the Verified Complaint, on or around October 1, 2023, Dr. Rajapakse said to Complainant in front of Busuttil, “You cannot go to the December conference. That is not a good one for you, it is more for doctors, not NPs”. Complainant said to Human Resources employee Chase Renz (“Renz”) in front of Busuttil, words to the effect of:
“All this started when I was out sick with my daughter. I feel like Dr. Rajapakse is harassing me, creating a hostile work environment, telling me to find a nanny for my sick child, denying my conferences twice. telling me they are not good because I am only a NP. I don’t call out sick a lot. You can review my time as my husband takes off with her much more.”
Renz said generally, “Dr. Rajapakse needs to stop this and realize that this is not her fucking private practice.”
As alleged in the Verified Complaint, on or around October 2, 2023, Dr. Rajapakse said to Complainant in front of Busuttil generally:
“You can no longer work from home. I don’t know who let you work from home when you were out. Your schedule is full on Fridays, and your administration time is now moved to the middle of the day, not at the end of the day, so you cannot leave early. You have to message me and email me your time off, and I have to approve it before Hannah changes your schedule. You cannot go to the conference in December since it is not suitable for an NP. You cannot take off two weeks’ vacation either. You can no longer see new patients anymore.”
According to the Verified Complaint, on or around November 10, 2023, Busuttil said to Complainant in front of female employees Stephane Kucharski (“Kucharski”) and Candace Tomarrazo “Tomarrazo”) generally, “I am sorry that you are being treated this way. It is wrong. You are here working hard all the time, and she is always on vacation and not here. She should not be treating you this way.”
Tomarrazo said, “I don’t know why she is like that with you only. The rest of us don’t have an issue, it is not right”, and Kucharski said, “I hear the way she talks to you sometimes because I am so close and it makes me uncomfortable. She asks a question and doesn’t even let you finish when she starts accusing you of lying.”
As alleged in the Verified Complaint, on or around November 16, 2023, female nurse Michele Guale-Torres said to Complainant in front of Tomarrazo and female nurse Marisa Latino (“Latino”), “The way Dr. Rajapakse is treating you is not right. This is harassment and making a hostile working environment for you, and we can all feel it. Something needs to be done.”
According to the Verified Complaint, on or around November 28, 2023, Dr. Rajapakse said to Complainant, in front of Busuttil, “I am denying your third request for conference since there are other conferences outside of sunny Florida that you can go to.”
According to the Verified Complaint, on or around December 1, 2023, Complainant said to Busuttil, in front of Tomarrazo, “Dr. Rajapakse is still making this horrible working environment. She is denying my third conference. I am just trying to be up to date in our practice. Someone just needs to tell her to stop.” To which Busuttil replied, “This is so wrong, I don’t even know why she is denying it. The manager in every other office is the one who approves it.”
As alleged in the Verified Complaint, on or around January 3, 2024, Dr. Rajapakse screamed at Complainant in front of Kucharski, “You are lying to me about this patient. You never called them and now they are clogging up my schedule. Why do I have you here for.” Kucharski later said to Complainant in front of Tomarrazo, “That was horrible. Why was she yelling at you across the hall? The whole staff was there and she didn’t even give you time to talk at all. She was accusing you, but you literally called that patient. She didn’t even close the door to the office when she was yelling at you.”
According to the Verified Complaint, on or around January 10, 2024, Complainant became aware of several emails Dr. Rajapakse circulated to patients in an attempt to make it look like Complainant had been underperforming. In response, Complainant emailed Dr. Rajapakse to discuss these findings and Dr. Rajapakse never responded.
Complainant said to Busuttil generally, “Now she is sending emails about patients trying to make is seem like I am doing something wrong but all these issues are contrived and trace back to her. When I send email back to her about it I don’t get a response back. She is trying to make me look bad now and this has to stop.” Busuttil said, “I know. You are right.”
As alleged in the Verified Complaint, on or around January 25, 2024, Dr. Rajapakse said to Complainant generally, “You need to stop reaching out to the Fellows and bothering them,” even though Dr. Rajapakse regularly directed Complainant to do such work. Complainant later said to Busuttil, in front of Tomarrazo, generally, “She told me to always reach out to the Fellows, and now not to. This is just yet another way to make my working environment hostile. She is trying to push me out,” to which Busuttil said, “I know you are right. This is so wrong.”
According to the Verified Complaint, on or around January 30, 2024, Dr. Rajapakse said to Complainant, in front of Busuttil, generally, “You are uncollegial for not letting me know of a day you were going to be out a day of work.”
As alleged in the Verified Complaint, on or around February 1, 2024, Dr. Rajapakse told Complainant in front of Busuttil, “You are not a good fit for the office, you are uncollegial, disrespectful, and unprofessional, I never met a NP like you before and I do not want to work with you in the office anymore, nor does anyone else.”
Busuttil told Dr. Rajapakse that Complainant was “hard-working,” to which Dr. Rajapakse responded, “Shut your mouth in meetings. If you don’t back me up, you should just quit. No one is on my side.”
Complainant later told Renz in front of Busuttil, male employees Dr. Joseph Ng (“Dr. Ng”), Zach Chaudry, and Terry Bertovitch:
“Dr. Rajapakse is harassing me and now creating a hostile work environment with crude emails, denying conferences, yelling in front of staff and patients, taking patients off my schedule, telling me I can’t see new patients, micromanaging my time off, making issues when I need to take time off with my sick child, telling me that I am not clinically doing well but yet denying my requests to broaden my education. The staff feel it and are complaining as well,” [February 1, 2024 HR Complaint].
According to the Verified Complaint, on or around March 1, 2024, Complainant asked Dr. Ng about the status of the February 1, 2024 HR Complaint to which Dr. Ng admitted, “We are looking into your charts and reviewing your clinicals.” Thus, Complainant believed her February 1, 2024, HR Complaint was being ignored.
As alleged in the Verified Complaint, on or around March 2, 2024, Busuttil told Complainant, “I was sitting in the meeting with Dr. Rajapakse and Dr. Ng, and he never asked about her harassing you. He told her about the meeting, and that’s when she was complaining that you were not clinically doing well and tried to pin everything on you.”
According to the Verified Complaint, on or around March 10, 2024, Latino told Complainant, in front of Tomarrazo, generally, “She is taking so many patients off your schedule now. She gives us handwritten notes, so it’s not in the computer system. She is also not booking follow-up visits with you anymore. She is trying to do this so that there is no trace on the records, but we are keeping all the notes and taking notes of the patients she is telling us to take from you. Some of the patients are your patients.”
As alleged in the Verified Complaint, on or around March 11, 2024, Tomarrazo said to Complainant, in front of Kucharski, “Chase from HR came around to ask about how you were being treated. I told him she was not treating you fairly and everything that was being done, but I also said I don’t want her to retaliate against me.”
According to the Verified Complaint, on or around April 1, 2024, Dr. Rajapakse began restricting new patients and removing patients scheduled to meet with Complainant. Complainant said to Renz in front of Busuttil, “Dr. Rajapaske is taking patients off my schedule, even patients that followed me from my last practice. She is not allowing me to see new patients and trying to minimize my schedule.”
Busuttil said, “This is too much now, it is wrong. If I speak up, I’m afraid she’ll retaliate against me as well.”
As alleged in the Verified Complaint, on or around April 2, 2024, Busuttil said to Complainant generally, “They don’t want me in your meetings anymore. I think because I back you up in saying that Dr. Rajapakse has been treating you unfairly.”
According to the Verified Complaint, from April to June 2024, Dr. Rajapakse minimized Complainant’s role by removing scheduled patients and restricting her from seeing new ones while circulating emails with false and spurious allegations of Complainant’s underperformance on account of the protected classes and in retaliation of her opposition to discriminatory practices. On or around June 14, 2024, Complainant was terminated on account of the protected classes and in retaliation of her opposition to discriminatory practices.
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