On May 13, 2025, The Law Office of David H. Rosenberg, P.C. (“Firm”) filed a Verified Complaint of sex/age discrimination (“protected classes”) and retaliation with the New York State Division of Human Rights on behalf of a former female employee (“Complainant”), against Respondents Renu Contracting & Restoration, Inc. of 20 35th Street, Copiague, New York 11726 (“Premises”), male chief executive officer, Daniel Coffey, female corporate compliance officer, Beth Anne Susi, male project manager, John Campo, male field laborer, Ivan Guerra, male safety manager, Edward Caballero, and male carpenter, Douglas Centeno (“Respondents”).
As alleged in the Verified Complaint, starting in or around August 2022 and continuing thereafter, Complainant was subjected to a hostile work environment on account of the protected classes, which included Centeno typically saying to her words to the effect of:
a. “You know, I like dating older women, and you’re really hot.”;
b. “Would your kids have a problem with you dating a younger guy?”;
c. “Can I say the next thing? You had me very aroused, I’m just saying”; and
d. ”You know, I had lipo-suction on my sides, and I’m gonna [sic] have more. Do you want to feel it? Promise you won’t say anything,” as he would typically lift up his shirt at Complainant.
Complainant would typically oppose the treatment by changing the topic of conversation after saying generally, “No” and “Please stop.”
According to the Verified Complaint, on or about December 4, 2022, Complainant complained to Susi of the treatment described above, saying words to the effect of:
“I’ve had several incidents with one of the carpenters, Doug Centeno. He’s been saying sexual and inappropriate things to me for several months. I need it to stop. Do you have any suggestions? I’ve tried ignoring the comments, but it hasn’t stopped.”
Susi replied, “Please make this go away. Sometimes, as women, it’s best. It’s not good for the company culture. How do we make this palatable?” Notwithstanding this discrimination complaint, no investigation was conducted, no corrective action was taken, and no disciplinary action was taken. On the contrary, the hostility continued.
As alleged in the Verified Complaint, on or about March, 20, 2023, at the side of the Greenport Union Free School District construction site (“Greenport School Site”), Guerra asked Complainant, “What are you doing?” to which Complainant replied, “I’m looking for the restroom.”
Guerra grabbed Complainant’s left hand with his right and physically manipulated her walking movements towards the back of the darkened and empty Greenport School gymnasium while repeating, “(Complainant), what are you doing? There’s one back here. Come here. Come here, there’s a bathroom back here. Come here. Come here.” There was no bathroom there, and Complainant opposed the treatment by physically breaking free of Guerra’s grasp, and immediately left in her car (“March 20, 2023 Incident”).
While in the car, Complainant called male safety site manager, Tom Tabosky (“Tabosky”), and said, “I’m in my car at the Greenport site. Ivan asked me what I was doing and when I said looking for the bathroom, Ivan kept saying, ‘There is one back here. Come here. Come here.’ and physically tried forcing me there where there is no bathroom.”
According to the Verified Complaint, on or about April 13, 2023, at the Greenport School Site, Complainant reported the March 20, 2023 Incident to Campo, saying generally:
“Something happened when I was here last time. I walked to the side of the site to use the porta-potty when I was here at Greenport last time. When I came out, Ivan was there. He asked me what I was doing. When I told him I was looking for the bathroom, he said, ‘There’s one back here. Come here. Come here.’ Can you walk me into the back of the gym? Last time I was in there, there was no restroom. I just want to check.”
Campo walked to the back of the gymnasium and confirmed there was no bathroom where Guerra was trying to get Complainant, saying words to the effect of, “I can see that you’re upset, but there’s no bathroom back here.” Notwithstanding this discrimination complaint, no investigation was conducted, no corrective action was taken, and no disciplinary action was taken. On the contrary, the hostility continued.
As alleged in the Verified Complaint, on or about April 20, 2023, Tabosky told Complainant generally about a conversation he had with the male director of programs, Matthew “Matt” Squillacioti Sr. (“Squillacioti” or “Matt”):
“Matt said Dan wanted me to talk to you about what happened with Ivan. Matt said that John told him and Dan about what happened with Ivan, and that you came to John about it. Matt asked me if I knew about it, and I told him you told me. I told him I know it’s Ivan. Matt said, ‘Ivan is one of our best employees, and we don’t want to lose him. Can you please tell her not to go to the Greenport site anymore or anywhere Ivan is?’”
“I told Matt, she’s not a wishy-washy woman. She’s worked for me in another company, and she’s a pretty tough girl. We’re not talking about some young, unseasoned woman that this guy was leading her in there for whatever reason. Ivan’s a big dude, but I’m not going to tell that woman she can’t go there anymore. Maybe you should have a conversation with Ivan.”
“Matt told me they’re worried that something will happen, and it will come up. Then Matt said he would talk to Dan about it, and maybe it will just become a dead issue. I suggested that maybe if Matt and Dan feel they need to speak with you, we’ll bring you in, and I can sit with you guys. Matt told me they don’t want you going to the Greenport site anymore.”
As alleged in the Verified Complaint, on or about April 21, 2023, Tabosky said to Complainant generally that Susi “Told me I have to speak to you about what happened with Ivan, and she told me to fix it.” On or about June 20, 2023, Tabosky said to Complainant, “Matt told me that John Campo has been complaining about you, saying that you make him feel uncomfortable.”
According to the Verified Complaint, on or about August 5, 2023, a white male mustached carpenter with long brown hair (name unknown), approximately 30-35 years of age, said to Complainant generally, “John Campo is going around telling people to stay away from you. He said you’re already trying to get one guy fired, so you should be careful.”
As alleged in the Verified Complaint, on or about September 12, 2023, a clean-shaven white male subcontractor from Keller Contracting, approximately 50-55 years of age (name unknown), said to Complainant, “Yeah, you looked thrilled to be here. I said it when you walked away. It was directed when you walked out of here and it was directed as a fucking joke. We all don’t want to be here.”
Complainant told Susi, “A sub-contractor from Keller Contracting just confronted me as I was exiting saying sarcastically that I looked thrilled to be here, and that it was a quote-unquote, ‘fucking joke’.” Susi said, “I don’t think there’s much I can do about it.”
According to the Verified Complaint, on or about October 15, 2023, Guerra told Complainant, who was using a company iPad to photograph a site, “Make sure you get my best side. Should I put some cologne on?” Complainant opposed the treatment by leaving the conversation and reported this incident to Tabosky.
As alleged in the Verified Complaint, on or about December 15, 2023, a white male carpenter with wavy brown hair, approximately 25-29 years of age (last name unknown), said to Complainant, “What happened with you and Campo? He’s telling people not to trust you.” Complainant then reported this incident to Tabosky.
According to the Verified Complaint, on or about February 20, 2024, Susi asked Complainant, “What makes it better? Think maybe…I don’t know, you want to become a laborer?”
Complainant said words to the effect of, “Do you see what the guys do to me here?”
To which Susi said, “I know. I understand. You’re a woman, and you’re older.”
Complainant reported this incident to Tabosky and told Tabosky, “Beth just asked me if I wanted to become a laborer. I feel like I’m being pushed out of the Company.”
After speaking with Susi, Tabosky later told Complainant:
“Beth just told me that Sal said we should go to one person. I told her if that’s the case then I’ll quit cause I’m not going to let that woman lose her job. (Complainant) told me she feels like she’s being pushed out of the company. Also, did you tell (Complainant) she should become a laborer? Beth said, ‘Yes’.”
As alleged in the Verified Complaint, on or about June 26, 2024, Tabosky told Complainant, “Beth and Tara said they’re going to fire you and not to tell you. I told them they were making a big mistake.”
According to the Verified Complaint, on or about June 27, 2024, Tabosky told Complainant, “We had a meeting in Matt’s office with Matt, Beth, Tara, and Dan. I’m not supposed to tell you this, but Dan said they’re going to fire you. Dan said he felt you were disgruntled and unhappy, and if you have any issues with your car to use your PTO. I stuck up for you, and now I’m in the middle of this.”
As alleged in the Verified Complaint, on or about June 28, 2024, Susi told Complainant, “I feel like you are frustrated. You shouldn’t have taken your vacation when you did, but since it was approved by your manager, I couldn’t take it back. I feel like I’m missing the mark with you. There are times I don’t think you are where you should be. You shouldn’t be my problem, I inherited you from Rob Monty.”
According to the Verified Complaint, on or about July 19, 2024, Complainant informed Cabellero of a scheduling conflict with the 3-11 pm night shift in accordance with Company policies and practices. Cabellero refused Complainant’s schedule change request and told Complainant she would have to “Use your PTO time.” Other non-female employees and those who did not oppose discriminatory practices were not treated this way.
As alleged in the Verified Complaint, on or about August 22, 2024, Susi told Complainant, “Do you think that perhaps this is just not the right fit for you? I feel that you are disgruntled.”
According to the Verified Complaint, on or about August 28, 2024, Susi told Complainant, “Your vacation has to be approved by me going forward. Had your vacation come to me initially, I never would have approved it. You know my husband and son went to Italy for two weeks this summer, and I couldn’t go. How does it look that you went away? You can’t do that again.”
Caballero told Complainant generally that Tabosky was to “No longer do your reports,” to which Complainant responded, “I always have done my own reports.” Susi said, “Well, that’s not my problem.”
As alleged in the Verified Complaint, on or about September 6, 2024, Tabosky told Complainant generally, “Cabellero has been checking all of your reports, saying he can’t find them and copying everyone on the emails. Makes it look like you are not doing your work. Did all of your jobs go through?”
Complainant responded, “Yes, they are all downloaded. They went through.”
According to the Verified Complaint, on or about September 19, 2024, Complainant informed Cabellero of a scheduling conflict with the 3-11 pm night shift in accordance with Company policies and practices. Cabellero refused Complainant’s schedule change request and told Complainant she would have to “Use your PTO time.”
Complainant said generally, “I can’t work after 3:00, so I’m being forced to take an unpaid day. When Tom has his sports officiating every week, it’s never an issue when he needs time.”
Knowing that she could not work the 3-11 p.m. night shift, Caballero continued to schedule Complainant at that time on account of the protected classes and in retaliation of her opposition to discriminatory practices.
As alleged in the Verified Complaint, on or about September 23, 2024, Susi told Complainant generally that, “Taking unpaid days shouldn’t be standard practice.”
Complainant said generally that Caballero had been scheduling her to work the night shift, knowing she would be unable to do it. Notwithstanding this complaint, no investigation was conducted, no corrective action was taken, and no disciplinary action was given. On the contrary, Caballero continued to schedule Complainant to work the night shift he knew she could not cover.
According to the Verified Complaint, on or about October 11, 2024, despite having Complainant’s request to not work the night shift since at least August of that year, Caballero again scheduled Complainant to work the night shift and again made her use PTO.
As alleged in the Verified Complaint, on or about December 2, 2024, Tabosky told Complainant words to the effect of, “At the sanitary district, the guy from Park East said he met the new boss who said (Complainant) doesn’t come here anymore because she’s not qualified.”
According to the Verified Complaint, on or about December 5, 2024, Complainant was terminated on account of the protected classes and in retaliation of her opposition to discriminatory practices.
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