Case 15-1328, Document 123, 04/28/2016, 1760706, Page1 of 14

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

Thurgood Marshall U.S. Courthou se 40 Foley Square, New York, NY 10007 Telephone: 212,.857-8500
\10TION L~FOR.\1ATION STATE.\fENT

Docket Number(s): _1_5_-_1_3_2_8

______________

___

___

....::C""a""'pt,.,,,10<!.!nc.L.[u""s"'-e""sh!.:::o.,_,_n..:.:ti.:.:;tle..._J
_______
_

REINSTATEMENT OF ORDER TO ASSIGN Varughese v. Mount Sinai Medical Center et al

Motion for:

PRO BONO COUNSEL

Sel forlh below precise, complete statement of relief sought:

I DEMAND THAT A NEW PRO BONO COUNSEL IS

ASSIGNED TO REPRESENT ME ON MY
APPEALS

MOvtN~RTY:
Leena Varughese , M.D .
ILJ Plaintiff
Defendant
(Z] Appellant/Petitioner
Appellee/Respondent

MOVING ATTORNEY:

OPPOSING PARTY:

Mount Sinai Medical Center et al

pending
OPPOSING ATTORNEY : Rory Mc Evoy
-------------~
-------- ----~
[name of attorney, with firm. address, phone number and e-mail)
Blank Rome LLP
405 Lexington Avenue
New York , NY 10174-0208

coun-Judge /Agencyappealed from:

Southern District of New York - Judge McMahon

Please check appropriate boxes:

FOR E:\1RGENCY MOTIO:-iS. MOTIONS FOR STA VS ANO

INJUNCTIO~S PE NDING APPEAL:

noti~ opposing counsel (required by Local Rule 27 . 1):

Has moW}I.
Ll.JYeslJNo (explain):___________
Opposin~un

sel's position on motion:

sed (Zp on't Know
Does opposing counsel intend to file a response:
O ves D o [l]o on't Know

INJUNCTION AND DECLARATOY RELIEF

D No

Is oral argument on motion requested?

[Z] Yes

Has argumentdate of appeal been set?

D Yes [Z] No

Sig~na'

:e-of Moznl!~ torne,::

A

Form T-1080 (rev. 12-13)

Date:

IZJ D No
D

Has request for relief been made below?

Yes
Has this relief been previously sought in this Coun?
Yes [lJ No
Requestedreturn date and explanation of emergency:NEW PRO

BONO COUNSEL IS REINSTATED, IMMEDIATE

LJ Unopposed[}:>ppo

-1,""-.-._,u,rv,,-..
.......4--1,,q,~-"''-"--'"""'---=-~/1\...t.,..-...

04/28/2016

(requestSfor oral argument will not necessarilybe granted)

lfyes , enterdate:._____

___

Service by: llJ cMJECF

__

_ ________

D Other [Attach proof of service)

Case 15-1328, Document 123, 04/28/2016, 1760706, Page2 of 14

DEMAND TO REINSTATETHE ORDER TOASSIGN PROBONO COUNSEL

I am writing to inform the court of what transpired and what did not between me and the court
assigned attorney, Scott A. Korenbaum , who was assigned to me by the 2nd district Court of
Appeals. While the court is allowed to remove him as my counsel , it should not punish me by
vacating the order that allowed me legal counsel , a decision for which I petitioned the court early
on in the appeals process . I will highlight all the problems with Korenbaum 's representation in
detail in this submission and why an order that was not in contest should not be vacated.

At the time of Korenbaum writing to the cou1t to be removed as my counsel, he had not
communicated with me with regards to a single substantiative issue on my case , because he
evaded any discussion with me with regards to the specifics of my case, including avoiding
substantiative legal responses on questions posed to him by simply not responding , hanging up
the phone on me, and repeatedly telling me to be pro se since the date of his assignme nt (he
called me on the date of his assignment itself). As the court is we11-aware, I had submitted
extens ive documentation and compelling reasoning for the assignment of legal counsel to me,
with which this court agreed , so I am miffed by this insistence by Korenbaum of me to be pro se
since his assignment, and thereafter , in every discussion. Korenbaum who demanded that I be
pro se during my first discussion with him, which is against my interest , was advertising his
conflicts of interests in representing me, as minority , a Naturalized immigrant , a professional
woman medical doctor of color. In the field of law, especially in civil rights law related to
employment , this hostility and aggression is rampant and exhibited by lawyers without any
regard for professionalism and in specific cases of actual representation as with Korenbaum , with
disregard of his fiduciary duty to me .

Since, Korenbaum expressl y limited any and all discussion on substantiative matters with m e by
simply not communicating with me or leaving me out of important decision making , meaning
that during the months he was my lawyer on paper, there was very little discussion between he
and I that wou ld be protected by attorney client privi lege. Korenbaum proceeded to do as he
1

Case 15-1328, Document 123, 04/28/2016, 1760706, Page3 of 14

pleased without informing me as to why or what his intentions were and when confronted by me,
he refused to acknowledge his behavior or apologize or even explain himself , despite ample
evidence to this court and myself as to his problematic conduct as my lawyer. For example,
Korenbaum did not file the documents in my case in a timely manner, and when I emailed him,
there was no response. When I called him to discuss this issue , perhaps only the second phone
conversation, he did not respond to phone calls and there were dropped calls from his end. Also,
Korenbaum cancelled court scheduled conference on what was a designated schedule without
any discussion with me, and what his plans were or why he cancelled the meeting or if he
intended to reschedule the conference.

On the day that Korenbaum was assigned as my lawyer , he informed me that he was a White
Jewish Male, and stated to me that he wasn 't sure that he could represent me, and then he
demanded of me to respond to his questions of whether he could represent me being that he was
White Jewish Male. I launched into a long explanation of my own ideas on religious affiliation
and gender as not being a limiting factor as long as he was a good lawyer and adhered to his
fiduciary duty. I was concerned about his statements that I conducted a very limited research
into Korenbaum 's work history and his work, such as that he works or worked at Cardozo Law
School like Magistrate Francis , to better understand this lawyer and his behavior. I wrote to
Korenbaum a friendly email about two pages long on my ideas and my opinions relevant to the
case and his representation, which is to succinctly reassure this court that the interpersonal
communication was kept professional and cordial by myself. I never met Korenbaum, despite
several attempts on my part to set up an in-person meeting with him to discuss the specifics of
my case. Korenbaum exhibited his ongoing reluctance to represent me in the next conversations,
since his citing of his apparent identity as a "White Jewish Male" as potentially prohibitive of his
legal duties to me, continued with his refusal to discuss the legal aspects of the case , he refused
to consult me on requests by the Defendants , he filed important documents in my case late, and
finally, to my surprise , he filed with the Court of Appeals a minimal and very odd Motion to be
relieved as counsel citing failure of communication without any other explanation.

Case 15-1328, Document 123, 04/28/2016, 1760706, Page4 of 14

Korenbaum seemed to be out to prove to me and to this Court that he was handicapped and
preoccupied by his racist sexist bigotry and status quo advantages associated with his status to
represent me, a professional woman of color physician oflndian National Origin. My reading
into Korenbaum's behavior and conduct is that he would, rather than work with me for me on my
case by assisting me, per his fiduciary duty, he would rather remain on an hostile and aggressive
terms against me that would not represent me and my best interests, despite my best efforts to
keep robust communications based on respect (a two way process) and professionalism (even
though this his primary responsibility to me). For example, I do not diagnose a person based on
my feelings about what they look or their racial gender identity etc, nor do I ridiculously
announce to a patient that I am of Indian National Origin and a woman, obviously heavily
melanin pigmented, and then ask a patient outside any of my identity, if it is possible for me to
be a doctor to them. The premise for his legal practice and the understanding of the law seems to
rest first on his being a White Jewish Male, and this is not based on the law and the justice or the
facts of my case, and his failure rate, like many of the other lawyers are very high, so these
lawyers are not particularly competent professionals by definition with their high failure rates to
Plaintiffs . The problem with predominantly white male run systems that exclude people of color
is that there is this sort of misconduct, unprofessionalism, microaggressions, intentional poor
communication, and racist sexist rhetoric that is practiced against people of color. The intention
of these activities are fundamentally nihilistic and not constructive for the courts that represents a
diversity of people in United States and to the laws that it adjudicates for her people . The
nihilism by whites represent the malicious subversion and an extension of institutionalized
systemic problems of racism and sexism of the nostalgic past for some of you to destroy the
present law and to consistently thwart the appropriate application of Jaw to allow for equitable
adjudication for aggrieved minority Plaintiffs like me and entire groups.

The further proof of Korenbaum's false flag operation of some mysterious communication
failme was that he filed a non-substantiative motion to be relieved as counsel without requesting
that it be filed under seal. If there was something of actual import to be discussed worthy of his
removal, he would have done so transparently to the court, which both the Judiciary and I know

Case 15-1328, Document 123, 04/28/2016, 1760706, Page5 of 14

very well is the reasonable way to go forward, so that I may know his points as well, other than
his adamant refusal to perform his fiduciary duties. Based on my experience, Korenbaum is a
lousy duplicitous racist sexist bigot shirking his fiduciary duty after antagonizing me for months
in any way he can to create a dramatic meltdown , which when it obviously failed, he had to find
a way to sabotage me as he had intended all along. Korenbaum 's comm um
cation breakdown
claim was a fiction he created to abdicate his responsibility because they represent conflicts of
interests for him (which he may not ever tell this court or me) but the closest that we will get to
the bottom of that for now is that he sees himself as a White Jewish Male. I will divulge to the
court that Korenbaum who was already determined to file the motion to be removed as counsel,
then apparently suffered a last minute meltdown as to whether he could even write to the court
given his pattern of unprofessional conduct. I have truly found Korenbaum 's behavior given my
limited discussions and communications with him , as the Cowt can review if it so pleases, (I am
happy to print out every email and whatever log I have of the total of about five conversations
(most are about 5-10 minutes) I had with him to demonstrate this fact), since his first
conversation with me foreshadowed that he would try not to represent me and sabotage me in the
long run.

Korenbaum is unprofessional , unethical , and untrustworth y. Korenbaum 's actions were bad faith
conduct that is unfit to be called lawyering according to his :fiduciary duty to me. This court
should not allow Korenbaum 's non-substantial filing to removed as counsel as an opportunity to
marginalize me, thus compounding factors of retaliation and impermissible discrimination
against me that are based on my gender and my Indian National Origin. As the court is also well
aware, my outspoken criticism of racist sexist activities of the court , that are also attested by the
writing of well known lawyers and academics , on the disparate impact and treatment of people of
color and women as discussed extensively in my previous filings , are not reasons to be punitive
towards me now either. Korenbaum expressly limited any and aJJ discussion on substantiative
matters with me by simply not communicating with me and by leaving me out of important
decision making , meaning there was very little discussion that would be protected by attorney
client privilege. Meanwhile , he was most certainly in extensive contact with the opposition, even

Case 15-1328, Document 123, 04/28/2016, 1760706, Page6 of 14

canceling conferences without making any sort of alternative plans , schedules, and without any
discussions with me! Korenbaum ' s communication breakdown was created by himself , rather
than simply informing the court prior to starting the representation of me as to any conflicts of
interests or personal relationships in which he may be with Defendants or other actors that he
would be criticizing , he has worked since the moment he was assigned to undermine me and
create problems. I had maintained a professional relationship with Korenbaum which was also
devoid of any attorney client privileged advice but the court has no confidence in Korenbaum
nor his professionalism or his competency as deemed by removing him on alleged failure of
communication that he cannot even articulate.

Lawyers , especially like Korenbaum and Ronald J. Wronk.o Jr who are supposed to be at the
forefront of civil rights law related to emplo yment law are mere shells of human beings who
have no regard for the protection of the civil rights , labor rights, and even the basic human rights
and dignity of an Indian American Woman doctor in the professional class , who is as educated
and have successfully managed over 15000 patient cases , even protecting individual patients and
coworkers from the fiascos rampant with the Defendant Institution and the individual
Defendants. My primary concern with any professional , since I hold them to a high standard at
which I perform professionally and ethically , so my concern again was whether or not
Korenbaum was qualified , has the experience , and that he was an ethical professional. It' s my
conclusion that Korenbaum is more interested in looking for communication issues , rather than
admit to conflicts of interests and his failings such as the failure to have a single substantiative
discussion with me on the case and to ignore all my legal question s. My dealing with
Korenbaum and Wronko , to the Judges in the lower courts, to the appeal courts , informs me that
the theme in US judicial system is that melanin pigmentation and other impermissible factors
play the largest role in determining justice and adjudication , not the relevant facts or evidence in
the case, but that must change.

There is no way for me to root out bad lawyers like Korenbaum , Wronko , or Rory McEvoy
because for you Whites , the benefactor of nihilism made possible by racist sexist deeply

Case 15-1328, Document 123, 04/28/2016, 1760706, Page7 of 14

entrenched activities are funded by millions of dollars to litigate against me, and with ways to
prevent me from getting jobs , publish false defamatory statements apparently as a group activity
against me, claim one of you fear me, that I am threat, all of which apparently even when
objectively farcical does not get stopped by even one of you is baffling to me as a professional.
In 2016 , the protectionism of white privilege and white supremacy reek so extremely but has
created unequal segregated workplaces by caselaw , and allows the court mandated subjugation of

all the other women of color and immigrant United State s citizens of color to racism sexism
fueled disparate treatment and lost opportunities , right under our noses , despite the stench. This
nihilistic conduct towards minorities and woman , that is based on obliteration of the laws of this
country that protect each and every one of us, is beyond out of control that many your just hide
behind duplicitous terms such as a being a strict constitutionalist (meaningless term), like the late
Antonin Scalia.

Finally , the other lawyers assigned to me were not able to represent me through no fault of mine ,
such that there isn't even a remote possibility of my culpability with their removal as my counsel.
David Boyd and his law firm Gravel and Shea had an alleged conflict of interest. Noreen
McCarthy was too busy, could not be reached , and she wrote to the court informing it as much.

In this court, there is a barrier to litigation and representation that shuts out women and men of
color from every aspect of justice system such that entire case law within this system is
undeveloped and not even representati ve of reasonable protections for minorities such as myself
as law in being guaranteed equal rights , and civil rights protections enjoyed by Whites in
employment and labor. The majority of the lawyers and Judges are of some Caucasian derivative
which explains the level of injustice that currently exists in the employment law for people of
color, from which minorities are forcibl y kept out through practiced aggressions and hostilities
preying on the disparities derived from race and gender of minorities. The lawyers representing
Plaintiffs , like Korenbaum, have to shirk their duties in not so subtle ways , as in my case, with
implausible allegations of communication issues that cannot really be substantiated by him, who
is the lawyer. It 's often up to this court to enable this or prevent this from affecting Plaintiffs like

Case 15-1328, Document 123, 04/28/2016, 1760706, Page8 of 14

me, who are vulnerable, marginalized by wealthy and powerful (billionaires like Carl khan & a
number of his cohorts sit on he Board of Trustees of the Defendant Institution) impermissible
White interests. I am without power to change these circumstances on our own. Many Plaintiffs
unlike me are often further worse off in that they cannot even articulate the problem or
understand concretely the root causes of their issues but I am like many in that I have still been
powerless to obtain the sort of justice that I need to survive.

Employment law also houses a class of predominantly non-minority lawyers, especially in New
York City and the 2nd District Courts, who have very powerful and wealthy influences adjacent
to them that are interested in the utter destruction of civil rights protections afforded by Jaw to
minorities. I have done vast searches into the litigation records and success rates of many of
these lawyers, and I am perturbed by the failure rates in excess of 99% for these lawyers on
motion for summary judgment or trial or appeals, but their still nonchalant carefree existence as
civil rights lawyers practicing employment law! In 2015, my attempt to find a minority lawyer
to represent me has lead me to discover that there are almost none in a field that largely involve
minority issues! White and Indian National Origin lawyers have explicitly and directly told me
that they cannot represent me because they are afraid for themselves and their families who
could be targeted by the Defendant Institution and it's proxies. In my opinion, this lack of
representation because of fear of rich whites and it's proxies has again shifted the law on civil
rights protections into illegal activities, and has caused an unacceptable brain drain in the field of
employment law that is now almost entirely represented and run by White Males of
Korenbaum's hostility to protect their "White Privilege" and "White Supremacy" and who shield
White employers and the law breakers from consequences and accountability for breaking the
Title VII of Civil Rights Act of 1964 and Section 1981 which afforded legal protection from
discrimination.

To make matters confusing for many is the highfalutin talk of White lawyers and Judges.
However, in my opinion, the talk cannot hide the obviously unjust and improper conduct that
contradict the intent of the laws such as Title VII of the Civil Rights Act of 1964 and the

Case 15-1328, Document 123, 04/28/2016, 1760706, Page9 of 14

meaning of justice. The race to the bottom nihilism of current brood of lawyers actively engage
in propagation of institutionalized discrimination and retaliation against minorities like myself.
From my experience of having dealt with lawyers in employment law covering civil rights, the
clearly articulated agenda for them as with Korenbaum, is based on their status as kept men of
the corporate interests, these lawyers protect the impermissible discriminatory and retaliatory
practices of the known racist sexist employer, the Defendant Institution, Mount Sinai Medical
Center et al. As discussed in my earlier submissions to the this particular court, the negative
results for Plaintiffs far exceed logical possibilities in an equitable civil justice system.

In my opinion, the civil justice system demonstrates that it has connected itself together on only
one impermissible agenda of propagating white supremacy based on white skin color which is a
high stakes game that is made possible by the outrageous spending in civil rights employment
lawsuits in the millions by Defendants like Mount Sinai Medical Center against a competent
professional, an innocent vulnerable individual like me who did nothing wrong. Their extortive
sum of payments doled out to Rory McEvoy causes him to ignore his own duties to the court as
an officer of the court and the law or to align with an already existent agenda of White
supremacy, despite his being kicked out of his former law firm, Locke Lord LLC which came to
their senses, but Blank Rome LLC seems to be keeping him on! The legalization of
impermissible discrimination and retaliation against me, a person of color, against an US citizens
of foreign national origin, a lawfully immigrated individual, and a woman professional, who for
all intents and purposes is among the best of you, just not a White Male or Jewish or White
Female , or basically, not "white enough" as Melissa Pessin (a former supervisory personnel at
Defendant Institution) would label me is in a constructive and proper court and system would not
be possible. I invested hundreds of thousands of dollars, and figuratively speaking much sweat
and tears into my education and my career, and I made all of these sacrifices because I am
building a good future for myself in United States. I am attacked, not treated fairly, and my
building is knocked down, and everything that I worked for is destroyed by the petulant racist
sexist Defendants and their similarly ideological lackeys in retaliation for legally protected
activities as a woman profe ssional of color of Indian National Origin.

Case 15-1328, Document 123, 04/28/2016, 1760706, Page10 of 14

I am a medical doctor , and despite the fact that I am as highly educated as you are, I am in the
field of Pathology by training , I had no exposure to the legal system other than with this case ,
and based on my reading into the law and review of thousands of cases in the past few years. I
have never engaged in any unprofessional activity nor conduct and all my professional work was
done correctly and if I had the opportunity to succeed using my professional discretion and
educatio~ I most ce1tainly would be very successful as a practicing pathologist, as you can
probably tell , even if that 's not for your to even ponder about. The Defendants and their lawyers
acting against me with free reign on capital , lacking any adherence to law and ethics or the
evidence to support their allegations against me since they unlawfully terminated my
employment have taken to the extreme position of doubling down on their racist sexist
employment practices and retaliatory activities , rather than settling this case , apologize for their
conduct towards me, and retract their defamatory statements and publications marring my
reputation. My case with the actual facts of which I know , the timeline, and the law met the
standards for going to trial or being settled , meaning that this case should have been settled a
long time ago. Instead , the white supremacy , the corporate billionaire funded racism sexism ,
disparate treatment and retaliation showed it 's true face, their goal of apartheid enforceable
against people of color in professional workplaces that should represent a low hanging fruit to be
avoided for them but criminals like the Defendants and their lawyers are using caselaw to negate
substantial legal protections afforded with Civil Rights laws and statues. In my opinion, the
courts have done nothing to very little to balance the scales of justice to prevent this nihilism ,
and based on the statistics , the federal courts are engaged in unconstitutional conduct that
entirely relies on subterfuge and subversion with bold faced lies as seen in my case.

I did not discuss with the court nor did the court request that I appear to an hearing on the
decision from which I am appealing or that I submit a statement before deciding to vacate an
important order that is critical for me, which was not even up for debate or discussion with
Korenbaum's motion to be relieved as counsel. Korenbaum can go but I do not want to be prose
because it 's not in my interest nor within my expertise to do so as I had previously informed the

Case 15-1328, Document 123, 04/28/2016, 1760706, Page11 of 14

court in my filings. I did everything in my power to communicate with Korenbaum who refused
to communicate with me on the specifics of my case and canceled court scheduled conference
without notifying me. In my opinion , Korenbaum will have communication problems with any
minority woman professional, because he did not adhere to his fiduciary duty to me. None of
you would tolerate any of Korenbaum 's conduct during representation if you were in my
situation. I would like to be appointed an attorney who is capable of representing me fairly and
who has integrity and who does not make decisions along racial gender lines based on
impermissible interests as noted by Korenbaum's language and rhetoric. Korenbaum only
alleged communication issues after making decisions without communicating with me and I
requested that he answer for his decisions. I also did not get rid of the other lawyers, such as
Boyd or McCarthy, rather they had their own issues unrelated to me. The civil rights and basic
human rights of women of color employees, an United Citizens who immigrated from another
country are chipped away with poor logic, racist sexist rhetoric infused into legal briefs, invented
facts and speculation , and with the continued blackballing and retaliation of professionals like
me due to the egregious failure of this federal court to uphold the laws that should protect me and
others who fall into entire classes from discrimination and retaliation.

I also cannot avoid White-run employers because invariably majority of the businesses and
opportunities in my field are controlled or owned by 'Whites ', including for institutions that
should be under the control New Jersey or New York State. Minorities , like me , we have largely
been unsuccessful in federal courts where serious substantiative matters are not adjudicated
according to law but by the impermissible factors of racism, sexism , and personal gains as
millions of dollars are thrown around by the Defendants, that forcibly exclude aggrieved
Plaintiffs from justice and equitable adjudication. By definition , Korenbaum's conduct was
unprofessional and hostile , and most importantly, the display of his communication problems as
the professional. The Defendant Institution Mount Sinai Medical Center and it's billionaire
Board of Trustees have dug in their heel on disenfranchising and marginalizing me while their
Institution continues to shield bad doctors such as Defendants Carlos Cordon-Cardo , Adolfo
Firpo-Betancourt, among the countless others , and the heads of the organization such a Kenneth

10

Case 15-1328, Document 123, 04/28/2016, 1760706, Page12 of 14

Davis etc are involved in setting up cardiac catherization schemes to bill public funds etc etc etc
continue on unabated without accountability or consequences. However, these same people have
spent millions in litigating a case against me, a minority woman of Indian National Origin to
destroy my life and career, because it seems that the current system is built on scapegoating to
the extreme by the racist sexist bigots to detract from their own criminal activities and their
catastrophic failures of colossal levels. 1 expect that this court will not condone retaliators and
retaliation by reinstating the order to appoint me pro bono counsel. Let's balance the scales of
justice to protect my rights and interests as intended by The Civil Rights Act of 1964 to put an
end to the discrimination against minorities, protect individuals, and groups from impermissible
discrimination from unscrupulous racist sexist retaliatory employers such as the Defendant(s).

My civil rights has been violated in violation of the protections afforded to me by U.S. laws and
statues, I have incurred millions of dollars in damages , and every job that I apply to I am further
discriminated and retaliated against, and my former medical school with an African American
man as the Dean informed me directly that the termination of my employment to abdicate his
responsibility in assisting me with the routine processes available for employment for medical
professionals. I applied for an advertised job at Robert Wood Johnson Medical School
(shortened to RWJMS hereon in) to complete my final year of Anatomic and Clinical Pathology
last year, following my application, they removed their advertised posting, refused to consider
my application, and then, shortly afterwards, RWJMS posted the job advertisement again by
changing certain criteria to exclude me. The facts are that I worked for over three years
delivering the standard of care to thousands of individuals without a single error of judgment or
mistake, and that is no small feat, in what was an inarguably one of the worst and most hostile
workplaces. It's also not my fault that I worked for a self-proclaimed racist sexist failure of
Defendant Institution, Mount Sinai Medical Center, where I could be targeted for discrimination
and retaliation for simply being a minority woman of color professional. The Defendant
Institution and their various white doctors continue to be embroiled in unprofessionalism and
criminal conduct but are shielded from attack with multimillion dollar litigation. The Defendant
Institution is causing so much grief and harm to so many people, including me. I did not do
11

Case 15-1328, Document 123, 04/28/2016, 1760706, Page13 of 14

anything wrong to warrant malicious and negative employment actions taken against using
pretext to unlawfully terminate my employment me that has destroyed my life and career for the
past 6 years.

12

Case 15-1328, Document 123, 04/28/2016, 1760706, Page14 of 14

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

CAPTION:

_V_a_ru~g~h_e_s_e_
, _L_____

v.

CERTIFICATE OF SERVICE
Docket Number : 15-1328

Mount Sinai Medical Center

et al

I, Leena Varughese , M.D.

(name)
April 28, 2016

PRO BONO~~(JNSEL

, hereby certify under penalty of perjury that on

, I served a copy of DEMAND TO REINSTATE

TO PLAINTIFF DR. LEENA VARUGHESE

(list all documents )

by (select all applicable)*

[S2fu oited States Mail
D Federal faq,ress
D Overnight Mail
D Facsimile
[ZJ E-mail
D Hand delivery
on the following parties (complete all information and add additional pages as necessary):

NY

NY

Address

City

State

Zip Code

Name

Address

City

State

Zip Code

Name

Address

City

State

Zip Code

Name

Address

City

State

Zip Code

Rory McEvoy

405 Lexington Avenue

Name

APRIL 28, 2016

Today's Date

10174

Isl Leena Varughese

Signature

*If different methods of service have been used on different parties, please indicate on a separate
page, the type of service used for each respective party.

Certificate of Service Form